By John Brown
Many years have past since I remember the days that I would lie awake at night thinking about that pounding at the door from an ATF Agent who wanted to see my books at 4 in the morning. I would look over my books two and three times a day and make sure, out of pure fear, that I had everything in order and that I was certain no one would ever find anything amiss with my books. Twenty five years later that fear still exists and I still check the books as much as I did 25 years ago. Once again I know that even after a number of compliance reviews there is just something unsettling about an audit. It doesn’t really make any difference how well you are prepared, that twinge of nervousness just doesn’t go away. That same fear exists in a lot of dealers whether they hold a C&R license or are running a full fledge manufacturing operation and are making guns by the thousands. I often equate that fear factor as the same one you have when a police officer runs up behind you in your car, and you all of a sudden have that horrible sweat break out from the nervousness. It’s the fear of the unknown, and we all have it, no matter how well you are prepared for someone looking over your shoulder.
One of the goals of the NFATCA has always been to break down the fear factor and to develop a better working relationship with ATF in all aspects of both of our operations. In late 2007, NFATCA board members met with Assistant Director of Field Operations Billy Hoover and Deputy Assistant Director of Field Operations Jim Zamillo in an effort to better understand the initiatives being taken in the enforcement branch of the bureau, specifically with Compliance Reviews. During 2007, the NFATCA had received several calls complaining about the overbearing efforts with several compliance reviews. We met with the Branch to try and determine if there was something the NFATCA could do to help dealers in staying prepared for an audit.
We learned that the division office has made some monumental changes in the design and the implementation of the compliance reviews during the last several years. The surprise factor isn’t going to go away any time in the near future and giving notice and allowing the law breakers time to clean up their act is not in the cards. That logic is understandable. We learned that there are many tools that new and more experienced dealers can access to better prepare them for audits and to generally keep their house in order with ATF. Most every tool and documentation to give dealers of all kinds of the right information is available on the ATF web site,
http://www.atf.treas.gov/pub/fireexplo_pub/1004safsec_info_ffl.pdf. Looking through the information that is available on the web site will provide a mountain of information for those dealers that are interested in getting a jump on a successful compliance review. All of the information points in one primary direction: stay organized and maintain control of your inventory. Sounds like a simple task but unfortunately it is not always the case.
When it was explained that thousands of guns were missing from the inventories completed during previous year’s audits, it became quite clear that a lot of dealers simply don’t understand the seriousness of keeping good records and control of their inventory. As a community we have a lot of work to do in order to eliminate this kind of problem.
During our meeting, the NFATCA discussed the possibility of offering assistance in whatever way possible to work with the dealer community in making the entire effort more successful. The Board of Directors is considering offering a “New Dealer Program” that will offer up answers and training to anyone that might be interested in obtaining a license to do business in the firearms industry. In addition, the NFATCA is also looking into a variety of ways in assisting the dealer community in keeping an organized presence in their business.
The NFATCA’s Chief Counsel and lobbyist, has written several articles on keeping good records and maintaining good control of your inventory. But with several thousand guns still missing it is obvious that our industry still needs help. In our efforts to be proactive, the NFATCA met with the appropriate personnel within ATF and have initiated several ideas on how we might work together to better assist dealers nationwide in keeping good records and better control of their inventory. As the NFATCA rolls out training programs or other forms of assistance, we are asking every dealer in the nation to help everyone stay better organized in our respective businesses. We ask that you keep posted on our progress through future articles and visit us at www.NFATCA.org. for more information.
|This article first appeared in Small Arms Review V11N7 (April 2008)