Opening a Gun Store: FFL Compliance Checklist for New Dealers

Getting your FFL is the beginning of your compliance obligations, not the end. New dealers are among the most commonly inspected FFLs — ATF wants to verify that new licensees are operating correctly from day one. This checklist covers the foundational requirements every new FFL needs to have in place.

Before Your First Transfer

License posted: Your FFL must be prominently displayed at your licensed premises. Not in a drawer, not in a file — visibly posted where business is conducted.

Bound book ready: Your A&D bound book (whether paper or electronic) must be set up and ready to record acquisitions before you take possession of any inventory. The first entry in your bound book should be your initial inventory acquisition.

Form 4473 supply: Have current Form 4473 (5300.9 Revised August 2023) on hand. Using outdated versions is a compliance violation.

ATF-required notices posted: Federal law requires certain notices to be posted at the point of sale. Verify current posting requirements with ATF.

Your First Transactions

Your first Form 4473 transactions set the habits that will define your compliance record. Work through each section carefully, follow the ATF instructions exactly, and do not rush. A mistake on your 10th form is far better than establishing a pattern of the same mistake starting from form number one.

For your first few transactions, consider having an experienced FFL dealer or compliance consultant review your completed forms before filing them. The cost of a few hours of expert review is trivial compared to the cost of establishing bad habits that persist across hundreds of forms.

NICS Procedures

Establish clear NICS procedures from the start: how to initiate the check, where to record the NTN, how to handle delays, and what to do with a denial. Every employee who will conduct transfers needs to understand this process completely before their first transaction.

Bound Book Discipline

Your A&D bound book must be maintained with discipline from day one. Every acquisition entered promptly. Every disposal recorded completely. No backlog of unrecorded entries. The bound book discipline you establish in your first month sets the standard for everything that follows.

Employee Training

If you have employees from day one, train them before they touch a Form 4473. Document the training. The responsibility for their errors falls on you as the licensee — and "I didn't train them properly" is not a defense in a compliance proceeding, it's an aggravating factor.

Your First ATF Inspection

Expect to be inspected in your first year. ATF routinely inspects new FFLs to verify they understand their obligations. Approach this inspection as an opportunity — the IOI can answer questions and clarify requirements that you're uncertain about. Dealers who engage professionally with their first inspection typically leave it better prepared for ongoing compliance than those who treat it as an adversarial encounter.