Are you ready for your next ATF compliance inspection? If the ATF showed up today, would you have a pit in your stomach or a feeling of confidence? Likely, you have audited yourself, maybe found and fixed some errors along the way. How about your inspection logistics, are they planned? Today’s topic focuses on the differences between your daily compliance tasks, i.e. the things you do everyday to stay in compliance, and your ATF inspection preparation; the actual logistics for the big day.
Remember, “compliance doesn’t happen overnight.” Once it’s in motion, the need for fine-tuning doesn’t stop or end. Sometimes it requires additional effort and other times it’s a smooth sailing ship. It never just “stands still” and neither can you. There are things that must be reviewed and audited regularly to ensure accuracy and compliance.
For example, a daily review of your A&D Book entries is helpful to catch smaller issues that could otherwise accumulate over time. ATF F 4473s can benefit from an on-the-spot review in addition to a final evening review, every day. Generally speaking, ATF Form population is better to review and perfect the first time around. Regardless of your size and resources, the goal is the same, to operate compliantly and to be adequately prepared for your actual inspection.
Internal controls “tighten the compliance screws” and allow you to find and prevent your errors quickly. All of the daily, weekly, monthly, quarterly, and annual audits increase the likelihood of compliant operations and allow you to identify process deficiencies. Theoretically, your ATF compliance inspection should reap the rewards of these efforts and be reflected in your inspection results. Remember, you are encouraged to audit yourself and find and fix your own grammatical errors and human mistakes.
While your auditing tasks are likely to reduce process errors that could affect your inspection results, there is more to do to get your prepared for the actual inspection day.
These tasks focus on the logistics of your ATF compliance inspection.
For example, you may be great at populating and even auditing your electronic A&D Book, but are you able to “make it available for inspection.” Can you print it or properly export it to a thumb drive if needed? Have you practiced querying your information as required by ATF Ruling 2016-1? If you use paper A&D Books, have you moved those old open dispositions to your newest book so they are easy to find? How about your NFA forms, are they scattered throughout your store or factory; or are they consolidated in a central location and easy to access? What would your serial number inventory process look like if ATF came today? If a team of IOIs came to visit, would they be able to efficiently conduct the inventory and have the tools necessary?
The goal is to plan ahead and prepare the resources that you may need for an efficient inspection. ATF inspections can be time consuming when the IOI has to wait for you to find a way to reach higher shelved inventory or search in desk drawers or backrooms for that one missing form.
Consolidate and organize your forms and inventory. Practice your own ATF-styled inspections to ensure you can produce your records and forms and are confident that your inventory matches your A&D Book.
Sometimes it’s the little things that matter. For example, do you have “count stickers”, an ink stamp, or someway to account for the completed inventory located in your backroom? Do you have flashlights available for those dark corners? How about power strips for the IOI computers in factories with few outlets? All these little details matter and can help to avoid inspection interruptions. You’ll be surprised at how much you learn when you practice, practice, practice.
Take the time to plan your compliance tasks and break them into your daily, weekly, monthly, quarterly and annual routines. Don’t forget to include training too!
If unsure where to start; feel free to give Orchid Advisors a call!