Gun Storage and More

What really constitutes secure legal storage? 

Q: Can the standard two-letter state abbreviation be used in box Nos. 2 and 20a on the 4473 form or does the state have to be spelled out?
A: The United States Post Office has designated a unique two-letter abbreviation for each of the United States and six military “states.” These two-letter abbreviations are acceptable to identify the state.

Q: When a customer takes delivery of a second handgun within five business days of acquiring the first, I always file the required report (Form 3310.4). If the same customer comes back and acquires a third handgun on the very next day, do I file another report, and, if so, do I list only the third handgun on the second report?
A: Licensees are required by 27 CFR 478.126a to use an ATF Form 3310.4 to report all transactions in which an unlicensed person has acquired two or more pistols and/or revolvers at one time or during five consecutive business days. The form is to be submitted to the ATF National Tracing Center no later than the close of business on the day that the multiple sale or other disposition occurs. If that same unlicensed person acquires another (third) handgun on a different date within five business days, the subsequent acquisition of the third handgun would have to be reported on an ATF Form 3310.4 by the close of the day upon which that third handgun was sold.

Q: What qualifies as a secure gun storage or safety device?
A: The term “secure gun storage or safety device” is defined in 18 U.S.C. 921(a)(34) as follows: “(A) a device that, when installed on a firearm, is designed to prevent the firearm from being operated without first deactivating the device; (B) a device incorporated into the design of the firearm that is designed to prevent the operation of the firearm by anyone not having access to the device; or (C) a safe, gun safe, gun case, lock box, or other device that is designed to be or can be used to store a firearm and that is designed to be unlocked only by means of a key, a combination, or other similar means.” 

Q: When must secure gun storage or a safety device be provided. Any exceptions?
A: Under 18 U.S.C. 922(z), a secure gun storage or safety device is required with the sale, delivery or transfer of a handgun to a nonlicensee. This provision does not apply to the transfer of handguns to any
federal firearms licensee, nor does it apply to the following:
1: [a] The handgun’s manufacture for, transfer to, or possession by the United States, a department or agency of the United States, a state or a department, agency, or political subdivision of a state; or [b] The handgun’s transfer to, or possession by, a law enforcement officer employed by an entity referred to in paragraph (a) for law enforcement purposes (whether on or off duty);
2: The handgun’s transfer to, or possession by, a rail police officer employed by a rail carrier and certified or commissioned as a police officer under the laws of a state for law enforcement purposes (whether on or off duty);
3: The transfer of a handgun listed as a curio or relic to any person by the attorney general pursuant to 18 U.S.C. 921(a)(13); or
4: The transfer of a handgun to any person for which a secure gun storage or safety device is temporarily unavailable for the reasons described in the exceptions stated in 18 U.S.C. 923(e), if the licensed manufacturer, licensed importer or licensed dealer delivers to the transferee within 10 calendar days from the date of the delivery of the handgun to the transferee, a secure gun storage or safety device for the handgun.
Most commercially marketed handgun safety locks or devices fit within the statutory definition. The ATF does not consider the use of zip ties, rope or string sufficient to satisfy the definition set forth in 18 U.S.C. 921(a)(34).
Proposed rules that will clarify provisions of the Child Safety Lock Act are under review within the Department of Justice and will be published in the near future.