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General Milsurp Weapons => General C&R Information => Topic started by: running-man on January 13, 2015, 10:21:16 AM

Title: Q: What happens when I choose not to renew my C&R FFL03?
Post by: running-man on January 13, 2015, 10:21:16 AM
Disclaimer: SKS-files.com is not composed of legal experts, we do our absolute best to make sure that what we post here is accurate, thorough, and factually based.  Still, it is the epitome of foolishness to listen to “a guy on the internet” as your sole basis for legal advice.  If you have specific questions about this subject, you should consult appropriate legal council who specialize in firearms law or contact the ATF directly to obtain a formal determination about your particular firearm or issue.

In short, pretty much nothing.  You become a regular Joe Schmoe just like everyone else and all your interstate firearms purchases, both regular and C&R, must now go through a FFL01.  You do not need to maintain your bound book any longer once your license expires.   You can choose not to renew your C&R FFL03 and are not required by law to do anything special to quit. 

There is often confusion, however, because FFL01 license holders must turn over their records when discontinuing their business per 18 U.S.C. 923(g)(4) (http://www.gpo.gov/fdsys/pkg/USCODE-2013-title18/html/USCODE-2013-title18-partI-chap44-sec923.htm):
Quote from: 18 U.S.C. 923(g)(4)
Where a firearms or ammunition business is discontinued and succeeded by a new licensee, the records required to be kept by this chapter shall appropriately reflect such facts and shall be delivered to the successor. Where discontinuance of the business is absolute, such records shall be delivered within thirty days after the business discontinuance to the Attorney General. However, where State law or local ordinance requires the delivery of records to other responsible authority, the Attorney General may arrange for the delivery of such records to such other responsible authority.
Since C&R FFL03 licensees cannot engage in the business of buying and selling C&R firearms, this portion of the United States Code does not apply to them.  See Q: Are licensed collectors required to turn in their acquisition/disposition records to ATF if their collector’s license is not renewed or they discontinue their collecting activity? (https://www.atf.gov/firearms/qa/are-licensed-collectors-required-turn-their-acquisition-and-disposition-records-atf-if) for additional information.