New Reporting Requirement for Firearm Manufacturers and Importers in Border States

 

July 5, 2024 News from Reeves & Dola, LLP New Reporting Requirement for Firearm Manufacturers and Importers in Border States Attention Type 07 and 08 Federal Firearms Licensees in Arizona, California, New Mexico, and Texas! Beginning on October 1, 2024, you must report to the Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF) whenever, at one time or during any five consecutive business days, you sell or otherwise dispose of two or more semi-automatic rifles to an unlicensed person. This reporting requirement applies only to semi-automatic rifles that are greater than .22 and capable of accepting a detachable magazine. The required information must be submitted on an ATF Form 3310.12 no later than the close of business on the day the multiple sale or other disposition takes place. The requirement does not officially go into effect until October 1, 2024, but ATF is encouraging Type 07 and 08 FFLs to begin reporting immediately. This requirement will stay in place until ATF issues a written notice to stop. Dealers and pawnbrokers have been required to make these reports since 2011, but ATF is extending the requirement to manufacturers and importers to "assist in its efforts in investigating and combating the illegal movement of firearms along and across the Southwest border." ATF web posting, New Reporting Requirement for Type 07 and Type 08, available at https://www.atf.gov/firearms/new-reporting-requirement-type-07-and-type-08 (accessed July 5, 2024). Please note, this new reporting requirement is in addition to the multiple sales reporting for pistols and revolvers required of all licensees under 18 U.S.C. 923(g)(3). The pistol & revolver multiple sales reports are filed on a different form, the Form 3310.4. The full text of the notification is available here. Receipt of this alert does not establish an attorney-client relationship. Questions about this alert may be directed to: Johanna Reeves: 202-715-9941, jreeves@reevesdola.com About Reeves & Dola Reeves & Dola is a Washington, DC law firm that specializes in helping clients navigate the highly regulated and complex world of manufacturing, sales and international trade of defense and commercial products. We have a deep understanding of the Federal regulatory process, and use our expertise in working with a variety of Federal agencies to assist our clients with their transactional and regulatory needs.   Reeves & Dola, LLP Reeves & Dola, LLP 1775 I Street, NW, Suite 1150 Washington, DC 20006 202-683-4200 info@reevesdola.com