We are human. We are going to make mistakes. It is going to happen. In the FFL business while mistakes do happen once we identify the mistake we need to fix them correctly and put steps in place to ensure they do not happen again. All while maintaining our ATF compliance.

Recently an issue came up with a client. This client uses a separate point of sale (POS) for their daily transactions and EzOnlineFFL on the backend to maintain their A&D. During a inventory the client realized they were missing firearms. In my Forest Gump voice “this is a bad thing”. So upon further research they determined that the guns were sold in the POS however one here and there did not make it onto the 4437 creating the illusion that the guns were still in inventory when in fact the customer had paid for them and left.

So we are posed with a few questions and considerations.

• We know the firearms went to a legitimate person who passed a background check.
• The missing firearms simply need to be added to the existing 4473’s which would take them out of inventory and resolve the descrpancy.
• All 3310’s needed to be updated and resubmitted.

And all of this has to be done by the letter of the ATF because no one wants to get in trouble. So what did we do, we contacted our IOI and explained the situation. Believe it or not in this circumstance they were understanding and very accommodating. The IOI was grateful that an inventory was done and that the issue was identified during the in-house inventory and not during an ATF visit. The IOI did say that if they had discovered it during an inspection that it would have resulted in a write up but were glad that an effort was being made to fix the problem and not cover the problem up.

So what was the solution? Turned out to be pretty easy.

• We downloaded all 4473’s and 3310’s as they are currently in EzOnlineFFL. These documents are labeled our “Originals”
• Once all originals were collected and secured we added the missing firearms to the appropriate transaction. Taking careful care to ensure each firearm landed where it was supposed to go.
• Once all the transactions were confirmed correct we added the original documents to each corresponding transaction and labeled them originals as the new ones are now the corrected copies.
• The client printed out the originals and the corrected copies and combined them together for recording purposes.
• Corrected 3310 were marked across the top as “CORRECTED” and resubmitted.

That is it! Disaster avoided. All the documentation matched what had happened and what was done to correct it and the clients inventory is now accurate.

Now, it has to be said. A good relationship with your local ATF personnel is paramount. In our experience we have a good interaction with our IOI’s however there has been cases where one was telling you to go right and the other was telling you to go left. In these situations find a contact and shoot off an email. Get a response in writing will always help.

Just remember the last thing you want to be accused of is deception in your record keeping. Be honest, and have that prof.

As always we are here to help.