This time last year, ATF published its first monthly firearms compliance inspection report. Satisfying a new Biden administration requirement to provide greater transparency in its regulation of FFLs through more detailed inspection reporting, previous reporting had only been published annually.
Beginning with data from October 2021, we now have 12 months of monthly inspection data following the latest report. And though somewhat limited, the reports provide context for how many FFL inspections are completed in each of the ATF’s 25 field divisions every month, as well as how many resulted in a warning conference or license revocation.
In total, 7,051 FFL inspections were completed between October 2021 and September 2022. Of those, 136 resulted in a warning conference, and 91 in revocation. Below is a further breakdown of the monthly inspection data and observed trends.
In reviewing the data, keep in mind ATF fails to provide comprehensive information regarding all corrective actions issued and no monthly data exists prior to October 2021
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The data below represents monthly ATF compliance inspections completed between October 2021–September 2022.
Though monthly inspection reports don’t exist publicly prior to October 2021, we do have annual data dating back to 1975. Historically, 10,000 FFLs are inspected each calendar year, with slightly fewer completed on average in the last decade. But, with the challenges of the COVID-19 pandemic, ATF industry operations investigators (IOIs) were forced to conduct many inspections remotely during much of 2020-2021, resulting in just 12,500 inspections in the last two years.
If the total from the first 12 monthly inspection reports were to be considered a full calendar year, it would rank as the 13th fewest in the last 47 years. However, revocations (91 total) would be the highest since 2008.
If we averaged annual inspection data to obtain rough monthly totals, we can see FFL inspections have been on the rise since their drastic decline in 2020. Between October 2021 and September 2022, an average of 587 inspections were completed each month – an increase over 2021 (553) and 2020 (486). Still, inspections are down nearly 50% from before the pandemic.
Analyzing each month, inspections increased in 10 of 12 months, with only slight decreases in December and June from the prior months. Overall, inspections grew by 110% from October 2021 (436) to September 2022 (916), with the largest growth (25%) occurring between February and March this year.
As for ATF field divisions, which are responsible for inspecting FFLs in multiple states, individual states, or parts of single states, Kansas City, Columbus and Dallas completed the most, totaling 2,675 inspections, or 40% of all inspections. Rounding out the top-five were Phoenix and Houston – the only other divisions to surpass 300 inspections during the 12-month period. The fewest inspections were recorded by Newark, St. Paul and New York, who each completed fewer than 100 inspections.
Regarding warning conferences, only one field division reported double-digits, with Dallas totaling 13 between October 2021 and September 2022. The next highest were Boston, Columbus and Nashville with eight each, while another 11 divisions recorded two or fewer. Similarly, divisions with more warning conferences also typically recorded higher revocation totals, though as one might expect, there appears to be greater correlation to inspection totals. The more FFLs are inspected, the greater the chance of revocation.
The top five field divisions in inspections, previously mentioned, recorded some of the highest revocation totals, combining for 37% (29) of all revocations. Columbus and Charlotte tied with 10 revocations, followed by Denver and Nashville with six, and Houston, Kansas City, New Orleans and Phoenix with five each. Seven divisions recorded zero revocations.
While this information is all beneficial for the industry, it’s important to remember it’s only 12 months. With more time, we’ll have more data to compare, observe longer trends, and provide greater context.
ATF inspections are not a matter of if, but when. You may not be able to predict when industry operations investigators (IOIs) will show up at your door, but you can prepare for their inevitable arrival.
With FFLs facing increased scrutiny and greater correction action for common violations, practicing proactive compliance is critical to protecting your license from revocation. Contact Orchid’s in-house legal and FFL compliance professionals for a Zero Tolerance Rapid Assessment of recent ATF Forms 4473 or A&D bound book records, a remote or in-person mock ATF inspection, or demo of our cloud-based compliance software solutions for manufacturers and retailers.