My recollection is that the law simply states that a person shipping a gun must ship it to an FFL holder and, like most of the Code of Federal Regulations (CFRs), it does not give a method on how to comply.
In the past, the ATF had provided advisory information that a signed copy sent by mail was an acceptable method on how to comply. Later, they created the web listing and said that was another acceptable way to comply.
What it boils down to is that neither the signed copy nor the web list is required, it is just an acceptable method and other methods may be acceptable, if I read the law correctly and if it is similar in philosophy to our Federal Aviation Regulations. In other words, if you do what they have previously accepted as a verification method, they won't prosecute you for not complying if it turns out the signed copy or the web is not accurate.
If you know that Remington has an FFL and want to send them a gun, you likely won't recieve a FFL copy from them. Yet you know they are a FFL and you know that the ATF won't challenge you on shipping to Remington. Since you are simply required to send it to an FFL, you are compliant because Remington is indeed an FFL. It's a matter of knowing if you are complying to the law that says you must send it to an FFL, or, if you are wrong, was your method of verification 'due diligence' in the eyes of the ATF.
Last edited by Chuck H; 07/02/12 06:02 PM.
