I think you may be missing something in the US Gov't publication.

As you already point out,,the BATFE up front expects all FFL's to be Compliance Checked by them ONCE every 12 months.

With that time frame in mind, the Manual is printed with all the FFL's records checked are noted as being 'of the last 12 months period'.

Their perfect world would only need to check the preceding 12months of your FFL books if they did in fact stop by once every 12months.

But they don't. They simply don't have the personel to so that.
So you get yrs betw checks.
When they do come, they check as far back as the last Compliance Check,,if that was noted and I'm sure they have record of it even if not recorded with a big notation in your books.

While they're at it, they are free to browse thru anything earlier than that and they do.

So don't think that after 12months in the book,,it's out of reach by the Compliance Agents check.
If it's in the book,,it's always under their scrutiny.

They actually own that Log Book of yours,,not you.
Try and keep the orig when you close up shop and see what they'll charge you with if you don't turn it and the rest of your records over. Pack it up and send it Certified Mail with in 30days.

With regard to the certified copys of the FFL.
They were always needed to show where the gun went to
(disposition) when the gun was transfered to another FFL.
You had to produce the FFL hard copy,,or the 4473 of the Disposition.

Always an orig signiture copy up until around the late 80's IIRC when they started allowing FAX copies.
Then still later Email copies were allowed.

When the orig signiture copies only were allowed back before electric lights, many FFL's would only accept them if signed in blue or red ink. Black ink on a B&W copy couln't always be seen as an 'original' signiture'.
Times have changed!



My first Compliance check was in 1973 IIRC. Maybe 1974
The last one was in 2017.
At that last Check, I still had to produce valid hard copys of FFLs for dispositions to other FFL's.
Agent would read the transaction disposition out of the log book with the Dealers/FFL name. I had to dig that FFL copy out of the file and hand it to him for verification of #, valid, ect.

Every disposition to a non-licensee I had to produce the 4473 for that transaction.

Everytime went like that.

I guess that's changed? Don't have to keep them anymore, doesn't effect me anyway.
...But I'd still keep them if I got another 01FFL.

I dropped my 01FFL (non-renewal in 2018)

Have a great Holiday.