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Old January 6, 2013, 07:05 PM   #1
YankeeRebel
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C&R inventory question

I am considering getting a C&R license. One article I read said that any C&R eligible firearm you own before getting the license must become part of your C&R inventory. This is contrary to what I have heard previously concerning this. What is the skinny on this? Also, where is a good source for the "bound" book for your inventory?
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Old January 6, 2013, 07:55 PM   #2
leadchucker
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You don't have to keep an "inventory" of your C&R guns. Any C&R guns you already owned before you got the license aren't part of the C&R process unless you sell them while you hold a C&R license.

You do have to keep a "bound book" listing all C&R transactions you make while your C&R license is in effect. This includes all acquisitions (purchases) or dispositions (sales) of C&R guns. If you sell a C&R gun you had before you got the license, you record the sale.
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Last edited by leadchucker; January 6, 2013 at 08:02 PM.
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Old January 6, 2013, 08:08 PM   #3
Shadow7d
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to expand on it
just like ANY FFL you keep a bound book
except you legally only have to record those guns covered by you license (I.E. C&R's)
and then the rules, when you have the C&R you have to record your acquisition and dispositions of them. So if you have a C&R from PRIOR to your license, you have two methods generally used, 1, when you get it, log ALL covered guns in (from yourself) so you don't have to later if you get rid of them.

2, when you sell, you log the gun in from yourself, and OUT to the person you are selling to.
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Old January 7, 2013, 08:56 AM   #4
leadchucker
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I guess some might be concerned that a C&R log might show a disposition of a rifle, and yet there would be no record of the acquisition of that rifle previously. I don't worry about that.

There is no harm in adding C&R guns that don't fall under the requirements to your log. The BATFE isn't going to penalize you for keeping too much information.
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Old January 7, 2013, 12:35 PM   #5
Shadow7d
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Ok, so you LOG THE GUN IN,THEN OUT
so you have both, when you do it, if you feel the need you write something like 'owned previous to FFL'

and um, when you have a larger collection doing pages and pages and pages of paperwork vs. just when required by law
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Old January 9, 2013, 10:23 PM   #6
tobnpr
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I printed a few of these, numbered the pages and stapled them into a file folder...

http://www.surplusrifle.com/graphics/boundbookpage.pdf

It doesn't need to be an actual "book", in fact, it doesn't even need to be paper, at all, anymore.

Electronic record keeping is acceptable now by the BATF.

If you acquired the firearm BEFORE you had an FFL, disposition does not need to be recorded...even though it might be a "collectible" firearm, it need be treated no differently than any other since it was purchased before you were licensed.
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Old January 10, 2013, 12:35 PM   #7
Scimmia
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Quote:
If you acquired the firearm BEFORE you had an FFL, disposition does not need to be recorded...even though it might be a "collectible" firearm, it need be treated no differently than any other since it was purchased before you were licensed.
Where'd you get that idea? The law seems to disagree with you.

18 U.S.C 923(g):
(2) Each licensed collector shall maintain in a
bound volume the nature of which the Attorney
General may by regulations prescribe, records of
the receipt, sale, or other disposition of fire-
arms.


Any time you acquire or dispose of a C&R firearm while you have a C&R license, it needs to go in your book.

Last edited by Scimmia; January 10, 2013 at 12:49 PM.
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Old January 10, 2013, 12:58 PM   #8
jonnyc
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"If you acquired the firearm BEFORE you had an FFL, disposition does not need to be recorded...even though it might be a "collectible" firearm, it need be treated no differently than any other since it was purchased before you were licensed."

Agreed, this is incorrect. If you dispose of a previously acquired C&R while you are a C&R licensee, it MUST be logged in and out at the time of disposition.
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Old January 10, 2013, 07:42 PM   #9
tobnpr
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Quote:
Where'd you get that idea? The law seems to disagree with you.

18 U.S.C 923(g):
(2) Each licensed collector shall maintain in a
bound volume the nature of which the Attorney
General may by regulations prescribe, records of
the receipt, sale, or other disposition of fire-
arms.
I got that idea, from the same regulations book that you quoted.
This applies ONLY to firearms obtained AFTER you obtained your license.
Before that date, you weren't a "Collector", you weren't licensed...You were John Q. Public, non-FFL , and had no recordkeeping requirements just like every other citizen that doesn't hold a FFL.

Refer to the:

"OPEN LETTER TO ALL RECENTLY FEDERALLY LICENSED COLLECTORS OF CURIO OR RELIC FIREARMS", dated Jan. 19, 2005 and since I'm not unique- would have been in everyone's big fat packet from BATF that comes with your license.

Under "REGULATORY OBLIGATIONS" on the reverse side of the letter, refer to the second bullet point:

Enter into the A/D all curios and relics acquired after receipt of the Collector's license.

If the weapon was acquired before you were licensed, it need not be included in your transaction records- from what I see...
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Old January 11, 2013, 02:47 AM   #10
Scimmia
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tobnpr, yes, I've read that letter, which only specifies the acquisition of firearms, it says nothing about what to do with a disposition. That omission doesn't free you from following the law as I quoted earlier. If you want another reference, let's look at the Code of Federal Regulations, which is referred to a number of times in the actual law.

27 CFR 178.125
(f) Firearms receipt and disposition by
licensed collectors. Each licensed col-
lector shall enter into a record each re-
ceipt and disposition of firearms curios
or relics. The record required by this

Again, this couldn't be simpler. Each receipt and disposition.

I think you're operating under the impression that the license is somehow tied to the specific firearms. It's not. With any other FFL, it's tied to the business, so only firearms that go through the business need to be recorded. A C&R is different, in that it's tied to a person. There's no difference between what you owned previously or what you acquired after you got your license because the individual firearms don't matter. What matters is the transaction, and each and every transaction of qualifying firearms must be logged.
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Old January 13, 2013, 10:21 PM   #11
Shadow7d
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Quote:
What matters is the transaction, and each and every transaction of qualifying firearms must be logged.
EXACTLY
to say otherwise puts you in grave danger of losing your licence.
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