In this session, JB & JC with FFL Consultants will be covering the critical moves for FFLs to successfully optimize firing range and retail operations through uncertain times.
Although we have partners within the political community, we have insights from the National Shooting Sports Foundation. Right now, we’re all in the same place; we just don’t know. Of course, we’re hoping for many positives.
The first thing everyone’s asking about is assault weapons, will there be a ban?
We know there was a ban in the last Administration. High-capacity magazines are definitely on the Harris agenda. So we know that will be an issue on the table. Firearms surrender and enforcement is talked about all the time. What happens if there’s a ban? Who will enforce the ban, collect firearms… States across the country are adopting Private-party sales. This could sound like a negative, but the real positive is that it brings more business to every gun dealer who can do a private-party transfer.
We have red flag laws being adopted by communities across the country. Laws are being implemented everywhere that penalize lawful gun owners when their firearms are lost or stolen, and they have to report it to the local jurisdiction. That’s not fair. We’ve seen the recent issue with the Honey Badger… they were given a 60-day stay, but there will be some fallout on this for all AR pistols and other NFA-type weaponry. And ATF inspections, are they on the rise? Will they continue to be postponed? We have seen an increase in inspections relatively recently. We can only expect the rise to continue.
Let’s talk about ATF inspection activities and what’s on the table. So, first of all, it’s important to note that inspections are starting to occur again. It comes down to what state you’re in and the conditions in that state. So you have to pay attention to that to see if they’re willing to make their way out again.
And they are playing catch-up. They have many things to catch up on. First of all, they had an entire plate of inspections that were scheduled previously. In addition to that, they have a requirement to get out to all the new licensees. So, anybody who recently applied for a license and was approved during the pandemic can expect a site visit, initial interview, and inspection. So results are pretty much 50-50. We’ve had about 30 or so clients that have received audits so far around the country. Warning conferences are still occurring during the pandemic phase
We have a good relationship with the ATF, so we like to make sure that the FFLs that we support are doing things the right way and ensuring that they’re going to be good to go the next time they get inspected. So let’s talk about what causes an inspection. You have the random inspection that occurs; basically, if you haven’t been inspected in a while. But more importantly, if you’re an FFL or a firing range FFL, and you see a lot of denials, a lot of individuals coming in who have been denied for a transaction to purchase a firearm, that could be an indication that somebody’s targeting you to attempt to buy a gun. One thing we’ve heard a few times now, that we need to be careful when it comes to those individuals that are targeting you to attempt to purchase a firearm; don’t let them walk in and say, “Hey, I just want to see if I can pass a background check.”
That’s a huge red flag. There needs to be a genuine intent to purchase a firearm. The other one is trace requests. If you’re receiving an excessive amount of trace requests, it’s important to pay attention to that and see what’s going on. And then just your overall quantity of NICS or point-of-contact state background checks. If you’re processing a lot of guns, you may show up as a potential target of inquiry; “Hey, we want to take a look at that FFL and see what’s going on there.”
The random inspections are a lot fewer than the rest. Suppose you’re an FFL with a lot of denials – there’s going to throw up a flag.
The things that you need to pay attention to every day; 4473s, your transfers, that’s private party transfers, your FFL-to-FFL transfers, etc. Your A&D logbooks. We have training guides for all of this, and we’re going to make those available to you. So SOPs for critical processes. If you’re a one-person shop or a husband and wife team, it may not necessarily be needed. But if you’re operating a store that has any number of employees, you need to make sure that you have your processes, procedures, and practices documented so they have a point of reference to reference. That’s vitally important. We’re finding that ATF is liking when FFL’s have documented procedures outlining what their employee base is supposed to be doing.
We’re going to talk about double and triple checks. If you’re, again, that one-man-shop or a husband and wife team, maybe a double check’s all you need. But we highly recommend double checks at a minimum. Triple check if you’re processing a lot of firearms. You may want to have that third set of eyes on it at the end of the business day just to make sure everything’s good to go before you file that 4473. Warnings and revocations, we help a lot with warnings and revocations. The warning conference or warning letter is your first indication that you’re on your last step. You’ve got one more chance, and you need to take that seriously. And that’s where those corrective action plans come in. And revocations, that’s serious. You’re going to lose your license.
And that’s where our partner law firms and we come in. We take a look at what’s going on to determine things like willful negligence, and we work with you to figure out if there’s a remedy to the situation that works. The important thing here is at any point throughout your business operations, if you’re sitting back thinking to yourself, “I don’t know if that’s right. I don’t know if I have the right processes in place.” Pick up the phone and call us. Just schedule a call with us. We’re happy to talk to you.
Regarding that warning and revocation piece, what we’ve seen is that once you get that first warning letter, you’re on a list. The ATF is not going to forget about you for quite a while. You talk about reinspections and revisits. That’s one of those triggers that keep you on a list that if you had a bad visit this year, you’re most likely going to have a visit next year. I would tell you between 12 and 24 months is a certainty.
Let’s talk about inspection prep. It’s vital to keep this in the back of your mind that there’s the potential that every 12 months, the ATF can come in and inspect you. That’s by law. They’re authorized to do this. And the frequency of that happening is difficult to estimate. If you have had an inspection and had a pretty lengthy report of violations, received a warning letter or warning conference, make sure that you’re continuously monitoring all of your business activities, paperwork, your A&D records, etc.
So one of the things that I’ll tell you as far as preparation, expect that the ATF will do is that one-year look back. They’re going to go back to the trailing 12 months, review your 4473s, review your denials, review your 3310s, review your NTN reports, and they’re going to bring an NTN report with them. They’re going to verify that for every NTN number you were issued for the sale of a firearm before denial, that there’s an ATF form 4473 present for that transaction. So keep that in mind. They’re going to do an all firearm inventory, and they are going to verify gun-to-book, book-to-gun, and they’re going to do a complete and thorough A&D review. This could include several IOIs in your premises for a week, maybe even two weeks, depending on what your firearm inventory looks like. Finally, they’re going to go through all your ATF form 4473s for at least the last 12 months. So be aware that paperwork is vitally important to your business and is vitally important to pass an ATF inspection successfully.
Next, they’re going to do those employee interviews and observations. We do all of these things on our mock inspections. And I will tell you right now, and we do a lot of corrective action right on the spot with the FFL employees. The ATF will be monitoring how transactions are processed to see how you’re qualifying customers. Lastly, when the inspection is done, they’re going to do that closing conference, and they’re going to walk you through all of their findings. Now, they’re going to allow you to ask questions, give responses, and even dispute things. We want you to be cordial with the ATF. They’re not your enemy. They have a job to do. It goes a lot easier if you’re not adversarial. I sat in on a couple of the closing conferences recently with our clients, and most of them, for the most part, have gone pretty smooth.
One thing to consider is whether or not this is in a random audit, “We haven’t seen you in five years or three years.” Or if this is a visit resulting from a bad visit last year. And I have to say, there are specific indications, whether it goes one way or another. Suppose you get the same inspector there last year on your inspection that didn’t go so well. In that case, you can almost assume it’s going to be somewhat of a little bit of stress going through another review with them again, especially if you haven’t corrected all of the items they documented explicitly in that last report of a violation.
We can’t reiterate enough how important it is to be cordial, inviting, and collaborative during that inspection. It’s vital to have that corrective action plan. Take that report of violations, sit down with each violation, and map out corrective action for each violation. I will tell you the vast majority of FFLs that we support find that to be very, very helpful for them and their staff. So they know. Because that IOI will come back in, and they’re going to bring that report of violations that you had. And they’re going to make sure every one of those things is corrected. So it’s vitally important to take that seriously.
We help gun dealers with FFLs to create that corrective action plan, not only does it get submitted to the ATF, but they review it. And the biggest challenge is you, as a gun dealer implementing it. And that’s where we follow up on our monthly calls with our clients. We must go through that action plan with you and make sure you’re doing what you said you would do.
So let’s go through the top violations from our team visits. This list may not precisely align with what the ATF is publishing, but here’s what we want to reiterate with you right now to get ready for your next inspection. The ATF will verify, inspect and make sure transfers are done correctly. So we want to start by saying that every box counts. It’s not a matter of how many 4473s I had incorrect. The report of violations will list each box online on your form incorrectly completed, missing information, etc. So every box counts, and that’s good training for your employees.
Next is legibility. If the ATF inspector cannot read or decipher a number on a serial number, that will be a problem. So we urge you to make sure your staff is using good penmanship, printing correctly, taking their time, and make it readable.
Remember, these forms will last a lifetime of the firearm for tracing purposes for at least 20 years. And that’s the big concern with Legibility. These forms have to be able to be read 10, 12 years down the road. If that firearm ever shows up in a criminal situation, it has to have a trace done. Next, we find invalid and expired IDs being used all the time. We urge you that if you’re accepting invalid or expired IDs, that they are noted as such in box 31 or box 32 in the new 4473. Note that it was an authorized expired ID due to pandemic. Remember these inspectors might come in a year or two or three from now and look back at your forms and see expired IDs, driver’s licenses being used.
On the next form, so we have a tremendous amount of errors. This is probably one of the most significant issues I see when conducting audits onsite; firearms are being sold to denied folks. That does happen, believe it or not. It may not be happening in your firearms dealership, but it does happen. And that’s a big, big, big red flag—something where the ATF has to go and react to and retrieve those firearms. And we see Brady dates expiring all the time or not documented at all or guns being transferred before the Brady date expiration, another big problem. That whole box 27 information is critical to validating and authorizing the transfer of the firearm. So many eyes are on this section, and very important for you to incorporate or include updated dates.
If you were releasing a firearm on a date before a Brady date because you received the proceed box 27, make sure all of that information is included. It used to be box 19 on the old form. This is probably the most common phone call we get weekly; “I have an out-of-state purchaser looking to purchase a long gun. Am I okay to do so?” And I know it’s hard for everyone to know all of the States’ laws, but we do this all the time. So we either have our list handy, or we see the information. We’ll have to do a little research in places like California and Washington State, or New York. But most out-of-state transfers require that you follow the in-state law for your firearm sale, as well as the out-of-state law for the person if they are from out-of-state.
So again, you must comply with both. Illinois has a lot of restrictions. Florida has restrictions, and more and more States are implementing state requirements for firearms transfers. So the ATF, even though they’re federal, will be validating you’re following both state laws. Missing signatures goes without saying. We can’t be missing a signature by a transferee, and we can’t be missing a signature by an employee. And missing signatures invalidate that firearms transfer and will be a significant citable violation on your report if and when you have an inspection. This is hard to talk about because it happens more and more, and it’s a challenging program to manage. But if you’re not submitting your 3310.4s for handguns and 3310.12s for multiple long gun purchases on the southern border states, these are significant violations, and they’re critical to the functions of the ATF.
That’s why these forms are so important to be sent in on the day that multiple firearms are purchased. These forms are critical for the criminal division of the ATF to be tracking gun trafficking on a daily, possible straw purchasing occurring in a specific region. So these are critical to be submitted, and they can’t be missing from the 4473s during the inspection. It would help if you did not keep them in a separate file. We urge you to keep them attached to 4473s involved in the transfers. One error equals multiple reports of violations. If you miss a signature in a box, a date is incorrect, or a NICS wasn’t updated, not only can you have a violation cited by the inspector for that block or that line that it relates to, but that violation will show up in other sections of the report.
There’s a statute that says the invalid or illegal transfer of a firearm, if you’re missing a signature from a transferee, that shows up in the citation area on the report for missing signatures. But then that same violation will show up elsewhere later when you report for processing an invalid or an illegal firearms transfer. So sometimes, we see the report of violations that are eight or nine pages. And sometimes, we see reports of violations that have 20 or 25 pages long. And we find when we audit and look back at all the violations and try to figure out the action planning that it’s the same violation showing up in many places. Even if you’ve never had a report of violations, it’s an interesting document to review.
If there’s one issue that sets off the fireworks during an inspection, the ATF team finds that you are missing firearms from your book inventory; if firearms are supposed to be in stock, that aren’t. We know this happens for so many different reasons. Still, it all comes back to daily disciplines, training, and responsibilities from your folks who are completing transfers and updating your bound book. Missing a firearm sets off the fireworks, as we say. Not only do you have to get it reported, but this is a critical violation result that’ll show up in your report and certainly lead to the other steps JC talked about, warnings and revocations.
If they’ve left the store and are waiting for that background check to be completed when they come back in, you need to make sure that they’re certifying the date of that box. So the missing 3310.4s, missing but delayed, have to be completed at the end of the business day.
The same day firearms get transferred, you have to submit your 3310.4 and 3310.12, where appropriate. We see it all the time during our mock inspections where they either haven’t submitted or were delayed. Do not take the position of, “Oh, my person does it at the end of the week.” It has to be the same day. On missing firearms, it’s a good thing that you catch the missing firearm. It’s a bad thing if the ATF catches a missing gun. That’s why firearms inventories and firearms counts are so important. Depending on the size of your shop, we make the recommendation for larger shops to do it on at least a quarterly basis. Reach out to us, and we’ll give you some insights into some of the things we recommend to midsize and larger shops.
We have a good methodology for FFLs to follow for firearms inventories and counts. It helps alleviate some of the staffing constraints that come along with that.
Regarding the new form 4473, the significant changes are the format; the five sections. The firearms section they’ve moved to the very top of the form. And I know there’s been a lot of concerns and talk about firearms registration, and that’s why they did it. On the old form 4473, the certification, and question 11. a the buyer, the transferee, was certifying that the guns listed on the form were purchasing for themselves. If you weren’t filling that form out until they finished section A, they were certifying that they weren’t buying any firearms. So all they did was move those firearms to the top of the form.
What does this help you do?
This helps you ensure that the customer has a genuine interest in a firearm; somebody who’s walking into your store and just simply saying, “Hey, listen, I want to see if I can pass a background check.” Absolutely not acceptable! There has to be a firearm on that form before you start the process. So why firearms description first?
Zero, number of firearms transferred on the old form 4473, you’re required to mark out, line out whatever number it was if no guns were transferred, and in a zero. You are no longer required to do that.
Box 8, private party transfers, really simple there. I think it’s pretty much self-explanatory. Box 14, sex, non-binary. It’s important to note what the individual recognizes themselves as; the fact of the matter is unless their identification stipulates non-binary, then it does not apply, and they have to put whatever gender sex they are. So if they’re transgender and transgender to a male and their driver’s license or identification still says male, they have to put that. If it says female, they have to put that. So what you’ll see in some instances, some states they’ve started putting non-binary on the license. It has to state non-binary.
The number one thing is to get it right the first time.
If we train our folks and retrain and review and take time to examine our forms at the end of the day, or maybe you got a second set of eyes throughout the day, go back and have the corrective behavior conversation with every person. And, don’t just correct the form; have the conversation so that we continue to get it right the first time. And think about how much time would be saved, not only on you, on your managers and supervisors and us, if we come in and review, how much time can be saved if everything looks good.
And we’re pretty sure that if the ATF inspector comes to your location for an inspection and reads through maybe 300 or 400 4473s and everything’s good, we can only assume this will be a good outcome. But if they read through 300 or 400 like we do on a visit and find many errors, I think there’s not going to be a great outcome.
So get it right the first time and reduce your errors. Legibility and penmanship; if you’re not using an electronic package to print out the information for make-model, serial numbers or import a distributor, etc., it may be a problem.
We often see enough where FFLs are debating in a warning conference that they can read the form and figure out the numbers, but the ATF inspector marked it incorrect because today, he or she cannot read the document. Well, remember these forms get sent to a tracing center when necessary. They get presented in a court of law to defense attorneys and prosecutors if and when those firearms are involved in criminal cases. That form has to be readable to a jury. Otherwise, that form is not going to be a valid presentation of evidence. So we recommend e-Form 4473; either sign up with the ATF for their electronic package or find the vendor out there. The more electronic you go with your forms and your record-keeping, the better.
On section C; train, train, train. That was formerly section B. Train your staff. Every box, every line meets up with the relative information if necessary. And if you’re a member of the National Shooting Sports Foundation, go ahead and order what they call the 4473 overlay that helps you and your staff look at these forms when they’re completed and before transferring the firearm to make sure the respective boxes that need to be filled in are. It’s a great little tool available from the National Shooting Sports Foundation. Educate the transferee; you’re not allowed to coach- we know that- you’re not allowed to help answer questions. But you can have signs or guides. We have a few available if you need these. Go to our website. You can have signage that says, “Make sure you have a valid, unexpired state photo ID before asking to look for a firearm.” You can have that in writing on your gun counter. You can have a sheet of different things we include; you’ll read the form carefully before proceeding.
Our employees are not capable or able to answer questions in section 12. So you can give especially the first-time gun buyers some information ahead of time so that they can flow through the process more easily for themselves and you. The double-check/triple check can’t be reiterated enough. You’re just losing out if you’re not having a second set of eyes look at the form. In a high-volume, high-transfer location, even a third set of eyes before that form gets filed.
For 3310s and 12s, as we say, same day, end-of-day business. Get those into the ATF. They’re essential to the ATF tracing and trafficking activities ongoing to keep our community safe. And then lastly, just timely transfers in and out, whether it be the A&D process or especially on your 4473 transfers; ensure that you’re getting the proper documentation updated in your bound book or your electronic system.
Some other errors that we see in the A&D record-keeping: importing. When we do our mock inspection, I look for my troublemakers; my Berettas, my Glocks, my Taurus, Walther, any number of those firearms that I know have been imported. The first thing I look at is the A&D log. I make sure that the FFL knows how to print it off because the ATF will expect you to print it off. And then I look down the line, and I start filing the guns. And then once I do that, I actually go out to the floor, and I verify. I check everything. So you must be paying attention to what’s on that physical form and understanding that importer is required.
Make sure that you’re training your staff on how to receive firearms, what to document when they need to document it, et cetera. Timely transfers in and out, a gun gets transferred, physical custody of that firearm goes to the transferee, the buyer, the purchaser, guess what? You’re on the hook. Document your A&D record books that that firearm left your building.
You don’t want to wait. Things get lost in the process. People don’t realize, “Oh, I thought Jim over here did it. He thought I did it.” Make sure that those are documented in A&D records. Everything you’re doing as far as your A&D records and your 4473 are focused on potential traces coming down the pipe later on.
Warning and revocations: I want to call out as far as a warning where revocations are concerned is that if you have an inspection and it goes sideways quick, there’s nothing that says that you have to go through any type of step process before revocation. So, in other words, if IOI shows up and does an inspection in your store and they find out that you’re transferring firearms to people that were denied previously, you’re transferring firearms without 4473s. This is the most extreme scenario; you can go right to revocation.
The ATF takes this stuff very seriously. So you need to make sure that you are conducting business properly. So let’s walk through it here. So you get revoked, you get that letter of revocation, you receive a certified mail, and here’s the process: essentially, what’s led to this is you had an inspection, which led to a report of violations. From there, you probably either received a warning letter or a warning conference. You’ve then been reinspected. And at that time, they’ve taken your past reports of violations and said, “You know what? You’re not only not correcting what we’ve already found multiple times potentially, but you’re also making mistakes on other things.” So they take a look at that, and they determine that this individual is not serious. They’re not doing what they signed up and said they were going to do, following the laws and regulations governing a firearms business.
So this is the process: once you get that revocation letter, you’ll have a revocation hearing. You’ll have two. You can request an informal hearing where you have a conversation, and you can plead your case. And then there’s a formal revocation hearing. And you will have to travel to the field division to have that conversation. Depending on wherever you are, that could be a long way off. There’s a process to this. We help with a lot of these. The law firms that we support bring us in to help them with these processes. And we build out the corrective action plan. We have relationships with most of the field divisions that have conversations. But I will tell you, once you get to this step, it’s a fight. And it is what it is. You may have been given multiple chances to do what you’re supposed to do, and you haven’t. So the ATF has taken that pretty seriously.
How do you stay compliant?
As we know, the inspections are going to be forthcoming. The Biden Administration could be imposing stricter guidelines for FFLs. So avoid willful negligence.
Make sure your trace requests are going in on time. We explained earlier how important they are, especially to the ATF criminal division. Make sure they’re going in within 24 hours. And if you’re in a demand-letter program, make sure you’re getting that information to the ATF quarterly. We help a lot of our clients with this. We use the electronic files and send them in timely so that the tracing centers, first of all, can use that information more quickly to determine traces without bothering you. That’s what this is all about. They don’t want to call you all the time if they could just figure out the information from files you’re sending in.
Straw purchases: Prevent straw purchases!
Too many straw purchases, and you will be a target of an inspection or a criminal investigation by the ATF. Make those pamphlets available that the ATF and FBI have available to you. Youth Handgun Safety Act, make sure the sign is posted. It’s imperative to community safety. Handgun locks must be distributed to used and new gun purchasers, new transferees. If you don’t have them, contact your local law enforcement agency, they usually have some available. Or contact us. We’ll provide cheap vendors for you. The National Shooting Sports Foundation has revamped the” Don’t Lie” program. All of those materials are available for free. So go to nssf.org or dontlie.org and find out where those program components are available for display in your place of business. NFA segregation is critical. If an ATF inspector comes in and finds you mixing NFA inventory or your books with your non-NFA, it’s going to be a problem. So make sure it’s all segregated and secured. And lastly, make sure you’re cordial to that ATF inspector if and when they ever show up.
Regarding “willful intent/willful negligence,”- I’ve mentioned the most extreme; knowingly transferring a firearm to somebody that was denied, something of that nature, or transferring a gun to somebody and not getting a 4473 completed. Those are probably the most extreme. But I will tell you that if IOI comes in and does your inspection, and they start seeing the same thing; missing signatures, missing certifications, not checking boxes, etc. Those are also willful. So you want to watch that.
We see more and more cases and revocation issues we’re dealing with that willful negligence is being cited simply as the FFL not adhering to knowledge and requirements as outlined in the FFL guidebook. So because you have the ability, you’re just not using it is being cited as willful negligence. So just be aware of that. We work with the ATF across the country, every field division. And I will tell you right now, for the most part, where they can, they will bend over backward to help you and make sure that you know how to conduct business properly. So don’t take an adversarial role when they show up. Be cordial, welcome them in, let them do their job.
Range issues: So, one of the big ones right now, we’re getting it from FFLs and ranges across the country, is, “How do I survive without ammo?” Or, “How do I even get ammunition?” Well, I wish I had a good answer for you. Essentially ammunition, nobody is increasing their supply chain in this, mainly because we said it earlier, there aren’t any supplies.
Ammo is constrained right now, metals, raw materials, et cetera. So surviving without ammo is tough. You can do some training and coaching classes without ammo. There are cheaper solutions out there. Many FFLs in ranges maintain their supply and hold back one box of ammunition for every firearm they have for sale. In other instances, we see ranges reserving their ammunition supplies for individuals coming in to utilize the range facilities. So that’s a couple of strategies that we see out there that are working pretty well. It’s a rationing process. And that’s the other thing FFLs are doing, the two-box rationing or one-box rationing, depending on how much ammunition they’re getting. So we’re going to talk a lot more about pandemic here in a few, but pandemic restrictions, make sure you have a plan.
Touching on noise suppression real quick; if you’re operating a range, maybe you’re in a residential area or have other neighbors or business neighbors. If you’re starting to see complaints about any noise, or you’re staying open later, or whatever the case may be, reach out to us. We have noise abatement solutions. We have several organizations that work with us and refer to help with noise abatement concerns. So just reach out to us. We can help you with that.
We’ve had people who considered moving into a range and purchasing a range or constructing a range. Know that we do have an entire range development team to help you. So again, reach out to us; we’ll get you in contact with them. There’s a little bit of a process to it. Our folks like to vet and make sure that the individuals are ready to go. And we’ve got a complete checklist that will help you determine whether or not a range is suitable for you. So definitely reach out to us for that as well.
Safety training for new shooters is another hot topic. And it’s something that we talk to many of our ranges, with 12 million new firearms out there right now. And of that, about five-to-seven million of those firearms are in the hands of new shooters. People who have never been involved in shooting sports before. Here’s an excellent opportunity for you to either do coaching or do instructions for concealed carry or whatever the case may be. It’s a huge opportunity. We talk to FFLs and ranges all the time, and I’m just simply having a cleaning class, teaching people how to clean their firearm appropriately, how to break it down, how to put it back together, and what to use to clean it and things like that.
We get many questions about NRA versus non-NRA and all the politics and all the other things going on with that. There are other organizations out there with training curricula, such as the USCCA, for example, which have an excellent curriculum that you can use to train your new customers or even your existing customers. So take a look at those opportunities. The industry as a whole is very focused on the female shooter, and that should continue. Having women’s leagues and family-oriented events, that’s a big one. Groups, businesses, corporate entities, the “Let’s Go Shooting” program, the “USA Shooting” program, the +ONE program from the National Shooting Sports Foundation. All great programs offer extensive advertising and marketing suggestions, recommendations, and solutions that you should be taking advantage of as an FFL and as a firing range.
Looking ahead to range operations, there’s a lot of competition out there, and it’s only growing. We’re getting a lot of calls. Our range development team is doing a lot of work as far as starting up new ranges, doing construction, just feasibility studies on whether or not a range can be placed where an individual interested in owning a range wants to put one. So I will tell you that I think range operations and range facilities will be growing for a while now.
Regarding range compliance, ATF, state, local OSHA regulations, we support all of those different functions. We’ve been seeing quite a bit of local ordinances, and in states, we would never have expected it as far as gun ranges, and gun stores are concerned. So be aware of that, especially if you’re a new FFL.
We’ve developed SOP manuals across the board, whether standard FFL operations, FFL transactions or the 4473 or range operations. Our human resources team has an entire gambit of standard operating procedures as far as your employee handbook and things like that.
Reach out to us if you’re interested. We can certainly help you with all that. Compliance auditing, and training, we’re doing a lot of onsite work right now. We have many FFLs that have us come in unannounced just to test their employees. To make sure operations are running the way they’re supposed to. So reach out to us for any questions relative to your insurance or risk management. We can help you with all those things. We work closely with all the insurance providers out there, especially the underwriters, to ensure that you all know exactly where you need to be covered and how to protect yourself in the long term.
Watch the full video interview on the MT2 Firing Range Services Virtual Summit; click here
FFL Consultants is a specialty consultant group focusing exclusively on supporting firearms retailers, range operators, manufacturers, distributors, and importers. Our experts possess many decades of experience with ATF/OSHA regulatory compliance
and the big-box sporting goods retail sector. Over the last 7 years FFL Consultants has grown from presenting at various firearms industry training and educational events sponsored by the National Shooting Sports Foundation, the ATF and FBI/NICS, to
providing time-sensitive support to more than 10,000 FFLs nationwide. When it comes to supporting our FFL community, no question is too trivial and no project too difficult.
We’ve “been there done that” many times over and stand ready to help you with your everyday needs as well as your next challenge! We stand ready to support you and your FFL business 24/7!
John “JB” Bocker – Co-Founder, FFL Consultants
JB is the co-founder of FFL Consultants and a leading expert in commercial security, internal operations, and firearms compliance programs for the firearms industry. He is a well-known and respected presenter, author, educator, and supporter of FFL's
nationwide. JB also consults for the firearms trade association and is an SBA-SBDC Certified Small Business Advisor. Having managed an inventory of over 85,000 firearms and more than 80 licensees, John believes in supporting clients through trustworthy
relationships, simplicity, confidentiality, shared education, and time-sensitive 24/7 support.
John “JC” Clark – Co-Founder, FFL Consultants
JC is co-founder of FFL Consultants and a veteran of the military, law enforcement, and retail arenas. JC has also been directly responsible for managing and overseeing nearly 500 licensees operating across the country. This has afforded him extensive
personal knowledge and experience related to the firearms industry, FFL business operations, driving profitability, and protecting organizations against risk. JC thrives in supporting clients in the areas of state and federal compliance initiatives, business
assessments, OSHA and range operations, internal control functions, and the implementation of corporate governance practices. JC also serves as a primary business, security, and compliance consultant to the firearms industry, supporting the
Members of the National Shooting Sports Foundation.
About MT2 Firing Range Services
MT2 is the Firing Range Lead Management Authority. We operate from regional offices across the country and always pay the highest value for range lead Guaranteed!!
You Operate the Firing Range. We Get the Lead Out!™
Contact us today to learn how we can help you keep your range safe!