Connecticut House Bill No. 6667, signed by Governor Lamont on June 6, 2023, introduces significant changes to the regulations governing Federal Firearms Licensees (FFLs) in the State. Among its many provisions, the bill aims to enhance State oversight of firearm sales, require certain practices with respect to inventory management, and further prohibits certain types of firearms by expanding the definition of “assault weapons”. Read further below to learn about some key provisions of the bill and explore their potential impact on FFLs operating in or selling firearms to consumers residing in Connecticut.

Assault Weapons Regulations (effective immediately)

House Bill No. 6667 introduces new definitions and regulations for assault weapons. It designates certain firearms as “2023 Assault Weapons” and outlines criteria that determine their classification. Most notably, the Bill seems to prohibit the sale of the popular “CT-OTHER” category of firearms in addition to a broad array of other firearm configurations.  The bill also establishes exemptions for individuals who lawfully possessed such weapons prior to a specified date provided they properly register such items.

Impact: FFLs need to be well-informed about the updated “assault weapons” definitions given the immediate effect of this section of the bill. They should further be aware of the exemptions granted to individuals who possessed these weapons lawfully before the designated date as in very limited circumstances a transfer back to certain individuals is permitted.

Permit Requirement for FFLs (effective 10/1/2023)

One of the notable provisions of the bill is that FFLs selling 10 or more firearms in a year are now required to obtain a permit for the sale at retail of firearms.  Whereas this permit requirement previously only applied to FFLs selling pistols or revolvers at retail, the requirement is now broadened to include all firearms.  FFLs holding permits for the sale at retail of pistols or revolvers are considered to hold a valid permit for the sale at retail of firearms until it expires (upon which it may be renewed as a permit for the sale at retail of firearms) or is revoked, suspended, confiscated, or surrendered.

Impact: FFLs engaging in firearm sales beyond the low threshold will need to apply for and obtain the necessary permit. This process will involve additional administrative tasks and costs for FFLs.

Physical Inventory Reconciliation (effective 10/1/2023)

Under the new law, FFLs must conduct a physical inventory reconciliation by comparing their physical inventory with their Acquisition and Disposition (A&D) Book. This reconciliation must be performed no later than the 5^th business day of October each year. FFLs must also submit an attestation to the commissioner within 5 business days, confirming that the inventory reconciliation was conducted and any missing firearms were reported to ATF and law enforcement authorities appropriately. 

Impact: FFLs will need to allocate time and resources to perform the annual physical inventory reconciliation. Although this requirement aims to enhance accountability and reduce the risk of missing firearms nearly every FFL already performed such an inventory.  Failure to so-certify this task has been conducted can provide grounds for a violation issued by local authorities the failure to timely cure of which could lead to a stop sales order which would halt firearms sales at the licensee’s premises.

Compliance and Enforcement (effective 10/1/2023)

The bill grants state authorities the power to issue a notice of violation to an FFL if there is probable cause to believe a violation of the specified duties has occurred. The FFL then has a limited time frame to cure the violation after receiving the notice (not less than 30 days). Failure to do so may result in a prohibition on further firearm sales at the premises through the issuance of a stop sales order. Additionally, civil penalties of up to $100 per day may be imposed for ongoing violations.

Impact: FFLs must ensure strict adherence to the regulations outlined in the bill to avoid potential penalties and significant disruption to their business operations. It becomes crucial for FFLs to maintain strict adherence to the extensive list of mandates identified in Section 8 of the bill, to promptly address any identified violations if so identified, and be prepared to respond to enforcement actions or hearings if necessary. 

Limitations on Handgun Sales (effective 10/1/2023)

The bill imposes limitations on the sale of handguns by prohibiting the Department of Emergency Services and Public Protection (DESPP) from issuing more than three authorization numbers for the sale at retail of handguns to an individual within any 30-day period. However, certified firearms instructors are allowed to obtain up to six handguns within a 30-day period.

 Impact: FFLs must closely monitor and track handgun sales. This may require adjustments to inventory management, software controls, and sales processes to align with the new restrictions.

Conclusion

Connecticut House Bill No. 6667 brings significant changes to the regulations governing FFLs in the State. FFLs should familiarize themselves with the details of the bill, adjust their operations accordingly, and remain vigilant about compliance to ensure continued lawful operations in Connecticut.  Even minor violations of many requirements may result in issuance of a violation and subsequent stop sales order that can effectively shut down firearms sales.

Stay State Compliant

State and local firearm laws – like those signed in Connecticut – often change more frequently than Federal regulations, putting an increased burden on FFLs to abide by state restrictions, avoid revocation, and guard against legal liability. But when armed with Orchid eState™, staying up to date with the latest firearm restrictions in your state and across the country is easy!

Whether integrated into your ecommerce webstore or used as a standalone tool, Orchid eState™ enables FFLs to monitor and check transactions against state and local-level firearm laws by customer ZIP code, product characteristics, and item UPC to prevent illegal shipments and sales, both in-store and online. Plus, non-firearm laws, like purchase age and waiting periods, are also tracked for complete transparency and compliance to better protect your FFL from ATF.

To learn more about Orchid eState™, contact Orchid today for a free demo.