That is not the answer I was expecting, it's much better. This is starting to look kind of attractive. Applying is mainly the same info I'm producing every time I fill out a transfer form, and maintaining the book doesn't look to me to be any worse than what a person really should be doing anyway, with or without the license, just to keep the 'ol backside covered.
So when ATF calls on me, as long as I have my book up to date and they don't spot a still or some other stupidity, I'm good ? Are there common mistakes C & R holders make in one of these audits (?) that cause it to rain crap ?
Now that's funny, I don't care who you are!
Pretty much. Let's say you recently got a C&R license, owned one Russian SKS prior to getting the license, and bought two more Russian SKSs after getting the license. The two most recent Russian SKSs would be on your license, but the old one you previously bought before you got the C&R license would not be logged into your bound book until/unless
you sold/gave//lost/otherwise disposed of it. At the point of sale/gifting/loss/etc you would log the entire acquisition record of that one particular gun into your bound book complete with importer, country of manufacture, S/N, caliber along with the disposition record information of where that particular firearm went.
Now if ATF called you up and wanted to do an audit, you would have the option of taking your records and firearms to the agent's office, or allowing the agent access to your premises to inspect your records and firearms there. I'd suspect that if they came to your place and you opened the safe and you had three SKSs in there but only two in your bound book, you'd get questioned about it. Your answer should be a straightforward "I obtained this XYZ firearm in 20XX, before obtaining my C&R license. I understand that if I dispose of it while my C&R FFL03 is active, I would have to record it in my bound book." Simple as that. Simple and direct is always best, without excuses and without trying to get into lots of legalese. Show them you know what you're doing w/o presenting a bunch of attitude and they are likely to stop looking for any inconsistencies.
This scenario is one of the reasons that many people choose to take the option of meeting the ATF agent at their office, they wouldn't have to deal with any guns obtained prior to a C&R license it at all. Of course, with large collections, this can get to be ridiculous as transporting more than 5 or 10 guns across town is no picnic! There is also the perception aspect to look into. Anything that makes the agent scrutinize you during the audit (i.e. being extremely evasive in answering any questions, having incomplete or inaccurate records, missing any gun in your collection because you're "storing" it at your brother in law's place etc.) should be avoided. It also depends on what the agent is actually looking for. If you're under active investigation and it's an ATF special agent
wanting to talk to you, that's a time to immediately clam up and ask if you are free to go, and if they won't allow you to, to immediately request to talk to your lawyer. If it's just a typical agent and he tells you he's meeting his quota of audits for the year, it's probably nothing to worry about.
Obviously, honesty is the best policy, though there's always a difference between being the agents best bud (being too friendly like this this could also be perceived as hiding something as well) and simply giving him the information he asks for, answering his questions to the best of your ability, and then sending him on his way as quickly as is reasonable. It's probably a fine line and many people are more comfortable to err on the side of being extra friendly than they are to be on the side of being extra cautious. Depends on your personality I guess.