Compliance Considerations for Relocating Your FFL

Written by Orchid


November 08, 2021


White text atop red background next to photo of Weatherby grand opening ribbon cutting

Earlier this fall, Smith & Wesson announced they would move from Springfield, Mass. – their home since 1852 – to Maryville, Tenn. beginning in 2023. The news shocked the industry and gun owners alike, but it was just another move by another major firearm manufacturer in the last decade to relocate from an increasingly anti-gun state to a more welcoming political and business climate.

However, such a move, which will relocate the company’s headquarters and some 750 jobs to a state more than 800 miles away, is no small undertaking for even the largest of manufacturers. On top of moving logistics and establishing operations, relocating an FFL is a challenge that takes significant time, money and planning to maintain proper compliance – but it’s not impossible.

If your manufacturing, import or retail FFL is interested in making any move, big or small, here are five compliance considerations to understand before packing up.

Obviously, the first step in relocating your FFL is finding a new location. Assuming your firearms business is moving to escape restrictive legislation or mounting political pressure, you’ll need to find a state more friendly to our industry.

Of course, there are many factors in determining the “firearm friendliness” of a state, but great consideration should be given to the legality of firearms you manufacture, import or sell in the state and/or jurisdiction to which you are moving. Such was the “primary catalyst” for Big Blue’s move following the introduction of legislation that would ban “assault weapons” in Massachusetts.

Once a location has been chosen and an address established, you will need to file an Application for an Amended Federal Firearms License (ATF Form 5300.38). During the term of an active license, licensees may move their business or activity to a new location where they intend to regularly carry on such business. Following an interview and approval, a new FFL will be issued.

After obtaining your amended FFL, you will then need to share your license and contact information with vendors and trading partners so they can update their records and to not delay ongoing production schedules.

Firearms businesses should also apply for any required state or local firearms licenses. And if new offsite warehouses and storage facilities will be utilized, a notification should be sent to the Federal Firearms Licensing Center informing them of the location(s).

ATF Variances
As with licensing, your FFL may need to have any existing ATF variances rewritten or reapproved prior to restarting operation as they are specific to your license. From marking variances to digital Form 4473 storage, variances should be submitted to the ATF’s Firearms and Ammunition Technology Division and/or Firearms Industry Programs Branch for review. And as always, variance approval is required before using an alternative manufacturing, importing or selling method or procedure.

All firearms are required to be marked with the city and state of the manufacturer or importer on the frame, receiver or barrel. As such, moving to a new location will require firearm markings be updated on all newly manufactured or imported guns – a change easily made with an integrated ERP and laser engraver.

For transitioning manufacturers operating out of two locations, efforts should be made to have all in-process builds serialized at one location before being sent to and assembled at another. This will also help with our last consideration – inventory management.

One of the final steps before moving, your FFL should conduct a full book-to-firearm inventory of all serialized firearms and components. This pre-move inventory will not only ensure your current bound book records are accurate, but also establish records to balance against when rechecking inventory once moved.

Should any firearms be found missing or to be lost or stolen in transit, federal law requires FFLs file a theft/loss report (ATF Form 3310.11) within 48 hours of discovery to the ATF and local law enforcement. Depending upon the jurisdiction from which an FFL is departing or relocating to, there may be additional local notifications or alternate timelines for reporting theft/loss.

Relocating an FFL is a big move, but with the proper preparation and planning, it doesn’t have to be full of compliance challenges. Contact Orchid today to begin planning your move with our strategy and operations experts, schedule demos to upgrade your ERP and POS software, and ask the attorneys at FFL Law about additional compliance and legal concerns to ensure you have a smooth, risk-free and successful move.

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