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Form 4473 – “N/A” and Question 12.d.2

posted on January 18, 2019

Q: Solution number 00005266 indicates that if question 12.d.1. Is answered “No” then question 12.d.2. Should be answered “N/A”. on Monday 1/9/2017 in a meeting with FFL Dealers at the Arkansas State Police HQ, ATF Industry Operations Investigators told all Arkansas FFL dealers that were present that in that question 12.d.2 should not be answered at all if question 12.d.1 is answered “No”. Their reasoning was not that the question didn’t apply, but that one of the possible answers to that question was that exceptions didn’t apply. That doesn’t make sense to me, but we were directed by ATF to NOT ANSWER question 12.d.2 if 12.d.1 was answered “No”. Until told otherwise, I will direct my staff to follow the advice of our attorneys in Solution 00005266 (and answer N/A). Please advise.

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