September 27, 2024 – ATF’s new reporting requirement for Type 07 and Type 08 FFLs located along the Southwestern border goes into effect Tuesday – October 1, 2024. Under the new requirement, if a manufacturer or importer located in Arizona, California, New Mexico, or Texas sells or transfers two or more semiautomatic rifles (that can accept a detachable magazine and have a caliber greater than .22, including .223/5.56 caliber) to an unlicensed person during a five business day period they must, just like Type 01 and Type 02 dealers in these states, report it to the ATF. While the ATF has been encouraging FFLs to start reporting immediately, it will be mandatory to report all such sales beginning October 1, 2024. Remember, the information must be submitted on ATF Form 3310.12 to ATF and the designated local law enforcement agency no later than the close of business on the day when the multiple sale or transfer happens.
According to a letter published by the ATF, “To assist its efforts in investigating and combating the illegal movement of firearms along and across the Southwest border, the Bureau of Alcohol, Tobacco, Firearms and Explosives is now requiring all licensed Type 07 manufacturers and Type 08 importers (in addition to Type 01 dealers and Type 02 pawnbrokers who are already so required) in Arizona, California, New Mexico, and Texas to submit record information concerning multiple sales or other dispositions of certain rifles.”
These new reporting requirements are in addition to the prior obligation to submit reports of multiple sales or other dispositions of two or more pistols or revolvers to an unlicensed person during a five business day period. 18 U.S.C. § 923(g)(3). Reports of multiple sales or other dispositions of handguns must be reported using ATF Form 3310.4 and must be submitted in accordance with the instructions on that form, separately from the new reporting requirements.
Renzulli Law Firm will continue to monitor and provide updates on legislation, regulations and cases concerning the manufacture and sales of firearms. If you have any questions about ATF reporting requirements or the firearm industry, please contact John F. Renzulli or Christopher Renzulli.