I got this letter last week from Carson W. Carroll, Assistant Director of Enforcement Programs and Services for ATF:
The purpose of this open letter is to provide you guidance on certain regulatory requirements and voluntary security measures, as well as recommended guidelines for securing and moving firearms records and inventory in the event of a natural disaster. Guidance is also suggested in the event that your business premises is destroyed or partially damaged.
As a Federal firearms licensee (FFL), it is your duty and obligation to account for the acquisition and disposition of firearms, and it is essential to ensure that firearms are not diverted to the criminal element whether by theft or pilferage. ATF is dedicated to your success in fulfilling your duties and preventing the unlawful diversion of firearms. The following guidance on required and recommended security measures is intended to assist you in accomplishing these goals.
Among other things, Federal regulations require that you report any lost or stolen firearms to ATF by contacting the Chief, Law Enforcement Services Branch at (888) 930-9275 or 1-800-800-3855 (after hours), and by submitting to ATF the ATF F 33111, Federal Firearms Licensee Theft/Loss Report, within 48 hours of discovery of the theft or loss. The Theft/Loss Report is available at http//www.atf.gov.forms/pds/f331011.pdf or can be obtained by contacting the ATF Distribution Center at (703) 455-7801. You must also report the theft or loss to the appropriate local authorities.
You are also required to keep timely and accurate acquisition and disposition (A&D) records. Acquisitions must be recorded by the close of the next business day, and dispositions must be recorded within 7 days. You are required to record all thefts or losses as dispositions in your A&D record. You should do this by indicating whether the incident is a theft or loss, the ATF incident report number, and the incident number provided by the local law enforcement agency. Any firearms that are later recovered should be reported to your local ATF office.
Additionally, if your business premises are destroyed, you should contact your local ATF office regarding requirements for changing your business premises address. If you choose to cease operations, you must make arrangements to surrender your business records to the Out-of-Business Records Center.
A Web site you may find very useful in helping your business to plan for a natural disaster can be found at www.ready.gov. Following are additional voluntary measures you can take in the event of a natural disaster:
Recommended voluntary steps that you may take now to prepare for a pending natural disaster:
Contact your local ATF office and provide a cell phone number so that we may update our Federal Firearms Licensing Database.
Conduct a full inventory of all firearms on the premises. Match each firearm with an open entry in your A&D records (i.e., bound book).
Although conducting a firearms inventory is not required by law or regulations, proper inventory control is critical in assisting law enforcement with tracing firearms and potentially solving crimes. Also, having an accurate inventory may be very useful to you in establishing losses for casualty claims.
A proven method of controlling inventory is a periodic complete inventory to bound book reconciliation. PLEASE NOTE: Any lost or stolen firearms identified during the reconciliation must be reported to ATF in accordance with the firearms theft/loss procedures previously mentioned.
Recommended voluntary procedures to follow if you need to evacuate your premises and/or store you records and inventory at an alternate location:
Contact the local ATF office.
Provide your Business Name, Licensed Premises Address, and FFL Number.
Provide a telephone contact number.
Provide a temporary address.
In certain emergency situations, local field supervisors may be granted authority to verbally approve certain requests, such as change of business premises or to remove firearms inventory and records to an alternate location.
Provide the ATF National Tracing Center (NTC) with your temporary address and contact number in the event you need to be contacted to complete a firearms trace. This will also keep NTC apprised of your situation in the event there is a delay in obtaining the information needed to complete a trace.
Recommended voluntary procedures to follow when the firearms premises are destroyed, or the firearms inventory or records are destroyed or partially damaged:
If the firearms inventory is damaged, we recommend that you conduct an inventory when it is safe to return to the business premises. You should record the disposition of the damaged firearms in your A&D records.
If your firearms records (e.g., A&D Records; ATF F 4473 _ Firearms Transaction Record; ATF F 3314 _ Report of Multiple Sale or Other Disposition of Pistols and Revolvers) are damaged, we recommend that you conduct an assessment of the damage to the firearms records when it is safe to return to the business premises, and report the extent of this damage to the local ATF office.
Finally, we recommend that you not destroy any damaged records until written approval has been received from ATF. Please forward any requests to: Bureau of ATF, ATTN: Firearms Programs Division, 99 New York Ave NE, Mail Stop 6N/672, Washington, DC 20226.
ATF Contact Information:
ATF remains committed to assisting licensees in complying with the Federal firearms laws. We have always viewed this commitment as a partnership between industry and the Government and continue to do so. We thank you for your continued diligence in helping to keep America safe, and we look forward to continuing this relationship in future years.
The Firearms Programs Division staff is available to answer questions about the issues addressed in this letter. You may reach them by telephone at (202) 648-7090 or by fax at (202) 648-964