Now past the halfway point of 2022, we find ourselves in the heat of summer. For some FFLs across the country, that may mean slower sales, but for the firearms industry’s regulatory agency, it’s business as usual.
Earlier this year, we published our first quarterly summary of ATF firearms compliance inspections of FFLs using monthly data published by the Bureau. The compiled data revealed inspections and license revocations were on the rise despite overall inspection pace falling well short of pre-pandemic totals. However, with each new month’s report, we learn more about ATF industry operation investigator (IOI) activities, better understand how they’re enforcing new compliance standards issued by the Biden administration, and get closer to having a full calendar year of monthly data.
Below, we’ll provide inspection numbers for the second quarter (April–June) of 2022, as well as inspection trends observed from Q1 and previous years.
Before diving into the latest numbers, it’s important to note these reports do not tell the complete story of ATF compliance inspections. First, total inspections may still be low in comparison to pre-2020 numbers, but the administration’s zero-tolerance policy for “willful violations” by “rogue gun dealers” suggests monthly numbers will continue to increase.
Second, the agency’s monthly reports provide limited data on inspection corrective action, only including data for warning conferences and license revocations despite additional levels of action being issued at the ATF’s discretion. These reports also fail to address the qualitative impact of compliance inspections on FFLs, which can affect customer traffic, sales, and production schedules during the time in which IOIs conduct their inspection.
Lastly, no historical data of monthly ATF compliance inspections exists prior to October 2021, nor has the Bureau updated its public annual inspection data since 2020, preventing any attempt of estimating more recent monthly numbers.
April–June 2022 Data
Below are the monthly ATF firearms compliance inspections completed between April and June 2022.
In the second quarter of 2022, ATF IOIs completed a total of 1,773 compliance inspections of FFLs across the country. Up 7% from Q1 2022, an average of 591 FFLs were inspected each month, aided by back-to-back months of 600-plus inspections in May and June. Still, neither month topped the 2022 and monthly high of 660 inspections from March. Combined with last quarter’s numbers, roughly 2.6% of all active FFLs have been inspected in the last six months.
The same three ATF Field Divisions, Kansas City, Columbus and Dallas, led all divisions in inspections for the second consecutive quarter, each surpassing 225 inspections and their Q1 2022 totals. Of the 25 divisions, 13 recorded more inspections in Q2 than in Q1, while 12 divisions recorded fewer. Outside the top three, Seattle was the biggest gainer from the first quarter while Atlanta had the biggest decrease in inspections. And despite doubling their Q1 output, Newark remained the field division with the lowest inspection total, completing just 12 of some 480 FFLs.
Combining Q1 and Q2 totals, 3,429 FFLs have been inspected through June 2022, with 51% coming from within the Kansas City, Columbus, Dallas, Houston, Phoenix field divisions. Of all divisions, 88% have completed 50 or more compliance inspections, 40% have completed at least 100 inspections, and 20% have completed over 200 inspections.
Between April and June, 37 ATF inspections resulted in a warning conference – up seven from Q1. Another 24 resulted in license revocation, doubling last quarter’s total. Dallas-division FFLs have recorded the most warning conferences (11) while Charlotte and Columbus share five revocations each, all of which were reported in the last three months.
Given that inspections are low probability-high impact events, the best way to protect your FFL is to implement operational practices and technology suitable to reduce your compliance risk. Contact Orchid’s technology and legal professionals today to schedule a mock ATF inspection and learn how we can protect your FFL from ATF violations.