How Do You Record an A&D Book Disposition?
The ATF required Book of Acquisition and Disposition is specific. It dictates the information fields required, the specific format that must be followed and, among other things, it dictates the timing of when entries must be made.
To ATF the A&D Book’s importance is directly connected to their ability to trace firearms through the National Tracing Center, when needed. An important aspect of the tracing process is reviewing the disposition information in the A&D Book. There is a typical path that the firearms industry follows in the lifecycle of a regulated firearm: Manufacturer/Importer – Wholesaler or Distributor – Retailer or Dealer – and then at some point to the non-licensed customer.
Today we are going to talk about four of the different disposition types that can be found in the A&D Book; it’s not always just as simple as a “sale”.
Dispositions from Licensee to Licensee:
When one licensee transfers to another there are some specific steps that must be followed and information that needs to be recorded in the A&D Book. This is the case whether it was a sale from the Internet, a sale at the gun show, or an order from the Manufacturer them self.
It starts with the exchange of a valid, certified, signed copy of the Federal Firearm License. Each FFL must prove that they know that the transfer they are making is to another federally licensed person or business. This let’s ATF know that since the receiving party went through the licensing process and background check, they are not prohibited from receiving the firearm. It is what allows the FFL to complete with transfer without having to complete a NICS check.
A best practice in validating the FFL is to run the FFL through the ATF FFL EZ Check database to ensure the current license status.
When populating the A&D Book disposition, you must include the following pieces of information: Date of Disposition, Name of FFL, and the FFL number. This disposition should be be made in your A&D Book as soon as possible to ensure accuracy; however you are allowed 7 days when you have a commercial document that contains all of the required disposition information. Be sure that the date entered is the actual date of transfer or disposition and not the date that you made entry into your A&D Book.
Dispositions from Licensee to Non-Licensee:
Firearms are typically sold from licensees to non-licensees on the retailer or dealer level, that being said, most license types allow for this type of transfer. These types of transfers require two basic standard steps: 1. An ATF Form 4473 must be completed prior to the transfer. 2. A NICS background check must be completed prior to transfer.
Once you have deemed that the transfer is permissible, you must record the transfer information into your A&D Book. Specifically, the Date of Disposition, Name and Address of Purchaser or Form 4473 Serial Number if Forms 4473 are filed numerically. Similar to transfer to licensees, you should enter this information from your completed ATF F 4473 into your A&D Book as soon as possible. You are authorized up to 7 days for the disposition entry as long as the ATF F 4473 is retained and available for inspection. Again, be sure that the date entered is the actual date of transfer and not the date that you made entry into your A&D Book.
Dispositions of Theft/ Loss Firearms:
Firearms that are reported to ATF as “missing” (theft/loss) firearms must have a corresponding disposition entry. This allows those conducting your inspection to know that these firearms will not be available for inventory inspection since they are now considered “closed dispositions”.
When making a disposition entry into the A&D Book be sure to include the following information: 1. A statement indicating that the firearms were reported to ATF; such as “Reported ATF Theft / Loss” and 2. Be sure to include the “Incident #” provided by the ATF.
Dispositions of Scrapped or Destroyed Firearms:
When firearms are internally classified as “junk” guns or are beyond repair and you plan to destroy them, you must make sure that you account for this type of disposition. Just this week our Blog addressed “Best Practices” for scrap accountability and record keeping.
Keep in mind that all firearms acquired into the A&D Book at any point need a corresponding disposition even if there is no actual transfer involved. When destroying firearms be sure that the disposition date is equal to the actual date of destruction and make that entry immediately.
The A&D Book must be consistently maintained accurately and must always be up to date with timely recordings. Periodically check to ensure that your entries match the “snapshot” of your inventory and other records. If an ATF inventory was completed today, are all of your dispositions recorded? Do the dates on Theft/Loss reports match what’s in your A&D Book? Were firearms scrapped and not logged out? Audit the dispositions in your A&D Book regularly to make sure you are on the right path for compliance.
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