Two questions on selling a C&R firearm

[GonzoGeezer]

Hello All,

My possibly flawed search methods here and on ATF.gov did not find the answers to two questions I have regarding disposing of C&R handguns, so I'm posting them here hoping to receive guidance.

1. A) If I own a C&R eligible firearm that was purchased before I obtained my C&R license (and is therefore not documented in my bound book) and decide to sell it, must it be entered into my bound collectors book to record its disposition? B) Is there any difference if it's being sold to a non-licensee, a dealer, or another C&R licensee?

2. If I sell a C&R firearm that was acquired with my license and is recorded in my bound book to a non-license through a dealer what documentation should/must I collect to document the transaction in case of future audit by ATF?

I hope I didn't confuse things with my wording. Thanks for any guidance.

[39flathead]

1: A:Only C&R firearms acquired with your license need entered and shown disposed in your book. (The ATF says all C&Rs acquired while a license holder need to be recorded, I have never read where guns owned prior to being a licensed need to be entered and I spent tons of time on the net and reading all the ATF literature when I got mine)
B:Not that I can think of...

2:Show it disposed to the FFL doing the transfer.


Not legal advice, just my opinion.

[LTCcarrier]

And it really does not matter if you entered into the bound book in error as the book is yours when you get rid of license.

[Greywolf]

2:Show it disposed to the FFL doing the transfer.

I would get a copy of the receiving dealer's FFL. Your license may be a C&R FFL, but it is an FFL, so you're shipping FFL to FFL. You should have a copy of his license for your records and your protection.

[39flathead]

I would get a copy of the receiving dealer's FFL. Your license may be a C&R FFL, but it is an FFL, so you're shipping FFL to FFL. You should have a copy of his license for your records and your protection.

Good luck with that.
The ATF not too long ago sent out a bulletin advising non-C&R FFL's to not give out a copy of their license.
I've had more than one 01 refuse to provide a copy of their FFL.

There is no requirement that you have an actual copy.
The book says name and license number if licensee.

In the case of a FFL not providing me a copy, I simply keep the shipping receipt from USPS showing who I sent it to.

[GonzoGeezer]

Thanks all, for the replies. I'm going to show disposition of my C&R eligible handguns on my bound book for a record of the transaction.

I have a follow-on: In PA, can a C&R license holder sell a handgun directly to a non-licensee? ATF regs do not forbid it but uses the old catch-all of 'subject to state and local laws'. I understand the concern about accidently selling to a prohibited person, but otherwise, is it legal in PA?

[39flathead]

No, C&R is not a dealers license, you are a private seller with a collectors license and need to use a FFL.

[GonzoGeezer]

Thanks for the reply. I appreciate everyone's assistance.