Dlr-04 ATF Trace Response Sample Policy

a.     Overview

·       Trace requests may be requested by the ATF at any point in time.  Company must respond to ATF requested traces within a 24-hour window, 365 days per year. 

·       Trace requests from personnel or organizations other than the ATF should be immediately directly to [employee or department tbd by company[O1] ].

·       In either case, no employee should submit any information that is inferred, determined based on assumption or arrived at by way of guessing. Trace responses should only correspond to facts as presented in Company records (e.g., A&D Book and Forms 4473) unless [employee or department tbd by company[O2] ] has determined those records to be in error.

·       Trace requests that are of concern (e.g., there is no trace data, there are apparent duplicate A&D Book entries, cannot find a Form 4473, firearm reported Theft / Loss) should be discussed with Management and Ownership.

b.     Applicable Regulations and Forms

·       27 CFR 478.25a

·       A&D Book

·       Forms 4473

·       Report of Multiple Sale or Other Disposition of Pistols and Revolvers 

·       Report of Multiple Sale of Certain Rifles 

·       ATF Trace Response Log

a.     Responding to ATF Trace Requests

·       Upon receipt of a trace request from ATF, the first point of contact shall record the serial number, manufacturer, model, caliber, and type of firearm.  The employee shall read the information back to the ATF employee for confirmation (if the trace was received via telephone). The employee shall record the ATF employee’s name, email, and phone number (if the trace was received by phone). 

·       The employee who received the request shall ask the ATF employee exactly what information is requested (e.g., Disposition only, Acquisition and Disposition, etc.), and in what format and by what method (phone, email, etc.) the response is requested to be provided (if trace was received by phone).

·       The first point of contact shall notify [employee or department tbd by company] immediately upon receiving the trace request. 

·       [employee or department tbd by company] shall notify management and/or ownership, as applicable. 

·       [employee or department tbd by company] shall review the A&D Book information, and any Forms 4473, and/or Multiple Sales forms, as applicable. 

·       [employee or department tbd by company] shall provide the requested trace information in the format requested by the ATF employee within 24 hours of ATF contacting Company.  

·       If the firearm does not appear in any record, [employee or department tbd by company] shall immediately notify management and/or ownership, as applicable.  [employee or department tbd by company] shall thereafter immediately contact the ATF employee and request they confirm the serial number, manufacturer and model when possible.

·       If there is no information in Company records, ATF shall be so notified.  If it is determined the firearm is a pre-1968 firearm for which Company does have trace information, the information shall be provided and ATF shall be notified the firearm had no serial number. 

·       Upon completion of the trace, the results shall be recorded in the ATF Trace Response Log. The Log shall be a document maintained by [employee or department tbd by company].  The format of the Log shall be as follows:

b.    Responding to Other Law Enforcement Trace Requests

·       Upon receipt of a trace request from another law enforcement agency, the first point of contact shall immediately refer the trace to management and ownership. 

·       Fulfilling ATF Trace Requests – [employee or department tbd by company].

·       Management of non-ATF requested traces - [employee or department tbd by company[O3] ].