The folks at Dead Air Armament, Gemtech and Silencer Shop have gotten together with ATF to create a Form 4 generator. The process automates some of the data entry involved with ATF processing forms. Makes sense right? Automating the regulatory process should make the government more efficient. Pundits are prognosticating processing times will drop. Yes, well . . .

First, know this: the firearm industry is a victim of its own success. Thanks to ATF rule 41F — removing the requirement for a CLEO to sign their forms (click here for an explanation) — the amount of ATF Form 4 paperwork generated for silencers, short-barreled firearms, etc. is unprecedented.

The ATF’s new bar coded data system is supposed to make things a lot faster by shifting some of the paperwork burden from the government’s side to the industry’s side.

Naturally, when word of this new technology broke, my inbox flooded with requests from customers to have their previously printed form 4‘s and not-yet-submitted paperwork redone with bar codes. So I loaded up the website with the form generator and started poking around.

My first impression: it’s a good idea. As I dug into it, though, I’ve concluded that it’s not my friend. For starters, one of the disclaimers is:

ATF Form 4 generation is a complimentary service of Silencer Shop.
Silencer Shop does not store, review, or validate any information entered on this site.
By clicking the Generate Form 4 button you accept responsibility for the accuracy and validity of the information entered.

The Silencer Shop has data on many manufacturers’ products and can populate them to prevent incorrect data entry. However, because we aren’t using “previously known good” information – there’s always the risk of garbage in, garbage out.

The first thing I learned: Your FFL can still screw up your forms, but this way it will happen faster. Bad data is still bad data.

So, I have several customers who want a Form 4 with a bar code. They already have responsible party forms printed up. I loaded all their information. After triple-checking all the data — because there is no way to validate the typed-in data with a known good data set — I was about 20 minutes into filling-out one set of forms. Not counting the 30 minutes it takes to duplex them off a printer.

I tried to generate the form and . . . got an error. It wouldn’t print the form because I hadn’t listed any responsible parties for the responsible party forms. The website says Form 4 generator not ATF Form 5320.23 generator. I don’t want a responsible party form. I want a Form 4.

The second thing I learned: You can’t just print a Form 4 with a bar code.

But I’d gotten that far, and some new system hiccups were to be expected. So I loaded up all the responsible parties and chased down all the CLEO’s in their respective areas (since all three of them live in different states and localities). Once again, I tried to print the forms. They still wouldn’t print. The data on the responsible party questionnaire was missing.

Wait a minute. I’m the FFL. I have the item. I have the onus of doing the forms correctly. Not only am I supposed to populate all the fields manually — each time, every time — but now I’m supposed to electronically pencil whip your forms for you?

The third thing I learned: This is going to cost me money.

As it stands, the new Form 4 bar code generating system is more time-consuming to complete than the old purely paper system. If the fellow with three responsible parties in three different states has all his data together and I have to basically be a form 5320.23 secretary, it’s going to take me an hour to generate ATF form 4‘s on each purchase.

Time is money.

Before this bar code bonanza, I discounted an item and then factored in 20 minutes to bang out a paper form 4 (pre 41F). Now, when I tell customers who want the Form 4 sent to the ATF electronically that I want more money because it takes more time, people looked at me like I have brain damage.

Long story short, with this new process the industry is going to spend more time on your form so you don’t have to spend more time waiting for your stuff. But don’t expect FFL’s to welcome the new system, at least as it currently stands.

 

[Editor’s note] TTAG spoke with Silencer Shop and they did have feedback on Firearm Concierge’s observations. Summarized (not quoted) as follows:

•  Exactly like completing a Form 4 via any other means, if the data entered by the FFL is incorrect then it’s incorrect. This Form 4 generator system is designed to eliminate data entry errors on the ATF side (and save them significant time), but cannot do all of that on the original input side. However, the F4 generator does prevent the top three errors the ATF finds in Form 4s: it prevents FFL info from being inputted incorrectly, it force matches Form 4 names to 5320.23 names, and it ensures pre-41F forms aren’t used. It should take no longer than writing or inputting the necessary data into the Form 4 fields via any other means. Sending the completed forms to one’s printer should be near instant. Physical printer speeds vary.

•  The 5320.23 is a part of the Form 4 process since the implementation of 41F. While the 5320.23 responsibility could be pushed onto the customer, it’s better and more efficiently handled by the FFL to ensure proper firearm and law enforcement information entry plus correct formatting and the mandatory matching of Form 4 info to 5320.23 info. When the ATF scans one of these new barcodes, all of the Form 4 and 5320.23 information for all responsible parties is automatically ingested into the ATF system. The efficiency gained by avoiding manual data entry of 5320.23 information for all parties is crucial to driving down approval times. Again, whether the FFL fills out these fields in Silencer Shop’s online form generator or via pen and paper or in an ATF PDF file, they’re the same fields and the same inputs and the time spent should be similar (if not fastest in Silencer Shop’s software).

•  Silencer Shop will fill out, create, and submit all necessary paperwork (Form 4s including 5320.23, and more) for any item a Powered by Silencer Shop dealer sells. Becoming a Powered By dealer is simple and there is no charge: www.silencershop.com/dealer-purchase-programs

•  Generating a barcoded form is entirely optional. It’s also free, and it helps avoid the top three errors the ATF sees in submitted forms. Additionally, it will help the ATF allocate resources in a way that will speed up approvals.

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43 COMMENTS

  1. The FFL’s that I do business with are more than happy to jump through a couple extra hoops for me if it makes my life a little easier and results in another sale. Of course, I deal with decent, honest FFL’s, not the greedy, selfish, obnoxious know-it-all types that can’t be bothered with developing a mutually beneficial relationship with his/her customers.

    • I agree with Renner. I’m a FFL and SOT. I WILL do whatever I have to do to make sure MY customers are not inconvenienced, I do all of the paperwork, so my customers don’t have to worry whether they made a mistake. I do it for a fair rate and I go the extra mile for all of my customers. I’m always busy!!!!!!!, and a lot of my customers become friends.

  2. So much like “new customers” for cable and other such entities what is the benefit for those of us who have been submitted and waiting.

    I guess we are just sol.

    So the new purchases get priority because of a new avenue for forms?

    How does this help overall if he cost increases and it still continues to backlog and create more lanes of traffic and potential issues for government approval.

    Seems like a gimmick to promote new sales for moving stagnant inventory but just like he efiles it will play out and not help

    • I learned a few days ago that the ATF isn’t planning on processing barcoded forms differently until they begin encountering them in the normal queue. As Silencer Shop has been sending barcoded forms since mid-July, once the ATF is through the backlog to the point that they’re encountering mid-July 2017 forms then the barcoded forms will begin to see faster approvals than non-barcoded forms. However, this does NOT mean that non-barcoded forms will take longer. The ATF is saying that, if at least half of all Form 4s are barcoded, they expect that no Form 4s should take longer than approximately 90 days to approve by the end of the year (e.g. a non-barcode form submitted in late December 2017 shouldn’t take longer than 90 days). The barcodes will help ALL Form 4 submissions get processed faster.

      BTW, Silencer Shop submits over 40% of all of the Form 4s the ATF receives. It won’t take a whole lot of additional adoption to get to the point where at least half of F4s have the barcode on ’em.

      BTW #2: you mentioned that e-filing hasn’t panned out, but that isn’t true. Right now, today, an e-filed Form 3 takes on average about 72 hours to be approved. A paper Form 3 takes three to four weeks. A lot of people were cynical if not derogatory when the ATF announced that the new F3 e-file system would provide this sort of efficiency and rapid approval, but it has been verified now industry-wide.

  3. The primary miscalculation made here is the harebrained idea that anything government is involved with would possess any efficiencies.

  4. I read most of that post, especially the rebuttal, in “Charley Brown’s Teacher” voice… because it made exactly that much sense to me.

  5. Honestly, I can’t believe TTAG still prints stuff from this guy. Every post I’ve read from him screams “arrogant, selfish sellout.” It’s nauseating.

    • Let’s not forget too that he said he’d be voting for Hillary because that would drive more gun sales. The ONLY thing I’ve ever read by this author that didn’t make me shake my head in disgust was an honest, raw account of how he (she?) felt after selling a firearm to a close friend who then used it to end their own life.

    • I can. It’s free content for them and generates controversy & views. So, more people load their intrusive, noisy, flashy ads.

  6. It seems like less of an issue with the forms and more unfamiliarity with the new system on the author’s part. Plus, I’ll wait as many hours in a day as you’d like me to at your shop as long as the wait time is cut down by months.

  7. “Before this bar code bonanza, I discounted an item and then factored in 20 minutes to bang out a paper form 4 (pre 41F). Now, when I tell customers who want the Form 4 sent to the ATF electronically that I want more money because it takes more time, people looked at me like I have brain damage.”

    Some sage advice, FC: If you think everyone is an asshole, YOU’RE the asshole.

  8. FC, if you hate your customers, your paperwork, your suppliers, and just about everything regarding the industry you work in, maybe you should find a new avenue of employment.

    Seriously, 4 year old girls whine less and throw fewer tantrums.

  10. TTAG, can you please stop using clickbait headlines for your articles. The same annoying headline formulas you see all over Facebook and news sites. This website is better than that.

  11. Well FC might seem like an asshole, if you have ever been the sole desk man as well as on the floor when your paperwork backs up isn’t that a burden on the customer as well since you have to neglect one for the other, time is money period you guys act like you don’t understand the basic fundamentals of business

    • Having been the sole person on the floor with backed up paperwork I can tell you you always take care of the person in front of you first.

      The way FC talks he always has time or can drop whatever he’s doing in an instant if it means hooking a new sucker.

    • Your first FC article? He has the resources and ability to hire someone to do all the admin he bitches about, the very admin that (presumably) has made him a lot of money. But he does nothing about it except Bitch and charge people more. Why he continues to have a single customer is baffling. Why TTAG continues to publish his drivel, except that clicks in anger generate the same revenue as clicks in genuine interest, is also baffling.

      Also, this and forever this:
      http://web.archive.org/web/20161110172142/https://www.thetruthaboutguns.com/2016/11/firearmconcierge/voted-hillary-clinton/

      The guys a (flame deleted, if I were to guess).

      I’ve drifted towards TFB to balance out some of the nonsensical articles I see here. I miss the glory days of 2011-2013, with gun and gear reviews dominating the majority of the articles. RF’s torrid love affair with the Caracal, the R51 debacle…pure gold.

      • A lot of FFLs and folks invested in the industry voted for Hillary. The truth isn’t always pleasant and I don’t think TTAG has every existed to try and protect us from difficult information and treat readers with kiddie gloves.

        • 2 separate issues:
          1. FC is a douche. Hyperlink and comments above directed appropriately.
          2. I have zero issue with TTAG reporting the story as it is, regardless of how pleasant or unpleasant it may be. That is not the same as giving FC a pulpit to whine about the very process and industry that has lined his pockets, especially when he has the resources and ability to alleviate the burden of said processes. There are more informative, interesting, and well-meaning articles than whatever junk FC vomits onto his keyboard.

          Separately: The new webpage reloads about every 45-60sec, erasing pending comments or jumping to a new spot on the page. It’s getting to be unreadable.

    • How about another fundamental of business? If you cant take the load yourself, hire another to help or turn customers away. Adapt or die. Pretty simple.

  12. Hey, I thought it was put best when they said we should take the people that cleared out the Hillary emails on Anthony Weiner’s Latop and have them start processing these forms.

    • That was my thought as well. “I was filling out forms with a stone tablet and chisel just fine before these newfangled data entry machines came along and made everything more complicated!”

  14. Does anyone know FC? Does he have a shop? I’m not sure. But I am rather sure he DID work at Silencer Shop, or still does. Jeremy I’ve heard may or may not. There is a Jeremy there. My husband does a lot of business with them and I’ve been there and they’ve been nothing but superb and professional. Even prefer to hire vets. Have turned away LE though, for good or bad I don’t know. I give the barcodes a chance and support and thank you to Silencer Shop for doing something after the industry only whined and BATFE only screwed it up. Sure there are bugs, they’ll get it. It will help. Thank you SS

  15. I will start caring about what FC has to say as soon as he has the courage to tell everyone who he actually is. Until then he is just another piece of “turd” (don’t want to flame too hard). He is too scared to tell everyone who he is.

    • I don’t have the time to search for it, but a year or so ago someone figured who he was and where his shop was located.

      But you’re right, he lacks the courage of his convictions, much like the pansy asses in Antifa who wear masks.

      • I would love to see the info if someone could dig it up. I might have to commit some time to it over the weekend to see if I can locate the comment. It would be worth it just to make sure I never do any business with him. I tend to think that I would be able to sniff him out even if I didn’t know who he was. His “special” prices and glowing personality would probably be a dead give-away.

  16. Theres no way FC really exists. Any retailer who behaves like this fictional character will go broke fast.

    This is a massive trolling by TTAG.

    Well played Robert. Well played.

  17. “TTAG spoke with Silencer Shop and they did have feedback on Firearm Concierge’s observations. Summarized (not quoted) as follows:”

    FC is a ******, that is all.

  18. Lol best response ever, “physcial printer speeds will vary”. That is an equivalent response of f you because you are complaining about something that is a non issue and clearly in the realm of the problem being between the keyboard and the chair.

  19. Isn’t it great how modern technology can effortlessly do anything from the loss of $200 to a prison sentence, all at the speed of light. Truly this is the future.

    Perhaps the best technology would be no NFA. Just sayin’.

  20. Being an FFL who fills out NFA forms all the time for customers, I find this system to be pretty efficient. I can fill out forms, attach photos, print, sign, AND do fingerprints in about 20 minutes, and have yet to have one kicked back. I don’t know what the hell this guy is talking about – most of it sounds like “operator error”.

    My only gripe about the system is that it has no provision to electronically attach a photo before printing; but even that isn’t very valid – I save it as a PDF and attach a photo using Adobe Acrobat Pro before printing. I haven’t manually filled out a PDF in many months, and for good reason.

  21. I get the impression the author still uses an old Motorola flip phone because those damn smart phones are garbage.

    The form generator allows you to easily copy and paste info from online sources which is then duplicated throughout all the forms for you.

    If entering customer information is a challenge someone could easily create a form that can be emailed or put on a tablet they fill out for you. Copy paste that data into the form or get a 14 year old write a script that copies the data for you.

    I’d bet a tech savvy FFL could get that processimg time down to 10 minutes.

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