A Federal Firearms Licensee’s Bound Book must record every firearm that enters or leaves inventory, with specific identifying details on both sides of the ledger and tight deadlines for each entry. The core FFL Bound Book requirements come from 27 CFR 478.125: capture the manufacturer, importer (if foreign), model, serial number, type, and caliber or gauge for each firearm; log the source on acquisition and the recipient on disposition; and meet the recording deadlines that apply to your entry type. Everything else, from format choices to corrections to what happens when the business closes, builds on that foundation.
What Goes in an Acquisition Entry
Each incoming firearm gets a line with the manufacturer’s name and, for foreign-made guns, the importer’s name. The model, serial number, type (rifle, pistol, shotgun, and so on), and caliber or gauge complete the physical description. The entry also shows the date received and the source: for an unlicensed individual, their name and address; for another FFL, that dealer’s federal license number.1eCFR. 27 CFR 478.125 – Record of Receipt and Disposition
Privately made firearms have their own convention. If the gun has no manufacturer marking, log “privately made firearm” or “PMF” in the manufacturer field. If it also lacks a serial number, mark it under ATF’s marking rules and update the acquisition entry with the assigned serial number, prefixed by your license number.2ATF eRegulations. 27 CFR 478.125 – Record of Receipt and Disposition
What Goes in a Disposition Entry
When a firearm leaves through a sale, trade, or other transfer, the disposition side gets the date of transfer and the identity of the recipient. Transfers to another FFL take the recipient’s license number. Transfers to an unlicensed buyer take the person’s full name and residential address.1eCFR. 27 CFR 478.125 – Record of Receipt and Disposition
There is one shortcut. If you sequentially number your Forms 4473 and file them in numerical order, you can record the 4473 transaction number in the disposition column instead of the buyer’s address. It is optional, and it only works if the 4473s are consistently filed numerically so an inspector can pull the corresponding form fast.1eCFR. 27 CFR 478.125 – Record of Receipt and Disposition
Each disposition ties back to the original acquisition line, closing the loop on that serial number. An acquisition with no matching disposition is an open entry, meaning the firearm should still be on the premises.
When Entries Must Be Made
The deadlines catch people off guard because they run the opposite of what most dealers assume. The default rule for an acquisition is the close of the next business day after receipt. A firearm received Tuesday must be in the book by end of business Wednesday.3eCFR. 27 CFR 478.125(e) – Record of Receipt and Disposition
The often-cited seven-day rule for acquisitions is an exception, not the standard. It applies only when you hold a commercial record, such as an invoice or packing slip, that already contains every field a Bound Book entry needs. That record must be kept separate from other paperwork and available for inspection. Meet those conditions, and you have up to seven days after receipt to make the Bound Book entry.4Bureau of Alcohol, Tobacco, Firearms and Explosives. Federal Firearms Licensee Quick Reference and Best Practices Guide If the firearm is sold before it has been entered, the acquisition must be recorded at the time of sale regardless of whether the seven-day window is still open.
Dispositions get the longer window. You have up to seven days after the sale or transfer to complete the disposition entry.2ATF eRegulations. 27 CFR 478.125 – Record of Receipt and Disposition
Gun shows follow the same clock. The regulations do not create separate timelines for off-site sales. Many dealers bring the Bound Book to the show or keep a detailed event log and transcribe entries into the permanent record afterward, as long as the deadlines are still met.
Firearms Held Overnight for Repair
Not every firearm that comes through the door needs a Bound Book entry. The line for gunsmithing is whether the gun stays overnight. A same-day repair returned to the owner before closing does not need to be logged. If the firearm has to stay after hours, log it as an acquisition on the way in and as a disposition when it goes back to the customer.4Bureau of Alcohol, Tobacco, Firearms and Explosives. Federal Firearms Licensee Quick Reference and Best Practices Guide
The same-day exception also appears in the general acquisition regulation, which exempts firearms returned to the person they came from on the same day they were received for adjustment or repair.3eCFR. 27 CFR 478.125(e) – Record of Receipt and Disposition If a repair might stretch past closing, log the firearm on receipt.
Moving Guns Between Personal and Business Inventory
Licensed dealers who also own firearms personally have to watch the boundary. Moving a personal firearm into business inventory for sale requires an acquisition entry with all the standard details, listing the source as your own personal collection.3eCFR. 27 CFR 478.125(e) – Record of Receipt and Disposition
The other direction takes an extra step. When you pull a firearm from business inventory into your personal collection, the regulations require an acquisition entry in the Bound Book followed by a disposition entry out of business inventory into the personal collection.5ATF eRegulations. 27 CFR 478.125a – Personal Firearms Collection A firearm must have sat in the personal collection for at least one year before it falls outside certain reporting requirements, including the theft and loss provisions. Shuffling firearms back and forth without proper documentation creates exactly the gaps inspectors flag.
Paper vs. Electronic Records
The traditional format is a bound paper ledger with consecutively numbered pages, written in permanent ink. Binding is required so pages cannot be added or removed without detection. Pencil and erasable ink are not acceptable; the record has to stay legible and tamper-evident for decades.
ATF Ruling 2016-1 authorizes all FFL types, including collectors, to keep records electronically instead, provided several conditions are met.6Bureau of Alcohol, Tobacco, Firearms and Explosives. ATF Rul. 2016-1 – Electronic Acquisition and Disposition Recordkeeping The system must contain every data field the paper format requires. It must be searchable by serial number, acquisition date, manufacturer or importer name, and purchaser name and address. And it must be able to print any record immediately on request during an inspection.
One constraint trips up dealers who try to mix formats: if you use an electronic system for any A&D records, all A&D records must be electronic. You cannot keep gunsmithing entries on paper and sales in software. The electronic system also cannot lean on paper invoices or manual documents to supply required information; every field has to live inside the electronic record.
Fixing Mistakes
Mistakes happen, and ATF expects them. What matters is the correction method. The cardinal rule for both paper and electronic records is that the original entry must never be destroyed or made unreadable.
For paper Bound Books, the accepted method mirrors what ATF requires on Form 4473: draw a single line through the incorrect information so the original text stays visible, write the correct information nearby, and initial and date the change. Correction fluid or tape should never be used. If a whole line entry is wrong, such as a duplicate, a brief note next to the strikethrough gives inspectors the context.
Electronic systems must handle corrections through one of three methods permitted under ATF Ruling 2016-1: retain every correction as a new entry while preserving the original, with the ability to toggle views between original, corrected, and combined records; generate a separate printed correction report with all required fields; or, for spreadsheet-based systems, track all changes in a notes column that records what was changed, who changed it, and why.6Bureau of Alcohol, Tobacco, Firearms and Explosives. ATF Rul. 2016-1 – Electronic Acquisition and Disposition Recordkeeping
Theft, Loss, and Multiple Sales
When a firearm is missing from inventory, two obligations kick in at once. Report the theft or loss within 48 hours of discovery by calling ATF at 1-888-930-9275 and submitting ATF Form 3310.11, and also report to local law enforcement.7eCFR. 27 CFR 478.39a – Reporting Theft or Loss of Firearms Then update the Bound Book. You have up to seven days after discovery to close the open acquisition entry with a disposition that notes whether the firearm was stolen or lost, the ATF-issued incident number, and the local law enforcement incident number.4Bureau of Alcohol, Tobacco, Firearms and Explosives. Federal Firearms Licensee Quick Reference and Best Practices Guide For losses on a common carrier during shipment, the sender is responsible for reporting and recording.
Certain sales also trigger paperwork alongside the Bound Book. Two or more handguns transferred to the same unlicensed buyer at once, or within five consecutive business days, require ATF Form 3310.4: one copy to the ATF National Tracing Center by close of business on the day of the transaction, one copy to the chief local law enforcement official, and one copy attached to the corresponding Form 4473. A separate rifle-reporting requirement on Form 3310.12 applies only to FFLs in Arizona, California, New Mexico, and Texas.8Bureau of Alcohol, Tobacco, Firearms and Explosives. Reporting Multiple Firearms Sales or Other Dispositions
Keeping and Closing the Records
A&D records have no fixed retention measured in years. The rule is simpler and more demanding: keep them for as long as you hold the license. Records stay on the licensed premises, readily accessible for inspection, until the business or licensed activity is permanently discontinued.9eCFR. 27 CFR 478.129 – Record Retention
When a licensee permanently closes, all records must be delivered within 30 days to the ATF Out-of-Business Records Center in Martinsburg, West Virginia, or to any ATF office in the division where the business was located.10ATF eRegulations. 27 CFR 478.127 – Discontinuance of Business If a new licensee takes over the business, the predecessor’s records can be transferred to the successor or sent to the Out-of-Business Records Center within the same 30-day window.
Penalties for Getting It Wrong
Federal law creates two tiers of criminal exposure for recordkeeping failures. A licensee who knowingly makes a false entry, fails to make a required entry, or fails to properly maintain any required record violates 18 U.S.C. § 922(m). That offense carries up to one year in prison and a fine.11Office of the Law Revision Counsel. 18 USC 924 – Penalties
Willful violations of the broader firearms chapter carry more. Under 18 U.S.C. § 924(a)(1)(D), a willful violation can result in up to five years in prison and a fine.11Office of the Law Revision Counsel. 18 USC 924 – Penalties “Willful” does heavy work in that statute. Carelessness is treated differently than a deliberate pattern of falsification or concealment.
Short of criminal prosecution, ATF has administrative tools. Repeated recordkeeping deficiencies found during inspections can lead to warning conferences, warning letters, and eventually revocation. For most dealers, revocation is the more immediate risk. An inspector who finds unrecorded acquisitions or systematic gaps between physical inventory and the Bound Book does not have to prove criminal intent to start that process.