C&R audit question

[CLRTR999]

Considering getting a curio and relic FFL 03 license (while they're still useful in WA, I know you OR guys have had them rendered useless). For those of you that have had your C&R for a while, have you ever been audited? From my conversations with C&R holders I've never heard of anyone ever being contacted by ATF. My assumption is that ATF has more important things to deal with and as long as you don't blatantly raise any red flags you'll probably never be asked to see your bound book.

Also I know when you apply you send a courtesy copy of the application to your local CLEO. Anyone ever had them ask about your C&R?

Thanks for any insight you have.

Read More

 

[Nosferatu]

No

 

[308]

Nope
I have a 20+ yr/old bound book that no one has seen but me

 

[WheatNuts]

No to both. My advice though, is to let your license lapse and reapply for it later, instead of renewing it when it expires. If you do this, the firearms that you bought or sold on the previous license are no longer subject to an audit, and the bound book can be disposed off. So these firearms are essential now "off the books."

 

[brownmouse]

why do you say that the C & R license in oregon is useless? I have one and have been able to sell old lugers to licensed dealers.
Are you referring to making a sale in oregon?

 

[CLRTR999]

why do you say that the C & R license in oregon is useless? I have one and have been able to sell old lugers to licensed dealers.
Are you referring to making a sale in oregon?

My understanding is that SB941 signed into law in 2015 mandated that all firearms transfers go through a regular FFL, along with a BGC, and there would be no exceptions for anything normally covered under a C&R license, thus rendering the usual advantages of having one moot. I don't live in Oregon so perhaps one of the OR guys can expand on that a little more. We haven't had this particular assault on firearms liberties happen in WA...yet.

 

[ma96782]

You can bet that somewhere in Biden's budget increases.....there are provisions for more BATF agents.

Aloha, Mark

 

[clanhanson]

You can bet that somewhere in Biden's budget increases.....there are provisions for more BATF agents.

Aloha, Mark

My dog: *gulps*

 

[ma96782]

Perhaps, it could be sold to the public as.......

Closing the C&R Loophole

Aloha, Mark

 

[WheatNuts]

My understanding is that SB941 signed into law in 2015 mandated that all firearms transfers go through a regular FFL, along with a BGC, and there would be no exceptions for anything normally covered under a C&R license, thus rendering the usual advantages of having one moot. I don't live in Oregon so perhaps one of the OR guys can expand on that a little more. We haven't had this particular assault on firearms liberties happen in WA...yet.

Just another example of the geniuses at the anti-gun brain trust at work, considering the ATF performs a background check on all C&R applicants...

 

[User 1234]

No to both. My advice though, is to let your license lapse and reapply for it later, instead of renewing it when it expires. If you do this, the firearms that you bought or sold on the previous license are no longer subject to an audit, and the bound book can be disposed off. So these firearms are essential now "off the books."

That chestnut gets passed around the C&R world on a regular basis. Unfortunately the requirement to keep the bound book for 20 years applies to 03 FFLs too, not only dealers.

 

[User 1234]

Public service announcement for 03 FFLs

I’ve seen people on various message boards boast about burning their bound books when their C&R expires. Just as an FYI, the ATF’s regulations require licensees (both dealers and collectors) to retain their bound books for 20 years. 27 CFR 478.129(e)...

www.northwestfirearms.com

 

[40Garand]

why do you say that the C & R license in oregon is useless? I have one and have been able to sell old lugers to licensed dealers.
Are you referring to making a sale in oregon?

If you're selling to a licensed dealer what good does having a C&R do?

 

[WheatNuts]

That chestnut gets passed around the C&R world on a regular basis. Unfortunately the requirement to keep the bound book for 20 years applies to 03 FFLs too, not only dealers.

Interesting. I obtained the info from an ATF agent over the phone. The ATF has to be one of the most poorly run government agencies in this country. I've read many stories of people getting conflicting advice and info from them over the years.

 

[40Garand]

Interesting. I obtained the info from an ATF agent over the phone. The ATF has to be one of the most poorly run government agencies in this country. I've read many stories of people getting conflicting advice and info from them over the years.

9 months to get form 4 approvals should be the first clue.

 

[CountryGent]

I was audited for my 03 FFL (C&R) in 2009. The BATFE representative looked at my bound book, compared the serial numbers to said, and done with that. He then read over a script detailing current federal statutes on firearms. I asked a few questions. That was it; total nothing burger.

When I acquired my current 01 FFL (Dealer) license in 2018, an BATFE Investigator came out to my commercial location. He also went over a script detailing the regulations. I asked a few questions. Again, that was it. I renewed recently and received the updated license.

During the aforementioned 2018 visit, the Investigator noted I had C&R licenses in the past. I made a passing reference to my audit and he said something like "Oh, you were one of those back in 2009? For the first time we did a massive audit of C&Rs. We found pretty much no problems. It was before my time, but it is still talked about.". I remember thinking "in order to burn off stimulus budget, perhaps?" But I opted to keep my mouth shut.

Long story short (I know, too late), it is really nothing to be concerned about. Happy collecting.

 

[CLRTR999]

CountryGent, thanks for posting your experience. Interesting information. When the agent did your C&R audit, did he come to your house or did you meet him at a field office? And when you say he compared serial #'s to your bound book, I assume you needed to physically produce the firearm(s) in question for inspection? No concerns from him along the lines of "the firearm(s) listed may not qualify as eligible for C&R classification"? Do you know if he also contacted the CLEO for your area? Not trying to sound overly paranoid, but with the Biden administration wanting to vastly increase the number of ATF agents, just want to be prepared for what may be coming down the road.

 

[CountryGent]

Howdy @CLRTR999. I'll try to answer your questions in order:

• The C&R audit was at my residence. We talked a the kitchen table.
• I did physically produce the firearms in question. I had, literally, just started that C&R license, so there was not much to check. He did not ask to see any other firearm in my possession.
• He did not mention C&R eligibility. The few items he saw were all pre-war guns, so well within date range though.
• I don't know if he contacted the CLEO. If he did there was no reference to said. I strongly doubt it though as it the point of the compliance inspection is, largely, to make sure we're keeping our paperwork in order.

Anyway, I hope that helps.

 

[CLRTR999]

@CountryGent, thanks for your response. Good information.

Anyone else have any C&R audit experiences they'd like to share?

 

[Alexr4920]

No not at all but i think that be the cool i dea im not sure.