Hi, my name is FC and I’m a gun dealer. Welcome to my hell.

Today, we’re going to explore the not-so-pretty side of the gun industry in a multi part series. Exploring the business side of the gun business is a rather multi faceted subject that not many gun dealers are wont to discuss, but I’m not your normal gun dealer. Let’s start with some of the basics and talk about the anti-money laundering (AML) regulations of the Bank Secrecy Act and how they could ostensibly be used as the new Gun Control Act of 1968 and a few related financial industry topics…

For gun shop owners, the financial issues start even before the guns hit the shelves. In order to get product, you need to pay for it. Or, at least have a line of credit to use. And where normal businesses (like adorable cupcake bakeries and poodle waxing shops) can apply for lines of credit at banks, we in the shady underworld of retail firearms sales don’t get the same type of treatment.

I have an uncle who said it best: the bank is not your friend. You are a number, you are a piece of meat they have to get a slice of every month and they’re in business to make money. If the housing crisis didn’t underscore every single one of those words to a T, I don’t know what else will. Banks do NOT lend firearm companies money. Whether it’s buying corporate bonds, underwriting a factory expansion or a revolving line of credit, they do NOT LEND THIS INDUSTRY MONEY. Period. Just ask Kelly McMillan for his take on the subject.

If you’re starting from the ground up with nothing to your name, things get even worse. The long term lending institutions that bankroll other industries have been giving the gun world the cold shoulder despite the massive profits generated. GE Capital is the latest example, and Michael Bloomberg has been doing his part to urge people to stop investing in the firearms market for retirement funds. In short, you’re boned.

Short term financing comes in a few flavors, most of your brand name consumer/business credit card issuers will issue a firearm business a credit or charge account without an issue, but we are usually careful to tiptoe about the issue. Chase and American Express have been relatively friendly with me, but I suspect that’s because I pay my bills on time and I spend more on annual fees than some people spend on ammunition. I use my business cards to handle inventory, paying Fedex and USPS, and general operational detritus.

Most of the financing in the gun industry comes from the gun industry itself. It’s rather strange. In the olden days when we had farmers and a far less service oriented economy, when things hit hard times, your neighbors would help you and you would reciprocate in their time of need. Think of it along the lines of: What would the Amish do? That’s the gun industry. I knew we were old fashioned, but even I think that’s a bit much.

That’s how many of us operate. Most of my inventory comes from manufacturers or distributors that are willing to extend me terms that let me run a business effectively and efficiently. Not the greatest plan, but it works. The problem is that when you become a larger enterprise, you reach a rate limiting factor which is X vendor will only lend you Y amount of product. You have to diversify your business spending across multiple vendors, but that’s a growing pains issue.

For the most part, the amount of product that I can carry is dictated by how much insurance coverage I have and how much credit my vendors will extend me.

In a perfect world, my place would be wall to wall with AAC, Wilson Combat, LaRue, Springfield Armory and I can’t decide on the last one but it’s a toss up between Silencerco/SWR and FN. I do love my Saker 5.56 but chicks dig SCAR’s…

As if getting financing wasn’t bad enough, getting it there is half the fun. Now that you have a firearm waiting to be shipped to or from your shop, you have to deal with the unmitigated morass that is shipping a firearm. For those who have had to do so for an occasional sale or trade out of state, or even for some seasoned professionals – it’s a front row seat to a common sense free-zone.

I have personally dealt with phone calls from UPS and Fedex outside sales reps vying for my firearm shipping business – and when I retort that I’d love to use them if their drivers and their counter clerks actually knew their own employers own protocol regarding the shipping of firearms. Looking at the contract of carriage for both UPS and Fedex, each of them carry specific handling requirements for firearm deliveries. In a nutshell: long guns can go ground, hand guns they require to go overnight.

This policy is regrettably lost on too many of their employees. Some will refuse to send the firearm. I’ve heard of a modern day version of the butcher with the thumb on the scale where people are forced to ship a long gun overnight (this is a $20 trip via ground and a $120 trip via overnight) and some even have the audacity to claim that their local operation supersedes what is their national policy.

Much to my chagrin, corporate HQ has sided on the side of the center in that they have created a company wide corporate policy that is subject to interpretation on the local level. If that’s the case, I have no idea why they created the policy in the first place. Must be some ISO 9000 bullshit.

I’ve had USPS clerks tell me that they cannot ship handguns from my business by pointing to the “Prohibited Items” poster, I point out that it’s wrong, they look it up in the manual and decide I’m right. It’s a gigantic circle of misinformation and all it does is result in higher costs for consumers due to the fact that we as an industry have to take more time getting their product sent. This would be no different than dealers charging more to send guns to California due to the higher regulatory burden and time involved with such transaction.

So, now the guns are paid for, and have finally gotten in the shop. Customers are milling about getting their greasy fingers all over your inventory and asking you every dumb question you can image. Someone tries to haggle you down to a price on a handgun where you’d actually be taking a loss on the sale. But  finally, you actually make a sale that is profitable. Hooray! Pop the champagne! But wait — they bust out a credit card instead of cash. How are you going to take their money?

Credit card processing is without question one of the biggest clusterfucks I have ever had to experience. For the uninitiated, there are more credit card processors than online traffic schools – every single one of them wants your money, and they know you need them more than they need you.

Many businesses take credit cards with low interchange fees with no problem. Not this industry however.

Gun dealers need someone to swipe their customer’s plastic and take their interchange fee. The problem: Most credit card processors hate guns.

It is an exceptionally strange problem. You could sell cigars, cigarettes, beer, wine, bourbon, pizzas, harpoons, hammers, you name the object – and it’s not a problem until they find out it is a gun. I sense this is partly due to the slippery slope nature of civil litigation. The only reason that plaintiffs lawyers don’t sue Budweiser or Beam when someone misuses their product and hurts themselves or someone else is that nobody has set the legal precedent to do so yet, whereas the reason that major firearm manufacturers get on the hook legally when someone misuses their product is that they have a legal precedent to do so (Brady Campaign v Bushmaster, 2003).

After all, first the manufacturer of the deadly product and the credit card processor that swiped the card on their merchant terminal should be held equally liable as well, right?

While we’re at it we should just add Gregg the UPS driver to that list of defendants since he’s the one that physically brought those instruments of death into our perfect little world.

As James Trafficant would say – Beam me up.

What actually occurs in the real world is we are severely limited in terms of selection in finding a credit card merchant processor that fits the needs of the firearm retailer. Lets review some of the more visible and notorious payment providers, shall we?

  • Square
  • Google Checkout (Google is shutting this down, effective November 20, 2013)
  • Paypal – No firearms or related materials
  • Pay Anywhere / Intuit – face to face card present sales only
  • First Data – face to face card present sales only
  • Nova/Elavon – I did not get a call returned from them on this subject, so we’ll chalk that up as a no
  • GunPal

You get the picture. There’s a handful of providers that service the firearm business, all that know they charge more and that consumers have to pay it. I don’t like having such few options but I’m not being given much of a viable choice in the matter and it is what it is. I’ve learned to stop worrying and love the bomb. Speaking of financing terrorist activities…

I’ve recently identified a major contributing factor to the war on guns, and that factor is a three letter acronym called AML. For those who don’t work in the financial industry, that stands for ANTI MONEY LAUNDERING. 

Very recently, I received a certified letter from a law firm. There’s only two things that come in certified letters from law firms – checks and bad news. It was bad news.

The letter that I got used extremely vague boilerplate language and terms such as “extra ordinary transactions” and “additional risk assessment” and my personal favorite phrase “termination of checking account privileges within 5 business days” – which is a great thing to be reading when you have $40,000 in auto drafts to Chase, American Express, EFT’s to pay vendors and $200 checks to BATFE for customer tax stamps, not to mention customer refunds, consignment distributions and the like.

What was interesting about this was a lack of due process and a lack of recourse. The letter wasn’t along the lines of a “Please contact us there’s a problem” so much as it was a “We have a problem and it’s you, get out”. So much for common courtesy.

I got this letter on a Monday afternoon after all the branches had closed and they informed me they were terminating my account the following Monday. Not knowing if this was a freeze or a closure or what it was, the bottom line is that this throws a major wrench into my business operations on a number of fronts, the most immediate being a lack of a way to bring in money and a lack of a way to pay vendors and other parties that extend credit. The secondary concern being that when vendors look at a customer’s credit profile, they perform what is called a verification of deposit with their financial institution to look at overdraft activity, average balance, transaction history, account length and other metrics. They do this to see if you are bouncing checks and dealing in good faith.

Over the many years I have been in business, my vendors get paid on time. Without exception. That’s why we get along so well, that’s why I get allocations from some of my best reps, and don’t let anyone else tell you – money is what makes the world go round. Distributors love accounts that pay on time, and getting a KSG or a PMR30 on allocation is one very big incentive we have to keep the vendors happy.

My Tuesday just had a new action item: Find out what’s going wrong and get it fixed. Little did I know I was about to enter a world of pain. I spent the evening reviewing accounts looking for discrepancies and account closure protocols from the Office of Thrift Supervision on my iPad until I passed out on the couch.

Waking up and rubbing my eyes, I realized that I had overslept my alarm. I had slept about 2 hours and I had a feeling I’d have a big day ahead of me. My first stop was visiting my favorite branch and talking to one of the gals I know there. She greeted me with an unenthusiastic guttural sound as she had gotten the memo that my business was no longer welcome at the firm. I asked her to print out everything that I had signed in terms of terms of service, fee schedules, signature cards… if it has my signature, I want a copy of all if it. She fired up her printer, ran off 9 pages, stapled it and handed it to me. I asked her if that was everything she had on my account. She said yes. I asked her if anyone would be able to help me in the branch. She said no, her corporate office instructed her not to talk about it and that I would have to speak to their lawyers as they would be the sole point of contact.

I folded the sheaf of paper into my briefcase and left for my office. Stuck at a read light, I skimmed the packet she had handed me. 9 pages? For a business account? They were not duplex printed so it seemed exceptionally light to me. My voice mail had indicated a call from a different branch from yesterday that I had not listened to that I decided to put on the speaker. One of the managers wanted to speak to me. I decided to skip the office and head straight to see the branch manager. A Facebook message came in from a buddy of mine who went to elementary school with me who works at the same organization and he told me I would have to resolve it on the branch level before escalating it. I told him I was on my way as I walked into the managers office, parked my butt in the guest chair and set my iPhone to shuffle.

As I was serenaded with the dulcet tones of The Waiting by Tom Petty and The Heartbreakers, I questioned if Skynet is alive, well and self aware in the form of Siri. That’s a thought that’s going to fester.

Five minutes later the branch manager walks in stating that there’s a problem with my account, I cut her short and show her the letter I got. I ask her if there’s any way to resolve this in house. She says no, she was instructed to direct me to their legal team and they would be the only ones capable of discussing the issue. Having nothing to lose, I ask her to call them. She hands me the phone and I realize how awkwardly short the cord is as she tries to write email and get work done while I’m on the phone waiting for Godot. The law firm asks who I am and if I can hold. After 15 minutes the receptionist said that the only attorney in the office designated to speak about this issue had appointments until 2PM.

Me: Does he have anyone scheduled after the 2PM?

Receptionist: No

Me: He does now. I’ll be there at 3. Okay?

Receptionist: Okay…….

The tone of her voice led me to believe she was scheduling me at 3PM and the local police at 3:01. I hung up the phone and the branch manager asked me if I needed anything else. Feeling like I was missing something, I asked her the same question I had asked the gal at the other branch – if she could print out everything they had on file for my business account. Looking at me for a moment with trepidation, she reached for the phone and called her legal department to see if she could give me everything they had in the file. Legal gave her the all clear, so she proceeded to print EVERYTHING on my account. This sheaf of papers was substantially thicker than the first batch I had received.

I realized that she had either stumbled upon a separate file on my business and was willing to share it with me and the other branch was not – or the other branch simply did not recognize my request when I asked for EVERYTHING on my account. Whatever the truth may be is not germane to the discussion, except I learned a number of critical things from my visit to the second branch that I’ll get into later. I reviewed the packet with the branch manager noting a number of discrepancies, the most glaring being that my name is now apparently Juan Suarez and my email address is a real estate agency in El Paso, Texas. I asked her what that was about and she had no idea how that got mixed up. Before I left, I made sure she knew how much of a pain in the butt this was going to create for me as I went to work.

Oddly enough, it took me only 10 minutes at my desk reviewing all the paperwork that I realized that there was still not enough fine print that I had been given. Financial institutions create fine print by the truckload, and there was an alarming lack of it. There’s no way to phrase it without making it sound like an accusation but I had a feeling there was a distinct lack of transparency occurring.

My Saddleback briefcase had decided that two adventures would not be enough fun for the day as I drove back over to talk to the branch manager. She was on the phone and after a short wait I asked her what I was missing here since there was an alarming lack of fine print. I got a guarded look as she once again hit CTRL-P and ran off a 14 page wall of text. As I was handed this wall of text, I realized that the third time was in fact the charm. Transparency and getting it right the first time was not on my side today.

Running on Empty is a great Jackson Browne song but a terrible way to start your day so I had lunch and I stopped by the corporate office to visit the buddy of mine I went to elementary school with to see if there was any way he could help me. He was not at his desk and the receptionist basically told me that the branch manager at my local branch would be able to help me with everything. I tried to explain to her that there was no way that I was getting any kind of resolution. She handed me a phone and dialed a branch manager who put me on hold. After a short wait in the branch manager’s office, I was informed that the decision to terminate the account was made by the legal counsel because there was something funny going on and they had to file a Suspicious Activity Report (SAR) on me. He went on to state that the financial institution had nothing to do with the decision and I would have to talk to the lawyer that sent the letter.

When the most consistent thing in your day is people telling you to call their lawyer – you’re having a pretty bad day.

It was nearing 3PM so I drove to the law firm of Dewey, Cheatem and Howe. That’s not their real name, but this is by far the worst law firm I have ever dealt with on the face of the planet. This is one of those law firms where the name partners must have graduated from Cooley or Peoples (the one in L.A. not the good one in Houston), it was that awful. If my previous statement sounded condescending then my sentiment carried perfectly. I arrived and told the receptionist that I was a 3PM. She informed me that he was still in with his 2PM and to have a seat.

Thirty minutes later I was informed that he had no 3PM appointment, he had left for the day, and there would be nobody at the firm that I would be able to discuss the matter with. As I am hearing this from the receptionist/office manager I’m getting a Facebook message from my guy at the corporate office telling me “Go call the lawyer, they’re the only ones that can talk about it and they’ll be able to help you” sending me into a level of range only Don Draper could achieve, complete with throbbing vein in forehead.

Since that was quite the long read, lets recap our events.

1. The certified letter I was sent indicates the law firm is the point of contact for the account termination.

2. Every branch manager, the corporate office, and my man in Havana indicates the law firm is the point of contact for the account termination and is the sole communication point.

3. One branch manager indicates that the decision to terminate the account was not made within the financial institution and that it would have to be discussed at the level of the law firm.

4. A representative of the law firm indicates that they had nothing to do with the process, they were following orders from their client to terminate the account and that the issue is not up for discussion, debate, or appeal.

5. A representative of the law firm indicates that the lawyer that wrote the termination letter has left for the day, even after I telephoned them 4 hours in advance to let them know I wanted this issue discussed and that I was in the lobby.

Clear as mud? Good. Either the law firm has decided that they’re going to selectively represent the client when they sent the notice of account termination and not represent them when someone actually calls them out on it or the client has instructed their legal representation to stonewall everyone. Some would call that a failure to communicate. I view it as someone dealing in bad faith, grounds for a complaint to the state bar association, or a combination of both.

(My good friend Steve made a joke about this and I laughed so if anyone is wondering, the financial institution in question IS NOT BANK OF AMERICA. Along those lines, I will not respond in kind and will leave our financial services provider nameless and not drag their name through the mud.)

Meeting the Socratic wonder that is a middle aged woman in her 40’s that has decided she’s not taking any shit from people like me is always entertaining, albeit challenging. I argued with her over how ridiculous this idiotic round robin was and she was not about to give up any ground. The unstoppable force had met the immovable object. Finally, a young woman who was a paralegal of some kind offered to intervene. I like to think she felt pity for her boss, but she sat down with me and was willing to discuss the issues I had. Dialing it back a notch was difficult but the woman said that she’s just a legal assistant and I didn’t want to run roughshod on someone who didn’t deserve it.

The first thing I brought up was the lack of transparency. There was no reason or foundation for my account closure. She pointed out some flaws in my account structure and was able to say a few things without saying a few things. Basically, there’s a zero tolerance policy for structuring deposits and money laundering. Apparently my business account seems to have caught one or both of those somehow.

Extending her the transparency that was not extended to me by letting her look at the books led to a discovery. When my account was opened, I was not properly classified as a firearm enterprise. This is not weeks or months ago but years ago. According to her not a law school graduate opinion, the fact that I was running a firearm business without calling it a firearm business means that every dollar that my business brought in from account inception is considered laundered money and kind of a big deal, what with all the terrorism and meth labs floating around. There’s only one sticking  point (actually, several) with that. .

Remember when I told you about the hunt for fine print and the second trip back to see the branch manager? Not just a pretty face, she had given me the proverbial smoking gun.

When my account was first opened several years ago, they got a copy of the IRS Employer Identification Number statement that has MANUFACTURING FIREARM in big bold Helvetica like print. This had been apparently overlooked. When I registered my trade name with the state division of corporations, and I disclosed the trade name to them a week after the account opened. This too had been apparently overlooked. Last year when I added my brother as a signatory to the account, they asked me how business was and if we needed to make any updates to the account – and they printed the “About Us” section of my website and my company Facebook page and added it to the file. This too had been apparently overlooked as well as my apparent name change to Juan Suarez, REMAX Top Producer 2012 and general delivery email box.

So, they’re claiming I didn’t disclose my firearm business to them which means I laundered money, when in actuality the documentation and disclosure of my firearm business has been there since account inception. The paralegal seemed to think I was a pretty honest guy and after making a scene with her boss and explaining this to her, she offered me a cold beverage and said she’d review this with the client tomorrow. I made an offer of Status Quo Ante – I got the idea from an old Tom Clancy novel, and I think that would be the path of least resistance in dealing with this massive quantity of mierda de toro. However, it did lead me to a number of surprisingly valid conspiracy theories.

  1. They are grossly incompetent and trying to blame me for their failures to adequately document customer disclosures.
  2. They do not like guns very much and are trying to find a way out of all firearm related businesses, so they are strategically eliminating them via Anti Money Laundering initiatives.
  3. I’m more profitable dead than alive. I suspect they’ve taken out a life insurance policy on me and are trying to get my blood pressure so high I have a stroke, AMI or some other type of fatal stress related injury.

If #3 is their real plan, I hate to say it but it is working.

After doing some basic research via the FINCEN website, it yields that a few interesting things. For starters.

This particular organization seems to be pretty vigilant in fighting money laundering, which is understandable. What I don’t get is that disclosing the existence of a SAR is in fact a federal criminal offense. So, they’re all about enforcing one law but not really enforcing another? That’s one interesting pick and choose.

Want to know the really interesting part? By telling me that they have a SAR open on me, they’ve broken federal law. If I tell someone else in the same organization that I know they opened a SAR on me, they will probably open a SAR on me. No, this is not a recursive joke. According to the manual I discuss below, you can have a vicious SAR circle where discussing the unlawful disclosure requires mandatory reporting which may lead to additional unlawful disclosures and mandatory reporting et al.

We live in one fucked up society sometimes.

According to the Bank Secrecy Act/Anti-Money Laundering Examination Manual – almost everything a firearm business does, is considered some sort of money laundering or structuring. The bar is set so low that even the flimsiest generic things will trip a red flag. For example. 30 Sig 226 Elite Dark pistols come in. The dealer sells 2 of them a day for 15 days and the credit card company or cash deposit or whatever deposits to the account and at the end of the month, the dealer pays Sig with a wire transfer or a check.

That example – would constitute a satisfactory example of structuring or laundering.

I guess that’s my long-ass way of saying that, for gun dealers, the financial side of the business sucks from start to finish. The system is setup to make the process of handing guns to legal owners as difficult as possible, and getting paid for that trouble even more so. And thanks to the AML laws, if a bank decided to start “cracking down” on firearms businesses they have a a perfectly legal way of making their lives a living hell without one single recourse.

Oh, and when they terminate your account – good luck getting credit at vendors now. Vendors look at three things: duration of checking account, overdrafts, volume of deposits vs drafts and average daily balance. Your business credit history is effectively deleted.

Biggie was right. Mo Money Mo Problems.

91 Responses to The War on Guns: Are AML Regs the New GCA?

  1. I was considering opening a side business as a gunsmith. not even a home-based business, but this kinda makes me leery of getting my FFL.
    I know it’s not the same, but what if banks stop wanting to deal with people who work FOR fire-arm related businesses?

    • Mike, it’s a slippery slope. That’s the only thing I learned is a constant after all these years.

    • Agreed. Thanks for the insights. My sympathies for your troubles, but I’m glad people like you can somehow put up with it and go on. Best of luck.

    • I’d like to see more – the guy writes well, and it’s always interesting to get a peek behind the curtains.

      • I disagree. He doesn’t write well; he writes magnificently! I got a headache from it, but it’s the most enlightening and interesting headache of my life. Thanks so much for filling me in. Personally, I look forward to every word. The dude can WRITE.

        As for your mention of your law firm: “It was nearing 3PM so I drove to the law firm of Dewey, Cheatem and Howe. That’s not their real name,

        May I suggest my own corpse-grinding lawyers, CRONY DEAL BURNHAM AND STEELE?

  2. Greasy fingers, stupid questions, the ‘trouble’ of the sales process. I understand your pain, but in this and your other posts I don’t like seeing the disdain that you have for your customers. Retail would be great if it wasn’t for the customers, right? Well… most of the people on TTAG reading these posts are gun shop customers, not businesses/owners. It might suit you better to scale back on your open resentment of the people who are responsible for keeping you in business.

    • Open resentment of people who point guns at you all day long is understandable. Especially when they act like all prices are negotiable.

      • I get treated like border-line shit in just about every gun store I’ve been to. I know it’s a difficult environment for the business owner and sales associates so I bend over backwards being polite. It doesn’t help.

        Solution? Buy from Buds and transfer everything at a friend who runs a teeny tiny FFL out of his home.

        I don’t know what the answer to all of this is.

  3. I had a line of credit with Portland Teachers Credit Union here in Oregon. They cancelled my line due to being an FFL dealer.
    They are now known as Onpoint Credit Union.
    I started doing cash only after that.

    • Interesting. I have my personal and business accounts with OnPoint. I’ve been really happy with them vs. commercial banks (they’re not completely sleazy money grubbers), but I’ll keep their anti-gun bias in mind.

  4. Very fascinating read. Yoou know, you could make up a pretty good conspiracy theory by “connecting the dots” with the following facts. The investment banks and Wall Street are heavily populated with anti-gun democrats. The big banks are cracking down/refusing to lend to gun businesses. Meanwhile, these same banks, having determined that the derivatives market for mortgages is fraught with risk of being sued for fraud, are now moving into the commodities market, lead initially by Goldman Sachs and Bank of America and HSBC. Conclusion: the banks are trying to control the economies of the western world; and if they get caught, they want to make damned sure that the hoi polio aren’t armed!

    • +1 accept that many of those big name bankers aren’t Democrats or Republicans. They hold no allegiance to either party… it’s puppets within both parties that owe them their allegiance via big $$$ campaign donations.

      Their God, president, and political mantra is “more mammon… FOR ME.”

  5. Wow. I knew most shops were being by financial institutions but I never
    considered how AML would be folded into the mix. For what you wrote
    it seems that the institution in question is not blameless, so you might
    have a chance. However. the cynic in me says that the feds would back
    the law firm to the hilt rather than take a chance of admitting that AML
    might have unintended consequences or worse is being pushed to
    ensnare lawful dealers.

    On a lighter note, maybe you should go to FNH and talk them into using
    “chicks dig SCARS” in a marketing campaign. Maybe they’ll cut you a deal.

  6. It’s your friendly corporate banker here! Nine years experience dealing with small- to med-size businesses and their banking-related needs.

    First, yes, you are right. Banks are very difficult to deal with. If you don’t have a designated banker that CARES, you’re in trouble. And those “Bankers that care” don’t come cheap. This isn’t just for gun-related industries, but ALL industries. Your relationship with your banker will help you in times like this. You and your banker should be reviewing ALL of your paperwork that the bank has on file at LEAST once a year. Mistakes are made, terms expire, and policies change.

    Second, find a bank that wants to work with you. There ARE banks that are not hesitant to have customers that are in the firearms industry. Actually, having a gun-store customer is easy compared to other challenging (but legal) businesses (medicinal marijuana retailers, check-cashing stores, etc).

    I had the luxury of being able to pick my customers. Give your (new) bank a reason to want to do business with you. Are you well capitalized? Do you have significant collateral? Show how low-risk your business is, besides a good credit score. If you’re not well capitalized and collateralized, refer back to “‘Bankers that care’ don’t come cheap”. It’s going to cost you in fees, interest, and time.

    Third, lawyer-up. Banks typically have 2 legal teams. One team is the fodder, the grunts that you were dealing with in this article. They send out the boilerplate, council HR, draft the pages of fine-print, etc. There there is the A-team. These high-priced lawyers get the bank out of sticky situations when they’ve made a mistake. Having your lawyer send a letter explaining the situation and (all) the documentation you’ve uncovered will put a halt to your account closures, at least until the issues are sorted out. In the meantime, you can be reviewing your account documents with your “Banker that cares” and your lawyer.

    But wait! The banker is part of the bank, and the bank is against you, right? NO! Good bankers cater to their customers, especially when disasters like this happen. They stay late, conference with customers and lawyers, find and fix the mistakes. That why “Bankers that care don’t come cheap…”

    Fourth, the banking industry painted itself into a corner over the past 20 years by offering everything for free. Free merchant deposits, free checking accounts, free overdraft, free checks, free notary, free… Truth is, this business model can’t be supported in ANY industry! Staff and supplies cost money, but the public is now conditioned to receiving it for free. On the flip side, it doesn’t do a bank any good to nickle-and-dime their customers to death. I don’t want to lose customers because they paid too much for the services at the bank. Review the fee structure when you sit down with your banker on an annual basis.

    Fifth, and finally, the banking industry has gone through the bowels of hell and is sitting in a toilet right now. The collapse of the banking industry over the past 10 years has resulted in more regulatory hurdles than one can imagine. Federal, state, and local laws have been passed so quickly trying to “regulate” banks that they oftentimes conflict one another. The “experts” on the regulations are paid more than the “A-team” lawyers, and even then they don’t guarantee their answers. Gun laws are a cakewalk compared to the banking hurdles. And if there’s ever a question about the feasibility of an account, it’s easiest to close it rather than address the issues.

    Find a bank that wants to do business with you and your industry. Give them a reason to do business with you. Work with the best banker you can find, and treat them better than you want to be treated. Because good help is hard to find, and “Bankers that care…”

    • B-money is right, I to am a banker with 16 years experience.I would like to add that there is no way a SAR (Suspicious Activity Report) should have been filed unless you were purposely structuring your deposits to avoid a CTR (Currency Transaction Report). A CTR is filed for cash transaction over $10,000. Or if you start doing transactions that are outside of the normal transactions that a firearms retailer would be expected to do. Every retail business brings in cash to deposit and then makes large payments to suppliers. Money laundering is the attempt to make cash earned in illegal means look legitimate. There is no way that your transactions would not seam normal to a reasonable Banker. If you choose to move banks start a relationship with your banker and Branch Manager. Invite them to come see your store and tell them how you operate your business. A good banker will want to know how much of your business is cash, credit card or check. If you give a discount for cash, let your banker know that most of your customers pay cash because of the discount you give and that you will be depositing a lot a cash. Don’t be afraid of depositing over $10,000 in cash. A CTR is no big deal if your business is legitimate. As a Banker I hate to see these kind of things happen but at some of the big banks they really don’t care, find a small community bank to bank at the specializes in small business they will be easier to work with. I wish you the best and good luck.

    • Spare me the whining about how tough it is to be a banker. You have fractional reserve lending, usury, to fleece your customers with so I don’t want to hear any crying about how giving away “free” stuff is hurting your bottom line. The banking industry has gone through the bowels of hell? Please! I haven’t seen one single bank executive arrested, let alone put in jail, for the mess they created over the last ten years. Fraudulent loans, fraudulent foreclosures, robo signing, fleecing customers, the list goes on and on. You won’t get ANY sympathy from me, as far as I am concerned, you are a large part of the problem.

  7. This is certainly an interesting insight into “the gun biz.” it’s a wonder how so many gun shops manage to stay in business under the circumstances. As an FFL licensee for 32 years (“Firearms expert/consultant), I haven’t yet run into any problems, but who knows what tomorrow may bring. Under the current administration, I wouldn’t say anything isn’t possible.

  8. Well that was a fascinating read … but also horrifying.

    Thanks for posting this. I’ll make sure to have a drink before I start reading the next one.

  9. After reading this I’ll make sure to purchase all my future firearms with cash; I don’t think anyone should have to deal with that crap.

  10. Very fascinating! I kept waiting for a same person to step in and make it right, but they never came. Here’s hoping they do in part 2.

    And I second the idea of paying in cash. I’d much rather my $$ go to my FFL than his card processor.

  11. I feel kind of bad about haggling gun prices down after reading this.

    I’d really like to consider the business of manufacturing ammo, but I live in CA. It’s really a shame that CA hates businesses, hates guns, and hates people who make a positive contribution to society.

    I fear that additional regulation and antagonism towards the gun industry will destroy the small businesses first, and then the corporate giants. It could soon be that the only businesses that can make a profit are those who are awarded government contracts. It goes without saying that those businesses will only get government contracts if they support civilian disarmament.

    • I never haggle with my regular LGS. They have reasonable prices. Yes I can get it a little cheaper online but I respect their trying to be fair on their prices and they keep a good stock of things I can check out before I buy.

      There is another LGS that clearly tries to make a killing on every opportunity. They almost always have what you want in stock but that is because they are so overpriced. I have tried to talk them down to a reasonable price but they won’t budge.

      I have spent many thousands of dollars just this year at the regular LGS and zero at the other one. If your LGS is treating you fairly and pricing reasonably I don’t think you should have to haggle.

      • I’ll always haggle if it is a used gun that I know they paid almost nothing for. For example, I know that for used or trade-in Glocks, XDs, or M&P 9mms, the most my LGS will pay or trade is $300 (usually less), so when I see one in the used case for $500, I’ll offer to meet them in the middle. They’ve never said no. YMMV. It doesn’t hurt that I’ve known the owner for 15 years.

        If it is a new gun,I am aware of how small their margins are (~3-5%) and understand that the price is take it or leave it.

  12. You didn’t explain how things are resolved and whether the legal assistant was cute.

    Bonus points on the Cooley reference. Anyhow – as an inhouse lawyer for a defense contractor who deals w the feds all of the time for work, yep, it is frustrating. I think you may have several legal causes of action against the bank and maybe the bank’s lawyers. But it helps w you having a lawyer to dig them a new ass hole. And good lawyers don’t come cheap, but many of us like guns and deals when helping buddies out of jams. i would really consider all my options even filing suit. just because there is a law does not permit the bank and others to run over due process and if you have done nothing wrong (as in suddenly become mexican in Texas sending stuff over the border), banks don’t want bad press from a civil suit that gets leaked to the press. think how jesse jackson or al sharpton make companies pay blood money just to go away. same thing, even with icky guns. and if you think the antimoney laundering regs are bad, try exporting a weapons system to the Middle East . . . I would also contact your local/supportive federal politican (you do donate regularly to them, right??). amazing how a politician on a key committee will give a bank fits that there are other low hanging fruits to pick if a congress person starts calling. also, if you are not chummy with the local judges and prosecutors, make sure your lawyer is. It helps for the benefit of the doubt. it sucks but that is the system. I actually budget my political donations and bar function activities even though I know it is just to get a call returned just in case.

      • let me know if you need lawyer recs/general advice (I may not be licensed in your state to help you specifically). Farago and Zimmerman have my contact email/info

  13. This is a hall of fame post. I’ll never bitch about prices at a small gun store again. (well almost) I hope he gets treated better by his ammo suppliers.

  14. If you can’t legislate, then regulate. This is happening all over America in banks and thrifts, from the FDIC, IRS, and DOJ. The current administration can’t pass the laws so they are regulating firearms, lenders, and conservative groups into submission. It’s not an accident or coincidence. It’s the political reality. When the abuse is finally brought to the light of day and exposed you get nowhere due to executive privilege, pleading the 5th, and hidden email correspondence. We have secret courts where hand-picked judges rubber stamp requests the clearly violate the 5th amendment.

  15. My FFL, who discounts aggressively, offers 2% off for cash-check-debit card. I’ve never bought anything from him with a credit card and I never will.

    So I get a great price, a discount above the great price, and super service from a polite and well-trained staff. The store gets my loyalty and the loyalty of a lot of other customers who feel as I do. It’s a good deal all around, which is probably how he became the busiest dealer in MA.

  16. After reading this, if dealing with payment is as costly in time and money as this article implies, I think if I ran a firearm store I might just get an ATM and make my business cash only. Or I might grant a 2-5% discount for paying with cash, pointing to the ATM in the room as I tell my customers about it, and in doing so minimize my dealings with credit agencies and processors and banks.

  17. Not to sound like a cynic, but I suspect that bureaucracies were created solely to cover up and protect a self-administered lack of standards, incompetence, or anything resembling personal responsibility. Decisions are made, actions are taken, but nobody can be held personally accountable. Oops, we misplaced 30 million dollars in customers funds, but amazingly, nobody is going to Club Fed. So sorry, but our mistake caused you to lose your business and credit rating, but you have no legal recourse available to seek a redress of this situation, have a nice day.

    There is a profoundly disturbing problem afoot here. Of all the businesses one can legally engage in, the firearms business is the only one that has its existence backed up by a constitutional amendment. From the right to keep and bear arms, is the explicit right to manufacture and sell arms. Tragically, if not ironically, the responsibility road is a one-way dead end street that leads to a bureaucracy that does everything under the sun and moon to prevent anyone from exercising that Constitutionally protected right. Such a bureaucracy must, by default, if it wishes to continue, has to be against the right to keep and bear arms, or anything to that furtherance. This is exactly why our founding fathers were afraid of a government that could grow too big for its britches. Its very existence is anathema to a constitutional republic. Wherever accountability is absent, tyranny reigns. The regulatory system is the bureaucratic enforcer of that tyranny. This is just the first installment?
    I feel like I need a stiff drink.

  18. Very interesting read! I know you’ve been contributing for a few months now, and I hope to read more about your experiences as a LGS owner/operator.

    I hope you can find a way to continue to do good business in this ever-expanding mess we call an economy.

  19. Very interesting read. Please continue with more.

    I had been considering expanding my local training business to include an FFL/firearm sales. After reading this, I’m about ready to say “forget it” forever. Not going to happen.

  20. As a bank computer programmer who must pass yearly anti-money laundering training as a condition of employment, I’ll say that almost any small business *could* fall under federal AML guidelines. However, those are largely for describing behavior in consumer accounts. Small businesses need a more judicious approach. The other part of the guidelines is Know Your Customer. The idea is that different customers will necessarily have different behavior patterns. You should know them well enough to know if something actually isn’t right.

    FYI: as near as I can tell (personal opinion here) SARs go down the memory hole until/unless they get picked up in the process of researching you.

    Still, that stuff about the name change to some realtor makes me wonder if someone was trying to fraudulently take over your business account. Watch the paperwork and your last several statements with an eye for anything unusual… or incorrectly done.

    • Having seen identity theft in action, the extraneous name added to FC’s business account got my antenna buzzing too. Clerical error, or attempt to defraud; the weasels are everywhere.

      This is probably the most intriguing and revealing post I’ve read on TTAG. Like an intensely riveting book, I was transfixed and fully focused all the way through, including all the comments that followed, in particularly those of the bankers.

      I am looking forward to “the rest of the story”.

  21. By the way, FC, if you decide the FA biz is too much of a hassle, I think you could get hired as a writer somewhere, I really do. Print out all your stuff and take it around; avoid effing ad agencies.

    • I can only echo William Burke’s sentiments. FirearmConcierge, please please please continue posting. Your ‘in the trenches’ experience of life on the other side of the counter is eye-opening (especially to those of us who occasionally daydream about getting an FFL and opening a store someday), and your narrative style is absolutely superb. This long form writing really captured your frustration and stalwart resolve, and I think I’d be just as engrossed reading your experiences with replacing an alternator on your car or completing a home DIY project as your interactions with the messy world of finance. In fact, while your snark is much more subdued (though evidently restrained), you remind me of another beleaguered proprietor, the Gord: (http://www.actsofgord.com/Justice/chapter09.php for an example of his daily tribulations)

  22. For those of you interested in reading more of FC’s rants and raves about everything from retarded customers to wanting to scream at ATF agents, head over to reddit.com/r/guns.

    He and other dealers prowl around on the subreddit and the stories are something to behold.

    More power to you FC and I hope this shit gets worked out.

    • A,

      many thanks on the heads up on the reddit link. These sorts of stories are interesting and very eye opening for those us who just want to put our mitt’s on the goods.

  23. My Son and I are just getting started in building an indoor Range. We currently have a small gun shop but after reading this, I’m a bit discouraged. Our ace in the hole may be the bank President we will be partnering with.
    Plus, we are in rural Iowa so most business is done with friends.

  24. This was an interesting read, the more so because it was not about Government regulation per se, but about the behavior of private banks and their lawyers, discriminating against a certain “class” of people. Ahem. Cough, cough.

    I’m sure all the big banks are thrilled to do business with “security” contractors and private intelligence firms.

    • A Poet Loreate from the Urban Arena who waxed on the trials and tribulations of his people. Considered by many to be a prophet and leader for the multitude of young, urban utes, his lyrical ways (heh) often dealt with the danger filled and risky nature of the lifestyle of his intended audience. He spoke at great lengths about the pursuit of monetary success and the troubles of such, the use of various and sundry substances to free the mind and body of stress, and many tulmotuous relationships with females of ill repute. He was also quite fond of being called “Big Pappa.”

  25. Excellent read!

    I really foresee a day when we will be paying for firearms with silver eagles (or gold).

    TPTB are using administrative agencies to slowly shut down firearms businesses.

  26. 1) Have you considered starting a small credit union who only does business with firearms companies?
    2) Have you considered starting a courier business that is firearm friendly?

    It sounds like you have a unique amount of knowledge that would be very useful (and profitable).

  27. I work in the financial industry, and I ahve to deal with AML policies every day. I understand the need for the regs, but when all I am trying to do is send out a check for a 90 year old great grandmother to give to her great grandchild for their birthday, it is a complete headache. It reminds me of a recent Dilbert where he tells a coworker needing a client signature “let me go get my time machine so I can go back to a time where getting a clien’t signature actually made sense”

    So as someone in the financial industry, I feel your pain. As someone wanting to get an FFL and set up an actual business for sales, putting together ARs for lazy people, and machining a few supressor designs I think might change the market a little bit, I have to ask – is it really worth it?

  28. As a former (name redacted) banker, I can firsthand attest to big corporate banks hatred of firearms. Anyone in a gun related business was not allowed to open an account at the branch, had to go through corporate. Also we did put aml restrictions on a certain large firearm retailer. Large banks are not your friend!

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  44. This is a corridor of acclaim post. I’ll never bitch about costs at a little weapon store again. (well practically) I trust he shows signs of improvement by his ammunition providers.

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