1140-0032 Supporting Statement-Justification - 508

DEPARTMENT OF JUSTICE
Bureau of Alcohol, Tobacco, Firearms and Explosives
Supporting Statement – Information Collection Request
Records of Acquisition and Disposition, Collectors of Firearms
OMB # 1140-0032

A. Justification
1. Necessity of Information Collection
The recordkeeping requirements as contemplated by 18 U.S.C. § 923, under the
Gun Control Act of 1968 (GCA), as amended, are for the primary purpose of
facilitating ATF’s authority to inquire into the disposition of any firearm in the
course of a criminal investigation. Because the regulations require uniform
formats for recordkeeping, the records serve a major secondary purpose: granting
ATF Officers the authority to examine a collector’s records for firearms traces or
compliance inspections, per 27 CFR §§ 478.23(c)(1) and (2). These compliance
inspections are also conducted under the authority of 18 U.S.C. §§ 923(g)(1)(A),
(B), (C), and (D).
The following changes are proposed to be made to the form:
• Justification revised to reflect a reduction in the number of respondents
• Justification revised to reflect a reduction in the public burden

2. Needs and Uses
Unlike other Federal Firearms Licensees, Licensed Collectors are not required to
use the ATF F 4473. Therefore, Collectors records are established by entering the
required information, (description of firearm, acquisition receipt, and disposition),
into the proper record book as mandated by 27 CFR § 478.125(f). The Collector
must record this information, no later than the close of the next business day
following the date of acquisition or 7 days following date of disposition of curios
and relics. The records must be maintained in bound form under the required
format. ATF may use the information for criminal investigations or inspections
for government purposes. The record retention requirement for this collection of
information is 20 years.
3. Use of Information Technology
Collectors record and maintain the required information on the premises of the
licensee (description of firearm, acquisition receipt, and disposition) in
accordance with the format required by 27 CFR § 478.125(f). See copy of the

required format attached to this information collection. ATF permits the use of
information technology. ATF Ruling 2016-1 details the approved use of
information technology for Acquisition and Disposition (A&D) records.
4. Efforts to Identify Duplication
The ATF subject classification system is used to identify duplication. No similar
information is available regarding this information collection.
5. Minimizing Burden on Small Business
This collection of information has no significant impact on small businesses.
6. Consequences of Not Conducting or Less Frequent Collection
Less frequent collection of this information would pose a threat to public safety as
the information is used for criminal investigations and firearms traces.
7. Special Circumstances
There are no special circumstances associated with this collection. This
requirement is conducted in a manner consistent with 5 CFR § 1320.6.
8. Public Comments and Consultations
A 60-day was published in the Federal Register, and received no public
comments. A 30-day notice was recently published in the Federal Register to
solicit public comments.
9. Provision of Payments or Gifts to Respondents
No payment or gift is associated with this information collection.
10. Assurance of Confidentiality
The records are maintained at the premises of the licensee in a secured location.
Confidentiality is not assured.
11. Justification for Sensitive Questions
No records of a sensitive nature are maintained.
12. Estimate of Respondent’s Burden
There are 56,928 respondents for this information collection, which is a reduction
in the number of respondents. Respondents will report once annually. The
estimated time to complete each report is 3 hours. The annual time burden
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associated with inspection reporting is 170,784 hours (3 hours x 56,928
respondents).
ATF does not have a data source to estimate the number of records produced
annually per respondent. Assuming that the average respondent creates or
maintains 1 record each, and the time needed to do so is estimated at 3 minutes,
the annual time burden to create and maintain records is 2,846 hours (3 minutes
divided by 60 minutes for 1 hour is .05. Take .05 minutes x 56,928 respondents =
2,846 hours).
The total annual burden hours for this collection is 173,630 (170,784 inspection
burden hours + 2,846 record creation/maintenance burden hours = 173,630),
which is a reduction in the public burden.
13. Estimate of Cost Burden
There is no new cost or annual cost associated with this collection.
14. Cost to the Federal Government
There is no cost to the Federal Government.
15. Reason for Change in Burden
The adjustments associated with this collection are due to the decrease in number
of respondents (Collector Licensees) and total annual burden hours.
16. Anticipated Publication Plan and Schedule
The result of this information collection will not be published.
17. Display of Expiration Date
ATF does not request approval to not display the expiration date of OMB
approval for this collection.
18. Exception to the Certification Statement
There are no exceptions to the certification statement.
B. Collections of Information Employing Statistical Methods
This collection of information employs no statistical methods.

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