Is a gunsmith who marks privately made firearms (PMFs) as part of a marking service for other federal firearms licensees (FFLs) required to enter those PMFs into his/her A&D record?

No. In cases where the acquiring FFL is contracting out marking services of PMFs to a licensed gunsmith (or unlicensed engraver), the gunsmith or engraver may only perform such engraving services on the spot under the direct supervision of the requesting FFL. The marking FFL need not record the PMF in his/her A&D records.

Last Reviewed July 22, 2022