The idea as stated by Kutter that "BATF agents on a compliance check will advise against such actions [providing a copy of their license to verify and assist]..." flys in the face of what is stated on the FFL itself. Maybe the part about an "ORIGINAL signature" has changed with the renewing of FFL's since 1/1/08, and the allowing of e-mail and fax copies, but if such "non-original-signature" copies are allowed now, why would the BATF tell a FFL not to provide them? And the idea that "...Everyone wants a copy of that license and only one person has it and doesn't have to give it to anyone other than another FFL." is strange in so far as the FFL's I have in my possession require the exact opposite as stated on their face and quoted above. Strange that there are so many opinions on how to avoid simple compliance. EDM
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EDM just read some of the updates provided by the BATFE to dealers over the last few months/couple of years and you'll see the changes that have been implimented. The hard copy FFL's did & still does in fact demand an ink signiture, but now FAX and Emailed copys are acceptable between FFLs along with their 'electronicly' transmitted signitures on them.
If a hard copy of the license is still used in the exchange, then yes an original ink signiture is required on them. If the two parties have their heads in the game, they will also exchange other forms of ID to verify in a FTF dealing if you don't know the other party. Again,,too many copys floating around.
The EZCheck will verify online if you doubt in a long distance transaction but will not verify C&Rs nor Ammo Manufacturers licenses.
I don't debate that the orig posted wanted to be beyond reproach and not cut corners, that is quite obvious and commendable.
I usually see people doing things the other way around. Mailing guns w/o declaring them (long box...uhh,,Golf Clubs..), unlicensed people sending pistols by USPO, ammo in the mail, guns interstate w/o using an FFL, etc. Goes on all the time.
It's not "strange that there are so many opinions around on how to (avoid?) compliance",,,it's very simple really.
As far as what a BATFE agent will tell you about distributing your FFL copys to UNLICENSED persons for shipping purposes,,,that is what I was told by the BATFE agent during the last 2 compliance checks I had, the most recent 3 weeks ago. No prompting of the issue on my part. I'm also sure it will vary as all opinions do from agent to agent, but it has always been my way of dealing with it too..Sure I have provided such to some folks I know well, but that I can keep track of. Others I know hand them out like candy to get business.
The UPS gets their notice of a 'gun in parcel' in writting on the shipping bill either at the counter or if you have pickup service on the daily shipping ledger,.. The USPO gets theirs in writting when they ask if "there is anything liquid, fragile, hazardous, etc" in the package. That's the cue to let 'em know that there is a firearm inside (falls under the USPO heading of Pub52 items) and a written statement is made of their likeing. They usually don't even reallize that one is needed and don't know what to do with it anyway, but at least you've done your part.
The only time an FFL is required to provide a copy of the FFL license is to another FFL (for an acquisition), or to a LE agency/agent. There is nothing strange nor confusing about that in my statement. An FFL may choose on their own to provide a copy to a nonlicensee (for ease of shipping as in this case) but they are not required to.
It's not always easy to stay abreast of all the rules and regs as they are constantly changing and will probably be even more of a challenge in the next few years. But if you want to stay in business and not become the focus of an investigation, unwitting or not,, you keep as up to date as you can and try to keep track of everything that goes on.
