ATF

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Bureau of Alcohol, Tobacco, Firearms and Explosives

February 1, 2010

www.atf.gov

ATF Form 4473 — Who Handles Your Paperwork?

Each year, across this great nation, responsible federally licensed firearm dealers perform millions of firearm transactions. Whether it is selling a firearm to a first-time buyer, hunter or sportsperson, a collector, someone concerned about personal or home defense, or just a customer who wants to enjoy the great outdoors, your primary responsibility remains the same — the correct completion of ATF Form 4473.

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Where do you draw the line on who fills out your ATF Form 4473s? Are you confronted with mistakes and their accompanying headaches? Train, coach and, perhaps, change who handles the paperwork.

During the last decade, this form has evolved into an important “gatekeeper” role to ensure proper transfer of firearms to a qualified individual. The form includes non-licensee and licensee information, probing questions, background approvals or denials, consideration of state law logistics and detailed firearm information pertaining to the manufacturer, importer, model and serial number of the firearm. It also wields three and one-half pages of instructions, and is backed by the 1968 Gun Control Act, the Brady Bill and a 483-page State Law book that makes good reading for most insomniacs.

Lastly, and most important, the form calls for the name and position of the person actually transferring the firearm. As responsible Federal Firearms Licensees (FFLs), dealers know better than anyone that selling and transferring a firearm is much different than selling a “widget.” Although each of us seeks to maximize sales and profits, we understand fully our special responsibility to our friends, neighbors and communities to do everything in our power to ensure the lawful transfer of a firearm to a qualified purchaser.

Whether you are a big-box retailer employing 200 or more employees, or a small gun shop in the middle of the north woods with two employees, the scenario is the same. We place this critically important transfer process in the hands of our employees. Every retail dealer has or should have some type of training program for their employees on the correct procedures in completing ATF Form 4473.

This can be simple and basic training, or more elaborate programs, which may involve computer-based training and perhaps weeks of shadowing experience by trained employees.

What policies does your store or company have regarding the correct completion of ATF Form 4473? How do you handle mistakes made by your employees? Your customers? As important as these forms are to the livelihood of a store owner, not to mention ensuring public safety in the neighborhood, where do you draw the line on who handles this paperwork?

Train, Coach And Evaluate

I’m not going to tell you how to handle serious or minor infractions on ATF Form 4473; however, I will advise you to take ATF in your confidence when you do find mistakes. They actually do care, and do not want a dealer to wind up being a headline in the newspaper or a breaking story on CNN.

What I will share with you are some common points to ponder in the way you train and coach your employees to ensure they complete the task of a proper and correct firearm transfer.

  1. Train your employees well. Spend time coaching your employees and answering their questions — remember, repetition builds confidence and skill.
  2. Let your employees know how important following applicable gun-control laws are, both from a business and public-responsibility standpoint. Be firm, but not threatening.
  3. Give your employees reasons why it is important: public safety. It is their friends and family who live in the neighborhood, as well. And your Federal Firearms License — you can lose it if they do not follow the law.
  4. When they make mistakes, make sure your employees understand, in detail, the nature of their error, and involve them in the correction process. This usually prevents the same mistakes from happening again.
  5. Use second and third checks to ensure proper completion of Form 4473. This will lower stress on the employee, knowing another set of eyes will assist in accuracy.
  6. When errors occur, hold your employees accountable, and be consistent with retraining and counseling.
  7. Do not use intimidation or “zero tolerance” policies. This may cause some employees to make mistakes and hide them in fear of losing their job, causing problems for you down the road during an ATF Inspection when the investigator catches it. Evaluate and respond to each situation based on the circumstances.

Decision Is Yours

Now, here is some practical advice for an owner, manager or supervisor. You have to realize that not everyone is detail oriented enough to be a good firearms employee. They may have all of the firearm knowledge in the world, but if they cannot ensure “The Form” is completed properly, you may need to make a change. So, again I ask, where do you draw the line on who handles this paperwork?

Coach your employees in becoming fluent in completing ATF Form 4473.

I cannot tell you where to draw the line at your firearm counter. I will say, if you have given your employees good training, coaching and an opportunity to own part of the process, rather than just be a tool in the transaction, you have given them the basic ingredients to be successful firearm salespersons. If they make mistakes, and coaching, retraining and counseling does not deter them from making further mistakes, then you truly have a decision to make on their future employment in firearm sales.

So the decision is yours. My advice is be a part of the solution, not the problem. If you are the owner, manager or supervisor of a firearm department or store, be involved. Know how your employees conduct firearm transactions. Understand their level of knowledge and attention to detail. Use this to coach your employees in becoming fluent in completing ATF Form 4473. Trust your employees, but verify they are getting it right by auditing their work early and often.

Lastly, help them to become Compliance Champions and not Compliance Catastrophes. Our industry does not win if we, as responsible firearm dealers, do not do our part in transferring firearms legally, to the best of our abilities, while using good judgment.

About the author: Kevin McKown is the director of Regulatory & Firearm Compliance for GanderMountain, with responsibility for 117 stores. I love the shooting sports, and want to do my part to try and make it a little better, he said.

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This article was reprinted, with permission, from the January 2010 issue of Shooting Industry Magazine.