FFLs Take Notice – Manufacturer and Importer Must Be Listed in Your A&D Books!

All Federal Firearms Licensees need to take notice that both the Manufacturer and the Importer must be listed in his/her/its Bound Books, pursuant to 27 C.F.R. 478.125(e). While many FFLs just list the manufacturer, especially when the manufacturer and importer are the same (or the same company but different corporate structures throughout the world). Recently, the Bureau of Alcohol, Tobacco, Firearms, and Explosives posted on their website a “tip” regarding this issue. Specifically, ATF stated, “Per 27 CFR 478.125(e), a licensed dealer is required to enter both the manufacturer and importer (if any) in the A&D record. <u>While the specific format required does not match the exact wording of the regulation, a licensed dealer is still required to record both</u>, because that information is spelled out specifically in the wording of the regulation. See ATF Tip of Month and 27 CFR 478.125(e).

Isn’t that nice? ATF acknowledges that the format does not match the “exact wording of the regulation,” yet, all FFLs are suppose to be clairvoyant as to the interpretation that the ATF is going to impose. Nevertheless, the language of 478.125(e) does state that the manufacturer and importer are to be listed. Frequently, FFLs will inquire whether they have to list Glock/Glock. Under ATF’s interpretation of 478.125(e), you must list Glock/Glock. Moreover, if one entity is an LLC and the other is Inc., you must distinguish the difference.

Now, as you are likely aware, the manufacturer and importer enrgavings must be placed on the firearm. Hence, all the information that you need must be depicted on the firearm. If the manufacturer/importer has obtained a variance to the marking requirements, you are to list the markings, as engraved on the firearm, in your Acquisition and Disposition book.

 

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