Bravo Store Systems · Free Compliance Toolkit
The 24-Point FFL & Pawn Compliance Checklist
The exact audit-readiness checklist nearly 4,000 independent retailers use to
stay ATF-ready, pass inspections cleanly, and avoid five-figure fines, updated for 2026 with the latest 4473 and A&D book guidance.
FFL · Pawn + FFL · Range
Updated 2026
Print & post in the back office
ATF inspectors don't show up looking to be lenient. They show up looking for
errors, and they find them in the same six places nearly every time. Walk
this 24-point checklist once a quarter and you'll close every one of them.
Section 1 of 6
A&D Book Hygiene
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Every acquisition is logged by the close of the next business day.
27 CFR 478.125(e). The single most-cited violation in routine inspections.
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Every disposition is logged within 7 days of the transfer.
Same statute. "I'll catch up Friday" is how you fail an inspection.
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Manufacturer, model, serial, type, and caliber are recorded exactly as marked on the firearm.
Mis-transcribed serials are the #1 source of "unaccounted-for" findings.
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Source FFL is recorded with full name, license number, and address, or "individual" with full name and address for non-FFL acquisitions.
Section 2 of 6
4473 Forms, The Form Itself
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Form 4473 used is the current revision (check the bottom-right of page 1).
Using a superseded form is an automatic finding even if everything else is perfect.
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All "must answer" fields are complete before the buyer signs.
An empty box in Section B is treated as the same severity as a wrong answer.
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Buyer signature and date match the date NICS was contacted.
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FFL employee signature in Section D is the actual person who conducted the transfer.
Not "whoever was at the counter when the form was finalized."
Section 3 of 6
NICS & State Background Checks
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NICS Transaction Number (NTN) or state equivalent recorded on every 4473.
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Delays and denials documented with date and outcome.
3-day default proceeds are legal but must be clearly noted with the original delay date.
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Cancelled / not-completed transfers have the firearm returned to inventory in the A&D book the same day.
Section 4 of 6
Multiple Sales & Reporting
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Form 3310.4 filed within close of business the day of any multiple-handgun sale to the same person within 5 business days.
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Form 3310.12 filed for multiple semi-auto rifles > .22 caliber with detachable mags sold to the same person within 5 days (border states only).
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Theft / loss reports filed within 48 hours on Form 3310.11, with local law enforcement notified.
Section 5 of 6
Pawn-Specific Compliance (if applicable)
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Pawned firearms entered in the A&D book at pawn (acquisition) AND at redemption (disposition back to the pledger), with 4473 + NICS on redemption.
The most-missed pawn FFL rule. Yes, even redemption requires a 4473.
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Pawn forfeiture firearms have a documented chain from pawn → forfeit → retail sale.
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State pawn hold period is honored before any firearm is offered for retail sale.
Section 6 of 6
Records Retention & Physical Security
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4473s for completed transfers retained 20 years; denied / cancelled 4473s retained 5 years.
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A&D book retained 20 years from the date of the last entry.
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Records are accessible at the licensed premises during business hours.
"They're at the accountant's office" is not an acceptable answer.
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Inventory matches A&D book on a documented monthly cycle count.
Inspectors will spot-check 20 random serials. Missing 1 is a finding; missing 3 is a problem.
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Responsible person list (Form 7) is current with ATF, every owner, officer, and anyone with the authority to direct management.
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Address, hours, and trade-name changes filed with ATF within 30 days.
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Quarterly self-audit log signed and dated by the licensee or responsible person.
Not required by statute, but a clean self-audit log is the single most effective defense in a hostile inspection.
Tip: the difference between a "warning conference" and a
license revocation almost always comes down to whether the FFL can show a
pattern of self-correction. A signed quarterly walkthrough of this checklist
is exactly the kind of evidence ATF wants to see.