How Long Do You Have to Keep Form 4473 Records?

Federal law imposes specific requirements on how long FFL dealers must retain Form 4473 and other firearms transaction records. Getting this wrong — destroying records too early or failing to transfer them when required — is a compliance violation that can survive even after a dealer stops operating.

The Basic Retention Requirement

ATF regulations require FFL dealers to retain completed Form 4473s for a minimum of 20 years from the date of the transfer. This applies to every completed transfer — approved transfers, denied transfers, and transactions that were initiated but did not result in a transfer.

What the 20-Year Rule Covers

The 20-year retention requirement applies to Form 4473, records of NICS checks, Multiple Handgun Sale reports (ATF Form 3310.4), and supporting documentation submitted with the form. It does not begin running from when you go out of business — it runs from the date of each individual transaction. A 4473 from a transfer made in 2010 is not eligible for destruction until 2030.

Electronic vs. Paper Records

ATF permits electronic storage of Form 4473 records under specific conditions. Electronic records must be retrievable within a reasonable time, must be reproduced in legible form, and must be maintained with backup procedures to prevent loss. Simply scanning and saving PDFs satisfies these requirements for most practical purposes, provided you can actually locate and produce any specific form on request.

When an FFL Closes or Is Revoked

When a dealer discontinues business or has their license revoked, the records do not simply disappear. The former licensee is required to submit their firearms records — all 4473s, the A&D bound book, and other required records — to the ATF Out-of-Business Records Center in Martinsburg, West Virginia. These records become part of the national firearms tracing system.

Transfer of Business

When an FFL is sold or transferred, the records go with the business if the transaction is structured as a business transfer to the new FFL. The new FFL assumes responsibility for the prior records and their retention. If the business is being wound down rather than transferred, the out-of-business record submission requirement applies.

Common Retention Mistakes

The most common retention mistakes dealers make include: destroying 4473s after they believe a shorter period applies (there is no shorter period under federal law), failing to retain denied transfer 4473s, not having a system to locate specific forms on request, and failing to submit records to ATF when going out of business. All of these are compliance violations, and the last one is a criminal offense.