Firearm Records Retention Periods

The commenter, a Federal Firearms Licensee (FFL) and Special Occupational Taxpayer, supports replacing the current indefinite firearm records retention requirement with a fixed term. They specifically urge the ATF to adopt a 20-year retention period rather than 30 years, arguing it is more consistent with historical standards, provides sufficient traceability for investigations, and aligns with statutory prohibitions against a federal firearms registry.

The commenter, a licensed Federal Firearms License (FFL) holder, opposes the proposed rule because the retention periods are too long and create an undue financial burden on small businesses. They argue that any retention period exceeding 20 years violates the Firearms Owners’ Protection Act of 1986 and advocate for the shortest possible retention period, ideally zero years, to protect gun owners' privacy.

The commenter opposes the requirement for dealers to maintain records for 20 years, arguing that it creates a financial burden for businesses and a corresponding cost for consumers. They suggest that the responsibility for maintaining these records should lie with the ATF, who made the ruling, and that dealers should have the option to ship records to the ATF annually.

The commenter supports reducing the firearm record retention period, arguing that 20 years is excessive compared to the national average time-to-crime. They propose a 10-year retention period for 4473 forms and a maximum of 20 years for A&D history to reduce the burden on FFLs and protect customer privacy.

The commenter opposes the proposed firearm records retention periods, arguing that it creates an illegal gun registry that violates privacy and risks future confiscation. They also claim the proposal places an undue burden on private businesses.