ATF records compliance

Built to the rulings, line by line.

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

An A&D record that proves it hasn’t been touched.

Ruling 2016-1 and 27 CFR 478.125(e). What the software does, in the order an inspector would ask.

Every field 478.125(e) names, in ATF column order

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.

Append-only, hash-chained, verified with one click

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.

Corrections tracked, never overwritten

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.

Timeliness on every row

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.

Searchable the way an inspection is run

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.

It writes itself from the transaction

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.

See the bound book →

The electronic Form 4473

The form, not a form like it.

Ruling 2016-2, the August 2023 revision of Form 4473, and 27 CFR 478.102 and 478.124.

The exact form, item for item

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.

The transferee answers Section B personally

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.

Signature and date captured, not typed

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.

The gates the form’s instructions describe are enforced

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.

Recertification when the day changes

If the transfer happens on a later day than Section B, the transferee recertifies and signs Section D again. Nothing is auto-populated.

One unalterable original per completed form

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

Kept for as long as the law says, and then some.

Ruling 2022-1 and 27 CFR 478.129.

Nothing federal can be deleted

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.

Encrypted at rest, shown on demand

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.

A backup the moment a form completes, and every day after

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.

Read-only access for an inspection

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.

Discontinuance package

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.

Multiple-sale reports timed for you

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

Software keeps the records. The licensee keeps the license.

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.

  • Notify the ATF Director of Industry Operations in writing at least 60 days before keeping completed 4473s electronically instead of on paper.Ruling 2022-1, condition 1
  • Keep an on-site device that receives the daily download when your server is hosted off-premises. Cloud-only storage does not satisfy the rulings.Ruling 2016-1 condition 12; 2022-1 condition 13
  • Print the 4473, with its Notices, Instructions and Definitions, at transfer and for every denied, cancelled or lapsed form, and keep the printout with the record.Ruling 2016-2, conditions 14 and 15
  • Run NICS yourself through FBI E-Check or your State point of contact and record the response. Iron Register never transmits a background check.27 CFR 478.102
  • File Forms 3310.4, 3310.12 and 3310.11 with ATF yourself and record the reference. Iron Register detects and times them; it does not transmit.27 CFR 478.126a and 478.39a
  • Notify the DIO within 30 days if the hosting facility changes, and deliver the discontinuance package if the business closes.Ruling 2016-1 conditions 10 and 15; 2022-1 conditions 3 and 15

How we know

Tested against the conditions, not against a demo.

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.

48automated checks on the electronic 4473 and Form 3310 flow, each mapped to the ruling condition it proves
14conditions of Ruling 2016-1 walked through for the bound book
22 + 15conditions of Rulings 2016-2 and 2022-1 walked through for the 4473 and its storage

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.

Want to see the chain verify on your own book?

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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