Questions and Answers

Applicants or selectees who have completed part or all of their education outside of the U.S. must have their foreign education evaluated by an accredited organization to ensure that the foreign education is comparable to education received in accredited educational institutions in the U.S. An evaluation is required before human resources can make an official job offer. We will only accept the completed foreign education evaluation.

The announcement will list details to help you determine whether you are qualified for the position. We encourage you to pay close care to these descriptions and guidelines so that you are fully aware of the specifics of the position and desired qualifications/requirements. We highly encourage you address the specialized experience requirements in your resume. Do not copy and paste the specialized experience into your resume; provide examples, illustrations and achievements instead, so we can better assess your experience.

Everyone hired for a federal job undergoes a basic background check of his or her criminal and/or credit histories to ensure that all federal employees are “reliable, trustworthy, of good conduct and character and loyal to the United States.” The U.S. Office of Personnel Management, a central agency that serves as the corporate human resources organization for the federal government, performs the majority of background checks. In addition, federal positions that include access to sensitive information generally require a security clearance. This clearance must be obtained to determine the applicant’s trustworthiness and reliability before granting him or her access to national security information.

Types of Security Clearances and Background Checks

Positions in the federal government are classified in three ways: Non-Sensitive Positions, Public Trust Positions and National Security Positions. Each of these positions requires some level of background investigation. The elements that make up a background investigation vary depending on the level of clearance that is deemed necessary for a position. Background investigations for lower risk levels generally rely on automated checks of an individual’s history. For a secret clearance in a national security position, the investigation requires agents to interview people who have lived or worked with the candidate at some point in the last seven (or more) years.

Once the agency has selected a candidate to hire, the applicant will typically receive a job offer contingent upon successfully obtaining a security clearance. The extensive background investigation takes place after the initial offer has been accepted.

The length and depth of the background investigation will depend on the position’s requirements, as well as the type of security clearance needed (if applicable) for a particular job or internship. This process may take several months or up to a year depending on backlog, need for more information, depth of the investigation process and other factors.

In order to help speed the process along, begin to gather relevant information now. Once you are offered the position, you’ll be asked to submit a series of forms and information about yourself. Gather this information now so you can save time on your end. You can view the forms for background checks (SF-85: Questionnaire for Non-Sensitive Positions) and security clearances (SF-86: Questionnaire for Non-Sensitive Positions) on the Office of Personnel Management’s website.

Once you have submitted the documentation, the designated agency will proceed with the investigation, depending on backlog and priority.

No.

Licensed manufacturers and importers must mark firearms they manufacture or import pursuant to 478.92(a)(1). However, there are exceptions allowing licensed importers and manufacturers to adopt existing markings previously placed on firearms under specified circumstances.

Pursuant to 478.92(a)(4)(iii)(A), licensed manufacturers may adopt the serial number and other identifying markings previously placed on a firearm by another licensed manufacturer provided the firearm has not been sold, shipped, or otherwise disposed of to a person other than a licensee, and the serial number adopted is not duplicated on any other firearm.

Pursuant to 478.92(a)(4)(iii)(B), licensed manufacturers and licensed importers may adopt the serial number or other identifying markings previously placed on a firearm that otherwise meets the requirements of this section that has been sold, shipped, or otherwise disposed of to a person other than a licensee provided that, within the period and in the manner herein prescribed, the licensee legibly and conspicuously places, or causes to be placed, on the frame or receiver either: Their name (or recognized abbreviation), and city and State (or recognized abbreviation) where they maintain their place of business; or their name (or recognized abbreviation) and abbreviated Federal firearms license number, which is the first three and last five digits, individually (i.e., not as a prefix to the serial number adopted) after the letters ‘‘FFL’’, in the following format: ‘‘FFL12345678’’. The serial number adopted must not duplicate any serial number adopted or placed on any other firearm, except that if a licensed importer receives two or more firearms with the same foreign manufacturer’s serial number, the importer may adopt the serial number by adding letters or numbers to that serial number and may include a hyphen.

Although licensees may adopt markings pursuant to the noted regulations, licensee must ensure ALL marking requirements are met under 478.92(a)(1). For instance, a licensed manufacturer that assembles newly manufactured receivers acquired from another licensee, must also mark the caliber (if not already marked) and model (if not already marked and the licensee assigns a model) of the completed firearm.

Yes. Amended regulations 478.129(b), (d) and (e) require ALL licensees to retain ALL required records until the license is discontinued. Forms 4473 must be kept on paper or in an approved electronic format at the licensed business premises and accessible for inspection. A warehouse may be used to store paper records older than 20 years of age. That warehouse would be subject to inspection and cannot be used to conduct other firearms business activities without obtaining a separate license.

Licensees can no longer send their records older than 20 years to the Out of Business Records Center, National Tracing Center. They can only submit their records upon discontinuance of business under the license.

Yes. Pursuant to 27 CFR 478.129(b), as amended, all ATF Forms 4473, to include those where a sale, delivery, or transfer did not take place, must be retained until business or licensed activity is discontinued.

Yes. Nothing in Final Rule 2021R-05F, requires licensees to use only one acquisition and disposition (A&D) record. If a licensee wishes to use more than one A&D record (e.g. manufacturing A&D record, NFA A&D record, sales A&D record, gunsmithing A&D record, etc.) they may do so, provided such information shall be recorded in formats provided in the final rule. 

No. Records are never to be consolidated between distinct FFLs. Prior to the final rule’s effective date of August 24, 2022, licensed importers were required to maintain separate records of sale or other dispositions made of firearms to non-licensees pursuant to 478.122, and licensed manufacturers were required to maintain separate records of sales or other dispositions made of firearms to non-licensees pursuant to 478.123. Also prior to the final rule, licensed importers were permitted to consolidate their records pursuant to Ruling 2011-1, and licensed manufacturers were permitted to consolidate their records pursuant to Ruling 2016-3.

The final rule codified Ruling 2011-1 and Ruling 2016-3. However, unlike the optional rulings, the final rule amended the regulations requiring licensed importers to consolidate their records of acquisition and disposition into a single record, and licensed manufacturers to consolidate their records of acquisition and disposition into a single record.

“Remanufacturing” occurs when a new and different firearm is produced from an existing firearm (i.e., frames or receivers or complete weapons) by completing, assembling, applying coatings, or otherwise making them suitable for use. Remanufacturing cannot occur if a firearm has never entered into commerce. An example is when a licensee purchases a used firearm from another licensee or a non-licensee, then performs a manufacturing process, such as cerakoting for the purposes of sales and distribution.

No. The AR-15 platform has been specifically addressed in the final rule and the lower receiver will remain the regulated receiver requiring the appropriate markings. Pursuant to the final rule, 27 CFR 478.12(f)(1)(i) “[t]he receiver is the lower part of the weapon that provides housing for the trigger mechanism and hammer (i.e., lower receiver).” for the AR–15/M–16 variant firearms.

Yes, the final rule states:

“Frames or receivers designed before August 24, 2022. Licensed manufacturers and licensed importers may continue to identify the same component of a firearm (other than a PMF) defined as a frame or receiver as it existed before August 24, 2022 with the same information required to be marked by paragraphs (a)(1)(i) and (a)(1)(ii) of this section that were in effect prior to that date, and any rules necessary to ensure such identification shall remain effective for that purpose. Any frame or receiver with a new design manufactured after August 24, 2022 must be marked with the identifying information and within the period prescribed by this section. For purposes of this paragraph, the term “new design” means that the design of the existing frame or receiver has been functionally modified or altered, as distinguished from performing a cosmetic process that adds to or changes the decoration of the frame or receiver ( e.g., painting or engraving), or by adding or replacing stocks, barrels, or accessories to the frame or receiver.”

If a licensed manufacturer or importer is unsure if a new firearm design is considered “the same component of a firearm” as existed before August 24, 2022, then the licensee should request a determination by ATF’s Firearms Ammunition Technology Division (FATD).

27 CFR 478.92(a)(1)(i), as amended, states that manufacturers and importers must legibly identify each firearm they manufacture or import by placing on the frame or receiver the serial number and either name, city and State or name and abbreviated federal firearms licensee (FFL) number (i.e. first three and last five digits) as a prefix, followed by a hyphen and the unique identification number assigned to the firearm.

478.92(a)(2), as amended, states that privately made firearms (PMFs) not previously identified by another licensee must be identified by the licensee receiving or acquiring the PMF by placing, or causing to be placed under the licensee’s direct supervision, an individual serial number on the frame or receiver that must begin with the licensee’s abbreviated Federal firearms license number, which is the first three and last five digits, as a prefix to a unique identification number, followed by a hyphen, and the unique identification number.

478.92(a)(4)(iii)(B), as amended, allows licensed manufacturers and importers to adopt the serial number or other identifying markings previously placed on an imported or remanufactured firearm sold, shipped, or otherwise disposed of to a non-licensee that otherwise meets the requirements of 478.92; however, the licensee must place, or cause to be placed, on the frame or receiver either their name (or recognized abbreviation), and city and State (or recognized abbreviation) where they maintain their place of business; or their name (or recognized abbreviation) and abbreviated Federal firearms license number, which is the first three and last five digits, individually (i.e., not as a prefix to the serial number adopted) after the letters ‘‘FFL’’, in the following format: ‘‘FFL12345678’’.

478.92(a)(4)(i), as amended, provides an exception for the above marking requirements described as “Alternate means of identification” and states:

“The Director may authorize other means of identification to identify firearms upon receipt of a letter application or prescribed form from the licensee showing that such other identification is reasonable and will not hinder the effective administration of this part.”

No. Firearm muffler or silencer parts transferred between qualified manufacturers for further manufacture or to complete new devices, and firearm muffler or silencer replacement parts transferred to qualified manufacturers or dealers to repair existing devices, need not be marked at the time of transfer. Any new device completed with such a part must be registered by the manufacturer. See 478.12(b). A subpart of a firearm muffler or silencer that is not a component part of a complete weapon at the time sold must be identified by an individual serial number. See 478.92(a)(1)(iv).

The final rule clarifies that the definition of “firearm” includes a weapon parts kit that is designed to or may readily be completed, assembled, restored, or otherwise converted to expel a projectile by the action of an explosive. It also clarifies that the term “firearm” does not include a weapon, including a weapon parts kit, in which the frame or receiver of such weapon is “destroyed” as described in the definition “frame or receiver.” The final rule also explains that persons engaged in the business of selling or distributing weapon parts kits cannot avoid licensing, marking, recordkeeping, or other requirements to which federal firearms licensees (FFLs) are subject ‘‘by selling or shipping the parts in more than one box or shipment to the same person, or by conspiring with another person to do so.’’

Licensees who require a determination whether a weapon parts kit is a regulated firearm may contact ATF’s Firearms and Ammunition Technology Division (FATD) for a determination.

If more than one part of a silencer attaches to the barrel, each part must be marked. However, if there are multiple segmented parts, only the parts that can be attached directly to the barrel must be marked. 478.12(b) states in the case of a firearm muffler or firearm silencer, the part of the firearm, such as an outer tube or modular piece, that provides housing or a structure for the primary internal component designed to reduce the sound of a projectile (i.e., baffles, baffling material, expansion chamber, or equivalent). In the case of a modular firearm muffler or firearm silencer device with more than one such part, the terms shall mean the principal housing attached to the weapon that expels a projectile, even if an adapter or other attachments are required to connect the part to the weapon. The terms shall not include a removable end cap of an outer tube or modular piece.

Yes. The final rule amended the definition “engaged in the business” as it relates to a ‘‘gunsmith’’ in 478.11 to mean, in part a person who, as a service performed on existing firearms not for sale or distribution, devotes time, attention, and labor to repairing or customizing firearms, making or fitting special barrels, stocks, or trigger mechanisms to firearms, or placing marks of identification on privately made firearms in accordance with this part, as a regular course of trade or business with the principal objective of livelihood and profit but shall not include a person who manufactures firearms (i.e., frames or receivers or complete weapons) by completion, assembly, or applying coatings, or otherwise making them suitable for use, requiring a license as a manufacturer.

27 CFR 478.12(a)(c) states:

The terms ‘‘frame’’ and ‘‘receiver’’ shall include a partially complete, disassembled, or nonfunctional frame or receiver, including a frame or receiver parts kit, that is designed to or may readily be completed, assembled, restored, or otherwise converted to function as a frame or receiver, i.e., to house or provide a structure for the primary energized component of a handgun, breech blocking or sealing component of a projectile weapon other than a handgun, or internal sound reduction component of a firearm muffler or firearm silencer, as the case may be. The terms shall not include a forging, casting, printing, extrusion, unmachined body, or similar article that has not yet reached a stage of manufacture where it is clearly identifiable as an unfinished component part of a weapon (e.g., unformed block of metal, liquid polymer, or other raw material). When issuing a classification, the Director may consider any associated templates, jigs, molds, equipment, tools, instructions, guides, or marketing materials that are sold, distributed, or possessed with the item or kit, or otherwise made available by the seller or distributor of the item or kit to the purchaser or recipient of the item or kit.

All situations are unique, and a determination can only be made based on an analysis of the facts specific to the individual scenario. Licensees may contact ATF’s Firearms and Ammunition Technology Division (FATD) at fire_tech@atf.gov if they require a determination whether the items in question are regulated under federal law and regulation. 
 

The term “firearm” is defined in 27 CFR 478.11 to includes a weapon parts kit that is designed to or may readily be completed, assembled, restored, or otherwise converted to expel a projectile by the action of an explosive, and would not include a weapon parts kit, in which the frame or receiver of such weapon is destroyed.

Licensees may voluntarily request a determination whether a weapons parts kit is a regulated firearm by contacting ATF’s Firearms and Ammunition Technology Division (FATD).

A weapon parts kits that is determined to be a firearm shall be recorded as a “firearm” in the licensees’ A&D records and on ATF Form 4473.

Any person manufacturing firearms for the purpose of sale and distribution must be licensed as a manufacturer. Cerakoting is considered a manufacturing activity.

The final rule amends 478.92(a)(4)(iii)(A) and states in part that “Licensed manufacturers may adopt the serial number and other identifying markings previously placed on a firearm by another licensed manufacturer provided the firearm has not been sold, shipped, or otherwise disposed of to a person other than a licensee, and the serial number adopted is not duplicated on any other firearm.”

If assembling firearms from a new frames or receivers, the licensed manufacturer must mark the caliber or gauge, if any, on the firearms and, if a model is assigned, mark the model on the firearms.

Yes. Amended regulations at 478.92(a)(1)(v) allow manufacturers and importers to mark the component of a firearm (other than a privately made firearm (PMF)) defined as a frame or receiver prior to August 24, 2022, in the same manner as before the effective date of the final rule. The final rule makes clear that almost all firearms ATF previously classified as falling within the definition of ‘‘frame or receiver’’ prior to issuance of the final rule are grandfathered and may continue to be marked in the same manner as before the effective date of the final rule. The only exceptions are certain ATF classifications of partially complete, disassembled, or nonfunctional frames or receivers.

The final rule clarifies that licensed dealers (including gunsmiths), manufacturers, and importers may conduct same day adjustments or repairs to firearms without recording them as acquisitions or dispositions, provided they are returned to the person from whom they were received on the same day. A licensed gunsmith may attach a scope (including drilling, if required) on a non-licensee customer’s firearm (not for sale or distribution) and is not required to be licensed as a manufacturer. This activity would be considered an adjustment, and if returned to the person from whom received on the same day, no entry into the acquisition and disposition record would be required. The mounting of a scope would also be considered a “customization” of the firearm, accordingly, no ATF Form 4473 is required to be completed, provided the licensee returns the firearm to the person from whom it was received. However, the firearm must be logged in the licensee’s A&D record if it is kept overnight.

Under federal law, it’s not unlawful for a person who is not prohibited from possessing firearms to make a non-NFA (National Firearms Act) privately made firearm (PMF) for their own personal use.