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FFL Watch — Compliance Checklist

Out-of-Business Records Transfer Checklist

18 items · Last updated May 4, 2026
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Before You Discontinue

Decide whether you are discontinuing or transferring (selling) the business

A "discontinuation" means you are exiting the firearms business and surrendering the FFL. A "successor in interest" sale (where another licensee buys your business and continues operations) follows a different procedure under 27 CFR 478.57. This checklist covers DISCONTINUATION. If selling to a successor, contact ATF FFLC first.

Notify ATF Federal Firearms Licensing Center (FFLC) in writing of your intent to discontinue

Send written notice to FFLC@atf.gov or 244 Needy Road, Martinsburg, WV 25405. Include your FFL number, business name, premises address, and intended discontinuation date. ATF will provide guidance on records transfer, final inventory, and license surrender procedures.

Stop accepting new transfers and consignments

Once you have decided to discontinue, stop taking new transfers, consignments, or pawn pledges. Existing in-progress transactions should be completed promptly OR returned to the customer/shipper before the FFL is surrendered. Do not begin transactions you cannot complete before discontinuation.

Inventory Disposition

Complete a full physical inventory and reconcile against the A&D book

Every firearm in your possession must either be sold/transferred to another FFL or transferred lawfully to a private party (with NICS) before discontinuation. Reconcile every serial number against your A&D book — any unaccounted firearm must be investigated as potential theft/loss and reported per ATF Form 3310.11 if missing.

Transfer remaining commercial inventory to another FFL via Form 4473 or wholesale invoice

Wholesale (FFL-to-FFL) transfers can move via commercial invoice with FFL eZ Check verification. Retail-to-private transfers must go through 4473 and NICS the same as any other sale. The fact that you are discontinuing does not waive any compliance step.

NFA items: transfer via Form 3 (FFL-to-FFL) before discontinuation

NFA items in your inventory at discontinuation must be transferred to another SOT-licensed FFL via approved Form 3, OR transferred to a non-licensee end buyer via approved Form 4 (with applicable tax stamp — $0 for suppressors/SBR/SBS/AOW under OBBBA, $200 for machine guns and DDs). Do NOT discontinue with unresolved NFA inventory — coordinate timing with ATF NFA Division (304-616-4500).

Personal firearms: distinguish business inventory from personal collection

Firearms held in your personal collection (not business inventory) do NOT need to be transferred out. However, ATF has historically scrutinized last-minute "I moved this gun to my personal collection" claims. The transfer from business inventory to personal must have been a documented disposition entry at the time it occurred — not a paperwork move at discontinuation.

Records Transfer to ATF

Within 30 days of discontinuation: transfer ALL records to ATF's Out-of-Business Records Center

Per 27 CFR 478.127, all FFL records must be delivered to the ATF National Tracing Center Out-of-Business Records Center within 30 days of discontinuation. Mailing address: ATF Out-of-Business Records Center, 244 Needy Road, Martinsburg, WV 25405. Use trackable shipping (UPS, FedEx, or USPS Certified Mail).

Records to send: ALL Forms 4473 + ALL A&D records + ALL multiple-sale reports + ALL theft/loss reports

Per ATF Final Rule 2021R-05F, every Form 4473 ever started in your business — completed transfers, denied, voided, or no-saled — must be delivered. Completed transfer 4473s separately from no-sale 4473s. A&D records (paper bound book or electronic export). Form 3310.4 multiple-sale copies. Form 3310.11 theft/loss copies. Any NFA registration documents you retained.

Format Forms 4473 in alphabetical (by transferee name) OR chronological order

ATF accepts either organization but requires consistency. Alphabetical (by buyer last name) is the most common. Within the alphabetical order, completed-transfer 4473s and no-sale 4473s must be SEPARATED — they cannot be intermixed. Use clearly labeled folders or boxes.

Electronic 4473 records: deliver in approved digital format per ATF Ruling 2022-1

If you used an electronic 4473 system: deliver records on a USB drive, CD, or DVD as PDF, TIFF, or JPEG images. Optical Character Recognition (OCR) must be DISABLED, and images must be flattened (not searchable). The system must have allowed printing, retrieval, and segregation of completed vs no-sale forms — vendor compliance with ATF Ruling 2022-1 is your responsibility.

Electronic A&D records: deliver as a complete export with software vendor documentation

Export the bound book per ATF Ruling 2022-01 specifications. Include software vendor name, version, and any documentation needed for ATF to read the export. If the vendor is going out of business or unreachable, contact ATF FFLC for guidance.

Surrendering the License & Final Steps

Surrender the original FFL license to ATF

Mail the original physical FFL license back to ATF FFLC with a cover letter referencing your discontinuation date and the records-transfer shipment tracking number. Do not laminate, fold, or alter the license — return as-is.

Cancel your Special Occupational Tax (SOT) registration if applicable

If you held a Class 1, 2, or 3 SOT, file a final SOT return for the partial year and notify ATF NFA Division of cancellation. SOT does not auto-cancel with FFL discontinuation.

Notify state and local authorities of business closure

State firearms licenses, local business licenses, and any state-level SOT-equivalents must be cancelled separately. Check your state for specific surrender procedures.

Cancel firearms-specific business insurance after records transfer is confirmed

Keep firearms liability and crime coverage in place until ATF has acknowledged receipt of your records. If records are lost in transit, the missing-firearms exposure can persist beyond the discontinuation date. Confirm with your carrier.

Retain a personal copy of the records-transfer shipment tracking and ATF acknowledgment

Keep documentation of the shipment (tracking number, weight, recipient signature) and any ATF acknowledgment letter for at least 5 years post-discontinuation. If a question arises later about a specific firearm transferred during your business operation, this is your evidence that records were properly delivered.

Do NOT destroy any records before delivery to ATF

Destroying or losing records — even old ones — is a federal violation that can result in penalties even after license surrender. If records are missing or damaged, document the situation in writing to ATF before discontinuation rather than discarding the file.