ATF Compliance

Thank you for selecting the services of Orchid Advisors. It is our mission to assist you in ensuring that your federally licensed firearms business operates in compliance with ATF regulations in a manner that is effective and efficient. To that end, the Orchid Advisors FFL Protection Packages provide clients a host of materials to aid in setting up appropriate business processes to drive compliant behavior.

The Sample Policy documents you have received are a set of documents created to “kick start” a company’s compliance program. All operating environments are different. A big box store operates differently than a small one-man shop. A small shop in Texas operates differently than a small shop in New York. As such, the Sample Policy documents are provided for you to begin crafting your own company policies and procedures; they should not be dropped into your environment without consideration of the effect any given statement or procedure may have on your business or whether certain procedures outlined are applicable to your environment.

Each document must be read, understood, and updated and tailored for your environment with your knowledge of your business operations. However, substantive changes to regulatory requirements within the document should not be made without contacting Orchid Advisors or consulting the regulations (e.g., changing a deadline to record an Acquisition, or changing Boxes to complete on a Form 4473).

The Sample Policy documents do not replace your responsibility for reading, understanding, and complying with the current regulatory requirements. THE SAMPLE POLICY DOCUMENTS ARE NOT LEGAL ADVICE. The Sample Policy documents are operational tools only. The documents as received were aligned with general requirements at the time of receipt. However, as regulatory requirements often change, the documents must be periodically updated to maintain compliance.

You will see in the Sample Policy documents there is bracketed and/or highlighted text. This text should be updated to your environment. Usually the text highlighted is “Company” or “[employee or department tbd by company]”. In these cases, each company should insert their name for “Company” and should select an appropriate department or employee with respect to vesting the particular responsibility identified and enter that selection in lieu of the highlighted text. Other highlighted text may identify specific options from which a company may choose to elect.

Once the applicable choices have been made and the document updated, you should train your employees on your new company policies before deployment. (NOTE: remove the cover page of each document)