Supporting Statement OMB 1140-0019 ATF Form 8 2024.09.05_508

Federal Firearms License (FFL) RENEWAL Application
ATF Form 8 (5310.11) Part II
OMB Control Number 1140-0019
OMB Expiration Date: XX/XX/XXXX

SUPPORTING STATEMENT FOR
Federal Firearms License (FFL) RENEWAL Application
ATF Form 8 (5310.11) Part II
A. JUSTIFICATION
1.
Explain the circumstances that make the collection of information necessary.
Identify any legal or administrative requirements that necessitate the collection. Attach a
copy of the appropriate section of each statute and regulation mandating or authorizing
the collection of information.
Title 18 of the United States Code, Chapter 44 (18 U.S.C. Chapter 44) provides that no
person may engage in the business of importing, manufacturing, or dealing in either
firearms, or ammunition, without first obtaining a license to do so. These activities are
licensed for a specific period. The benefit of a collector’s license is also provided for in the
statute. In order to continue to engage in the afore mentioned firearms activities without
interruption, licensees must renew their Federal Firearms License (FFL) by filing Federal
Firearms License (FFL) RENEWAL Application -ATF Form 8 (5310.11) Part II, prior to
its expiration.
ATF requests approval to make the following changes to OMB 1140-0019 (Federal
Firearms License (FFL) RENEWAL Application ATF Form 8 (5310.11) Part II):
I.
II.
III.
IV.
V.
VI.
VII.
VIII.
IX.
X.
XI.
XII.
XIII.
XIV.

Entire Form: Changed formatting of form.
Page 1: Removed a majority of the pink background.
Page 1 and 2: Changed some font to show italics or bolding.
Page 1: Made Renewal Amount Due and Amount to be Paid auto-filled upon printing
of application.
Page 1: Updated due date information from “DUE PRIOR TO” to “DUE NO LATER
THAN”.
Page 1: Updated mailing address from “Federal Firearms Licensing Center” to “ATF”.
Page 1: Removed option to pay by Diner’s Club.
Page 1: Updated method of payment options.
Page 1: Removed payment charge information. This information in the Instructions.
Page 1: Removed option to request Letter of Authorization.
Page 1: Removed FFL number from the center of the form and the expiration date from
the footer of the form.
Page 1: Part A: Updated sections for current FFL phone, fax, business email address
information; also made business email a required field.
Page 1: Part A: Removed ability to amend address and business name of FFL on
Renewal Form and added reference information regarding the Application for
Amended Federal Firearms License.
Page 1: Removed note regarding FFLs not being transferable. This information is now
in the Instructions.
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Federal Firearms License (FFL) RENEWAL Application
ATF Form 8 (5310.11) Part II
OMB Control Number 1140-0019
OMB Expiration Date: XX/XX/XXXX

XV. Page 1: Part A: Updated sections for Updated FFL Information and referenced note.
XVI. Page 1: Part B: Added verbiage “(please provide at least one hour in which you can be
contacted by ATF Personnel)”.
XVII. Page 1: Part B: Removed “Note: You do NOT have to list hours of operation if you are
a Gunsmith. If this applies to you, please check the appropriate box. Gunsmithing
activities only” and the corresponding box indicating gunsmithing activities only.
XVIII. Page 1: Part B: Updated table where license holders enter their hours of operation.
XIX. Page 2: Part C: Header – Updated sectional instructions.
XX. Page 2: Part C: Question 4 – Updated question to ask “You MUST send a “copy” of
this application to CLEO. Has a completed COPY of this renewal application form
(front & back) been sent or delivered to the Chief Law Enforcement Officer (CLEO) of
the locality in which the premises is located? See Instruction #7”.
XXI. Page 2: Part C: Question 5 – Added reference to “See Definition #4” and changed final
sentence to state “ONLY Collectors of Curios and Relics (Type 03) OR Manufacturers
of Ammunition (Type 06) should check N/A”.
XXII. Page 2: Part C: Question 6 – Updated to state “If yes, provide a letter signed by a
current RP requesting the change of RPs. Also, each new RP must provide a Part B RPQ of Form 7/7CR, fingerprint card & photo. See Instruction #4”.
XXIII. Page 2: Added references to Instructions and Definitions.
XXIV. Page 2: Signature: Added “(Must be a current RP to sign. See Definition #7)”.
XXV. Instructions and Definitions Sections: Added section headers.
XXVI. Instructions: Added instructions, which changed the numbering of existing
instructions.
XXVII. Instructions and Definitions Sections: Made statement modifications and
clarifications.
XXVIII. Instructions and Definitions Sections: Added at the top of both pages,
“IMPORTANT: This form is not available online. It is sent by ATF prepopulated 90
days prior to expiration. If this renewal form is not submitted to ATF by the date of
expiration and received timely, the current license will not be renewed and an
application for a new license and associated fee will need to be submitted. Complete
your form “UPON RECEIPT” and mail immediately with payment to ATF, P.O. Box
6200-20, Portland, OR 97228-6200. Retain a copy of the application for your records.”
XXIX. Instructions: Added Instruction #3: “Please provide payment by check, money order,
or acceptable form of credit card. For credit cards, ensure you sign and date the form
under the “Method of Payment” section and understand your signature authorizes the
amount of the renewal fee due. A charge from ATF Licensing Fee will be reflected on
you credit/debit card statement. In the event the license/permit is not issued, the above
amount will be credited to the card mentioned above.”
XXX. Instructions: Updated instruction on how to add a Responsible Person and the
documents required for the new RP to submit.
XXXI. Instructions: Removed instruction stating, “The certification of the renewal form must
be signed by the collector, owner, a partner, or in the case of a corporation, associates,
etc., by an officer duly authorized to sign for the applicant.”
XXXII. Instructions: Instructions 8 and 9: Added email addresses for Imports Branch and
NFA Division.
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Federal Firearms License (FFL) RENEWAL Application
ATF Form 8 (5310.11) Part II
OMB Control Number 1140-0019
OMB Expiration Date: XX/XX/XXXX

XXXIII. Instructions: Added Instruction #11: “Change of Control – Per regulation, in the case
of a corporation or association holding a license under this part, if actual or legal
control of the corporation or association changes, directly or indirectly, whether by
reason of change in stock ownership or control (in the licensed corporation or in any
other corporation), by operations of law, or in any other manner, the licensee shall,
within 30 days of such change, give written notification thereof, executed under the
penalties of perjury, to the Chief, Federal Firearms Licensing Center. Upon expiration
of the license, the corporation or association must file a Form 7/7CR (Firearms) as
required by §478.44.
Note that a “Change of Control” pertains to the continued licensing of the “same exact
entity” which often does not require a brand-new license but may require you to
complete and submit a new Form 7 along with your renewal to meet the requirements
of the regulation. If the entity is dissolved and a new legal entity is created, this would
be a “Change in Ownership”. An FFL cannot be issued to an entity that no longer
exists. See Change of Ownership below. Contact ATF licensing personnel at
[email protected] if unsure.”
XXXIV. Instructions: Added Instruction #12: “Change of Ownership – FFLs are NOT
transferable. If there has been a change in OWNERSHIP of the firearms business or
collection activity requiring a new license name or new legal entity, even by the same
name, you MUST submit a NEW application ATF Form 7 (5310.12)/7CR(5310.16).”
XXXV. Instructions: Added Instruction #13: “Request Letter of Authorization (LOA) – ATF’s
receipt of a timely renewal application allows an active licensee to continue business as
usual until the license is renewed/issued or denied. No additional documentation is
required even if a renewal is issued after the current license expires, per §478.45.
However, if your vendors require validity of your current license, and your license has
not yet been issued, an LOA can be requested, and FFL eZCheck
(https://fflezcheck.atf.gov/fflezcheck/) will reflect the issuance (and expiration date) of
the LOA. The LOA becomes void once the license is issued or denied. Completing
your application upon receipt helps to ensure your license will be renewed prior to the
due date, thus eliminating the possible need for an LOA.”
XXXVI. Instructions: Added Instruction #14: “FFL eZCheck - The purpose of FFL eZCheck is
to allow an FFL or other user to verify that a Federal Firearms License (FFL) is valid.
In FFL eZCheck, enter the first 3 digits and the last 5 digits of the FFL being verified in
the blocks provided and select the SUBMIT button. Selecting the RESET button will
clear previously entered data. FFL eZCheck does not post/validate Type 03 (Collectors
of Curios and Relics) and Type 06 (Manufacturer of Ammunition) licenses. You may
contact the FFL eZCheck hotline at (877) 560-2435 to receive verbal confirmation for
Type 03 & Type 06 licenses.”
XXXVII. Definitions: Updated Definition #3 Misdemeanor Crime of Domestic Violence to state,
“A Federal, including a general court-martial, State, local, or tribal offense that is a
misdemeanor under Federal, State, or tribal law and has, as an element, the use or
attempted use of physical force, or the threatened use of a deadly weapon, committed
by a current or former spouse, parent or guardian of the victim, by a person with whom
the victim shares a child in common, by a person who is cohabitating with or has
cohabitated with the victim as a spouse, parent, or guardian, or by a person who has a
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Federal Firearms License (FFL) RENEWAL Application
ATF Form 8 (5310.11) Part II
OMB Control Number 1140-0019
OMB Expiration Date: XX/XX/XXXX

current or recent former dating relationship with the victim (as defined in U.S.C.
§921(a)(37)). The term includes all misdemeanors that have as an element the use or
attempted use of physical force or the threatened use of a deadly weapon (e.g., assault
and battery), if the offense is committed by one of the defined parties. (See Exception
in the definition of “Prohibited Person”). A person who has been convicted of a
misdemeanor crime of domestic violence also is not prohibited unless; (1) the person
was represented by a lawyer or gave up the right to a lawyer; or (2) if the person was
entitled toa jury, was tried by a jury, or gave up the right to a jury trial. Person subject
to this exception should mark “no” in the applicable box.”
XXXVIII. Definitions: Updated Definition #7 Responsible Person to state, “Any individual
possessing, directly or indirectly, the power to direct or cause the direction of the
management and policies of a sole proprietorship, corporation, company, partnership,
or association, insofar as they pertain to firearms.”
XXXIX. Definitions: Updated Definition #8 Chief Law Enforcement Officer (CLEO) to state,
“The Chief of Police, the Sheriff, or an equivalent designee of such individual, of the
locality in which the premises sought to be licensed, is located.”
XL. Definitions: Added Definition #9: “Partnership – As it relates to FFL licensing, a
“partnership” would list each of the individuals’ names as the “licensee” name
(licensed entity) of the FFL. In this case, if any of these partners should no longer be
associated with this license, you will need to reapply for a new license upon expiration
as the licensed entity has changed. However, if there are partners under a corporation
or LLC, the Corporation or LLC can continue when one or more of the partners depart
as long as the entity remains the same and is not dissolved as a result of the loss of
partner(s). Also see Instructions #11 and #12.”
2.
Indicate how, by whom, and for what purpose the information is to be used. Except
for a new collection, indicate the actual use the agency has made of the information
received from the current collection.
The information collected on the Federal Firearms License (FFL) RENEWAL Application
-ATF Form 8 (5310.11) Part II is used to identify the applicant and determine their
eligibility to retain their current license. The renewal form is filed by the licensee, so they
can continue to engage in firearms activities. ATF personnel will analyze the submitted
application to determine the applicant’s eligibility to renew the requested license. As long
as 18 U.S.C. 923 requires that a person wishing to engage in the firearms business or the
collection of curios and relics firearms pays a fee and file an application, this form or one
like it will be necessary. Without the information provided by applicant on the renewal
form, ATF might renew the FFL for a person who is prohibited from engaging in firearms
activities.
3.
Describe whether, and to what extent, the collection of information involves the use
of automated, electronic, mechanical, or other technological collection techniques or
other forms of information technology, e.g., permitting electronic submission of
responses, and the basis for the decision for adopting this means of collection. Also,
describe any consideration of using information technology to reduce burden.
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Federal Firearms License (FFL) RENEWAL Application
ATF Form 8 (5310.11) Part II
OMB Control Number 1140-0019
OMB Expiration Date: XX/XX/XXXX

The Federal Firearms License (FFL) Renewal Application -ATF Form 8 (5310.11) Part II
is issued by the ATF’s Federal Firearms Licensing Center (FFLC) in Martinsburg, West
Virginia. The form is unavailable on the ATF website because it is electronically generated
from ATF’s FFL database, approximately 90 days prior to the expiration of an existing FFL
license. The form is pre-populated with data related to the expiring license, including the
appropriate renewal fee. The pre-populated data reduces the respondent burden and
processing delays, while increasing the accuracy of form completion. Once generated, the
partially pre-filled form is distributed to respondents for completion of the remaining
applicable fields, signature, and submission of payment for processing. All completed
forms must be accompanied by payment via check, money order, or credit/debit card for
processing. Electronic or online payment options to renew an FFL is currently unavailable.
4.
Describe efforts to identify duplication. Show specifically why any similar
information already available cannot be used or modified for use for the purposes
described in Item A.2 above.
ATF uses a uniform subject classification system to identify duplication and to ensure that
any similar information already available cannot be used or modified for use for the
purpose of this information collection.
5.
If the collection of information impacts small businesses or other small entities,
describe any methods used to minimize burden.
This collection of information has no significant impact on small businesses or other
entities.
6.
Describe the consequence to federal program or policy activities if the collection is
not conducted or is conducted less frequently, as well as any technical or legal obstacles to
reducing burden.
Less frequent use of this information collection would pose a threat to public safety, since
the collected information helps ATF to ensure that the applicant remains eligible for an
FFL Renewal.
7.
Explain any special circumstances that would cause an information collection to be
conducted in a manner:
• requiring respondents to report information to the agency more often than
quarterly;
• requiring respondents to prepare a written response to a collection of information in
fewer than 30 days after receipt of it;
• requiring respondents to submit more than an original and two copies of any
document;
• requiring respondents to retain records, other than health, medical, government
contract, grant-in-aid, or tax records for more than three years;
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Federal Firearms License (FFL) RENEWAL Application
ATF Form 8 (5310.11) Part II
OMB Control Number 1140-0019
OMB Expiration Date: XX/XX/XXXX

in connection with a statistical survey, that is not designed to produce valid and
reliable results that can be generalized to the universe of study;
• requiring the use of statistical data classification that has not been reviewed and
approved by OMB;
• that includes a pledge of confidentially that is not supported by authority
established in statute or regulation, that is not supported by disclosure and data
security policies that are consistent with the pledge, or which unnecessarily impedes
sharing of data with other agencies for compatible confidential use; or
• requiring respondents to submit proprietary trade secret, or other confidential
information unless the agency can demonstrate that it has instituted procedures to
protect the information's confidentially to the extent permitted by law.
•

This information collection is conducted in a manner consistent with 5 C.F.R. § 1320.6.
8.
If applicable, provide a copy and identify the date and page number of publication
in the Federal Register of the agency's notice, required by 5 CFR 1320.8(d), soliciting
comments on the information collection prior to submission to OMB. Summarize public
comments received in response to that notice and describe actions taken by the agency in
response to these comments. Specifically address comments received on cost and hour
burden.
Describe efforts to consult with persons outside the agency to obtain their views on the
availability of data, frequency of collection, the clarity of instructions and recordkeeping,
disclosure, or reporting format (if any), and on the data elements to be recorded,
disclosed, or reported.
Consultation with representatives of those from whom information is to be obtained or
those who must compile records should occur at least once every 3 years -- even if the
collection-of-information activity is the same as in prior periods. There may be
circumstances that may preclude consultation in a specific situation. These
circumstances should be explained.
Both a 60-day and 30-day notice will be published in the Federal Register to solicit public
comments.
9.
Explain any decision to provide any payments or gifts to respondents, other than
remuneration of contractors or grantees.
No payment or gift to respondents is associated with this collection.
10. Describe any assurance of confidentiality provided to respondents and the basis for
the assurance in statute, regulation, or agency policy.
In accordance with the System of Records Notice (SORN) Justice/ATF-008 Regulatory
Enforcement Record System FR Vol. 68 No. 16 3558, dated January 24, 2003, completed
forms for this information collection are kept in a secured location at the ATF Federal
Firearms Licensing Center. ATF staff who process these forms have special security
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Federal Firearms License (FFL) RENEWAL Application
ATF Form 8 (5310.11) Part II
OMB Control Number 1140-0019
OMB Expiration Date: XX/XX/XXXX

clearances. Confidentiality is not assured.
11. Provide additional justification for any questions of a sensitive nature, such as
sexual behavior and attitudes, religious beliefs, and other matters that are commonly
considered private. This justification should include the reasons why the agency
considers the questions necessary, the specific uses to be made of the information, the
explanation to be given to persons from whom the information is requested, and any
steps to be taken to obtain their consent.
Questions of a sensitive nature are asked on the application to determine the continued
eligibility of the applicant to renew an FFL.
12.
Provide estimates of the hour burden of the collection of information. The
statement should:
• Indicate the number of respondents, frequency of response, annual hour burden,
and an explanation of how the burden was estimated. Unless directed to do so,
agencies should not conduct special surveys to obtain information on which to base
hour burden estimates. Consultation with a sample (fewer than 10) of potential
respondents is desirable. If the hour burden on respondents is expected to vary
widely because of differences in activity, size, or complexity, show the range of
estimated hour burden, and explain the reasons for the variance. General, estimates
should not include burden hours for customary and usual business practices.
• If this request for approval covers more than one form, provide separate hour
burden estimates for each form.
• Provide estimates of annualized cost to respondents for the hour burdens for
collections of information, identifying and using appropriate wage rate categories.
The cost of contracting out or paying outside parties for information collection
activities should not be included here. Instead, this cost should be included in Item
14.
Estimated Annualized Respondent Cost and Hour Burden

Activity

ATF Form 8
(5310.11)
Part II

Number of Frequency Total
Time Per Total
Hourly
Respondents
Annual
Response Annual
Rate*
Responses
Burden
(Hours)
1 time per
33,500 per
every 3
year
years
33,500
30 min
16,750

Unduplicated
Totals

Hourly rate source citation or you may enter a footnote:
7

Monetized
Value of
Respondent
Time

Federal Firearms License (FFL) RENEWAL Application
ATF Form 8 (5310.11) Part II
OMB Control Number 1140-0019
OMB Expiration Date: XX/XX/XXXX

There are approximately 33,500 respondents per year for this application collection. Each
respondent will complete this form once every three (3) years. The average number of
annual responses to this IC is 33,500. The total time to complete the form is 30 minutes.
Therefore, the total annual burden hours are 16,750.
13. Provide an estimate of the total annual cost burden to respondents or recordkeepers
resulting from the collection of information. (Do not include the cost of any hour burden
shown in Items 12 and 14).
• The cost estimate should be split into two components: (a) a total capital and
startup cost component (annualized over its expected useful life); and (b) a total
operation and maintenance and purchase of service component. The estimates
should take into account costs associated with generating, maintaining, and
disclosing or providing the information. Include descriptions of methods used to
estimate major cost factors including system and technology acquisition, expected
useful life of capital equipment, the discount rate(s), and the time period over
which costs will be incurred. Capital and start-up costs include, among other
items, preparations for collecting information such as purchasing computers and
software; monitoring, sampling, drilling and testing equipment; and record
storage facilities.
• If cost estimates are expected to vary widely, agencies should present ranges of
cost burdens and explain the reasons for the variance. The cost of purchasing or
contracting out information collection services should be a part of this cost burden
estimate. In developing cost burden estimates, agencies may consult with a sample
of respondents (fewer than 10), utilize the 60-day pre-OMB submission public
comment process and use existing economic or regulatory impact analysis
associated with the rulemaking containing the information collection, as
appropriate.
• Generally, estimates should not include purchases of equipment or services, or
portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory
compliance with requirements not associated with the information collection, (3)
for reasons other than to provide information or keep records for the government,
or (4) as part of customary and usual business or private practices.
No new cost is associated with this collection. However, the annual cost has increased due
to a change in the postal rate from $0.63 during the last renewal in 2023, to $0.73 in 2024.
Consequently, the new public cost burden will be reported as $24,455.00, which is equal to
.73 (mailing cost per respondent) * 33,500 (# of respondents).
14. Provide estimates of the annualized cost to the Federal Government. Also, provide
a description of the method used to estimate cost, which should include quantification of
hours, operational expenses (such as equipment, overhead, printing, and support staff),
any other expense that would not have been incurred without this collection of
information. Agencies also may aggregate cost estimates from Items 12, 13, and 14 into a
single table.
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Federal Firearms License (FFL) RENEWAL Application
ATF Form 8 (5310.11) Part II
OMB Control Number 1140-0019
OMB Expiration Date: XX/XX/XXXX

Annual cost to ATF is estimated as follows:
Direct Labor $ 1,967.04 (GS11-2 hourly rate x 48 hours)
Printing
$ 2,224.40 ($.0096 per imprint x 134,000 imprints {33,500 x 4 imprints}
+ $.014 per sheet of paper x 67,000 {33,500 x 2 pages})
Postal Costs $ 23,115.00 ($0.69 metered postage x 33,500 envelopes)
Total
$ 27,306.44
15. Explain the reasons for any program changes or adjustments.
There is no adjustment associated with this information collection. The annual burden
hours for this IC remained at 16,750.
16. For collections of information whose results will be published, outline plans for
tabulations, and publication. Address any complex analytical techniques that will be
used. Provide the time schedule for the entire project, including beginning and ending
dates of the collection of information, completion of report, publication dates, and other
actions.
The results of this collection will not be published.
17. If seeking approval to not display the expiration date for OMB approval of the
information collection, explain the reasons that display would be inappropriate.
ATF requests authorization to exclude the IC expiration date from the printed ATF Form
5310.11. This is due to the fact that printing the expiration date on the form will incur
higher printing costs to replace inventories that become obsolete when this IC is issued a
new expiration date. Public use of this form is unpredictable, so ATF must maintain a
substantial inventory of this IC instrument. Therefore, omitting the expiration date will
ensure that inventories can be quickly replenished, and forms can be made available for
public use, as often as needed.
18.

Explain each exception to the certification statement.
There are no exceptions to the certification statement.

B. COLLECTIONS OF INFORMATON EMPLOYING STATISTICAL METHODS.
This collection does/does not contain statistical data.

9