Q: Is there a rule either by ATF or FFLGuard that requires employee of FFL to carry receipt for a firearm that they are carrying while working in FFL store?
A: The presumption exists that all firearms on a business premises are for sale, and thus should be entered in the records required to be maintained under the law and regulations. However, it is recognized that some dealers may have personal firearms on their business premises for purposes of display or decoration (or because the owner wants to go hunting after work, etc.) and such are not store guns and are not for sale.
Firearms dealers who have such personal firearms on licensed premises should not intermingle these firearms with firearms held under their license (in their A&D records). Such firearms should be segregated from firearms held for sale and appropriately identified (for example, by attaching a tag) as being “not for sale.” Personal firearms on licensed premises which are segregated from firearms held for sale and which are appropriately identified as personal firearms not for sale need not be entered in the dealer?s records.? The Personal Firearms Record book (ATF P. 3312.8), an ATF publication, can be used is a “personal” record of firearms to keep track of your private firearms not for sale. Something you will have to show to an IOI that the firearms really are personal firearm and not for sale (as opposed to simply unlogged firearms on premises). The Personal Firearms Record book (ATF P. 3312.8), an ATF publication, can be used as a “personal” record of firearms to keep track of your private firearms not for sale.
In our experience, the presence of the firearm on the employee’s hip has been a sufficient identifier, and none of our clients has been cited for a violation under such circumstances. However, it is better to simply keep a log on a piece of notebook paper at your store where all of your carrying employees note the identifying information of their personal carry gun. Of course, if an employee takes their firearm off their person at any time, it should be immediately segregated and properly labeled. Also, a receipt of bill of sale showing they own the firearm would serve as “proof of ownership” if ATF’s inquiry went that far.
[This information can be found in eBlast 1.30.15]