Q: This is a follow-up question regarding the FFLGuard email sent out with the subject: “FFLGuard California Solutions: Firearm Lock Inquiry.” We understand the findings in the solution, but would like further clarification for not requiring a new lock for a transfer. On the California DOJ website (http://www.oag.ca.gov/firearms/fsdcertlist/) there is a list of situations where a safety device is not required. The one that seems to pertain to safety devices brought in by the customer requires a receipt demonstrating the lock was purchased within 30 days: “Persons who can demonstrate the purchase of a DOJ-approved safety device in the 30 days prior to taking possession of the firearm by presenting the device to the firearms dealer and providing the firearms dealer with a receipt showing the purchase date and model name of the device.” We are currently copying such receipts to the transfer paperwork. From the section above, it appears that even if an OEM lock is presented with a transferred firearm, a receipt is required. Would you please clarify the following: (1) Given the above section, confirm that for transfer situations a new lock is not required, and (2) How we would need to document for the CA-DOJ that an approved OEM lock (safety device) was presented by the customer for the transfer if there is no receipt?
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