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JoeyV.
11-12-2020, 10:41 AM
Hi all,

Anyone have an example of how to keep a good ATF binder for a type 54 permit? I don?t have storage so it?s basic I?m looking for like a spreadsheet to fill out.
Thanks!!

BMoore
11-12-2020, 11:41 AM
The attachment is an example acquisition records sheet from the ATF. Many distributors also provide you with this information. If that's the case you can just keep what the distributor gives you and that will suffice. I keep two folders. One with the acquisition records which the ATF will review and another "Permanent File" where I keep copies of my my license, contigency agreement, e-mail correspondence, copies of application, permits, etc.


http://www.pyrotalk.com/bulletin/attachment.php?attachmentid=5319&stc=1

Bitzan
11-12-2020, 05:42 PM
So this is probably more of a question for the more experienced rather than an answer but...My belief (and I am a complete novice) is that keeping your records on a spreadsheet would NOT be acceptable. You would first need to "submit a letter application to ATF describing the proposed alternate records and the need for them" but most importantly the computer system you use must comply with
From ATF Rul. 2007-1...
"1. All data entered into the computer system must be recorded into the database and
cannot be capable of being edited or modified at a later date. The software system
must retain any correction of errors as an entirely new entry, without deleting or
modifying the original entry. The system may allow for entries in a notes column
to explain any correction."

Excel (or any other spreadsheet program) would not meet this requirement.

Once again - I am not experienced - I just recently went through the process, wanted to use Excel, and recalled deciding I could not. I hope others will comment.

BMoore
11-12-2020, 06:03 PM
Bitzan, now that you mention that I think you are correct. I does seem like I've heard before that the ATF does not allow spreadsheets. It wouldn't surprise me. I've been involved in many federal and state record audits (non ATF related) and spreadsheets are always a frowned upon means of record retention because of the ability to edit the data. You could certainly create a blank log in a spreadsheet to print out, but probably best to fill it in by hand.

Arclight
11-12-2020, 06:13 PM
But you can print out the spreadsheet, hole punch it and put it in a binder to be filled out when you get product. Or keep it electronically but save your receipts when you make purchases.

joewad
11-12-2020, 10:06 PM
Use the KISS principle , if you are not a magazine holder and rely upon contingency storage. Same setup for me here and both of my reviews have gone well and agents have been appreciative of just keeping your purchases in chronological order for date of purchase. Across bottom of each purchase record I print "items purchased were disposed of on date of acquisition", date and sign. No more, no less.

BMoore
11-13-2020, 10:12 AM
Use the KISS principle , if you are not a magazine holder and rely upon contingency storage. Same setup for me here and both of my reviews have gone well and agents have been appreciative of just keeping your purchases in chronological order for date of purchase. Across bottom of each purchase record I print "items purchased were disposed of on date of acquisition", date and sign. No more, no less.

Same here, but my distributor gives me an ATF friendly purchase record whenever I pick up my orders. That has the required details whereas the purchase invoices do not. I think most distributors do this, but I'm sure there are some that don't. I also agree with what you say about No more, no less. As stated earlier I keep two folders. One has the transaction records. The other has all other correspondence, permits, etc. etc. When the ATF comes around I only provide the transaction records, but if I should need anything else (which I really shouldn't) I know where to find it.

JoeyV.
11-13-2020, 01:45 PM
Thanks all. Thanks Bmoore for the spreadsheet!

displayfireworks1
11-13-2020, 09:22 PM
For those ATF license holders operating off of a contingency agreement with a distributor. A common occurrence with the ATF Inspectors prior to your RENEWAL is to go to the distributor you have listed as your contingency just prior to your renewal and ask for your purchase records over the last year just prior to your renewal. Then,when they show up for your renewal interview they already know what your purchased and wait to see if you show them , the same records they already have. This is why they always want you to update them if your contingency changes beyond what you initially listed on your application. Now during renewals they ask for an updated contingency agreement. My experience has been if you are just buying 1.3 fireworks and do not have storage, just keep your purchase receipt. Most of these distributors are using an ATF compliant software that list all the critical data the ATF is looking for. I also recommend making copies of the purchase records , then during your interview you can just offer them the purchase receipt copies to expedite the interview.