Justification for OMB 1140-0032 5.13.2020

DEPARTMENT OF JUSTICE
Bureau of Alcohol, Tobacco, Firearms and Explosives
Supporting Statement
Information Collection Request (ICR)
OMB 1140-0032
Records of Acquisition and Disposition, Collectors of Firearms
A. Justification
1. Necessity of Information Collection (IC)
The recordkeeping requirements established by 18 U.S.C. § 923, under the Gun
Control Act of 1968 (GCA), as amended, grants ATF the authority to inquire
about the disposition of any firearm, during the course of a criminal investigation.
Specifically, these regulations require a uniform recordkeeping format. These
regulations also grant ATF Officers the authority to examine a collector’s
records, during firearms tracing or compliance inspections, per 27 CFR §§
478.23(c) (1) and (2). In the case of the latter, compliance inspections, these
activities are conducted under the authority of 18 U.S.C. §§ 923(g) (1) (A), (B),
(C), and (D).
2. Needs and Uses
Unlike other federal firearms licensees (FFLs), licensed collectors are not
required to use the Firearms Transaction Record - ATF F 4473 (ATF Form
5300.9). In fact, collectors records are established by entering the required
information, i.e. a description of the firearm(s), acquisition receipt, and
information about the disposition of the firearm(s), into the proper record book,
as mandated by 27 CFR § 478.125(f). The collector must also record this
information, no later than the close of the next business day after the date of
acquisition, or within seven (7) days of the disposition of curios and relics
firearm(s). These records must be maintained in bound form in the required
format. ATF may use the collected information for criminal investigations or
government inspections. The record retention requirement for this collection of
information is 20 years.
3. Use of Information Technology
Collectors must record and maintain the required firearm information on the
premises of the licensee, along with the description of the firearm, acquisition
receipt, and disposition information, in accordance with the format required by
27 CFR § 478.125(f). Per ATF Ruling 2016-1, regarding the approved use of
information technology for Acquisition and Disposition (A&D) records,
collectors may also keep electronic records to fulfill the requirements of this IC.
4. Efforts to Identify Duplication

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ATF uses a subject classification system to identify duplication and ensure that
no previously submitted information can be reused for the purposes of this IC.
5. Minimizing Burden on Small Business
This collection of information has no significant impact on small businesses.
6. Consequences of Not Conducting or Less Frequent Collection
Less frequent collection of this information would increase the threat to public
safety, since the collected information may be used during criminal investigations
and firearms traces.
7. Special Circumstances
There are no special circumstances associated with this collection. This
requirement is conducted in a manner consistent with 5 CFR § 1320.6.
8. Public Comments and Consultations
No comments were received during the 60-day Federal Register Notice period.
However, a 30-day notice will be published in the Federal Register to solicit
public comments.
9. Provision of Payments or Gifts to Respondents
No payment or gift is associated with this IC.
10. Assurance of Confidentiality
The records are maintained on the premises of the licensee in a secured location.
Confidentiality is not assured.
11. Justification for Sensitive Questions
No records of a sensitive nature are maintained.
12. Estimate of Respondent’s Burden
There are 51,976 respondents for this IC, which is a reduction in the number of
respondents recorded during the last renewal in 2017. Each respondent will report
once annually. Therefore, the total responses is also 51,976.
The estimated time to complete each report is 3 hours. As such, the annual time
burden associated with inspections reporting is 155,928 hours, which can be
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calculated as follows: 3 (total hours to create each inspection report) * 51,976
(# of respondents).
ATF does not have a data source to estimate the number of records produced
annually per respondent. Assuming that the average respondent creates or
maintains one (1) record each, and the time needed to do so is estimated at 3
minutes, (3 minutes divided by 60 minutes for 1 hour or .05. Therefore, the
total record creation and maintenance burden for this IC is 2,599 hours, which
is equal to .05 (3 minutes or time taken to create and maintain each record) *
51,976 (# of respondents).
Therefore, the combined total annual burden hours for this collection is
158,527, which is equal to 155,928 (total inspection report hours) + 2,599
total record creation/maintenance hours).
13. Estimate of Cost Burden
There is no new cost or annual cost associated with this collection.
14. Cost to the Federal Government
There is no cost to the Federal Government.
15. Reason for Change in Burden
The adjustments associated with this collection include a decrease in number of
respondents (collector licensees) and responses by 4,952, since the last renewal
in 2017. Consequently, the total annual burden hours for this IC has also reduced
by 12,257.
16. Anticipated Publication Plan and Schedule
The result of this information collection will not be published.
17. Display of Expiration Date
ATF does not request approval to not display the expiration date of OMB
approval for this collection.
18. Exception to the Certification Statement
There are no exceptions to the certification statement.
B.

Collections of Information Employing Statistical Methods
This collection of information employs no statistical methods.
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