ATF records compliance
An electronic bound book and an electronic Form 4473 are only legal if they meet every condition ATF set for them. We read the rulings and the regulations as a checklist, built each item into the software, and wrote down where each one is enforced. This page is that checklist, in plain English.
The bound book
Ruling 2016-1 and 27 CFR 478.125(e). What the software does, in the order an inspector would ask.
Manufacturer or importer, model, serial, type, caliber or gauge, acquisition date and source, disposition date, the name and address or FFL of the receiver, and the 4473 number. One book per licensed premises; a firearm cannot be open in the same book twice.
Every acquisition, disposition, correction, void and note is an event carrying a canonical snapshot of the line and a SHA-256 hash that includes the previous event’s hash. Recompute the chain from event one and any altered row shows up as the first break. Entries are never deleted: a void stays numbered with its reason.
A correction records the before, the after, who made it, when, and why. The printout carries an appendix of every correction, and voided rows print struck through, exactly as an inspector expects to read them.
Each entry records when it was written next to the date it describes. Acquisitions due by close of the next business day and dispositions due within seven days are flagged late on the list and on the printout rather than hidden.
By serial, date, manufacturer, purchaser, address or 4473 number. The bound-book line links to its 4473 and the 4473 links back, so the two records are read together.
Posting a receiving writes the acquisitions. A transfer on a NICS proceed with a recorded signature writes the disposition with the 4473 number and NTN. Shipping an outbound transfer writes the disposition to the receiving FFL. Theft or loss opens the Form 3310.11 clock.
The electronic Form 4473
Ruling 2016-2, the August 2023 revision of Form 4473, and 27 CFR 478.102 and 478.124.
The August 2023 revision of ATF Form 4473 is stored as a versioned definition: every item label, every question 21.a to 21.n including 21.m.1 and 21.m.2, both certifications, and the Notices, Instructions and Definitions. The screen renders only that definition. A wording change is a new revision file; forms already retained keep the text they were signed against.
On the licensee’s device, on a screen with the staff interface hidden. Nothing in Section B is copied from a previous 4473; the questions always start blank. Every question must be answered before certification, and certification locks the answers.
The signature is drawn on the pad and stored as an image with its own hash; the date is stamped by the system. If the pad fails, the form is printed and signed in ink and the record says so. The transferor signs Section E the same way, with a printed name.
NICS cannot be recorded before Section B is certified and identification is entered, or against a prohibiting answer. Nothing transfers to a buyer under 21 for a handgun or receiver, or under 18 for a long gun, or to a non-resident buying a handgun. A Delayed response waits three business days, ten for the under-21 enhanced check, with federal holidays excluded. A NICS check older than 30 days cannot be used.
If the transfer happens on a later day than Section B, the transferee recertifies and signs Section D again. Nothing is auto-populated.
When a form reaches transferred, denied or cancelled it is rendered once to a PDF, with the Notices, Instructions and Definitions, and its SHA-256 is stored. That file is the retained record. It is never re-rendered; corrections afterward attach as copies and the original stays intact. Every print is counted and every view is logged.
Storage and retention
Ruling 2022-1 and 27 CFR 478.129.
The bound book, its events and every Form 4473 are protected at the database level: a licensee’s records cannot be cascaded away, and the application has no delete path for them. Forms 4473 of every outcome are kept indefinitely; multiple-sale report copies are kept for five years.
The transferee snapshot, including identification numbers, is encrypted with keys that belong to that one licensee. Staff without the right permission see a masked ID; the optional Social Security number is never returned to the screen at all.
The retained PDF is copied to a backup location as soon as it is rendered. A daily job writes the whole A&D book as CSV and JSON, with the hash chain, every retained 4473 PDF, and a manifest with a SHA-256 per file. The output is meant for the on-site device the rulings require when a server is off-premises.
A view-only login sees everything and can change nothing. Forms are searchable by buyer, transfer date, transaction number, firearm type, model and serial, with a filter for not-completed transactions and a flag for review.
One command produces the records package for the ATF Out-of-Business Records Center: the A&D book in plain ASCII CSV with a column key, and every retained 4473 PDF, nothing pruned.
Two or more handguns to the same person within five consecutive business days opens a Form 3310.4 due that day; the border-state rifle rule opens a 3310.12; a theft or loss disposition opens a 3310.11 due in 48 hours. Iron Register times them and keeps the filing reference. You file them.
What stays with you
The rulings put a handful of duties on the dealer that no software can perform for you. Iron Register reminds you of them; it does not pretend to do them.
How we know
Every ruling condition is a line in our compliance matrix with the code that enforces it, and the automated suite exercises the full path from a paid sale through Section B, certification, NICS, transfer, the retained PDF and the bound-book disposition, plus every gate that must refuse.
Iron Register does not transmit to NICS and does not file ATF forms. Compliance with the Gun Control Act, ATF regulations and state and local law remains the licensee’s responsibility. This page describes the software as built; it is not legal advice.
Bring a sample of your current A&D export. We will import it, start the verifiable chain from it, and walk you through an inspection.
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