How long to keep C&R records

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Bruce333

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Reading this thread :http://thehighroad.org/showthread.php?t=184638

EOD Guy said:
You have to keep a simple Acquisition and Disposition Record (Bound Book) in which you enter a few facts about the firearm and who sold it to you or to whom you sold it. You maintain it as long as you are licensed. When you no longer renew the license, you can destroy the record if you wish. There is no requirement to keep it or send it to the BATF.

The CFR seems to say you have to keep records for 20 years:
[Code of Federal Regulations]
[Title 27, Volume 2]
[Revised as of April 1, 2003]
From the U.S. Government Printing Office via GPO Access
[CITE: 27CFR478.129]

(e) Records of dealers and collectors under the Act. The records
prepared by licensed dealers and licensed collectors under the Act of
the sale or other disposition of firearms and the corresponding record
of receipt of such firearms shall be retained through December 15, 1988,
after which records of transactions over 20 years of age may be
discarded.
or is this only while your license is valid?

Why is this so confusing?

Lawyers!:banghead:
 
You only have to keep the record book while your C&R license is valid.

This is from the ATF's website:

(G8) 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? [Back]

No. The GCA requires the delivery of required records to the Government within 30 days after a firearms "business" is discontinued. A license as a collector of curios or relics does not authorize any business with respect to firearms. This is in contrast to firearms importers, manufacturers, and dealers who are licensed to engage in a firearms business. Therefore, the records required to be kept by licensed collectors under the law and regulations are not business records and are not required to be turned in to ATF when collector's licenses are not renewed or collecting activity under such licenses is discontinued.[18 U. S. C. 923( g)( 4), 27 CFR 178.127]

The 20 year rule applies to business FFLs, not collectors.

You might want to check out this link for more info:

http://www.atf.gov/firearms/faq/
 
I understand you don't have to turn your book in to the ATF when you discontinue collecting. However the CFR I posted says "dealers and collectors" when talking about keeping records 20 years. Or is this CFR only talking about records from before 1988 being retained for 20 years?

If retention is only required while the colletor license is valid, then where does it say your records can be destroyed after your license is no longer valid?

I have read the FAQ's and all the CFR's relating to collectors and none of it has answered this question.
 
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I understand you don't have to turn your book in to the ATF when you discontinue collecting.

I got a letter requesting mine after I did not renew. This was some years ago, however.
 
Only licensees are required to keep records. Once you are no longer licensed, you are not required to keep any records. Most licensees are required to send their records to BATF once their license expires and they do not renew. Collectors however, are not required to send in their records or to keep any once they are no longer licensed.

I have a letter from BATF Hq in Washington confirming this. When I wrote the letter, I fully expected a reply that I had to keep my bound book for x number of years. I was surprised when the reply stated that there was no requirement for collectors to keep any records once they were no longer licensed.
 
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