Comment on FR Doc # 2026-09182

As a high-volume dealer that completes hundreds of ATF Forms 4473 each year, we appreciate the improved flow of the proposed form and the consolidation of customer-completed and licensee-completed information. However, based on our operational experience, we are concerned that removing clear section delineations and field numbers will create confusion, increase missed information, and make the form more difficult to review, audit, and correct. We respectfully recommend retaining section headings and numbering each field. Numbered fields allow customers, employees, reviewers, and compliance personnel to clearly identify which questions and fields belong together. Without that structure, certain items could be easily overlooked, including the “Initial Only” and “NMN” boxes, as well as the question asking whether the transferee/buyer is an alien illegally or unlawfully in the United States. Field numbers also provide a practical compliance benefit. When identifying errors, it is far more efficient and consistent to reference “Box 10” than to describe the field by name or location, such as “address” or “Section 1, fourth field.” This is especially important for high-volume licensees reviewing large numbers of forms and tracking recurring errors for training and corrective action. Because the firearm information is no longer located on the first page with the customer information, we suggest the Transaction Serial Number (TSN) appear on all pages of the form. This would help ensure that pages from different forms are not inadvertently mixed and that the correct firearm information remains associated with the correct purchaser/transferee. We believe the number of firearms being transferred should not be optional. The form should require this information, while allowing the number to be entered either numerically or written out. Requiring this field would make it clear during review whether a continuation page is required. We also recommend that the initial boxes be returned to checkboxes. Providing a clear “yes” or “no” response option may assist in identifying prohibited persons who misunderstand or improperly answer the certification questions. The NICS transaction area on page 3 is difficult to read, and placing related NICS follow-up information several sections away may create confusion. When these sections are presented together, it is clearer where any additional NICS information must be recorded. Finally, we recommend against creating an optional requirement to attach customer identification. The current approach in Boxes 26.a. and 26.b., which allows the licensee to record the documentation reviewed rather than attach copies, should be retained. Introducing one optional attachment alongside multiple required attachments may create confusion. Additionally, many customers in this industry are understandably hesitant to have copies of their personally identifying information retained. Questions Is Section 8 intended to replace the current recertification area, or must Section 8 be completed for every transaction? With respect to Section 14, are employees required to complete this section for every ATF Form 4473, resulting in two employee certifications/signatures? Or is Section 14 only required when the form is being used to conduct firearm handler checks? Based on Section 4, it appears Section 14 may only apply to firearm handler checks, but clarification is needed.