Conducting a firearms inventory is an important aspect of business operations. Most importantly it should be done in an effort to prevent and detect the loss of firearms, but it should also be accomplished to ensure the accuracy of the inventory of the assets of your business.
The Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) has provided guidance on conducting inventories, focused on identifying and preventing firearms inventory loss by theft or improper recordkeeping. In addition, inventories support accurate record keeping, conducting inventories helps ensure all firearms are properly recorded in your A&D records and ensures those firearms that have been transferred have dispositions recorded.
The following steps should be taken to conduct an inventory and ensure that inventory processes are in line with ATF recommendations and how they conduct inventories during an Inspection.
Any firearms identified during the inventory that were not on the inventory list or A&D records should be recorded immediately. Obtain any corresponding invoices or shipping documents to determine the date the firearms were acquired and where the firearm was received from. If you can’t identify the actual date of acquisition, enter the date of acquisition as the date the inventory was reconciled.
In the event firearms are not accounted for or missing from inventory, make every effort to locate them immediately. Keep in mind, potentially missing firearms may still be in inventory or may have been transferred and a second physical inventory may be necessary. Ensure that you have recorded every single firearm in inventory on the list. Check ATF F 4473s, commercial records, transfers to other FFLs and returns for repair to reconcile the final disposition of the firearm. If the firearm can still not be located, re-check the firearms inventory.
If the firearm is located through alternative records, record the disposition information in the A&D record. If the firearm is not able to be located nor any corresponding transfer paperwork, the firearm must be reported as missing to your local law enforcement agency and the ATF.
Regular inventories are strongly recommended in order to ensure the accuracy of your inventory and reinforce an impression of control of inventory practices, further reducing the opportunity for losses to be created. Generally, the frequency of inventories is dependent on the size of the inventory and volume of transactions. A good business practice is to conduct firearms inventories on a quarterly basis at a minimum. Increase the frequency for larger inventories or higher transaction volume.
Report missing and stolen firearms first to your local law enforcement agency and then to the ATF Stolen Firearms Program Manager at 1-888-930-9275. ATF will provide you with a unique incident number that you will record on ATF Form 3310.11, Report of Theft or Loss. Form 3310.11 may be downloaded on the ATF website at https://www.atf.gov/file/4996/ download, obtained from your local ATF office, or obtained by calling the ATF Distribution Center at (703)870-7526. Follow Form 3310.11 instructions on recording the information in the A&D record for each firearm reported lost or missing. Please know that a firearm stolen or lost in transit on a common or contract carrier, including the U.S. Postal Service, is considered stolen or lost from the transferor/sender licensee's inventory for reporting purposes. Therefore, the transferor/sender of the stolen or lost firearm shall report the theft or loss of the firearm on ATF Form 3310.11 within 48 hours after the transferor/sender discovers the theft or loss.