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Are you HOT or COLD?

The key consideration to determine when a client joins the FFLGuard program is whether or not they are coming in HOT or COLD. It lays the foundation for how they are vetted in the interview process to join, as well as how legal services are paid: either by the client, or by FFLGuard.  How you are classified when joining us can be determined as follows:

HOT: You have a current, open, or pre-existing matter with ATF or a plaintiff pending. Your acceptance into the Program is PROVISIONAL and at the discretion of the National Coordinating Counsel after review.  We will only accept the HOT engagement (and may even do so pro bono, at our discretion) if the issues make it a ‘watchdog’ case “that will inure to the public benefit, the benefit of the FFLGuard Program, and/or all clients participating.”

If we take your HOT case, you will need to pay FFLGuard on retainer ($10,000 at a time) for us to work on your HOT matter.  Our normal and customary hourly rates, however, will be discounted as a courtesy.  We will develop a plan of action as to how we feel it would be best to proceed, all in an effort to keep you from business interruption.  While we cannot guarantee the outcome of your HOT matter, there’s no one else around who will do a better job for you.  Period.

COLD: You have no matters pending with ATF or any plaintiff.  You simply believe that proactive measures – preventative medicine – will provide the risk-management necessary to bring your operation to a level of compliance unmatched by other FFL’s, and thus help keep you in business. Your acceptance into the Program is almost automatic, but still at the discretion of the National Coordinating Counsel. You need only pay your yearly fee, and you are officially a Participant entitled to all of our Basic Services while eligible to engage us for our Additional Services.

So long as 90 days pass without going HOT, and you give us no less than 90 out of 100 points on our Law Plus Guidelines, you will pay NO ADDITIONAL MONEY FOR LEGAL SERVICES in case of an ATF audit or legal action by a plaintiff questioning your business practices. It’s already paid for through part of your (and every other client’s) yearly fee dedicated to our community chest: what FFLGuard refers to in the abstract as its “Consulting Services Fund.”

And here’s some additional information to consider before joining us:

  • More than 85% of our clients come in COLD, and no more than 10% of our clients are HOT at any one time. We will not accept new HOT clients if our 10% quota is exceeded.
  •  If you come in HOT, there are NO guarantees. We will represent you without compromising our principles, but with achieving the best possible outcome we can as our goal. If we are successful on your behalf, you must be committed to the FFLGuard Program for no less than the following three (3) years: our reputation is NOT for rent.
  • We’ve never lost a client who originally came in COLD. Ever.


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