DIO Warning Conference conducted on 6/30/2016. Conduct recall inspection after 3/3/2017.

ALTERNATE RECOMMENDATION : Warning Letter - No Recall The inspection meets the standard for Warning Conference under the current Administrative Action Policy, ATF O 5370.1 C (2/21/2017). The licensee was cited for repeat violations: Violation-1 - failure to accurately maintain the A&D record which resulted in the reported loss of redacted firearm - WL at Sec. 6 (c)(7); and Violation-2 - failure to obtain complete information on the F4473s in questions 11 (i.e. redacted forms - Blocks 11k/11l were left blank). Similar violations were addressed with the licensee during a DIO held Warning Conference in 2016 - WC at Sec. 6.d.(4)(f). (The licensee also attended AS Warning Conferences in 2008 and 2011). Two additional repeat violations do not rise to the level of administrative action. JUSTIFICATION FOR ALTERNATE: Although willfulness can be established based upon the licensee’s extensive inspection history, the number of inventory discrepancies has decreased from redacted in 2016 to redacted in the current inspection. Additionally the licensee's error rate among the Forms 4473 remained relatively the same (5% to 7%) among 108 forms completed in the past year. Of the redacted forms with blank answers in Blocks 11, all but one involved the same non-prohibited, repeat pawn customer. The licensee estimates the pawning of firearms accounts for 75% of its firearms business. None of the violations appears to have negatively affected public safety. The licensee is a low-volume pawnbroker in rural northwest Kansas and conducts less than 140 transfers annually. As a pawnbroker, the licensee is a Kansas Priority-2 dealer and will be inspected on a five-year cycle. AS Review: 4/25/17 Sent to DIO: 4/25/17 DIO concurs: 4/26/17 WL sent: 4/26/17 DE staged for 2019 Pll sent: 4/26/17 Show more