C&R FFL RENEWALS

Article Published Date: 11/17/2007

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As a companion article to our “How to” on C&R licenses, this article focuses on the renewal of your C&R FFL.  Your standard C&R license is good for 3 years and ATF send out a renewal notice about 3 months before your license will expire.  If you have not gotten something in the mail from them about your renewal, you should contact the ATF Licensing Center at: 

ATF Federal Firearms Licensing Center

2600 Century Parkway NE

Suite 110

Atlanta GA  303345

(404) 417-2750

M-F 8am – 430pm ET

You may also contact your local ATF field office for help as well.

This is the second time that I’ve renewed the license and the form has changed quite a bit since last time.  Arriving in a green envelope marked with “FFLC” as a return address, it contained the ATF Form 8 (5310.11) Part II (Renewal Application), ATF Form 5330.20 (dated 3-2002) (Certification of Citizenship) and even had a return addressed envelope.

Step by Step

PRINT LEGIBLY and in INK on all your applications!

FORM 8

The first thing you should realize is that the Form 8 is used for business type (FFL 01) licenses as well and some of the requested information does not pertain to C&R (FFL 03) licensees.  ATF has done a better job on this Form 8 by actually giving instructions about what does and what does not need to be filled out.  You will notice that the form is partly filled out with the current information that they have on file for your license. 

At the top left of the form is your FFL number and type.  You should check this number against your current license copy to make sure the numbers are the same.  Just below this you will notice that the renewal is due PRIOR to the first day of the month of expiration.  In my case, I had nearly 3 whole months to fill out the form before my old license expired.  Plenty of time.  If, however, for some reason you goof off over the 3 months, you can request ATF send you a Letter of Authorization to tide you over.  Basically, you MAY NOT continue using your license if it expires.  Read at the very bottom of the form that there are “criminal penalties for continuing… collector activities without renewing your license.”  You can contact your local ATF office and they can assist you with renewing your license or getting a letter of authorization.

As with the Form 7CR that you filled out three years ago, the fee for renewal is $30 for 3 years.

You may pay using a check, money order or credit card (check the appropriate box on the right side and fill in the amount on the left side).  There is a statement to that says that your card will be charged when the application is received, so basically it means they charge first, then process.

Now, if you are not renewing, you should check the red not renewing box, sign and date by #2.  As a C&R, you are NOT required to send in your bound book records if you do not renew.  That only pertains to other licenses.  You would then send this application to the ATF at:

ATF Out of business Records Center

244 Needy Rd

Martinsburg, WV  25401

1-800-788-7133, x204

Section A Current FFL Information

You should check over the information that they have for your current license.  Notice that there is a spot for phone numbers and an email address.  Are they required?  When I called the FFLC they said, “We’d like to see a phone number”.  Take it for what that is worth. 

As you know already, your C&R is tied directly to the address listed on your license.  Basically, if you moved you should have filled an application to change your address at that time.  FFL license numbers are based on where the licensee is located, so it is likely that your license number would have changed.  NOTE that the fine print says:

“NEW Licensee Name- Federal firearms licenses (FFLs) are NOT transferable.  If there has been a CHANGE in ownership or control of the firearms business or COLLECTION ACTIVITY, you may NOT use this form to obtain a renewed license.  You MUST fire a NEW application.”

And then further down in the section by the “**” is a line:

“You may NOT operate your business or conduct your COLLECTION ACTIVITY at the NEW premises address until you have received a NEW license reflecting your new address”

So, basically stated, if you moved, you should have already applied for a change of address license (which would have been free).  When I called the FFLC and asked why this section exists, they basically said that if you had waited to renew AFTER you moved, you can use the renewal to change the license address.  HOWEVER, this also implies that after you moved to a new address you DID NOT use the old license to procure, as it shows the old address on it.  Bottom line is, your address for collecting must be the same address on your license.

Yep, if you move there is a good chance that you will get a brand new number. Why? Because the license number issued is dependent on where you live. Let’s take a look at a C&R number.

A typical number would be:
1-23-456-78-9A-00000
Broken down as follows:

Position 1 represents= ATF region you are in
Position 2,3 represents= State the license is in
Position 4,5,6 represents= County the license is in
Position 7,8 represents= FFL type (in the C&R it would be 03)
Position 9A represents= digit is year of expiration, letter is the month(A=Jan, B=Feb, etc)
Position 00000= unique number to your license

That is why your number may change if you move. Because sellers are only supposed to ship to the address listed on the FFL, you can see why you need to update the records.

A change of address form is ATF Form 5300.38 (Application for an Amended Firearms License).  You can obtain a copy by writing or calling to the FFLC or your local ATF office, or you can get one on line at: www.atf.treas.gov/forms/pdfs/f530038.pdf.  Realize that this form is used by ALL types of licenses if there is an address change and there are many parts that do not pertain to the C&R license.  Fill out the parts that are geared toward more the individual rather than a business.  Questions on zoning, hours of operation, business numbers, etc do not need to be filled out.  Remember, the 03 license is ONLY for individual collecting.  I would find it prudent to send with the form a short note that explains that you have a C&R and have moved.  They will issue a new C&R.  There is NO fee for this form.

Section B  Hours of Operation

As a C&R licensee, you DO NOT have to fill this section out, HOWEVER do remember to check the box next to “Collector of Curios or Relics” in the section.

Section C  Questions

This section corresponds to Section 14 on the Form 7CR.  Basically, you are stating that you will comply with not only federal firearms laws, but also local/state laws as well.  You are also certifying that you will conduct your collecting at only the address stated on the license.  Answer the questions using “yes” or “no”

Take note of Question 4.  You DO have to make a copy (front and back) of this renewal form, and send it to your chief local law enforcement officer (CLEO).  This should correspond to the same office that you sent your original license to, but, you better check on the current CLEO name, as that may have changed in 3 years time.  You do not need to send the CLEO and money.

Take note of Question 6.  This refers to the ˝ sheet form ATF Form 5330.20 to certify your citizen ship.  This form does not need to be sent to the CLEO.  Make sure it is included with your completed renewal to the ATF or it will hold up your new license.  I enclosed a one sentence letter with my copy of the renewal to my CLEO to the effect of, “I am sending this copy of the my FFL 03 license renewal as stipulated by Section C, Question 6 on the ATF Form 8.” 

Question 7 is something new since the last time that I did a renewal.  Basically, ATF wants a count of how many C&R weapons went into and out of your bound book.  Why?  Good question, but my guess is that they want to make sure you are using a bound book. 

Section D  (more questions)

This section is self-explanatory.  You filled out a similar section on your original Form 7CR and if you have purchased a non C&R weapon from a dealer/store, you have filled out forms with similar questions. 

The Form 5330.20

This is the Certification of Citizenship form included in your renewal.  It must be filled out and returned with the application.  The new Form 7CR that ATF uses, has this form built into it (under section 18).  The renewal form does not, hence this little ˝ sheet. 

As I am a citizen and am not an immigration lawyer, I would recommend that if you have questions about specific issues on citizenship, you should contact ATF directly at the address/phone number above or get a hold of your local ATF office.  They can help you out.

If you are a citizen, YOU are both the name being filed and the person CERTIFYING TO the citizenship.  All you have to do is fill in numbers 1-3 and then skip to 7 and sign the form. 

FINALLY…..

1. Sign and date the forms and print your name and telephone number in required spaces.
2. Make copies for your records, noting when you sent it to the FFLC
3. Make a copy of the application and send it to your CLEO.  Nothing further needs to be done with the CLEO unless they have an issue with your license.  They will contact you or ATF directly with any problems.
4. If you are going to use a credit card to pay for your license, make sure that you fill out that section at the top of the front page.  If you are using a check or money order, make sure that it is payable to “ATF” and is enclosed with the form.
5. Make sure you have all info filled out, including the ˝ sheet 5330.20 form, put them into the supplied envelope and mail it…and wait.

If I recall, you will once again get a package of books on state laws and other info about FFLs just like you did with your original application.  Once your license arrives, remember NOT to sign the original…make copies, sign the copies and send them back out to the same companies that you did back 3 years ago.  Many of those companies automatically remove you from mailing lists and dealers pricing when your license expires, so update your info as soon as you get the new license.

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