Dlr-10 Inspection Readiness Sample Policy

See Below or Attached

Find attached: Orchid FFLPP Dlr-10 Inspection Readiness Sample Policy

Version: 1 2021.07.20 

Dealer-10

Sample Policy

ATF Inspection Readiness

a.     Overview

·       It is Company’s policy to remain ready for an annual ATF compliance inspection at all times. Following all Company policies should provide for a smooth inspection resulting in few to no regulatory transgressions.  

·       This document provides the necessary actions and coordination to follow upon surprise or scheduled arrival of an ATF IOI who will conduct the permitted annual compliance inspection. 

·       Company employees shall at all time cooperate with the ATF and shall not hinder or delay the inspection, and under no circumstances should provide false information to ATF officials. 

·       [employee or department tbd by company] is responsible for Company’s efforts with respect to the compliance inspection.  Per Policy Dlr-05 – ATF Compliance Record Retention, [employee or department tbd by company] is responsible for maintenance of ATF records and only they shall provide all documentation requested by ATF.  All employees shall defer to  [employee or department tbd by company] when asked by ATF for any Company documents. 

·       Employees shall answer questions truthfully when asked by ATF officials.  If an employee is unsure of an answer or the subject matter of the question is not that employee’s responsibility, under no circumstances should any employee attempt to provide a response of which he or she has no information or responsibility. 

b.     Applicable Regulations and Forms

·       27 CFR 478.23

·       27 CFR 478.101

·       27 CFR 478.121

·       27 CFR 478.129

a.     Arrival

·       When ATF arrives for a compliance inspection (whether surprise or scheduled), they shall be greeted and provided a space in which they may conduct their work. 

b.     Notification

·       Upon ATF arrival for a surprise compliance inspection, or, upon ATF contacting Company for a scheduled compliance inspection, the employee first interacting with ATF shall immediately notify and/or direct the ATF IOI to [employee or department tbd by company] who is tasked with facilitating the inspection. 

·       [employee or department tbd by company] shall immediately notify management and/or ownership of the commencing of an ATF compliance inspection. 

·       [employee or department tbd by company] should immediately notify Orchid Advisors of the commencing of an ATF compliance inspection. 

c.      Resources

·       [employee or department tbd by company] shall work with the ATF IOI(s) to assist them in performing their inspection.  This may include provision of applicable records, assistance with the physical inventory, or providing other necessary resources. 

·       ATF IOIs may request commercial documentation not mandated by regulation to be maintained or provided to ATF.  Should such a request occur, Company should contact an attorney to discuss.  

·       Facilitation and oversight of ATF Compliance Inspection – [employee or department tbd by company]

·       Notification of management, ownership, and/or outside counsel – employee or department tbd by company]

·       Notification to employee or department tbd by company] upon arrival of ATF  – All Employees

·       Cooperation with ATF throughout the inspection – All Employees