ATF Ruling 2016-1 coreSTORE Boundbook Compliance Responses

Created by Ezra Weinstein, Modified on Tue, 13 Dec 2022 at 01:55 PM by Hannah Harris

This ruling supersedes ATF Ruling 2013-5 Requirements to Keep Firearms Acquisition and Disposition Records Electronically.

ATF authorizes licensed importers, licensed manufacturers, licensed dealers, and licensed collectors to maintain their firearms acquisition and disposition records electronically, provided all of the following conditions are met:

1. The licensee records in the computer system all of the acquisition and disposition information required by 27 CFR 478.121, 478.122, 478.123, 478.125(e), 478.125(f), and 27 CFR 479.131, as applicable. Required information includes a record of both the manufacturer and the importer (if any). Additional columns can be utilized to capture certain additional information (e.g., inventory number, new/used, etc.), so long as the additional information is separate from the required information and the required information is readily apparent. An ATF Form 4473 serial number may be used instead of the address for recording the transfer of a firearm to a non-licensee if such forms are filed numerically.

 

The Boundbook module records all the required information.  The 4473 module supports unique 4473 serial numbers.

2. The electronic acquisition and disposition bound book software must track corrections and changes utilizing one of the following methods of tracking changes:

  1. The system must retain any correction as an entirely new entry, without deleting or modifying the original entry. When the software generates the bound book, the system must be able to quickly and easily change views of the bound book as follows: 1. Only view the original entries; 2. Only view the corrected entries; and 3. View both the original and corrected entries in the same bound book.OR

  2. The system must be able to print the corrections as a separate report containing the same parameters as are required for a paper bound book, including the firearm information, acquisition details, and disposition details. The format of the correction report may follow the traditional bound book format, or may be presented in any column format as long as the necessary information outlined above exists in the report (which may include a notes column).OR

  3. If a spreadsheet program (e.g., excel) is being utilized, the system must be able to track any edits/corrections/amendments in a “notes” column. Any edits/corrections/amendments may overwrite the original entry so long as the “notes” column explains any edits/corrections/amendments and/or tracked changes (i.e., what was changed, who made the change, and why the change was needed).

The Boundbook module maintains a complete audit trail of any changes and modifications made to a boundbook record.  The boundbook report can be printed to show all corrections in addition to the required acquisition and disposition information as outlined in #2.  In addition the audit trail on any boundbook record can be viewed by clicking the Edit History tab.
3. The system cannot rely upon invoices or other paper/manual systems to provide any of the required information. Also, if a licensee chooses to use an electronic recordkeeping system for any of its required acquisition and disposition records, then all acquisition and disposition records, regardless of type (e.g., gunsmithing, sales, NFA), must also be in the electronic format as prescribed by this ruling.

 

The Boundbook module stores all required information and does not rely on any other system or process. You can setup multiple A&D books for gunsmithing, sales, NFA etc. 

4. The system must allow queries by firearm serial number, acquisition date, name of the manufacturer or importer, name of the purchaser, address of purchaser or other transferee, and ATF Form 4473 transferor’s transaction serial number (if any).

 

The Boundbook module allows users to search for records using any of the required fields mentioned above as well as many other fields.

5. The licensee must download all records from the system to a physical storage device (e.g. hard drive, Compact Disc (CD), Digital Versatile Disc (DVD), or Universal Serial Bus (USB) Flash Drive) at the licensee’s business premises, or print and maintain them at the licensee’s business premises:

  1. at least semiannually; however, if the records are downloaded, from a host facility (e.g., remote server or cloud storage provider) contracted/leased by the licensee as provided in condition #9, they must be downloaded at least daily. In all cases, the records must be downloaded in a format that is unencrypted with the required information readily apparent;

  2. upon request of an ATF officer (must be provided within 24 hours);

  3. c. prior to discontinuance or change of: the software (program); the database system, whether or not maintained by a host facility (e.g., remote server or cloud storage provider); and/or the host facility (if applicable); and

  4. prior to discontinuance of the licensee’s firearms business.

The downloads/printouts must include all firearms in inventory, as well as all firearms transferred during the period covered, sequentially by date of acquisition, and must be limited to display only the information required by the applicable regulations. The downloads/printouts may contain additional columns capturing certain additional information, provided that the required information is readily apparent.

 

The Boundbook module allows users to download their boundbook at any time and it can be stored locally on any storage device that is available.  A daily automated backup of the bound book can be setup using the coreFFL Synchronization application that can run on Windows or Macs.  The synchronization program will store the backup on location storage.
6. If a licensee downloads the records onto a physical storage device (e.g., hard drive, CD, DVD, or USB Flash Drive), the download must be retained on the physical storage device until the next download is prepared. Additionally, the licensee must be able to present the most current version of the requested records in a printed format at ATF’s request.

 

The Licensee is able to retain the downloaded records until the next time they download.  The same applies to the automated backup, it is retained till the next backup occurs. 

7. If the licensee prints out the records, the printout must be retained until the next printout is prepared.

 

The Boundbook module allows the licensee to print their boundbook and retain it indefinitely in their records.

8. Downloads/printouts may include antique firearms, but cannot include other merchandise. However, antique firearms must be identified as such in the “firearm type” column.

 

The Boundbook module allows the licensee to print their boundbook and retain it indefinitely in their records.

9. Electronic firearms acquisition and disposition records may be stored on a computer server or device owned and operated by the licensee, or contracted/leased by the licensee through a host facility (e.g., remote server or cloud storage provider), provided that:

  1. The firearms acquisition and disposition records are readily accessible through a computer or device located at the licensed premises during regular business hours; and

  2. The licensee’s server is located within the United States or its territories, or if a host facility is used, that facility must have a business premises within the United States or its territories, and must be subject to U.S. legal process.

Licensees are strongly encouraged to ensure that there are proper and robust security protection measures in place (e.g., encryption) to ensure all data is protected.

 

coreSTORE boundbook data is stored on US Based servers which are backed up daily with multiple transactional backups throughout the day.  The hosting facilities are in Northern Virginia.

10. If the licensee contracts with, leases from, or changes a host facility (e.g., remote server or cloud storage provider), the licensee must, within 30 days, notify his/her respective ATF Area Office of the name and address of the host facility.

 

Please contact our support for this information by visiting Our Helpdesk or by sending an email to support@coreware.com.

11. Each licensee must maintain its firearms acquisition and disposition records on a separate/partitioned database that cannot be intermingled with the records associated with another license.

 

Each licensee using coreSTORE Boundbook module is setup in their own database and is not intermingled with the records associated with another licensee.

12. The storage system must back-up the firearms acquisition and disposition records on at least a daily basis to protect the data from accidental deletion or system failure.

 

The boundbook module is backed up on a daily basis.

13. Licensees must retain all records in accordance with 27 CFR 478.129, ATF Rul. 2010-8, Consolidation of Required Records for Manufacturers, and ATF Rul. 2011-1, Consolidation of Required Records for Importers (as applicable). It is strongly recommended that upon reaching 20 years, those electronic firearms acquisition and disposition records be either permanently maintained by the licensee or forwarded to the ATF Out-of-Business Records Center for preservation.

 

The Boundbook module allows the licensee to print their boundbook and retain it indefinitely in their records.

14. Upon discontinuance of business, the licensee must send required records to the ATF Out-of-Business Center in accordance with 27 CFR 478.127. The licensee must print out the required records or download them to a physical storage device (as defined in paragraph 5) or, at the discretion of the licensee, both. The complete printout or download must provide an American Standard Code for Information Interchange (ASCII) text file (in conformity with industry standards) containing all acquisition and disposition records, and a file description. The complete printout or downloaded ASCII text file (and file description) must contain all information prescribed by regulation. The NTC converts these files into image files not searchable by name.

 
The Boundbook module allows the licensee to export all their boundbook data to an Excel file which can then be saved as a CSV (ASCII).



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