Q: We applied for and received a new 01 FFL license to avoid being considered to be subject to ITAR by the State Department, and want to clarify how to handle the records properly. I believe you noted that we have the choice of sending our prior A&D book records to the ATF going-out-of-business records center or just continuing them on. We were thinking of simply continuing on. The ATF Quick Reference Guide notes that one should make an entry in the book noting when the license changed over, but we are using an electronic records system – do we just continue on in it? We need to surrender the 07 license. How do we do this? Do we send it to the ATF going-out-of-business center with a letter noting that we are continuing operation (and/or records if we decided instead to submit those?). If we went the other route, of starting a new book and moving all inventory onto it, I believe we are supposed to send the records to ATF going-out-of-business center with the old license.
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