Justification for Non-Substantive Change

Non-substantive Changes to ATF Form 8 Part II (5310.11) – OMB Number 1140-0019

Section C #5

Section C #5 has been edited to include a “N/A” check box for licensees who do not meet the criteria of the question.  On version 1.0 uploaded into ROCIS required respondents to write “N/A” however, when ATF adopted OMB’s recommendations to use “Yes/No” check boxes and uploaded version 2.0 into ROCIS it did not allow for the “N/A” option.

S ection C #5 now reads “As required by 18 U.S.C. 923(d)(1)(G), will secure gun storage or safety devices be made available at any place in which firearms are sold under the FFL to person who are NOT licensees.  Check “N/A” if you are a Collector of Curios and Relics or a Manufacturer of Ammunition.  N/A  ”

Section C #6

The correct version of ATF Form 8 Part II (5310.11) was submitted in ROCIS as version 1.0 however, when changes were made to adopt OMB’s recommendations those changes were not made to the correct version. Therefore, the incorrect version of ATF Form 8 Part II (5310.11) was uploaded into ROCIS as version 2.0 which referenced an incorrect form number. Additionally, after receiving phone calls/feedback from industry members, we are proposing to change Section C #6 from a statement format to a question format and clarify the required information from the respondents.

S ection C #6 has been edited to read as “Have all responsible persons (RPs) who are nonimmigrant aliens completed and signed ATF Form 5330.20, and submitted the form(s) with this application.  United States citizens are no longer required to submit this form.  Check here if ALL RPs are U.S. Citizens. N/A