Gunsmithing Few 07FFL Record Keeping Questions

[jonaddis84]

Few things I just want to make sure Im clear on before I get audited some day, just want my shit in order...

1. Custom Actions. Say I receive in a bare action from Defiance, two different situations here. First being a Defiance labeled action, second being branded with my FFL and models. I assume there is never a form 2 required here correct? Do I just log it in as a receiver, then log out as a rifle and note that is was changed over?

2. AR Receivers. This is probably the same exact process as above, but just incase it isnt Ill make this a separate section. Log in a serialized AR receiver, and I put it together as a rifle.

3. 80% AR Receivers (or any other firearm MFG in house). Im pretty sure the process here would be... 1. Form 2, with my information as the MFG, make up my own serial #. 2. Engrave receiver 3. Log into bound book as receiver?? Or if you know it is going to be a rifle can you skip right to that?

4. Rebarrels. Do you guys do anything special for these? Say you receive it in as a 22-250 and put a 308 barrel on it.

Finally, beyond the form 2 paperwork and bound book stuff, is there any other forms to fill out when it involves making a firearm? I will never do more than 50 in a year if that number matters.

Thanks in advance. Im sure Im going to have to correct some issues with my paperwork.

 

[LRI]

Step one (learned after being peeled like an onion last summer)

You call BATF Regional Center Industry Operations.
You get a name
You get told a procedure
You document who you spoke with

THEN

You call your local office and speak with the inspector
You get a name
You document the name
You get a procedure

You follow it.

Biggest thing I found with an 07 is ensuring you do the annual production report. You can FAX/Email it and when you do (I suggest email as then there's an audit trail) you CC a copy to your local inspector by name. Then you keep after the BATF Firearms/Service Div. to respond that they have your report. The acknowledgment is your golden ticket. The POC for this is:

Thomas B DiDomenico
United States Department of Justice
Bureau of Alcohol, Tobacco, Firearms and Explosives
Enforcement Programs & Services (EPS)
Firearms & Explosives Service Division (FESD)
Phone (304) 616-4590
Fax (304) 616-4591

I'd submitted my reports like a good little minion but failed to do the follow up. Well, low and behold they didn't have 2012 on record and it red flag'd me.

"Hello, were hear to ruin your life for the next two days. . ."

Your production will grind to a hault during an audit. One thing that made life easy (er) was having everything in electronic format. Check out Ebound from Gunderson Software. It's not elegant, but it's simple and meets the BATF audit trail requirements.

Thankfully, we are blessed to have some level headed/common sense oriented inspectors in my region. The horror stories abound however. Never forget that its YOU against the United States Government. Just ensure your making the diligent effort to document and ensure your A/D books have accurate/current information and you'll be fine.

You REALLY have to Eff up to have criminal matters come into play. Most are just administrative errors that result in a butt chewing. When you screw up, take it seriously and correct it.

The golden ticket....don't forget!

Good luck.

Chad