How good is your memory? How well do you associate additional documentation with your completed 4473s? Do you paperclip these documents to 4473? Do you staple them instead? Do you process hundreds of 4473s per year or just a few? Are you going to remember the incident of a firearm transfer three years ago?
FFLAssist’s attachments and comments features can mean the difference between sailing through an ATF audit or having a challenged audit.
Attachments
“Attachments” are electronic copies of supporting documentation that can be associated with specific FFLAssist records. These electronic documents are usually in the form of JPG, PNG, or PDF file types. But any file type is acceptable. The best part is that attachments become part of the record with which they are attached. This means 1) you won’t have to worry about losing any loose paperwork, and 2) they become part of the nightly FFLAssist backup. The following is a partial list of records for which attachments are applicable, along with examples of typical documents for each record:
- Customers – i.e., driver’s license or change of address forms
- Vendors – i.e., ATF license if they are one of your suppliers or GunBroker sellers, price sheets, contracts between you and your vendors
- Items – i.e., photographs and spec sheets of firearms as screenshots from manufacturers’ websites.
- Guns – i.e., packing list showing the gun serial number and from whom you received said gun, and photographs of any marks or scratches.
- 4473s – i.e., NICS (or state) transaction printouts, customer driver’s license, private bills of sale
- NFA Transactions – i.e., fingerprint cards, trust documentation, Form 4.
To attach supporting documentation, the paperwork must be in electronic format. So, to use this feature, you will have to invest in a scanner. It can be as simple as an ID Scanner, perfect for driver’s licenses and green cards, connected via USB. Or it can be as robust as a flat desktop scanner, perfect for ATF licenses, packing lists, and other full-sheet documents.
Simply scan the document and store it somewhere, either on your computer’s hard drive or in the cloud. Then click on the respective record listed above, click the “Attachment” menu choice, and locate the files from wherever you stored them. FFLAssist then imports the document and attaches it to the main record.
Comments
“Comments” is a function throughout all of FFLAssist in which you can make internal notes. Comments are also associated with the record types listed above and more. Each comment line is 80 characters wide, but you can have an unlimited number of lines. Theoretically, you could write a small novel if you desired.
Just like attachments, comments become part of the main record.
Comments are perfect for making internal notes about gun transfers. Did the customer seem shady to you? Did the customer walk into your place of business and attempt to purchase a firearm for the person they brought along (screams Straw Purchase)? Did the purchaser fail their background check?
Comments are a fantastic way for you to explain things during an ATF audit. According to the retired 30-year ATF field agent I hired to oversee compliance of this application, the ability for FFLs and their staff to make internal notes can make the difference between sailing through an audit or having to explain yourself to the auditor. If an auditor asks you why you cancelled a gun transfer for a specific 4473, you simply pull up the comments to refresh your memory on why you cancelled the transfer.
Comments are also a fantastic way for you to have a conversation or dialogue with your staff regarding the record in question, as the comments automatically include the User ID of the person authoring the comment.
Comments associated with 4473s can also be printed on the hardcopy 4473s, if desired. With regards to 4473 comments, there is a checkbox called “Print on 4473”. Putting a checkmark in this box prints that comment line in Box 32 of page 3 of the form, up to a maximum of five (5) lines.
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