ATF Requirements
- 4473 Electronic Storage (Ruling 2022-1): storage is enabled at login, but you must notify your local ATF office and wait 60 days before use. Keep printing forms until then. Submit your notice right away using the notification letter template. Link to Ruling 2022-1 ›
- Cloud Bound Book Backup (Ruling 2016-1): you must back up records to a local desktop, server, or thumb drive on premise. Our free “Drop Box” sync sets this up in under 5 minutes. Link to Ruling 2016-1 ›
How to Enable and Comply with 4473 Electronic Storage
As a matter of background, the ATF made possible the electronic storage of 4473s without a variance with the issuance of ATF Ruling 2022-1. That Ruling specified the manner in which FFLs could store in-process and completed 4473s, and attached documentation in a digital format. Orchid eBound™ is compliant with ATF Rul. 2022-1 and, unlike other FFL Bound Book providers, we offer this storage feature without a 3rd party integration and at no additional cost to you.
By default, is an electronic 4473 (i.e., a PDF) stored online considered Electronic Storage per the ruling?
The answer is NO. Just because Orchid and the industry’s other FFL Bound Book providers make available your completed 4473s in a cloud-based application, that is not considered compliant “Electronic Storage” as per the ATF. The online access we and others provide enables your ability to read, print, and reprint as needed.
How do I get approved for 4473 Electronic Storage? (“aka eStorage”)
Per Ruling 2022-1, each licensee needs to submit a notification letter to their local ATF office with the intent to enable this service. This is a notification only and does not require an approved response. The ATF requires that the licensee continue to print 4473s and related documentation for the 60 days following submission of that letter.
To assist, Orchid’s support team has developed a templated copy of such a letter and has been providing it to all clients requesting it. Download the notification letter template ›
If I didn’t send in my ATF Notification, am I required to print my 4473s and attached documentation?
Absolutely. To do otherwise would be considered non-compliant and risks inspection violations.
Please note:
- Each licensee is still required to understand and comply with Ruling 2022-1. Although we provide the service for free, you are still required to notify the ATF and wait 60 days prior to use. ATF is currently considering amending this requirement in its recent package of regulatory reform proposals but as of today it is still required.
- You are not required to use the service even though it is free; in other words, you may continue to print and retain paper copies of your Forms 4473.
- If you wish to have the 4473 eStorage alert turned off, please contact our support team.
Need Help?
Contact our live support team via the Orchid Support Portal.