For many in the firearms industry, the “bound book” is well known as the regulated record for tracking the lifecycle movement of a firearm through the commercial sector and between licenses and non-licensees. Perhaps less well known are the unintended consequences of relying on software company advertising and advice as the sole determination of your needs as an FFL.
The following are three important considerations when selecting an electronic Bound Book provider for your Federal Firearms License.
When it comes to selecting an electronic bound book, consideration needs to be given, not only to compliance with ATF Ruling 2016-1, as so many advertise, but also what that term really means. FFLs find the greatest compliance and financial investment when shopping with a keen awareness of the “fly by, drop in” A&D installation kit offered by software companies who lack on-hand, operational FFL expertise.
FFLs are most successful when they fully understand the capabilities of the electronic bound book software, including the source and use of firearm data, the location of backup files and user access rights. Consider asking the following questions during your purchase:
Implementation by software vendor alone is the equivalent of expecting a car manufacturer to ensure its future drivers known what speed to drive and when to stop or go.
Shopping for an ATF 2016-1 compliant bound book means knowing the details about the combined software and services expertise of your provider. Unfortunately, most software vendors don’t employ any ATF compliance experts and merely rely on outside, third party expertise. Such expertise may come with a deep knowledge of the regulations, but often lacks any experience in implementing an FFL’s Standard Operating Procedures.
Consider asking the following questions:
FFLs using paper-based records invest 4-5 minutes to acquire and validate firearms into their chosen ledger. And, for every disposition FFLs invest another 4-5 minutes to dispose and validate a firearm. Dispositions to a non-licensee via ATF Form 4473, or those involving NFA firearms, often require additional time.
For example, a mid-sized retail FFL acquires and disposes of 2,000 firearms per year. Running at top efficiency, that would require approximately 20,000 minutes between acquisitions and dispositions. Adding 4 minutes for each 4473 and the total time investment climbs to 24,000 minutes. At $17.00 per labor hour (business’s total investment, not employee’s hourly rate), that equates to $6,800 or $3.40 per firearm. FFLs using technology enabled processes can reduce overall processing time by upwards of 40%, equating to a savings of $1.36 per firearm.
Consider asking the following questions during your purchase:
Before selecting your electronic bound book software provider, talk to other software users – not the businesses whose names are in the software brochures – businesses that are in your area with similar business models (i.e. if you are a gun shop talk to a gun shop, not a manufacturer). Ask the software provider about clients’ inspection results and how they supported those clients if/when issues were detected. It is important to know if your provider can support you through your inspection process and supply functional solutions if issues are uncovered.
Visit us at SHOT Show ’19, booth # 3117, to learn more about our integrated bound book and e4473 software.
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