Q: Can the dealer have guns in the range area to be rented to customers by the range operator? My instinct says that this could not be offsite dealer storage as the range operator is a different business entity and now has control over the dealer?s firearms for rental purposes even though it is all one premises. The range operator would have to be a FFL and the dealer would have to transfer firearms to the range licensee (FFL to FFL transfer) with the appropriate A&D entries. It wouldn?t necessarily have to be a ownership transfer based on ATF?s past decisions regarding non-sale dispositions. The only way around it, possibly, is if the person renting the guns is a dual employee of both businesses. Then the dealer would not be relinquishing control.
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