The trigger under 18 U.S.C. §923(g)(3)(A) is two or more pistols, revolvers, or any combination of handguns to a single unlicensed transferee within 5 consecutive business days. The 5-day clock starts on the date of the FIRST disposition. Long guns are not counted (separate state-level multi-rifle reporting applies in some Southwest border states — see item below).
If two handguns are transferred to the same person on Form 4473 in your records — even across separate transactions, separate days, or different employees ringing them up — they count as a multiple sale. Sales to two members of the same family are NOT a multiple sale unless the same individual is the transferee on both.
A redemption of two or more pawned handguns by the same person within the 5-day window is a multiple sale and must be reported on Form 3310.4. Many FFL/pawnbrokers miss this — pawn redemption is a disposition under federal law.
ATF Form 3310.12 (separate from 3310.4) requires reporting of multiple sales of semi-automatic rifles greater than .22 caliber capable of accepting a detachable magazine, to the same unlicensed person within 5 consecutive business days, but ONLY for FFLs in Arizona, California, New Mexico, and Texas. Outside those four states, multiple long-gun sales are not federally reportable.
Older revisions of 3310.4 may be rejected. Download the current PDF from atf.gov before completing. The form is available as a fillable PDF.
Buyer name, address, date of birth, place of birth, height, weight, race, ethnicity, and ID type/number must match what appears on the 4473. A discrepancy between the 4473 and the 3310.4 is a common audit finding.
For every handgun in the multiple sale: manufacturer, model, serial number, caliber, and type. The serial numbers and other descriptors must match the corresponding 4473(s) and your A&D book exactly.
Form 3310.4 is filed by the FFL, not by the buyer. The buyer does not sign Form 3310.4. The FFL signs and dates after the second (or subsequent) disposition occurs.
Federal law requires the report to be submitted no later than the close of business on the day the multiple sale occurs (the day the second handgun is transferred to the same buyer). Do NOT wait — same-day filing is the rule.
Per 18 U.S.C. §923(g)(3)(A): the FFL must forward a copy to (1) ATF (typically the Industry Operations field office, address on the form instructions) AND (2) the state police or — if no state police agency exists — the local law enforcement agency where the sale occurred. Both copies are required; sending only to ATF is a violation.
ATF accepts electronic submission of Form 3310.4 through the eForms system. Electronic submission generates a timestamp confirming compliance with the same-day filing requirement and is the recommended method. Paper is still accepted.
Per ATF recordkeeping rules, the FFL's copy of Form 3310.4 must be retained with the corresponding 4473s. Cross-reference the 3310.4 in the A&D book disposition entries for the handguns involved.
Multiple-sale non-reporting consistently ranks in the top 10 ATF compliance violations. The remedy is procedural — staff training and a same-day-of-second-sale review of every customer's 4473 history is the standard control.
Filing the next morning is technically a violation even if all information is correct. The "close of business that day" deadline is statutory.
When the buyer abbreviates their name on the 4473 but writes it differently on the 3310.4, ATF flags it. Use the 4473 as the source of truth and copy buyer info verbatim to the 3310.4.
Most FFLs train staff on retail multi-sales but forget pawn redemptions. A customer redeeming two handguns within the 5-day window must be reported same-day, even though no money changed hands at retail.