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Licensee – Who Can Remove Gun from FFL

posted on January 18, 2019

Q: We have been told by local ATF during an ATF seminar, that only a responsible person may take a firearm off premise. After reading the Help Desk solution appended below, it would appear that is not the case. Just to clarify: If the FFL takes a firearm off site e.g. a) displayed at a fundraiser to be transferred later at the store to the winner (typically the firearm is out overnight as these happen after work hours), b) to the range to test fire a firearm, c) employee (not third party or separately licensed gunsmith) takes a firearm home overnight to clean or repair, it does not have to be a responsible person, does not have to be logged out, and does not require a 4473. Revision Date: 08/04/2015 Solution#: 00001829 Q:1. May an FFL take a firearm off-site to demo? 2. May an FFL send a firearm off-site to a gunsmith to be worked on?3. May a firearm in inventory be taken off-site to have its color changed? A: MAY AN FFL TAKE A FIREARM OFF-SITE TO DEMO? A. Yes. Because this is not a transfer, only a temporary demo, no A&D entry needs to be made nor is a 4473 completed. I would make some written receipt to show the employee has permission to take said weapon for demo purposes on said date(s). MAY AN FFL SEND A FIREARM OFF-SITE TO A GUNSMITH TO BE WORKED ON? A.When a firearm is sent off-site to a gunsmith to be worked on, it should be logged out in the A&D record to the gunsmith, then logged back in when it is returned. **(If the question is whether a gunsmith may work off-site, then ATF Rule 77-1 says a gunsmith may make immediate on-the-spot repairs to firearms at skeet, trap, target, and similar organized shooting events. Required records still must be maintained except for where the owner waits and it all happens in the same business day and no 4473 where given back to the person from whom received.) MAY A FIREARM IN INVENTORY BE TAKE OFF-SITE TO HAVE ITS COLOR CHANGED? A. Yes. Here again log it out in the A&D to the FFL who is specializing in coatings and treatments, and then log it back into the A&D record when it returns.

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