Stay up-to-date on ATF Compliance.
The Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF), via ATF Ruling 2016-1 (April 29, 2016), authorizes an alternate method or procedure to the firearms acquisition and disposition recordkeeping requirements. Compliance with ATF requirements is the highest priority of Gun StoreMaster. This ruling supersedes ATF Ruling 2013-5 (December 17, 2013) which also addressed the use of electronic recordkeeping.
As noted in the ruling,
"Held, pursuant to 27 CFR 478.22, 478.122(c), 478.123(c), 478.125(h), and 27 CFR 479.26, ATF authorizes an alternate method or procedure to the paper bound firearms acquisition and disposition recordkeeping requirements of 27 CFR 478.122, 478.123, 478.125(e), and 478.125(f), and 27 CFR 479.131. Specifically, ATF authorizes licensed importers, licensed manufacturers, licensed dealers, and licensed collectors to maintain their firearms acquisition and disposition records electronically, provided all of the following conditions are met:"
Here are the conditions of the ruling and how Gun StoreMaster™ meets or exceeds each one:
|ATF Requirement (Rule 2016-1)||Gun StoreMaster|
1. The licensee records in the computer system all of the acquisition and disposition information required by 27 CFR 478.121, 478.122,478.123, 478.125(e) and 478.125 (f), and 27 CFR 479.131, as applicable. Required information includes a record of both the manufacturer and the importer (if any). Additional columns can be utilized to capture certain additional information (e.g. inventory number, new/used, etc.), so long as the additional information is separate from the required information and the required information is readily apparent. An ATF Form 4473 serial number may be used instead of the address for recording the transfer of a firearm to a non-licensee if such forms are filed numerically.
With our eSAFE electronic Bound Book, Gun StoreMaster captures all required data to satisfy ATF requirements. This includes:
Gun StoreMaster can also record additional information, such as condition, notes and attachments (photos, scanned documents, etc.).
2. The electronic acquisition and disposition bound book software must track corrections and changes utilizing one of the following methods of tracking changes:
a. The system must retain any correction as an entirely new entry, without deleting or modifying the original entry. When the software generates the bound book, the system must be able to quickly and easily change views of the bound book as follows:
1. Only view the original entries;
2. Only view the corrected entries; and
3. View both the original and corrected entries in the same bound book.
b. The system must be able to print the corrections as a separate report containing the same parameters as are required for a paper bound book, including the firearm information, acquisition details, and disposition details. The format of the correction report may follow the traditional bound book format, or may be presented in any column format as long as the necessary information outlined above exists in the report (which may include a notes column).
c. If a spreadsheet program (e.g., excel) is being utilized, the system must be able to track any edits/corrections/amendments in a “notes” column. Any edits/corrections/amendments may overwrite the original entry so long as the “notes” column explains any edits/corrections/amendments and/or tracked changes (i.e., what was changed, who made the change, and why the change was needed).
We go well beyond the idea of using a spread sheet with macros to keep track of your valuable firearm data. Our system utilizes state-of-the-art database methods to insure that you know exactly what the history of all your bound book entries are.
Records with annotations (edits) are clearly marked on the bound book output in an easy-to-read chronological order. The original entry and any subsequent changes are readily organized, making both the FFL dealer and ATF inspection efforts simpler to manage.
|3. The system cannot rely upon invoices or other paper/manual systems to provide any of the required information. Also, if a licensee chooses to use an electronic recordkeeping system for any of its required acquisition and disposition records, then all acquisition and disposition records, regardless of type (e.g., gunsmithing, sales, NFA), must also be in the electronic format as prescribed by this ruling.
||Gun StoreMaster does not rely upon invoices or other paper/manual systems for any of the required information. Additionally, Gun StoreMaster can keep track of all types of firearm transactions, including gunsmithing, NFA, manufactured items, consignments, transfers, etc.|
|4. The system must allow queries by serial number, acquisition date, name of the manufacturer or importer, name of the purchaser, and address of purchaser or other transferee.||
With Gun StoreMaster, you can search by:
5. The licensee must download all records from the system to a physical storage device (e.g. hard drive, Compact Disc (CD), Digital Versatile Disc (DVD), or Universal Serial Bus (USB) Flash Drive) at the licensee’s business premises, or print and maintain them at the licensee’s business premises:
a. at least semiannually; however, if the records are downloaded, from a host facility (e.g., remote server or cloud storage provider) contracted/leased by the licensee as provided in condition #9, they must be downloaded at least daily. In all cases, the records must be downloaded in a format that is unencrypted with the required information readily apparent;
b. upon request of an ATF officer (must be provided within 24 hours);
c. prior to discontinuance or change of: the software (program); the database system, whether or not maintained by a host facility (e.g., remote server or cloud storage provider); and/or the host facility (if applicable); and
d. prior to discontinuance of the licensee’s firearms business.
The downloads/printouts must include all firearms in inventory, as well as all firearms transferred during the period covered, sequentially by date of acquisition, and must be limited to display only the information required by the applicable regulations. The downloads/printouts may contain additional columns capturing certain additional information, provided that the required information is readily apparent.
With Gun StoreMaster InStore, all your records are automatically downloaded to your computer (at your business premise). No need to perform an export or other complicated procedure.
Additionally, Gun StoreMaster InStore creates a nightly Bound Book output automatically (recycles every 30-days).
6. If a licensee downloads the records onto a physical storage device (e.g., hard drive, CD, DVD, or USB Flash Drive), the download must be retained on the physical storage device until the next download is prepared. Additionally, the licensee must be able to present the most current version of the requested records in a printed format at ATF’s request.
|Viewing or printing your eSAFE™ Bound Book can be done any time, with or without Internet access. Print output is in a PDF compatible format, which can be saved both in electronic form or printed on paper. The information contained in the eSAFE Bound Book output contains only information required and specified by regulation - attachments, documents and other notes are not part of the output.
|7. If the licensee prints out the records, the printout must be retained until the next printout is prepared||Printing your Bound Book is easy to do with Gun StoreMaster.
|8. Downloads/printouts may include antique firearms, but cannot include other merchandise. However, antique firearms must be identified as such in the “firearm type” column.
||Antique firearms are not included in the ATF bound book output. As a convenience, antique firearms can be entered into the Gun StoreMaster system where they can be searched and included on many performance and inventory reports.|
9. Electronic firearms acquisition and disposition records may be stored on a computer server or device owned and operated by the licensee, or contracted/leased by the licensee through a host facility (e.g., remote server or cloud storage provider), provided that:
a. The firearms acquisition and disposition records are readily accessible through a computer or device located at the licensed premises during regular business hours; and
b. The licensee’s server is located within the United States or its territories, or if a host facility is used, that facility must have a business premises within the United States or its territories, and must be subject to U.S. legal process.
Licensees are strongly encouraged to ensure that there are proper and robust security protection measures in place (e.g., encryption) to ensure all data is protected.
|With Gun StoreMaster InStore, your records are readily accessible through a computer you own. To protect the data stored in Gun StoreMaster and InStore, the data is encrypted.|
|10. If the licensee contracts with, leases from, or changes a host facility (e.g., remote server or cloud storage provider), the licensee must, within 30 days, notify his/her respective ATF Area Office of the name and address of the host facility.
||Since Gun StoreMaster synchronizes your firearm data with your own computer using InStore, there is no need to notify the ATF Area office. We keep it SIMPLE!
|11. Each licensee must maintain its firearms acquisition and disposition records on a separate/partitioned database that cannot be intermingled with the records associated with another license.
||Unlike other systems, when your records are automatically synchronized with InStore, they are not intermingled with records from other licensees. We work to keep it SIMPLE!|
|12. The storage system must back-up the firearms acquisition and disposition records on at least a daily basis to protect the data from accidental deletion or system failure.||Gun StoreMaster has an amazingly easy and comprehensive automatic backup system. With InStore, your data is automatically backed up to Gun StoreMaster every few minutes and your backup is accessible through a secure online connection. Additionally, you can command the system to perform local backups whenever you like and store the backups on a portable storage device or other media. If that isn't enough, daily backups are created and stored automatically on your InStore computer.
|13. Licensees must retain all records in accordance with 27 CFR 478.129, ATF Rul. 2010-8, Consolidation of Required Records for Manufacturers, and ATF Rul. 2011-1, Consolidation of Required Records for Importers (as applicable). It is strongly recommended that upon reaching 20 years, those electronic firearms acquisition and disposition records be either permanently maintained by the licensee or forwarded to the ATF Out-of-Business Records Center for preservation.
||Don't forget to keep the records in accordance with ATF rules! Gun StoreMaster helps keep those records organized for you.|
|14. Upon discontinuance of business, the licensee must send required records to the ATF Out-of-Business Center in accordance with 27 CFR 478.127. The licensee must print out the required records or download them to a physical storage device (as defined in paragraph 5) or, at the discretion of the licensee, both. The complete printout or download must provide an American Standard Code for Information Interchange (ASCII) text file (in conformity with industry standards) containing all acquisition and disposition records, and a file description. The complete printout or downloaded ASCII text file (and file description) must contain all information prescribed by regulation. The NTC converts these files into image files not searchable by name.
||Gun StoreMaster can easily export your bound book records to conform to this requirement. The CSV ASCII text file includes headers describing the content for each column. Pair this export with with a complete printout or PDF file to conform to this requirement.|
We recommend exporting your data periodically. This can be done by starting your Gun StoreMaster InStore program and selecting Manage | Export. This way, you not only leverage the sophisticated built-in automatic data safety and security systems of Gun StoreMaster, but you'll also have your 'local' exported copy of the data for peace of mind.
After all, how safe and secure is writing on paper?
Always Accurate, Simply Superior sm