Each item in this article represents the minimum ATF Compliance Standard together with what coreSTORE offers in its 4473 Maintenance Module and how we comply with these standards. The items on the left column are the ATF Minimum Standard in storing, processing, and accessing electronic 4473 forms. The column on the right are the compliance methods done by coreSTORE to meet the ATF Minimum Standards.
coreSTORE Compliance with ATF 4473 Digital Storage Requirements as of 4/4/22
(based on revised ATF Minimum Standards 5/4/21)
ATF Minimum Standard
Compliance Method in CoreSTORE
4473s are created in the Bound Books section of the CoreSTORE site; all sections of the 4473 form along with accessible ATF instructions are provided to the user.
Forms 4473 must be saved in an unalterable format. The original ATF Form 4473 must be retained and may not be deleted, amended, replaced or otherwise altered.
Information entered into the 4473 eForms is initially captured and stored in a MySQL database. A 4473 in the CoreSTORE system can be in one of two states: "complete" and "incomplete".
A 4473 is considered "complete" if all non-optional information has been provided (that is, in a state where it would normally be submitted to the ATF), otherwise it is considered "incomplete".
When a Complete 4473 is to be sent to the ATF, the CoreSTORE system fills out ATF E-Form 4473 (5300.9) using the data in the database and generates a PDF that can be attached as an email attachment to be sent to the ATF or may be printed manually.
This PDF is also stored on an Amazon S3 external server and is linked to the 4473 record in the database.
Complete 4473s are unalterable from the CoreSTORE interface (you can view but not change any of the information), but may be corrected if errors are found after submission (see below).
If errors are found on a Form 4473, corrections may be made to a copy of the original Form 4473.
This copy should be attached at the end of the original Form 4473, and all changes have initials, and dates must be visible on the corrected copy.
If errors are found, the 4473 record may be corrected through a "versioning" process; the record in the system is cloned and links to the original record, and the new version of the record may be edited. Each version of a 4473 record is linked to each other in the database.
Complete 4473s automatically generate a PDF when a change is submitted; Incomplete 4473s will generate a PDF on demand.
The PDF is created in a "stack" where the original (initial) Form 4473 is on top and each subsequent changed version is attached at the end of the previous version.
The Form 4473 version number is printed in red text in the top-right corner of the Form 4473:
Changes between the versions are easily identifiable by the initials and dates printed in red next to the area where data has been changed, for example:
All supplemental forms for a transaction (Multiple Sales, etc.) must be electronically attached at the end of Forms 4473 for continuity and ease of review.
Supplemental forms (such as Form 3310.4/3310.12) are stored in the database as well, and are internally linked to the 4473 record(s) to which they apply.
When the PDF is generated, any supplemental forms are attached at the end of the Forms 4473.
ATF must be provided uninterrupted access to the system to facilitate a compliance inspection. ATF access during inspections must be in a “read only” capacity.
The CoreSTORE system contains an "ATF User" mode that provides restricted access and specific rights allowing that person access only to the Bound Book area (which includes review of 4473s).
When the ATF User logs in, it automatically implements Read Only access, and viewing any Section includes a header that states you are in "ATF Mode".
Complete 4473 PDFs that are uploaded to Amazon S3 are stored in separate folders based on their NICS result ("proceed", "denied", "canceled", "no_response", and "not_required") and these folders act as a wall between those that required a background check and those that did not.
(There is currently no intention to store Form 4473s that do not follow 27 CFR 478.129(b) as PDFs (only in the database), but should this change we would store them in a separate folder on Amazon S3.)
The system must allow Forms 4473 to be printed upon request from ATF.
Clicking on any button marked "PDF" in the Manage 4473 screen will open the relevant "stack" of Forms 4473 as a single PDF.
If the Forms 4473 are Complete, the previously-stored PDF on Amazon S3 will be retrieved.
If the Forms 4473 are Incomplete, a PDF will be dynamically generated from the data in the database.
In either case, the PDF is displayed in a separate browser tab and can be printed.
The system must store Forms 4473s in alphabetical, chronological, or numerical order.
The system stores 4473s in numerical order based on the 'id' field in the 4473 database table.
This is being handled by the Amazon S3 system, which automatically backs up our storage area that contains the uploads of Forms 4473 PDFs.
The system must allow access to Forms 4473
When browsing 4473 records through the Manage 4473 interface, you can choose to open Section A, which will display the Firearms Table where there is a clickable link next to each firearm to view the corresponding A&D record.
The Manage 4473 screen includes a "flagged" column, allowing for the flagging/unflagging of records.
The Manage 4473 screen allows for column-based sorting.
A separate coreSTORE component (an application called "coreFFL Sync") installs a system task on one or more desktop computers. This task runs daily and backs up the 4473s from Amazon's S3 system to a local drive or mounted server. The files retrieved by this task are unencrypted PDF files, ready for viewing or printing.
Upon discontinuation of business, Form 4473s shall be submitted electronically to the National Tracing Center - Out of Business Records Center in a format suitable for imaging, such as a TIFF, JPEG, or PDF.
All PDFs from the Amazon S3 system can be retrieved and sent to the National Tracing Center.
NOTES:We are not currently including attachments to Section C (Q26a, Q26b) in the PDF output. The reasons for this are:
- The paper Form 4473 does not provide any instructions for photocopying or attaching these to the Form 4473, just to show the identification or documentation to the transferor
- Some identification methods (like some US Military IDs) actually have printed on them that they are not to be duplicated.
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