Justification for No Material/Nonsubstantive Change

Supplemental Document: Justification for a no material/non-substantive change
ATF requests approval to enhance existing instructions for OMB 1140-0018 (ATF Form
7(5310.12)/7CR(5310.16)), to clarify the procedures for adding a Responsible Person (RP) to a
Federal Firearms License:
1. Modify 2nd sentence in instruction #1 at the top of Part B – Responsible Person
Questionnaire (Page 3)
In the future, if you need to add an additional Responsible Person (RP) to your FFL, the
RP being added may complete this Part B-Responsible Person Questionnaire. If adding a
responsible person to an existing license, be sure to include a signed written request from
an existing RP on the license, giving permission to add the new Responsible Person (see
instruction #7).

2. Add sentence to instruction box, under heading “If only adding a RP to an existing
FFL:” (Page 4)
Each Responsible Person being added must complete a separate questionnaire/ATF Form
7/7CR Part B and mail it, along with their fingerprint card and photograph, to: ATF, Attn:
FFLC, 244 Needy Rd, Martinsburg, WV 25405. Each questionnaire must be
accompanied by a signed written request from a current/existing RP on the license, giving
permission to add the Responsible Person.

3. Add verbiage to instruction #7 on the form’s Instruction/Definition Sheet
You can use Part B of this application to add a Responsible Person(s) to an existing FFL.
You must include a signed written request from a current/existing RP already on the
license, giving permission to add the new Responsible Person. We cannot process a form
to add an additional RP to an existing license without the written consent from an
existing RP on the license giving authorization for this action. If you are only submitting
Part B for this purpose…