Compliance and record integrity

One canonical firearm record with acquisition, disposition and possession cycles, gap-free transaction references, premises-local regulatory dates, field-frozen ledgers and delete-blocked history.

27 CFR 478.125(e); ATF Ruling 2016-1

Guided intake with counterparty identity, serial gates and commit-gate re-validation on the server.

27 CFR 478.125(e)

Four-step disposition workflow with double-disposition protection, special-reporting findings and void/amend history.

27 CFR 478.125(e)

Buyer session, dealer review, certification capture, immutability after completion and an append-only correction trail.

FFL Elite is not an ATF eForms filing channel. The licensee remains responsible for the form's accuracy and for retaining it; FFL Elite never submits a form to ATF.

27 CFR 478.124

Background check records, delay and proceed tracking, and the outstanding-check queue.

FFL Elite does not connect to NICS or E-Check. The dealer runs the check with FBI/state systems and records the outcome here.

27 CFR 478.102

Value-aware mapping, anomaly detection, duplicate classification, disposed-firearm preservation and full provenance on every committed row.

Migrated data can only be as accurate as the source file. Staged rows are never called imported until they are committed, and the dealer reviews every finding before commit.

ATF Ruling 2016-1

Read-only paginated A&D rendering from the canonical ledger builder, with licence, premises, print date, page x of y and continuation marking.

27 CFR 478.125(e); ATF Ruling 2016-1

Complete ledger, correction history and manifest with expected-vs-exported reconciliation; a short read fails the export rather than shortening the file.

ATF Ruling 2016-1

Read-only inspection session over the committed record with export on request.

27 CFR 478.121; ATF Ruling 2016-1

Scheduled daily and incremental snapshots with checksum and read-back verification, plus a live health model.

ATF Ruling 2016-1

Documented restore procedure and an append-only rehearsal ledger; a rehearsal has been performed against a real artifact in an isolated target.

Restore evidence ages. A rehearsal older than 90 days stops counting as current evidence and the Evidence Center raises attention.

ATF Ruling 2016-1

Permanent retention: no purge or expiry job exists and every regulatory table is delete-blocked.

27 CFR 478.127; 478.129

Portability package containing the ledger, correction history, Form 4473 index and manifest, rehearsed end to end.

27 CFR 478.127

Incident workflow, ATF control number capture and an append-only A&D annotation on every affected entry.

27 CFR 478.39a; 478.125(e)

Detection of multiple handgun and certain rifle dispositions inside the reporting window, raised on the A&D path with what to do.

FFL Elite detects and states the obligation; the licensee files Form 3310.4 / 3310.12 with ATF. FFL Elite never files it.

27 CFR 478.126a

The holding is persisted when the firearm leaves business inventory and evaluated on every later disposition, with phase, days held, days remaining and the record path that applies.

The clock is advisory. It decides which record set applies; it never blocks a transfer, and it cannot know about a firearm that left inventory outside FFL Elite.

18 U.S.C. 923(c); 27 CFR 478.125a

Pawn intake, redemption and forfeiture phases with their ledger effect, recording trigger and Form 4473 / background-check consequences.

Loan terms, maturity and any statutory holding period are state and local law. FFL Elite records what the dealer enters from the pawn ticket and never computes a state term.

27 CFR 478.125(e); 478.124

The marking deadline is computed by the deadline engine and surfaced on the firearm record and the Day Board.

27 CFR 478.92; 478.125(e)

Production runs are recorded through the canonical manufacture origin: each firearm opens its possession cycle with origin_type = manufacture, the 7-day entry deadline is computed, required marking confirmation is captured, and the entries are permanent and correctable only through the correction workflow.

NFA Part 479 forms (Forms 2, 3, 4) are not generated, and ammunition manufacture is out of scope. A Type 07 SOT still files those outside FFL Elite.

27 CFR 478.123; 478.92

A Type 06 manufacturer of ammunition gets licence, premises, expiration, renewal and document tracking, plus a workspace stating exactly what the licence authorises, which federal duties apply on disposal, and that no federal ammunition acquisition, disposition, production, lot or inventory record exists inside Type 06 scope.

No ammunition ledger, production lot model, quantity inventory or component tracking is built — those would be optional business records, never ATF records, and are stated as future functionality. Ammunition never enters the canonical firearm record. Armor piercing ammunition and ammunition for destructive devices are hard exclusions. Firearms and ammunition excise tax (TTB, 26 U.S.C. 4181) and state ammunition law are outside the compliance engine.

27 CFR 478.41; 478.44; 478.23; 18 U.S.C. 921(a)(17), 922(b)(1), 922(d); Pub. L. 99-308

A Type 03 licensed collector records each receipt and disposition of a firearm curio or relic on the canonical firearm, possession and audit machinery, with the collector column set from Table 3 to Paragraph (f)(2) — including the transferee's date of birth and the identification method — its own next-business-day / seven-day recording deadlines, C&R status carried with the basis the collector established, server-held drafts and commit gates.

FFL Elite never determines whether a firearm is a curio or relic; it records the collector's determination and where that determination came from. Dealer functionality (Form 4473, background checks, pawn, manufacturing, importation, multiple-sale reporting) is not offered under a Type 03 licence, and paragraph (i) of 478.125 is not separately modelled.

27 CFR 478.125(f); 27 CFR 478.11

The importation workspace records the import event on the canonical firearm with importation as its own possession origin, the foreign manufacturer and U.S. importer kept as distinct identities, dealer-confirmed import markings, and the 15-day entry deadline tracked from the date of importation. A Type 11 importer of destructive devices works this same spine, with the destructive device determination and NFA classification attaching to the same firearm under a live Class 1 special occupational tax period.

Forms 6 and 6A, CBP entries, ITAR/DDTC matters, ammunition importation and the marking variance process are not represented. Every permit, Form 6 / 6A and Customs reference is dealer entered; FFL Elite files nothing and verifies nothing with ATF or CBP.

27 CFR 478.122; 478.92(a)(1)(ii)

A Type 09 dealer and a Type 10 manufacturer of destructive devices work on the record sets that already shipped: for a dealer the Part 478 acquisition and disposition record, for a manufacturer the 478.123 manufacturer’s record with manufacture as the possession origin, the destructive device determination carried on the canonical firearm with its statutory category, provenance and date, and the Part 479 form references and status history from the NFA domain. The workspace opens only against a live special occupational tax period — Class 3 for a Type 09 dealer, Class 2 for a Type 10 manufacturer. A claimed sporting-purpose exclusion must record its basis, and every determination is superseded rather than rewritten.

FFL Elite never determines that an item is a destructive device and never finds a sporting-purpose exclusion; a bore measurement is recorded as a measurement only. Nothing is filed with ATF, there is no eForms integration or status polling, and Part 479 forms are not generated. Ammunition for destructive devices and armor piercing ammunition are outside the offered record set. Type 11 is offered by composition on the importation spine under a live Class 1 special occupational tax period.

18 U.S.C. 921(a)(4); 26 U.S.C. 5845(f); 27 CFR 478.11, 478.41, 478.123, 478.125; 27 CFR Part 479

A Type 07 manufacturer holding a live Class 2 registration gets one workflow across manufacture, NFA classification and form tracking: the Form 2 notice obligation is computed from the manufacture date and kept separate from the 478.123 record-entry deadline, the tracking workflow runs from prepared through dealer-recorded outcome with an append-only history and visible provenance, production runs can be worked in bulk while each firearm keeps its own form record, and a recorded denial is evaluated on the server before a disposition is accepted.

FFL Elite files nothing. There is no eForms integration, no credential handling and no status polling; every external fact is what the licensee recorded, with its source. Federal holidays are not modelled in the next-business-day date, Part 479 form generation is not implemented, and a dealer SOT (Type 01/02 Class 3) gets tracking only, without the manufacturing integration.

27 CFR 479.31–479.34, 479.103, 479.84–479.90; 27 CFR 478.123

NFA classification is recorded against the canonical firearm with its category, provenance and measurements; the Special Occupational Tax is kept as a dated 1 July – 30 June period with its class and evidence; and ATF form references (Forms 1, 2, 3, 4, 5) are tracked with an append-only status history that always records who asserted the status and how it was learned.

FFL Elite does not file, submit or transmit anything to ATF, and has no eForms integration. The Part 479 registration workflow, form generation and any verified external status are not implemented. Statuses are what the licensee recorded.

26 U.S.C. § 5845; 27 CFR Part 479 (479.32, 479.34, 479.103)