Is a licensee, who receives a privately made firearm (PMF) solely for marking a serial number, required to complete an ATF Form 4473 and conduct a NICS check prior to returning the PMF to the customer?

No.  Marking serial numbers on PMFs is a “customization” and a licensee’s return of a firearm, received solely for repair or customization, to the person from whom it was received does not require an ATF Form 4473 pursuant to 478.124(a) nor a NICS background check.  However, licensees must record the acquisition and disposition of the PMF in the licensee’s A&D record.  

Last Reviewed July 22, 2022