FY2017 DA–TOP 100 INSPECTION (MANDATORY) Please conduct an on-site DE Compliance Inspection. Please conduct the following activities: -Obtain a business profile -Explore ownership and control to include Deconfliction Queries of the corporation and all RPs -Conduct a full physical inventory in conjunction with an A&D Records Review -Conduct a comprehensive review of ATF Form 4473s with a focus on suspicious purchasers worthy of referral to CE for further investigation -Ensure that all Multiple HG Sales were reported in a timely, accurate fashion -Conduct a detailed trace analysis -Issue a ROV documenting any violations (if applicable) -Conduct a Federal Firearms Regulations Review with a RP Show more

Beginning on December 13, 2016, Industry Operations Investigator (lOI) redacted conducted a firearms compliance inspection of RS & Company Inc dba Guns Priced Right located in Dravosburg, PA. Present for the inspection was Greg Cameal (PADL redacted, expiration redacted). Also present at times were employees redacted, Special Agent (S/A) redacted and IO redacted intermittently assisted with the inspection. Guns Priced Right holds a type 01 Dealer of Firearms Federal firearms license ( FFL ). Due to redacted with redacted, the licensee was identified in the 2017 Domain Assessment redacted as a result, the inspection was conducted with a disposition emphasis to identify potential patterns of suspicious activity. The inspection covered a period of January 1, 2016– December 12, 2016, although suspicious purchasers were identified through early 2017 during the course of the inspection. Advance notice was not given, IOI redacted identified herself with Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) credentials. Per ATF O 5370.1C, Warning Letter is merited due to transfer of a long gun to an out-of-state resident in violation of State law. The licensee does not meet threshholds based on volume to merit additional administrative action . Show more

Ul# 766060-2017-0204-BIB FFL # 8-25-05602 Licensee: RS & Company, Inc. dba Guns Priced Right Dates of Inspection: 12/13/2016-03/21/2017 Scope of Inspection: Top 100 DE Compliance (Type 01 FFL) Time Frame of Inspection: 01/01/2016-12/12/2016 Recommendation: Violations; ROV ; WL ; NO Recall IOI : redacted A/S Comments: From 12/13/2016-03/21/2017, IOI redacted conducted a DE Compliance Inspection at the licensed premises of RS & Company, Inc. dba Guns Priced Right. As a result of this inspection IOI redacted cited the following nine (9) violations: 1.) 27 CFR 478.21(a) Nature of Violation: With regard to ATF F 4473 , the licensee hhad redacted instances of this violation on redacted forms. On redacted occasions, purchasers responded “No" to item 11a, “Are you the actual transferee/buyer of the firearm(s) listed on this form?" and the licensee failed to halt the transaction. On redacted occasion each, the purchaser failed to complete item 24, “Transferee’s/Buyer's Signature” and item 25, “Recertification Date,” upon of transfer a firearm following a delayed PICS approval 2.) 27 CFR 478.99(a) Nature of Violation: With regard to ATF F 4473 and transfer to out-of-state residents, the licensee had redacted instance of this violation. On redacted occasion, the licensee transferred a long gun to an out of state resident in violation of the laws of the transferee's state of residence. 3.) 27 CFR 478 124(c)(1) Nature of Violation: With regard to ATF F 4473, the licensee had redacted instances of errors or omissions on redacted forms. 4.) 27 CFR 478.124(c)(3)(i) Nature of Violation: With regard to ATF F 4473, the licensee had redacted instances of this violation on redacted (5) ATF F 4473. On redacted occasion, the licensee failed to properly record the expiration date for the form of identification viewed. On redacted occasions, the licensee failed to record/verify additional documentation required for identification purposes. 5.) 27 CFR 478.124(c)(3)(iii) Nature of Violation: With regard to ATF F 4473, the licensee had redacted instances of this violation on redacted forms. On redacted occasions, the licensee failed to document on ATF F 4473 the additional documentation (hunting license) required for nonimmigrant alien exception. 6.) 27 CFR 478.124(c)(3(iv) Nature of Violation: With regard to ATF F 4473, the licensee had redacted instances of this violation on redacted forms On redacted occasions, the licensee made errors or omissions to Item 21c, initial PICS response. On redacted instances, the licensee failed to correctly identify a response in Item 21d when the initial PICS response was “Delayed." 7.) 27 CFR 478.124(c)(4) Nature of Violation: With regard to ATF F 4473, the licensee had redacted instance of this violation on redacted form. On redacted occasion, the licensee listed redacted firearm serial numbers in Item 28 with no indication of which was the correct serial number for the transfer. 8.) 27 CFR 47024(c)(5) Nature of Violation: With regard to ATF F 4473, the licensee had redacted instance of this violation on redacted form. On redacted occasion, the licensee failed to indicate a date of transfer in Item 36. 9.) 27 CFR 478.125(e) Nature of Violation: With regard to Acquisition & Disposition ( A&D ) records, the licensee had redacted instances of this violation. On redacted occasions, the licensee transferred firearms and failed to generate a corresponding disposition entry in the A&D record. Based upon these violations and in accordance with the AA Policy, IOI redacted has recommended a WL Only with NO Recall Inspection. A/S Comments: WL With Recall Inspection is recommended based upon the following reasons: 1.) First Compliance Inspection since issuance of the Type 01 FFL in 2014 2.) No missing firearms. IOI redacted inventoried over 670 firearms in inventory and reviewed almost 4000 acquisition entries and 4000 disposition entries with NO missing firearms identified 3.) No unreported Multiple HG Sales. For Multiple HG Sales that were not recorded by ATF, IOI redacted was able to obtain documentation demonstrating that said sales were correctly reported. 4.) Low Deficiency Ratings. All Deficiency Ratings pertaining to both the A&D Record Book and the ATF Form 4473s were less than 1%. 5.) No missed PICS background checks. The licensee conducted PICS Background Checks and completed the ATF F 4473 for all unlicensed purchasers. 6.) redacted traces. However, the licensee was the subject of redacted traces during the twelve (12) month inspection period which is cause for concern and warrants a Recall Inspection to determine if the Compliance Inspection raised awareness to detection of straw sales and firearms trafficking in general. Of note, the RPs made the immediate decision to cease selling Hi-Point Pistols, one of their most traced firearms. 7.) Internal policies & SOPs in place. The licensee appears to have internal policies and SOPs in place (i.e. use of a tag system, computerized back-up A&D Records, secondary reviews of ATF Form 4473s, copies of I D. documents, etc.). However, errors and omissions continue to occur which would seem to indicate a lack of attention to details by the licensee. A Recall Inspection is needed to ensure that the licensee is strictly adhering to their internal policies and SOPs and have significantly reduced, or elimated altogether, errors and omissions, specifically those related to ATF Form 4473 completion. The Narrative Report and all supporting documentation will be forwarded to the DIO for secondary review and final recommendation. Show more