Conduct a full-scope compliance inspection.

A Report of Violations was issued and a Warning Letter is recommended. Current inspection results disclosed 11 violations, eight stemming from errors/omissions on the Licensee’s ATF F 4473s . Based upon these violations, a Warning Conference is warranted, however a Warning Letter is recommended due to the following: 1 .When considering the Licensee’s A&D errors, there is evidence of a lack of understanding of requirements and not a disregard of record keeping requirements. For example, the Licensee recorded the names of the owners of repair firearms in the acquisition section, but repeatedly failed to record their addresses in the disposition section, believing that it was not a requirement to record the when it was the same owner receiving his/her firearm. These A&D disposition errors were redacted dispositions redacted that result in a 14.3% error rate, exceeding the allowed threshold for a Warning Letter redacted Preventative measures were discussed with the Licensee and the Licensee has already implemented some measures such as a firearm label system as described in the Closing Actions section of this report. 2, The high error rates of the ATF F 4473 are inflated due to a low tally of forms and proportionately high number of erroneous forms. For example, as only 16 forms were on file for review, redacted certification errors are exaggerated by the final statistic of 25%. Similarly, the failure to record any ID redacted 16 forms (12.5%) slightly exceeds the Warning Letter threshold|U21|G0j). 3. The inspection period was expanded to include the relatively small number of ATF F 4473s on file (16 total) beginning 9/2011 when Cooper Technical Services was issued its Type 07 FFL . It is worth noting the majority of ATF F 4473s that are cited in this report were completed prior to 2014 when an improvement in form completion is seen. Show more