Reality check · ATF-FFL
Your ATF compliance inspection is not a paperwork exercise. Walk the floor with operators who have been audited.
A pre-inspection walk for licensed firearms manufacturers, importers, and dealers. We find the gap between your A&D books and your floor before the ATF Industry Operations Investigator does.
ATF inspections happen for a reason and the reasons matter. Routine cycle. Notice of revocation hearing. Post-trace investigation. Ownership change. Volume threshold trip. Each context changes what the Industry Operations Investigator looks for. The Readiness engagement is led by Mike Fox because the work is half compliance walk and half ownership conversation: most violations the ATF writes up are not operator error, they are organizational drift between what the license requires and what the company is currently doing.
Quick answer
The ATF FFL Readiness engagement is a pre-inspection walk for federally licensed firearms manufacturers (FFL Type 07, Type 02 SOT), importers (Type 08, Type 11), and high-volume dealers preparing for an ATF compliance inspection. Brass & Bench partners come onsite for three to five days, walk your Acquisition & Disposition records against the floor reality, review Form 4473s where applicable, validate marking variances and serialization, and deliver a bound gap-matrix report. Pricing is $25,000 to $45,000 all-inclusive depending on license type, NFA inventory scope, and operational volume. Most clients use this engagement immediately after an ATF notice of inspection, or proactively for the first inspection following an ownership change or major operational shift.
By Mike Fox · Founding Partner. Business Development & Operations · Updated May 14, 2026The gap
What the registrar finds that your internal audit missed.
ATF compliance violations cluster in eight places. The 2024 ATF inspection results show the top five almost always involve recordkeeping.
Acquisition & Disposition (A&D) book accuracy (27 CFR 478.125). Every firearm acquired and disposed must be entered into the A&D book within the required timeline. Common gap: a frame or receiver enters the facility under one identifier and ships under another (after engraving, after configuration) without the A&D book reflecting the transformation chain. The IOI traces serial numbers backward and forward and finds the breaks.
Form 4473 errors (27 CFR 478.124). For licensees doing over-the-counter or transfer-based business. Common gaps: missing or incomplete responses, missing initials on corrections, incorrect verification of identification documents, missing background-check identifier numbers, missing required signatures. Even minor 4473 errors accumulate into a notice of revocation pattern.
Marking variances and serialization (27 CFR 478.92). Firearms must be marked with serial number, manufacturer name (or recognized abbreviation), city and state of manufacture, model designation, and caliber or gauge. Marking variances must be approved in writing by ATF before being used. Common gap: a variance approved at a prior location does not transfer to a new facility automatically. Or a model designation marking does not match the model designation on the 4473.
NFA recordkeeping (27 CFR 478.131, 479). For Type 07 SOTs handling NFA inventory (machine guns, suppressors, SBRs, SBSs, AOWs, destructive devices). NFA inventory has separate recordkeeping and transfer requirements. Common gaps: NFA inventory entered into the standard A&D book but not separately tracked; Form 2 (manufacturer's notice) timing slips; Form 5 (registered to dealer) chain breaks.
Importer marking and recordkeeping (Type 08, Type 11). Imported firearms must carry importer markings (name and location) in addition to manufacturer markings. Common gap: ammunition imports tracked as a single line item where the IOI expects sub-tracking by manufacturer and country of origin.
Multiple Sale Reports (ATF Form 3310.4). Required for multiple handgun sales to a single buyer in five consecutive business days, and the ATF demand letter expanded reporting for certain border-state long-gun multiples. Common gap: missing reports for transactions where the second sale fell outside the licensee's awareness because the first sale was an order delivered later.
Theft and loss reporting (27 CFR 478.39a). Theft or loss must be reported to ATF within forty-eight hours. Common gap: inventory shrinkage discovered during physical count, with no theft/loss filing because no individual theft event was identified. The IOI reads inventory shrinkage as a reporting trigger.
Storage and security (27 CFR 478, ATF policy). While ATF does not codify specific storage standards beyond NFA secure-storage, the IOI expects reasonable security commensurate with inventory value and theft risk. Common gap: storage practice has not kept up with inventory growth; high-value NFA inventory stored under the same security as commercial inventory.
The path
How we close the gap before the audit.
The Readiness engagement is structured around A&D accuracy, 4473 hygiene, marking validation, and NFA chain integrity (where applicable).
Day zero. Remote intake. Your current FFL and any SOT, your A&D book (paper or electronic, with backups), the last twelve months of 4473s where applicable, your marking variance approvals on file, your NFA inventory and Form 2/3/4/5 chain, your last ATF inspection report (if any), your inventory count records, your theft/loss filings for the prior twenty-four months, any importer registration and ATF Form 6 records, and any Multiple Sale Report logs.
Day one. A&D book walk. Mike Fox and Lorrie Lynn (or one of the operations partners) walk the A&D book end-to-end. The team picks twenty to fifty firearm serial numbers at random and traces each through the A&D chain, with cross-reference to the marking, the disposition record, and any related 4473. Every break in the chain is logged.
Day two. 4473 audit (where applicable). A targeted sample of 4473s is reviewed against the ATF checklist used by IOIs. Common error patterns are documented and walked back to the underlying process gap.
Day three. Marking and serialization walk. Variance approvals validated against actual markings on inventory. Model designation, manufacturer abbreviation, and serial-number format checked against the variance and the A&D book entries. Engraving station procedures reviewed where applicable.
Day four. NFA and importer (where applicable). For Type 07 SOTs, the NFA chain (Form 2, Form 3, Form 4, Form 5) is walked against current NFA inventory. For importers, the Form 6 record and importer marking are validated.
Day five. Findings build and ownership readback. The bound gap-matrix report is built in real time. Every finding tied to a 27 CFR clause, a severity rating against the ATF revocation framework, and a remediation effort estimate.
The bound report ships within forty-eight hours of onsite wrap. The recommended-path appendix sequences remediation, distinguishes between findings the licensee should remediate before the IOI walks in versus findings that should be disclosed proactively (in cases where pre-disclosure changes the violation framing), and identifies any pattern findings that warrant counsel involvement.
ATF-FFL audit coming up? Let's find the gap first.
The first call is a thirty-minute conversation. We tell you whether the Conformance Reality Check is the right product, or whether you need something different.