In ATF Ruling 2008-2

Some further information sent in by a member



(Index of associated material)


In ATF Ruling 2008-2, the first criteria for an automated A/D Bound book system is:

"1. All data entered into the computer system must be recorded into the database and cannot be capable of being edited or modified at a later date without generating an audit trail. The software system must retain any correction of errors as an entirely new entry, without deleting or modifying the original entry. The system may allow for entries in a notes column to explain any correction."

This is an impossible requirement. There is not a computer system made that is not capable of being "edited or modified at a later date … ". A software system could be built which would generate an audit trail, but any competent computer person can easily modify the content of the automated A/D Bound Book and bypass (evade) any audit trail. Therefore, every system being used by every FFL fails to comply with this requirement. Is this intentional? When BATF comes to audit an FFL, they can always find this violation …

♦ — A&D is a licensed dealer’s acquisition and disposition book, separate from his 4473s, and in which the dealer logs in all firearms as they come in, and as they are sold.


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