Happy New Year! That is, if you weren’t one of the 50 FFLs who received a warning conference or revocation following an ATF compliance inspection in the last three months of 2022. Now armed with one full calendar year of monthly inspection reports, we have 12 months of public data on ATF activity and corrective action to review.
While Q3 (July–September) 2022 only saw a 3% growth in total inspections from Q2 (April–June), monthly totals had increased 95% since January following mounting pressure from the Biden administration’s zero tolerance policy. However, the months of October, November and December would not continue this trend.
Despite a 10% jump from October to November, Q4 started with a drastic 47% decline in inspections that would set a slowed pace for the rest of the quarter. Likely impacted by the busy retail and holiday season, ATF reported just 1,511 inspections in Q4 – its lowest quarterly total of the year, though still more than Q4 2021 (1,268 inspections).
Below, we further break down the Q4 inspection totals by month and quarter, followed by inspection, warning conference and revocation trends.
While reviewing the data, keep in mind ATF reports fail to provide comprehensive information regarding all corrective actions issued or address the qualitative impact of compliance inspections. Lastly, no historical monthly inspection data exists prior to October 2021.
October–December 2022 Data
The data below represents monthly ATF inspections completed between October and December 2022.
In total, ATF completed 1,511 compliance inspections of FFLs in Q4 2022. Averaging 503 per month, October, November and December fell roughly 100 inspections short of the annual average (608).
However, what remained the same was ATF activity in the Kansas City, Columbus and Dallas Field Divisions. Recording the top three highest inspection totals for the fourth consecutive quarter, the divisions totaled 42% (639) of all inspections in Q4. Meanwhile, the Atlanta, Newark and St. Paul divisions combined for just 19 inspections – as many or fewer than only three other field divisions.
Unlike inspections, though, revocations continued to grow into Q4. During the last three months of 2022 ATF initiated 35 revocations, including monthly highs of 17 total in November and four in the Kansas City field division alone. Those 35 instances make up nearly one third of all revocations in 2022. During the same period, warning conferences decreased to their lowest quarterly total of the year (15).
ATF inspections are not a matter of if, but when. You may not be able to predict when industry operations investigators (IOIs) will show up at your door, but you can prepare for their inevitable arrival.
With FFLs facing increased scrutiny and greater corrective action for common violations, practicing proactive compliance is critical to protecting your license from revocation. Contact Orchid’s in-house legal and FFL compliance professionals for a mock ATF inspection or demo of our industry-leading compliance software solutions for manufacturers and retailers.
Don’t let your next ATF inspection be your last.