ATF Ruling 2016-1
This ruling supersedes ATF Ruling 2013-5 Requirements to Keep Firearms Acquisition and Disposition Records Electronically.
ATF authorizes licensed importers, licensed manufacturers, licensed dealers, and licensed collectors to maintain their firearms acquisition and disposition records electronically, provided all of the following conditions are met:
The licensee records in the computer system all of the acquisition and disposition information required by 27 CFR 478.121, 478.122, 478.123, 478.125(e), 478.125(f), and 27 CFR 479.131, as applicable. Required information includes a record of both the manufacturer and the importer (if any). Additional columns can be utilized to capture certain additional information (e.g., inventory number, new/used, etc.), so long as the additional information is separate from the required information and the required information is readily apparent. An ATF Form 4473 serial number may be used instead of the address for recording the transfer of a firearm to a non-licensee if such forms are filed numerically.
FastBound not only meets but exceeds all requirements listed in the applicable ATF CFRs. FastBound supports form 4473 serial numbers and can generate unique numbers guaranteeing that you will not have a duplicate.
The electronic acquisition and disposition bound book software must track corrections and changes utilizing one of the following methods of tracking changes:
The system must retain any correction as an entirely new entry, without deleting or modifying the original entry. When the software generates the bound book, the system must be able to quickly and easily change views of the bound book as follows: 1. Only view the original entries; 2. Only view the corrected entries; and 3. View both the original and corrected entries in the same bound book.OR
The system must be able to print the corrections as a separate report containing the same parameters as are required for a paper bound book, including the firearm information, acquisition details, and disposition details. The format of the correction report may follow the traditional bound book format, or may be presented in any column format as long as the necessary information outlined above exists in the report (which may include a notes column).OR
If a spreadsheet program (e.g., excel) is being utilized, the system must be able to track any edits/corrections/amendments in a “notes” column. Any edits/corrections/amendments may overwrite the original entry so long as the “notes” column explains any edits/corrections/amendments and/or tracked changes (i.e., what was changed, who made the change, and why the change was needed).
FastBound creates audit trails for all of the ATF required fields and displays these on the items information page as well as in the notes column on the ATF Bound Book report.
The system cannot rely upon invoices or other paper/manual systems to provide any of the required information. Also, if a licensee chooses to use an electronic recordkeeping system for any of its required acquisition and disposition records, then all acquisition and disposition records, regardless of type (e.g., gunsmithing, sales, NFA), must also be in the electronic format as prescribed by this ruling.
The system must allow queries by firearm serial number, acquisition date, name of the manufacturer or importer, name of the purchaser, address of purchaser or other transferee, and ATF Form 4473 transferor’s transaction serial number (if any).
FastBound allows users to query by all of the ATF mandated data types as well as many others (e.g. item location, item type, upc, sku)
The licensee must download all records from the system to a physical storage device (e.g. hard drive, Compact Disc (CD), Digital Versatile Disc (DVD), or Universal Serial Bus (USB) Flash Drive) at the licensee’s business premises, or print and maintain them at the licensee’s business premises:
at least semiannually; however, if the records are downloaded, from a host facility (e.g., remote server or cloud storage provider) contracted/leased by the licensee as provided in condition #9, they must be downloaded at least daily. In all cases, the records must be downloaded in a format that is unencrypted with the required information readily apparent;
upon request of an ATF officer (must be provided within 24 hours);
prior to discontinuance or change of: the software (program); the database system, whether or not maintained by a host facility (e.g., remote server or cloud storage provider); and/or the host facility (if applicable); and
prior to discontinuance of the licensee’s firearms business.
The downloads/printouts must include all firearms in inventory, as well as all firearms transferred during the period covered, sequentially by date of acquisition, and must be limited to display only the information required by the applicable regulations. The downloads/printouts may contain additional columns capturing certain additional information, provided that the required information is readily apparent.
FastBound allows users to download their firearms acquisition and disposition records at any time in an ATF compliant format. FastBound also provides users a secure download link so they can automate this process.
If a licensee downloads the records onto a physical storage device (e.g., hard drive, CD, DVD, or USB Flash Drive), the download must be retained on the physical storage device until the next download is prepared. Additionally, the licensee must be able to present the most current version of the requested records in a printed format at ATF’s request.
FastBound provides users with help examples of best practices so they are compliant.
If the licensee prints out the records, the printout must be retained until the next printout is prepared.
FastBound provides users with help examples of best practices so they are compliant.
Downloads/printouts may include antique firearms, but cannot include other merchandise. However, antique firearms must be identified as such in the “firearm type” column.
FastBound users can create a "antique firearms" bound book.
Electronic firearms acquisition and disposition records may be stored on a computer server or device owned and operated by the licensee, or contracted/leased by the licensee through a host facility (e.g., remote server or cloud storage provider), provided that:
The firearms acquisition and disposition records are readily accessible through a computer or device located at the licensed premises during regular business hours; and
The licensee’s server is located within the United States or its territories, or if a host facility is used, that facility must have a business premises within the United States or its territories, and must be subject to U.S. legal process.
Licensees are strongly encouraged to ensure that there are proper and robust security protection measures in place (e.g., encryption) to ensure all data is protected.
All FastBound subscriptions include compliant cloud hosting and encrypted storage at a hosting facility in the United States.
If the licensee contracts with, leases from, or changes a host facility (e.g., remote server or cloud storage provider), the licensee must, within 30 days, notify his/her respective ATF Area Office of the name and address of the host facility.
Each licensee must maintain its firearms acquisition and disposition records on a separate/partitioned database that cannot be intermingled with the records associated with another license.
If FastBound ever changes host facilities, customers will be notified in advance.
Data stored in FastBound is separate and partitioned so that records associated with one license are not intermingled with the records associated with another license.
The storage system must back-up the firearms acquisition and disposition records on at least a daily basis to protect the data from accidental deletion or system failure.
FastBound automatically backs up all customer data every 5 to 10 minutes.
Licensees must retain all records in accordance with 27 CFR 478.129, ATF Rul. 2010-8, Consolidation of Required Records for Manufacturers, and ATF Rul. 2011-1, Consolidation of Required Records for Importers (as applicable). It is strongly recommended that upon reaching 20 years, those electronic firearms acquisition and disposition records be either permanently maintained by the licensee or forwarded to the ATF Out-of-Business Records Center for preservation.
This process can easily be facilitated by contacting FastBound support.
Upon discontinuance of business, the licensee must send required records to the ATF Out-of-Business Center in accordance with 27 CFR 478.127. The licensee must print out the required records or download them to a physical storage device (as defined in paragraph 5) or, at the discretion of the licensee, both. The complete printout or download must provide an American Standard Code for Information Interchange (ASCII) text file (in conformity with industry standards) containing all acquisition and disposition records, and a file description. The complete printout or downloaded ASCII text file (and file description) must contain all information prescribed by regulation. The NTC converts these files into image files not searchable by name.
FastBound allows users to download all acquisition and disposition records as an ASCII text file at any time by clicking the reports tab and creating an ATF bound book report with the “Export in comma separated values (CSV) format” option selected.