Improving 4473 Processing

The firearms industry is one of the most highly regulated and its licensees are subject to federal, state and local laws. Given their inherent focus on transfers to unlicensed consumers, retail gun store owners bare the additional burden of accurately completing ATF form 4473, NICS background checks, and often times NFA transfer forms. Failure to follow these can impact an owners time, money and in some cases, their license to operate. In response, many gun store owners have migrated to modern technology that limits the risk of 4473 errors, for example, while saving time and money. The responsibility for making sure these documents are filled out correctly mainly falls on the front-line gun store counter staff. Often repetability in these positions is impacted by high turnover. Completing paper-based ATF forms accurately on a daily basis requires extra care both in execution, review and in many cases, second level review. ATF Form 4473 which is required to transfer a regulated firearm from an FFL to a non-licensee holds the distinction of being the highest source of ATF issued violations year in and year out. The form is full of opportunities to make simple but potentially costly mistakes. Even the most seasoned FFL compliance expert would have to memorize numerous of “what-if” scenarios. For example, what if the non-licensed consumer doesn’t have a middle name? Would a new hire intiuitively know that the middle name field must be completed with the designation “NMN”,  the official abbreviation for “No Middle Name.” Firearm retailers have been minimizing their ATF compliance risk by switching from manual, paper-based 4473s to online, controlled electronic 4473s (otherwise known as an e4473). Some of the industry’s FFL compliance software such as Orchid eBound™ includes a 2016-1 ATF compliant ebound book and a 2016-2 compliant e4473.  FFL software like this and others often include automated error-checking features built-in. The following are four examples of software-based compliance features:

• Personal information validation checks (country, county, middle name, etc.)
• FFL Retailer section completeness verification
• Missing data check
• Prepopulate FFL field data from FFL EZ Check

The risk of error surrounded by the use of a paper-based 4473 is a sound investment. Electronic bound book solutions and those with 4473 solutions can run independently or can be connected to other systems like a gun store point-of-sale (POS). Generally, an independent system is going to be less expensive and quicker to implement. An electronic A&D book with e4473 functionality that is integrated into a POS system will further reduce compliance risk, but it can cost little bit more. Regardless, a properly implemented electronic 4473 application can yield an overall reduction in labor hour investment and increase compliance. Finding a Quality e4473 and Gun Store POS Software Solution Consider the following when evaluating FFL software: Is the company providing the technology solution established in the shooting sports industry with a track record of client success? In the current day and age, technology providers sprout up everywhere – and disappear just as quickly as they arrived. Seek out a gun store software provider that works exclusively within the firearms industry and has a business reputation for treating customers fairly. How is the regulated gun store software kept current?  Businesses should seek partners that are committed to keeping their gun store software offerings current and compliant with ATF regulations, without having to purchase additional products or upgrades and with a simple process for delivery. How is the gun store e4473 technology vetted to assure compliance with ATF regulations?  There is no official “certification” offered by the ATF, so asking a vendor how their e4473 or gun dealer POS is vetted for compliance is essential. Know if you can rely on your selected partner to assure their technology is compliant now and, in the future, or if your partner is putting the compliance validation processes on your business’s shoulders. If your business is required to validate, do you have that expertise inhouse, or will you incur additional costs to source a provider? Do you have the hardware required to utilize e4473 software, or will additional investments be required (don’t forget to check your internet access and speed)? e4473 software solutions can vary widely with their hardware and data access needs. Therefore, ask your partner if there are specific hardware / infrastructure requirements and, if so, will any of your current hardware / network tools be utilized? If not, what is the investment in specific hardware / infrastructure needed to implement their system(s)? Can the e4473 software be integrated into other systems such as an electronic bound book, or a Firearm Dealer POS to further drive efficiencies and data accuracy?  Although the ATF’s version of the e4473 can solve the handwriting issue, it does not drive full efficiency due to the lack of integration with your ebound book. Without these gun store software integrations, you may lose access to some valuable control and time efficiencies. Having a single source of data, managed by your FFL expert, that flows across your bound book, inventory, and to the e4473 will enable your FFL to realize some of the highest levels of efficiency and compliance. Does the FFL software have logic to prevent transfers after denials or indication of prohibited status in e4473, Section A?  It is highly recommended to have ‘lock-out’ logic for known prohibited transfers in your chosen technology solution. More than once, simple oversights have created serious compliance issues for transfers; having a lock out that prevents transfers can save lots of headaches later. Does the FFL software have logic to assure valid identification, age requirements, and supporting documentation are all validated against the specific firearm(s) requested for transfer? ATF Form 4473 has hundreds of potential workflow scenarios. Look for gun store software that is smart enough to identify and navigate specific scenarios, preferably with alerts and notifications, to prevent even the most rarely encountered scenarios from causing issues. Does the FFL software allow for remote oversight and access to centralized processes?  Centralizing oversight allows for the information to come to the expert(s), not vice versa. Look for a gun shop software system that doesn’t require physical hands on to view in progress or completed documents so that all relevant employees can view transactions as needed, without tracking paper documents throughout your organization. Is there adequate implementation and conversion training available to support your retail firearm business? For many gun stores and ranges, the biggest hurdle for e4473 and POS software integration is change control and project management. Seek a partner that doesn’t just install hardware/software and leave. Instead, look for a partner that offers various levels of conversion support and can provide training for the specific needs of your business operation. Ask about technical support, as well as compliance support and what services are included with any purchase. Summary Gun stores that invest in modern FFL technology can empower customers and employees to transact efficiently and effectively – without the need for precision audit skills at the counter. It’s amazing the level of confidence you and your team will develop when they know there’s always a system in the background – checking and rechecking their accuracy. By implementing e4473 technology, you’ll improve more than just the bottom line, but your peace of mind as well.

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