Mobile Gunsmith FFL?

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Just an odd question from today when I was daydreaming about quitting my day job right after a successful do-it-yourself-at-home gun repair.

I know that if I opened a gunsmith shop, I'd have to get an FFL...input all guns...and receipt them back out. But what if, in these consumer oriented days, I opened a "mobile" gunsmith...doing only simple stuff and right in front of the customer. I come to someone's house, mount their scopes, reblue their 1911's, reassemble their Ruger Mark III's, whatever...I know I couldn't do anything dynamic without some machining tools, but that's not what most repair shops do anyway.

I'm not asking if I'd make any money or it's a good idea. I'm asking if I would need an FFL in that instance...where the gun never left the customer's property/possession.

(I'm obviously just daydreaming...no way that I can reassemble a Mark III in this world or any other:D)
 
berettaprofessor But what if, in these consumer oriented days, I opened a "mobile" gunsmith...doing only simple stuff and right in front of the customer. I come to someone's house, mount their scopes, reblue their 1911's, reassemble their Ruger Mark III's, whatever...I know I couldn't do anything dynamic without some machining tools, but that's not what most repair shops do anyway.

I'm not asking if I'd make any money or it's a good idea. I'm asking if I would need an FFL in that instance...where the gun never left the customer's property/possession.

Gunsmithing requires an 01FFL Dealer at the very least and if any of your gunsmithing involves a manufacturing activity then an 07FFL Manufacturer would be required.

§ 478.11 Meaning of terms. Gunsmith. A person who devotes time, attention, and labor to engaging in such activity as a regular course of trade or business with the principal objective of livelihood and profit, but such a term shall not include a person who makes occasional repairs of firearms or who occasionally fits special barrels, stocks, or trigger mechanisms to firearms;

478.50 mentions the locations where you can conduct business (basically your licensed premises or a gun show/special event).
478.100 specifically prohibits using a motorized or towed vehicle at a gun show/special event.


§ 478.50 Locations covered by license.

The license covers the class of business or the activity specified in the license at the address specified therein. A separate license must be obtained for each location at which a firearms or ammunition business or activity requiring a license under this part is conducted except:

(a) No license is required to cover a separate warehouse used by the licensee solely for storage of firearms or ammunition if the records required by this part are maintained at the licensed premises served by such warehouse;

(b) A licensed collector may acquire curios and relics at any location, and dispose of curios or relics to any licensee or to other persons who are residents of the State where the collector's license is held and the disposition is made;

(c) A licensee may conduct business at a gun show pursuant to the provision of § 478.100; or

(d) A licensed importer, manufacturer, or dealer may engage in the business of dealing in curio or relic firearms with another licensee at any location pursuant to the provisions of § 478.100.

[T.D. ATF-191, 49 FR 46890, Nov. 29, 1984, as amended by T.D. ATF-401, 63 FR 35523, June 30, 1998]


§ 478.100 Conduct of business away from licensed premises.

(a)(1) A licensee may conduct business temporarily at a gun show or event as defined in paragraph (b) if the gun show or event is located in the same State specified on the license: Provided, That such business shall not be conducted from any motorized or towed vehicle. The premises of the gun show or event at which the licensee conducts business shall be considered part of the licensed premises. Accordingly, no separate fee or license is required for the gun show or event locations. However, licensees shall comply with the provisions of § 478.91 relating to posting of licenses (or a copy thereof) while conducting business at the gun show or event.

(2) A licensed importer, manufacturer, or dealer may engage in the business of dealing in curio or relic firearms with another licensee at any location.

(b) A gun show or an event is a function sponsored by any national, State, or local organization, devoted to the collection, competitive use, or other sporting use of firearms, or an organization or association that sponsors functions devoted to the collection, competitive use, or other sporting use of firearms in the community.

(c) Licensees conducting business at locations other than the premises specified on their license under the provisions of paragraph (a) of this section shall maintain firearms records in the form and manner prescribed by subpart H of this part. In addition, records of firearms transactions conducted at such locations shall include the location of the sale or other disposition, be entered in the acquisition and disposition records of the licensee, and retained on the premises specified on the license.

[T.D. ATF-270, 53 FR 10498, Mar. 31, 1988, as amended by T.D. ATF-401, 63 FR 35523, June 30, 1998]
 
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