Conduct FULL RECALL compliance inspection in accordance with ATF regulations and the IO Manual. *** Please check for possible hidden ownership.

A Report of Violations was issued and a recommendation of a Warning Letter and No Recall Inspection in lieu of a warning conference is submitted for consideration based upon the following facts and findings: The current inspection disclosed a total of six (6) violations with all six (6) violations being repeat or similar in nature from a September 17, 2014 compliance inspection. Two (2) of the cited violations, Violation #1 - 27 CFR 478.125(e) and Violation # 2 - 27 CFR 478.21 (a), did not meet the required number of instances to warrant administrative action . One (1) of the cited violations, Violation # 3 - 27 CFR 478.124(c)(3)(i), involving errors and/or omissions on redacted ATF Form 4473 , (0.1% error rate), would warrant a warning letter. Two (2) of the cited violations, Violation # 4 - 27 CFR 478.124(c)(4) and Violation #5 - 27 CFR 478.124(c)(5) are violations not captured under the current Firearms Administrative Action Policy. The remaining violation, Violation #6 - 27 CFR 478.126a involving failure to timely prepare and submit the Report of Multiple Sales or Other Disposition of Pistols and Revolvers, ATF Form 3310.4, in redacted instances, would warrant a warning conference. The September 2014 compliance inspection previously mentioned resulted in a warning conference being held on February 26, 2015 based upon other violations than those cited during the current inspection. A warning letter is further recommended under the current inspection due to the following circumstances: 1. The licensee’s employees were distracted in ensuring ATF compliance based upon former management employees failing to perform their assigned duties within company standards, including their obligation to ensure that all employees and themselves adhere to ATF laws and regulations. The two (2) former management employees, with responsibilities to oversee firearm transaction activities, were terminated during the inspection review period based upon an extra marital affair between themselves, failure to ensure that ATF requirements are met, and the misrepresentation and falsification of internal company (store) records. The licensee has since filed criminal charges against the former management employees for theft by deception and a trial date is pending before the Chatham County, Georgia State Court, Savannah, Georgia. 2. Corporation President Eric Richman has since established “written procedures” for employees to follow in regard to ATF compliance requirements, including a mandate that all Welsh Pawn Shop locations will conduct a firearms inventory every ninety (90) days, procedures to be followed prior to transferring a firearm, and the policy of “consequences” for disciplinary action, including possible dismissal, if it is determined that an employee has been found to have five (5) or more ATF recordkeeping errors per year. 3. The licensee’s current inspection warrants a warning conference based solely upon cited Violation #6 - 27 CFR 478.126a - Failure to timely prepare and submit the Report of Multiple Sales or Other Disposition of Pistols and Revolvers, ATF Form 3310.4, redacted instances. The licensee's failure to comply with the regulation in redacted instances just did exceed the “threshold” for administrative action of a warning conference versus a warning letter. Based upon a recent change in store management, the establishment of written procedures to ensure compliance with ATF requirements, and the guidance and information provided during the inspection closing conference by IOI redacted, a recommendation of a warning letter in lieu of a warning conference is submitted for consideration. Show more

Reviewed the inspection report and the violations found during the inspection. I concur with the recommendation of the IOI for a Viols WL ONLY and No Recall Inspection based on the recommendation of the IOI and that the president of the business has already taken stern measures iin terminating two managers and initiating measures to ensure these violations do not occur in the future. Based upon a recent change in store management, the establishment of written procedures to ensure compliance with ATF requirements, and the guidance and information provided during the inspection closing conference by IOI redacted a recommendation of a warning letter in lieu of a warning conference is submitted for consideration. Show more