Requirements for Digital Storage of ATF Form 4473s

Written by jon rydberg

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February 21, 2022

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Does your firearm retail store suffer from a plight of paperwork? Are you spending too much on printer paper and ink cartridges? Do you feel the filing cabinets lining your hallways and offices closing in on you? If you answered yes to any of those questions, you and your retail FFL could benefit from digital storage.

All jokes aside, the storage of ATF documents, like Forms 4473, or “Firearm Transaction Records,” is often an overlooked aspect of operating a retail FFL. Historically, paper 4473s have been used to process over-the-counter firearm sales and transfers, with the industry only more recently adopting electronic 4473s (e4473s). However, while e4473s have made conducting firearms transactions more efficient, most dealers must still print, file and store paper copies of the completed documents.

For small FFLs transferring a dozen firearms a year, retaining paper records is manageable, but for larger brick-and-mortar dealers processing thousands to tens of thousands of firearms annually, the accumulation of paperwork retained over the lifetime of a business – as required by ATF regulations and the Gun Control Act – is a logistical nightmare.

Thankfully, there’s a solution for FFLs seeking to reduce their reliance on paper without sacrificing compliance – digital storage. And while digital storage can be used for nearly all ATF and FFL documents, we’ll only be focusing on the 4473s here.

Digital Storage Requirements
Simply because your FFL uses software that can save copies of e4473s to a computer hard drive does not mean you can stop printing them. Before you can digitally store 4473s, you must apply for a digital storage variance – a process of asking the ATF for an alternate method or procedure to fulfill regulatory obligations.

In preparing a variance request, FFLs must describe the following in detail:

  • Kind of digital storage system to be used
  • How Form 4473s will be electronically filed
  • How local ATF can gain access during compliance inspections
  • Electronic file format of Form 4473s

The ATF has also established 16 minimum requirements an FFL must meet to ensure their chosen digital storage system complies with all rules and regulations and will not interfere with compliance inspections. These system requirements include, but are not limited to:

  • Form 4473s must be saved in an unalterable format in which the original form must be retained and may not be deleted, amended, replaced or otherwise altered
  • The system must store Form 4473s in alphabetical, chronological or numerical order
  • The system must allow access to Form 4473s and the acquisition and disposition (A&D) record simultaneously
  • ATF must be provided uninterrupted, “read only” access to the system to facilitate a compliance inspection
  • The system must allow Form 4473s to be printed upon ATF request

After applying for a variance, your local ATF office may perform an onsite evaluation of your digital storage system and conduct a mock compliance inspection before approving your variance request. If all goes well, your FFL should be approved to begin storing 4473s digitally.

However, it’s worth noting the digital storage variance does not work retroactively. The ATF still requires all previously completed hard copy 4473s be retained on the licensed premises in the manner and for the length of time prescribed by regulations.

The Cloud Difference
While your FFL could store 4473s on existing computers, local hard drives lack sophisticated data security and can be susceptible to physical theft and fire or water damage. Luckily, there’s an alternative method of digital storage that offers greater protection – the cloud.

From the Silencer Shop suite of services, 4473 Cloud provides FFLs with the most innovative, secure and user-friendly e4473 digital storage available. Integrated with popular bound book software, like Orchid eBound™, 4473 Cloud seamlessly stores firearm transaction records in the cloud on trusted Microsoft Azure servers in a tamper-evident file format.

The application also features intuitive search functionality so you can easily access and find 4473s at any time, from anywhere, on any device. And with tiered pricing based on annual firearm transactions, there’s an affordable plan fit for every size retail FFL – all lower than the cost of paper, printer ink and additional filing cabinets.

Orchid & 4473 Cloud
At Orchid, our team of technology, operations and legal experts are experienced in providing FFLs with solutions that increase efficiencies, maximize profits and lower compliance risk.

In 2018, Orchid obtained the first-ever digital storage variance for a firearm retailer and has since helped others pursue and obtain similar variances. We were also among the first to integrate 4473 Cloud digital storage with an industry-leading bound book and point-of-sale in Orchid eBound™ and Orchid POS™.

Contact us today to learn about our software integration with 4473 Cloud and for assistance applying for a digital storage variance.

Digital ATF Document Storage

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