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There's no requirement to perform an audit now on those firearms sold by FFL's.
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No, but the ATF has the option of auditing the inventory of an FFL at will.
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If the last 4473 was before enactment date, the government has the burden to prove the transfer occurred after the transfer date.
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How long will they leave the system that way? The government won't
want the burden of proof, and they'll get this changed to shift it to the owner.
Whatever "proof" I may have of a background check will become an
affirmative defense, much like Form 4's for NFA items. If you can't provide proof, or if the proof somehow doesn't satisfy an investigator, charges will be pressed.