U.S.A. –-(Ammoland.com)- 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.
ATF 2016-1 Compliant Software is Different than FFL Compliance
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:
- I understand the software is 2016-1 compliant, but will my process be compliant?
- Who reviews your software for ATF compliance when the regulations change?
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.
Firearms Software Expertise is Different than Firearms Business Expertise
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:
- Can you evaluate the status of my current bound book data – am I ATF compliant?
- Will you assess the status of my ATF compliance in 90 days?
Don’t Stop at Compliance – Your Provider Should Prove FFL Cost Savings
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:
- Do I know all the features of the software and which should I implement?
- Are there changes to my FFL business process that could save more money?
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.
About Orchid Advisors:
Orchid Advisors helps firearms manufacturers, distributors and retailers achieve compliance and operational excellence through education, technology, software and consulting solutions that reduce risk, cut costs, and provide expert guidance to make our clients’ businesses more successful and efficient. Orchid Advisors is the Firearms Industry’s Trusted Compliance & Operations Experts and is endorsed by NSSF, the National Shooting Sports Association.
For more information, visit https://www.orchidadvisors.com.
ATF someone sits around and makes it as tough as the can for someone that is trying to make a living. That is not exactly the American way of doing things.
Why does this schmuck have 2 rifles pointed at him!? He doesn’t know the first rule of gun safety?