The two March 2013 ATF FFL Newsletters were packed with details to print-out and spend time considering in relationship to your current policies and practices. Heading up this to-do list for FFLs is the section for “Best Practices” on “How to Conduct an Inventory.”
The ATF laid out what it termed “four general steps” for conducting an inventory with a goal of maintaining a proper record of acquisition and disposition.
1. Count both the number of firearms in inventory and the number of firearms recorded as an open disposition;
2. Create a list of all firearms in your physical inventory;
3. Compare the physical inventory list to the open disposition list;
4. Conduct inventory reconciliation.
What is being recommended by the ATF as a “best practices” approach to inventory is both on paper and in person. The “on paper” portion is the written records of all firearms in inventory. An “open disposition” entry in your written records is a firearm recorded as having been acquired which has not yet been transferred or otherwise disposed.
The “in person” aspect of the ATF recommended “best practices” approach is your physical walk through the inventory. The ATF goes so far as to state “Record all identifying information derived from the firearm, not just from its box.”
If you end up with an open disposition that you cannot locate in the physical inventory, you are responsible to reconcile that entry. The ATF recommends you recheck the physical inventory, that you manually go through your ATF Forms 4473, and that you check any other commercial documents such as a transfer to another FFL and/or a return of a repaired firearm.
In the worst case that you cannot locate a firearm that is showing as an open disposition, you are required to report the loss or theft of the firearm from your business inventory. For this, the ATF “best practices” steps are (1) notify the local police; (2) report the incident to the ATF within 48-hours; (3.) complete and submit ATF Form 3310.11; and log the open disposition as “lost” or “stolen,” including date of incident, ATF-issued incident number, and local police report number.