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Zero Tolerance Protection: Compliance Is Only As Good As Your Data

Written by Orchid


October 19, 2022


White text atop black background next to grayscale photo of President Joe Biden

In the previous Zero Tolerance Protection article, we discussed some of the benefits of digital compliance technology over paper recordkeeping. However, while electronic bound books and ERP integrations can help limit human errors, streamline operations, and protect your license, compliance – whether paper or electronic – is only as good as your data. As they say, bad data in, bad data out.

To the end consumer, firearms are a tool, a means of sport, protection, or putting food on the table. But to manufacturers, retailers, and ATF, firearms are essentially data, made up of regulated information that allows for traceable distribution and sales. As such, each individual data point is critical to maintaining accurate FFL records, ATF compliance, and efficient operations.

Bound Book Data

Whenever a firearm is acquired from a manufacturer, distributor, retailer, or by other means, it must be recorded as an acquisition in your bound book. Similarly, whenever a firearm is shipped, sold, or transferred, it must be recorded as a disposition. As such, the following information, when applicable, is required for each firearm whenever an acquisition or disposition is made: 

  • Manufacturer
  • Manufactured Date, FFL, Name, Address
  • Importer
  • Importer, FFL, Name Address
  • Gun Type
  • Model
  • Caliber/Gauge
  • Serial Number
  • Acquisition Date/History, Name, FFL, Address
  • Disposition Date/History, Name, FFL, Address

In addition, retail FFLs must also record additional information regarding the buyer/transferee, as captured on the ATF Form 4473/e4473, including:

  • Full Name
  • Date of Birth
  • Address and Residence
  • NICS Transaction Numbers
  • Form Number

Together, this information provides context for the firearm, it’s movement in the supply chain, and its purchaser. As such, be sure to take extra care that each piece of information is correct. Its accuracy is not only required by federal regulation but relied upon should a firearm trace be requested. Accurate data is also needed should you

ERP System Data

Like your bound book, the data within your enterprise resource planning (ERP) system is critical to the operation of your firearms business. Because your ERP may connect numerous business functions, your data will likely span everything from firearm manufacturing and your supply chain to accounting, finance, and human resources. As they relate to federal regulation, some may be more important than others, but all are vital to your operations.

Production – Data inaccuracy during manufacturing can have a cascading effect. Starting with the input of marking and serialization attributes and requirements, accurate data will ensure inventory and production maintain ATF compliance and on schedule. 

Finances – Cash flow is what keeps your FFL in business. Wrong data can result in the wrong materials, material volumes, or order of purchase being triggered, tying up money in the form of holding costs and excess inventory.

Sales – When production slows and cash flow is held up, your FFL suffers. These stockouts and missed deadlines can lead to decreased sales, impacting sales goals and revenue-generating opportunities.

By maintaining accurate data throughout your ERP system, your FFL can drive operational excellence across the business.

Orchid Zero Tolerance Protection

At Orchid, our team of operations, technology and legal professionals understand the risks of today’s firearm businesses. For over a decade, we’ve worked with FFLs big and small to implement leading compliance best practices and software solutions to eliminate violations and protect licenses from revocation.

Continuing our Zero Tolerance Protection series, we’ll share our expertise and experience in proactive compliance as we look closer at Biden’s policy and its impact on the firearms industry, review how to avoid and correct violations, and suggest ways to protect your FFL from the risk of revocation. Next, we’ll discuss the importance of compliance programs and employee training in protecting your FFL.

In the meantime, learn more about a Zero Tolerance Rapid Assessment of prior ATF Reports of Violations, your A&D Bound Book, and recent ATF Forms 4473. We also encourage you to watch our webinar on ATF zero tolerance enforcement, schedule an in-person or remote mock ATF inspection, and implement leading compliance software in your retail FFL. Contact Orchid today to protect your FFL from a zero tolerance revocation.

Biden Zero Tolerance Webinar