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FFL Watch — Compliance Checklist

Bound Book / A&D Record Audit Checklist

13 items · Last updated May 4, 2026
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Access & Location

A&D records are maintained at the licensed premises and immediately accessible

Records must be available for inspection during business hours. IOIs do not need advance notice to review A&D records.

Commercial records (invoices, manifests) are kept separate from other business documents

Per 27 CFR 478.125, commercial records must be maintained separately and readily available. Commingling with unrelated business files is a violation.

Acquisition Entries

All firearm acquisitions are recorded by the close of the next business day after receipt

Per 27 CFR 478.125(e), acquisitions must be entered no later than the close of the NEXT business day. A firearm received but not yet entered by that deadline is an unrecorded acquisition — one of the most common ATF violations.

Each acquisition entry includes all required fields

Date acquired, name and address of source, manufacturer, model, serial number, caliber/gauge, and firearm type must all be present.

Consignment, pawn, and repair firearms held overnight are entered as acquisitions

Any firearm that stays on your licensed premises overnight — even temporarily — must be logged as an acquisition regardless of ownership.

NFA firearms are recorded separately with registration documents maintained chronologically

NFA items require their own A&D entries. Registration documents (Form 1, 3, 4, or 5) must be kept in chronological order at the licensed premises.

Disposition Entries

All dispositions are recorded within 7 days of sale or transfer

The 7-day rule applies to all dispositions. Recording same-day is best practice — waiting the full 7 days increases error risk.

Each disposition entry includes all required fields

Date transferred, name and address of transferee, and the 4473 transaction number (for non-licensee transfers) must all be recorded.

Spot-Check & Reconciliation

Spot-check 10+ random entries against physical inventory or documented dispositions

Each firearm listed as acquired should either be physically present or have a corresponding disposition entry. Discrepancies must be investigated and documented.

No firearms show as acquired without a corresponding disposition or physical presence

An open acquisition with no matching disposition and no firearm on hand is a missing firearm — requires immediate reporting if theft is suspected.

If using electronic A&D: system meets ATF Ruling 2022-01 requirements

Electronic bound books must meet standards for accuracy, integrity, searchability, and security. Confirm your software vendor is compliant.

Retention & Corrections

A&D records are being retained until business or licensed activity is discontinued (ATF Final Rule 2021R-05F, in effect since Aug 2022)

Current rule: A&D records (along with all Forms 4473) must be retained until the FFL is discontinued — the previous 20-year ceiling no longer applies. This applies to both paper and electronic records. If your license is discontinued, records must be transferred to ATF's Out-of-Business Records Center within 30 days. NOTE: ATF's April 29, 2026 reform package (1140-AA95) proposes a return to a defined 20–30-year retention window — this is currently a proposed rule (NPRM) with public comment open and is not yet effective.

Any discrepancies are documented, investigated, and corrected — without altering original entries

Never erase or obliterate an original entry. Make corrections by drawing a single line through the error, noting the correct information, and initialing the correction.