For many in the firearms industry, the “bound book” is well known as the regulated record for tracking the lifecycle movement of a firearm through the commercial sector and between licenses and non-licensees. Perhaps less well known are the unintended consequences of relying on software company advertising and advice as the sole determination of your needs as an FFL.
The following are three important considerations when selecting an electronic Bound Book provider for your Federal Firearms License.
When it comes to selecting an electronic bound book, consideration needs to be given not only to compliance with ATF Ruling 2016-1, as so many advertise, but also what that term really means. FFLs find the greatest compliance and financial investment when shopping with a keen awareness and aversion of the “fly by, drop in” A&D installation kit offered by software companies who lack on-hand, operational FFL expertise.
FFLs are most successful when they fully understand the capabilities of the electronic bound book software, including the source and use of firearm data, the location of backup files and user access rights. Consider asking the following questions during your purchase:
Implementation by a software vendor without any operational/regulatory experience is the equivalent of expecting a car manufacturer to ensure you do not break any traffic laws.
Shopping for an ATF 2016-1 compliant bound book means knowing the details about the combined software and services expertise of your provider. Unfortunately, most software vendors don’t employ any ATF compliance experts and merely rely on outside, third party expertise. Such expertise may – hopefully – come with a deep knowledge of the regulations (e.g., an independent attorney), but often lacks any experience in implementing an FFL’s Standard Operating Procedures to ensure regulatory compliance (e.g., an attorney or regulatory expert formerly employed by an FFL).
Consider asking the following questions:
FFLs using paper-based records invest 4-5 minutes to acquire and validate firearms into their chosen ledger. And, for every disposition FFLs invest another 4-5 minutes to dispose and validate a firearm. Dispositions to a non-licensee via ATF Form 4473, or those involving NFA firearms, often require additional time. FFLs using standalone technology can reduce their overall processing time by over 50%, bringing total Acquisition and Disposition time for each serial number down to 1-5 minutes. Even more savings can be realized when A&D software integrates seamlessly into your already existing systems. In such an environment, Acquisitions and Dispositions are automated and zero additional labor is spent on firearms records on a daily basis!
For example, a wholesale FFL may acquire and dispose of 300,000 firearms per year. Running at top efficiency, that would require approximately 300,000 minutes between acquisitions and dispositions. At $17.00 per labor hour (business’s total investment, not employee’s hourly rate), that equates to $85,000 or $3.53 per firearm. Integrating with an ATF Rul. 2016-1 compliant A&D Book can largely eliminate that cost and those resources can be directed to more productive and revenue-generating work!
Consider asking the following questions during your purchase:
Before selecting your electronic bound book software provider, talk to other software users – not the businesses whose names are in the software brochures – businesses that are in your area with similar business models (i.e. if you are a gun shop talk to a gun shop, not a manufacturer). Ask the software provider about clients’ inspection results and how they supported those clients if/when issues were detected. It is important to know if your provider can support you through your inspection process and supply functional solutions if issues are uncovered.
Orchid Advisors provides ATF and ITAR compliance services to manufacturing, distribution and retail FFLs. The firm offers FFL and Export licensing, deep record inspections, e4473 / NFA eForms, Electronic Bound Book software and delivers the largest online ATF and ITAR compliance training platform available. Together with its partners, Orchid delivers the only integrated firearm compliance, technology and legal solution.