Kutter, I don't know whether you're recalling inspection practices from many years past or whether the ATF singled your operation out for additional scrutiny, but current ATF practice is to look at just 12 months of 4473 forms.
Don't take my word for it. Recently, the online publication Ammoland obtained a copy of the ATF's Industry Operations Manual through a Freedom of Information request. THis is the guidebook that inspectors follow when doing FFL visits -- the BIBLE of ATF inspections. You can see a copy of the manual here:
ATF Firearms Industry Operations Manual PDF If you refer to page 50, section e, item 1, it clearly states that inspectors are to "Review 100% of the ATF Form 4473 completed
during the 12 month review period . . . "
I would also refer you to the top of page thirty-nine: -- "
Unless otherwise directed, the period of review will be the 12 month period immediately preceding the start of the inspection."Also, on page 134, the manual describes the information that is supposed to be in the inspector's report of a FFL visit. In that it says: -- "
ATF Forms 4473 on file (last 12 months) – Total number of ATF Forms 4473 on file for the licensee in the 12 months immediately preceding the inspection . . . "(Based on the official manual, it appears that the ATF tries to maintain the fiction that inspections occur annually . . . )
Finally, to settle the question of whether FFL's are required to keep physical copies of licenses provided by other FFLs, I would refer you to page 54: where it clearly states -
NOTE: Regulations do not require the licensee to maintain the certified copies of FFLs, but many licensees choose to do so.
