THE ATF WEIGHT LOSS PLAN – PART III
By John Brown
In this third installment of the ATF Weight Loss Plan, we will explore the final portion of an NFA inspection: the NFA portion of your inventory. Our objective is to help alleviate the fears of an ATF compliance inspection by providing you with enough information so that you are well prepared for an inspection.
One of the final things that your inspection will entail will be the thorough review of your NFA inventory. This may be the most painful portion of your inspections through no fault of your own. The inspector will bring a printout of your inventory that is a printout of the National Firearms Registry and Transfer Record (NFRTR) that details the serial numbers of your NFA inventory. That’s right, the serial number. If you were to have to locate anything in your inventory strictly by the serial number you may want to assess how you would find anything in your inventory.
The registry focuses on the serial number of your NFA items and the other information that may help you identify that item in many cases is difficult to decipher from the information that is located on the printout. It is my suggestion that if you have a significant inventory, you list those serial numbers in a way that allows you to search for the number. For example, a simple Excel spreadsheet will allow you to quickly and efficiently find a serial number and retrieve the necessary information that you need to retrieve the weapon for the inspector. Finding the serial number and retrieving the weapon will make your inspection go much faster. If you are using any of the software systems that keep track of your serial numbers, e.g. eBound by Gunderson, your search will be much faster and easier for you to perform. In addition to the search, any notes that you can place about the physical location of your item will also speed up the process.
At this point we will assume that you have a good handle on your existing inventory and that you have the necessary tools to track what you have and where you have it stored. In addition to this portion of your NFA inventory you will also want to make up a list of all of the NFA items that you have dispositioned in the last year. This list will help you quickly and efficiently let your inspector know what is no longer in your inventory that may show up on their printout. In many situations your inspector will ask for a serial number that you may have dispositioned during the last year but it is still showing up on the registry. I would further suggest to save time during this particular process, that you make copies of the Form 3s or 4s for at least the last 90 days to prove the disposition. The inspector will most likely keep a copy of that disposition in an effort to make certain that the registry is correct.
In addition to the forms that have already been dispositioned from your inventory, I would also suggest that you have copies of anything that you have in process for disposition from your inventory. This will help your inspector also know what will soon leave your inventory.
At this point you will have completed the inventory of your NFA items and everything should be accounted for. It will also be at this stage that you will have completed the majority of your inspection and you should be feeling pretty good about the inspection, especially if you have organized your inventory.
Once this portion of the inspection is complete the only thing you have remaining will be your closing conference. If you have done well in your inspection your inspector will finalize your inspection with a summary of all of the issues of your inspection. If you have any violations in your inspection the inspector will cover those violations in detail with you and provide you coaching on how to avoid any similar problems in the future. In addition to covering any issues during the closing conference the inspector will cover a host of issues including any new processes or help that is available in the conduct of your business. Under normal circumstance your closing conference is very detailed. I know you can’t wait for it to be over with, but take your time and listen as this conference contains a lot of good information. Once this is concluded you will sign the closing documents and your inspections will be complete.
If during your inspection you experience a host of problems or issues, you may be summoned to what ATF terms a warning conference. At this conference, held at your local ATF field office, you would be officially warned about issues and specific corrective action that may be required to get your practices in order to comply with all ATF regulations. Rest assured if you attend a warning conference, follow on inspections within the next year will surely be in order. Use your time wisely before the next inspection to put your house in order. You will certainly want to correct issues that were covered in your warning conference and to improve on your overall operations.
Given the fact that your inspection feels like it is finally over, make no mistake, it is not. As certain as the formal part of your inspection is over; the clock is ticking before your local inspectors will return and initiate the process once again. Use this time wisely to learn from your previous experience and prepare for your next inspection.
If all else fails, call the NFATCA and we will gladly provide you with resources that can help your next experience be a little less painful. Come join us and dig into helping the entire community make a difference with the NFA industry. Log into www.nfatca.org and help preserve NFA ownership for you and your family today.
|This article first appeared in Small Arms Review V16N2 (June 2012)