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What We Know from 1 Year of Monthly ATF Inspection Reports

Written by Orchid

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November 14, 2022

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White text atop red background next to magnifying glass showing ATF seal over ATF Form 4473

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

Inspection Data

The data below represents monthly ATF compliance inspections completed between October 2021–September 2022.
DIV
OCT
NOV
DEC
JAN
FEB
MAR
APR
MAY
JUN
JUL
AUG
SEP
TOTAL
ATL
3
1
2
15
8
33
11
7
13
13
8
11
125
BAL
11
14
17
11
9
18
12
4
9
11
14
22
152
BOS
13
54
11
8
9
21
14
20
20
25
22
34
251
CLT
25
30
16
22
26
28
19
19
20
13
19
17
254
CHI
10
14
9
16
20
13
7
12
7
22
14
22
166
COL
39
40
54
55
65
80
54
86
94
96
102
112
877
DAL
68
36
36
48
48
72
81
62
82
96
118
100
847
DEN
11
7
8
9
16
21
21
25
23
18
22
30
211
DET
6
5
11
14
16
16
14
11
10
6
13
3
125
HOU
21
16
18
34
45
43
43
54
30
47
47
72
470
KC
42
62
49
41
52
111
48
113
92
111
115
115
951
LA
13
16
4
11
11
15
6
10
8
14
13
14
135
LOU
13
9
9
11
11
15
17
15
20
17
15
27
179
MIA
15
18
17
15
17
30
15
20
20
20
18
17
222
NSH
16
23
15
15
13
18
22
14
15
16
20
38
225
NOL
4
9
9
5
8
6
11
14
15
4
22
23
130
NY
6
14
8
13
10
7
8
4
7
5
5
6
93
NWK
1
1
2
4
4
2
6
10
9
16
55
PHL
9
6
7
16
22
23
15
31
12
31
34
31
237
PHX
32
25
31
40
36
45
30
40
39
38
56
75
487
SF
14
8
8
13
15
16
13
13
15
16
14
21
166
SEA
9
11
5
2
1
10
12
20
12
6
10
28
126
STP
13
5
2
7
3
5
7
6
7
7
8
19
89
TAM
18
17
18
31
46
23
21
17
14
35
27
267
WSH
24
14
13
18
17
10
12
22
16
15
14
36
211
TOTALS
436
454
378
470
526
660
519
645
609
671
767
916
7,051

Historical Context

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.

Proactive Preparation

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.

Don’t let your next ATF inspection be your last.

Schedule ATF Inspection

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