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  #1  
Old 04-01-2020, 11:17 PM
QuinnBayArea QuinnBayArea is offline
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Default Selling a Collection to FFL 03/COE

So I am an FFL 02, and basically I have a Collector that has been buying guns from us for about 6 months, and now he works for me. He would like to purchase a bulk lot of fine firearms to add to his collection. He has FFL03 and COE. We've come to an agreement on 30 or so firearms, mixture of long guns and hand guns, all on roster of course, one or two C&R. My question is how should we get it done? I'm sure eyebrows at both ATF and DOJ will be raised if he buys and DROSes 30 Firearms at the same time and the ATF receives a Multiple gun form with 26 handguns. I know beyond a shadow of a doubt its for his private collection, and he is not re-selling or anything. Quite a collection. Just do it all in one go? Is it possible to DROS that many at once? I'm sure collectors buy collections all the time. Just curious whats the most efficient and the less eye-brow-raising way to do it besides all at once. Or is the best approach all at once?
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Old 04-02-2020, 11:20 AM
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Just do it all at once. They might ask questions and they might talk to him, but as long as everything is in order, nothing should come of it. Structuring to hide all the firearms would be more of an issue, as well as costing more. Doing it all at once means one DROS fee, which is a good thing.

You need to make sure to turn in the multiple sales for both the handguns and any long guns which apply (semi-auto with a caliber over .22). Since he has a C&R FFL, any C&R firearms would not apply.
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Old 04-02-2020, 10:48 PM
sass2924 sass2924 is online now
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All at once. We’ve done several in the high 20’s and many in the teens. No questions have ever been asked.
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Old 04-03-2020, 6:03 AM
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Quote:
Originally Posted by QuinnBayArea View Post
So I am an FFL 02, and basically I have a Collector that has been buying guns from us for about 6 months, and now he works for me. He would like to purchase a bulk lot of fine firearms to add to his collection. He has FFL03 and COE. We've come to an agreement on 30 or so firearms, mixture of long guns and hand guns, all on roster of course, one or two C&R. My question is how should we get it done? I'm sure eyebrows at both ATF and DOJ will be raised if he buys and DROSes 30 Firearms at the same time and the ATF receives a Multiple gun form with 26 handguns. I know beyond a shadow of a doubt its for his private collection, and he is not re-selling or anything. Quite a collection. Just do it all in one go? Is it possible to DROS that many at once? I'm sure collectors buy collections all the time. Just curious whats the most efficient and the less eye-brow-raising way to do it besides all at once. Or is the best approach all at once?
Sorry, I gotta ask, fine collectible firearms that are ALL on the CA roster?
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Old 04-03-2020, 6:08 AM
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When i bought 75 recently on one long form DROS nothing became of it. There is no worries as long as all are legal to be bought here in CA.
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Old 04-03-2020, 7:20 AM
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As I recall for the 3310.4 form you do not need to fill out the multiple gun sale form and submit it if he is "Licensed". If he has his 03 then he is a licensed individual.

Federal Firearms Licensees (FFLs) must use this form to report all transactions in which an unlicensed person acquired any combination of two or more pistols or revolvers totaling two or more at one time or during five consecutive business days.
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Old 04-03-2020, 8:08 AM
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RoundEye RoundEye is offline
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Quote:
Originally Posted by HPT View Post
As I recall for the 3310.4 form you do not need to fill out the multiple gun sale form and submit it if he is "Licensed". If he has his 03 then he is a licensed individual.

Federal Firearms Licensees (FFLs) must use this form to report all transactions in which an unlicensed person acquired any combination of two or more pistols or revolvers totaling two or more at one time or during five consecutive business days.
I think it depends on whether or not the multiple firearms being transferred are classified as C&R or not. If they're not, I don't see why the process would be any different (4473 + DROS) just with a 1:30 exception.

You are not transferring the "modern" guns to his FFL, but to him personally.
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Old 04-03-2020, 11:03 AM
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Quote:
Originally Posted by HPT View Post
As I recall for the 3310.4 form you do not need to fill out the multiple gun sale form and submit it if he is "Licensed". If he has his 03 then he is a licensed individual.

Federal Firearms Licensees (FFLs) must use this form to report all transactions in which an unlicensed person acquired any combination of two or more pistols or revolvers totaling two or more at one time or during five consecutive business days.
The person is ONLY licensed in terms of C&R firearms. Having a C&R FFL does not exempt the reporting for other firearms, so any non-C&R firearms has to be reported the same as anyone else.
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Old 04-03-2020, 1:31 PM
QuinnBayArea QuinnBayArea is offline
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Quote:
Originally Posted by taperxz View Post
Sorry, I gotta ask, fine collectible firearms that are ALL on the CA roster?
Yes sir.
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Old 04-03-2020, 1:31 PM
QuinnBayArea QuinnBayArea is offline
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Quote:
Originally Posted by CartridgeCalls View Post
When i bought 75 recently on one long form DROS nothing became of it. There is no worries as long as all are legal to be bought here in CA.
Ok cool, thanks. I called CA DOJ and they said no problem, do them all. They MIGHT call him and ask how he is storing them, thats all.

ATF has not called me back.
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  #11  
Old 04-03-2020, 4:36 PM
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Quote:
Originally Posted by kemasa View Post
The person is ONLY licensed in terms of C&R firearms. Having a C&R FFL does not exempt the reporting for other firearms, so any non-C&R firearms has to be reported the same as anyone else.
Good to know, thank you for the information.
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