The folks at Dead Air Armament, Gemtech and Silencer Shop have gotten together with ATF to create a Form 4 generator. The process automates some of the data entry involved with ATF processing forms. Makes sense right? Automating the regulatory process should make the government more efficient. Pundits are prognosticating processing times will drop. Yes, well . . .
First, know this: the firearm industry is a victim of its own success. Thanks to ATF rule 41F — removing the requirement for a CLEO to sign their forms (click here for an explanation) — the amount of ATF Form 4 paperwork generated for silencers, short-barreled firearms, etc. is unprecedented.
The ATF’s new bar coded data system is supposed to make things a lot faster by shifting some of the paperwork burden from the government’s side to the industry’s side.
Naturally, when word of this new technology broke, my inbox flooded with requests from customers to have their previously printed form 4‘s and not-yet-submitted paperwork redone with bar codes. So I loaded up the website with the form generator and started poking around.
My first impression: it’s a good idea. As I dug into it, though, I’ve concluded that it’s not my friend. For starters, one of the disclaimers is:
ATF Form 4 generation is a complimentary service of Silencer Shop.
Silencer Shop does not store, review, or validate any information entered on this site.
By clicking the Generate Form 4 button you accept responsibility for the accuracy and validity of the information entered.
The Silencer Shop has data on many manufacturers’ products and can populate them to prevent incorrect data entry. However, because we aren’t using “previously known good” information – there’s always the risk of garbage in, garbage out.
The first thing I learned: Your FFL can still screw up your forms, but this way it will happen faster. Bad data is still bad data.
So, I have several customers who want a Form 4 with a bar code. They already have responsible party forms printed up. I loaded all their information. After triple-checking all the data — because there is no way to validate the typed-in data with a known good data set — I was about 20 minutes into filling-out one set of forms. Not counting the 30 minutes it takes to duplex them off a printer.
I tried to generate the form and . . . got an error. It wouldn’t print the form because I hadn’t listed any responsible parties for the responsible party forms. The website says Form 4 generator not ATF Form 5320.23 generator. I don’t want a responsible party form. I want a Form 4.
The second thing I learned: You can’t just print a Form 4 with a bar code.
But I’d gotten that far, and some new system hiccups were to be expected. So I loaded up all the responsible parties and chased down all the CLEO’s in their respective areas (since all three of them live in different states and localities). Once again, I tried to print the forms. They still wouldn’t print. The data on the responsible party questionnaire was missing.
Wait a minute. I’m the FFL. I have the item. I have the onus of doing the forms correctly. Not only am I supposed to populate all the fields manually — each time, every time — but now I’m supposed to electronically pencil whip your forms for you?
The third thing I learned: This is going to cost me money.
As it stands, the new Form 4 bar code generating system is more time-consuming to complete than the old purely paper system. If the fellow with three responsible parties in three different states has all his data together and I have to basically be a form 5320.23 secretary, it’s going to take me an hour to generate ATF form 4‘s on each purchase.
Time is money.
Before this bar code bonanza, I discounted an item and then factored in 20 minutes to bang out a paper form 4 (pre 41F). Now, when I tell customers who want the Form 4 sent to the ATF electronically that I want more money because it takes more time, people looked at me like I have brain damage.
Long story short, with this new process the industry is going to spend more time on your form so you don’t have to spend more time waiting for your stuff. But don’t expect FFL’s to welcome the new system, at least as it currently stands.
[Editor’s note] TTAG spoke with Silencer Shop and they did have feedback on Firearm Concierge’s observations. Summarized (not quoted) as follows:
• Exactly like completing a Form 4 via any other means, if the data entered by the FFL is incorrect then it’s incorrect. This Form 4 generator system is designed to eliminate data entry errors on the ATF side (and save them significant time), but cannot do all of that on the original input side. However, the F4 generator does prevent the top three errors the ATF finds in Form 4s: it prevents FFL info from being inputted incorrectly, it force matches Form 4 names to 5320.23 names, and it ensures pre-41F forms aren’t used. It should take no longer than writing or inputting the necessary data into the Form 4 fields via any other means. Sending the completed forms to one’s printer should be near instant. Physical printer speeds vary.
• The 5320.23 is a part of the Form 4 process since the implementation of 41F. While the 5320.23 responsibility could be pushed onto the customer, it’s better and more efficiently handled by the FFL to ensure proper firearm and law enforcement information entry plus correct formatting and the mandatory matching of Form 4 info to 5320.23 info. When the ATF scans one of these new barcodes, all of the Form 4 and 5320.23 information for all responsible parties is automatically ingested into the ATF system. The efficiency gained by avoiding manual data entry of 5320.23 information for all parties is crucial to driving down approval times. Again, whether the FFL fills out these fields in Silencer Shop’s online form generator or via pen and paper or in an ATF PDF file, they’re the same fields and the same inputs and the time spent should be similar (if not fastest in Silencer Shop’s software).
• Silencer Shop will fill out, create, and submit all necessary paperwork (Form 4s including 5320.23, and more) for any item a Powered by Silencer Shop dealer sells. Becoming a Powered By dealer is simple and there is no charge: www.silencershop.com/dealer-purchase-programs
• Generating a barcoded form is entirely optional. It’s also free, and it helps avoid the top three errors the ATF sees in submitted forms. Additionally, it will help the ATF allocate resources in a way that will speed up approvals.