Comment on FR Doc # 2026-09158
National Firearms Act Trade and Collectors AssociationSupportTrade association
Summary: The National Firearms Act Trade and Collectors Association (NFATCA) supports the proposed rule to clarify that firearms records can be kept in either paper or electronic formats. They argue that this change provides regulatory certainty, reduces administrative burdens, and modernizes recordkeeping for Federal Firearms Licensees.
The National Firearms Act Trade and Collectors Association (NFATCA) supports this proposed rule. Accurate recordkeeping is an essential component of a Federal Firearms Licensee's (FFL's) regulatory obligations and routine business operations. The proposed amendment provides needed clarity regarding the permissible methods for maintaining required records and will promote more consistent compliance across the regulated community.
Although ATF has previously authorized certain forms of electronic recordkeeping, prior guidance has created uncertainty among many FFLs regarding whether the use of electronic records required an approved variance from existing recordkeeping requirements. As a result, some licensees have continued to rely on paper records or have been reluctant to adopt electronic systems despite their potential to improve efficiency, accuracy, and accessibility.
The proposed rule appropriately resolves this uncertainty by expressly recognizing that required records may be maintained in either paper or electronic format, provided the applicable regulatory requirements are satisfied. This clarification will reduce unnecessary administrative burdens, encourage voluntary compliance, and allow licensees to select the recordkeeping method that best meets their operational needs without diminishing ATF's oversight or enforcement capabilities.
NFATCA believes this clarification reflects sound administrative policy, provides greater regulatory certainty for the firearms industry, and appropriately modernizes the agency's recordkeeping regulations. Accordingly, NFATCA supports adoption of the proposed rule.