ATF Ruling 2013-5 Highlights


ATF Ruling 2013-5 Highlights

The following are notable highlights from the ruling. We strongly recommend that you review the entire ruling and contact the ATF or Orchid Advisors with questions.
It supersedes the prior ATF ruling on electronic record keeping (2008-2).
It “replaces and rescinds all previous

[ATF] approved variances covering electronic record keeping (i.e., Book of A&D). You must reapply for such variances unless your system meets all of the requirements of 2013-5.”
It ruling clarifies what were conflicting statements in 2008-2 about record correction alternatives. Simply stated, the options are: (1) Making corrections through an entirely new entry; or (2) Using a full change control log to explain the “who, what, why, where and why” is incorrect.
It eludes to, but does not explicitly say, that software such as Microsoft Excel is permissible provided that it meets all requirements of the ruling. ATF uses a specific term that pertains to Excel’s features such as “Protect workbook function.” Clarification from ATF is requested.
It requires various electronic queries (much like 2008-2), but that language has changed to include the name and address of the “purchaser.”
It requires record downloads within 24 hours of request by the ATF.
Read our Alert about this ATF Ruling here.