An FFL of our acquaintance recently had an out-of-schedule compliance inspection. The FFL would sooner be boiled in oil than quoted by name making these comments of his or her Federal regulator, so information that will narrow it down among the many, many dealers we, uh, deal with, no pun intended, will not be forthcoming.
We will, however, share these insights.
- “The IOI did not seem at all familiar with firearms. Seemed to be new and ill-trained.”
- “The IOI made disparaging remarks about our customers, especially customers who buy ‘assault weapons,’ customers who use non-stocking ‘kitchen table’ dealers,” and customers who buy multiple ARs or multiple lower receivers — once I explained what a lower receiver was.”
- “IOI said, ‘Only reason for these multiple buys is dealing without a license,’ and ‘We’re going to crack down on those guys.'”
- IOI copied all multiple-long-gun-buy information from the A&D Record.
- IOI assumed dealer shared IOI’s enthusiasm for the Democrats, gun control, and the President. The dealer did not but was noncommittal. And is now furious.
We recently dropped in on Dealer B. Without telling Dealer B about this tale from Dealer A, we had a conversation under remarkably similar lines. A major difference was that this inspection seemed to be routine in nature. (“I was about due for one.”) The IOI was focused on multiple buys, especially multiple AR-15 lower buys, and harangued the dealer:
“Why do you think this guy bought six lowers at once?”
“I don’t know. I’ve given up trying to figure out why people buy what they buy. Not everybody likes what I like, and I’m cool with that.”
“Come on, there’s no legitimate reason to do that.”
“That’s a mistake, to believe that. A lot of these guys like building ARs in different calibers and barrel lengths.”
The FFL tried to argue the point, that there were legitimate reasons for someone to buy multiple guns at once, but the investigator did not believe that for a minute, and was not being persuaded.
There was no mention of a coming crackdown. Dealer B did not mention any political disussion. Unlike Dealer A, Dealer B is a longtime union member and Democrat who parts company with his party on gun control only.
Dealer B did not get as much attitude as Dealer A from the investigator, but both had the sense that the investigator thinks all dealers sell to criminals with, at least, depraved indifference. Dealer B did not hear the term “kitchen-table dealer” but he may be one.
Neither dealer had major discrepancies, although both were given some detail corrections. Hot tip to FFLs and to everyone who fills out a 4473: spell out the buyer’s whole middle name.
Neither dealer wants (or deserves) to be identified publicly, but neither one was given a gag order, either.
We are not sure if this was the same inspector.
Maybe you guys can shake your trees and see if your dealers are encountering IOIs like these two (or this one?) whose clue level is below the add-a-quart line.
Again, this doesn’t herald any kind of a major crackdown, but it may be a foreshadowing of trouble ahead. Your best defense is to comply fully with the letter of the law. And to have an attorney familiar with firearms regulatory law and criminal law on standby, just in case.