Multiple Firearm Sales & ATF Form 3310.4: The Complete FFL Guide
When two or more handguns go to the same buyer within five consecutive business days, the ATF requires a report. Here's exactly when Form 3310.4 applies, how to complete it, what happens when you miss it, and how to build it into your workflow.
What Is ATF Form 3310.4?
ATF Form 3310.4 — the Report of Multiple Sale or Other Disposition of Pistols and Revolvers — is a federal reporting form required under 18 U.S.C. § 923(g)(3)(A). It must be filed any time an FFL sells or otherwise disposes of two or more pistols or revolvers to the same unlicensed buyer within five consecutive business days.
The purpose is straightforward: multiple handgun purchases in a short window are a known indicator of firearms trafficking. The report gives the ATF and local law enforcement visibility into these transactions so they can identify potential straw purchasing or trafficking patterns.
Form 3310.4 is separate from — and in addition to — Form 4473. Each individual firearm transfer still requires its own completed 4473 and NICS check. The 3310.4 is a reporting layer on top of those transactions.
Missing or late Form 3310.4 filings are among the most commonly cited ATF compliance violations — and one of the easiest to prevent once you understand the trigger conditions and build the report into your workflow.
When Is Form 3310.4 Required?
The reporting obligation triggers when all three conditions are met simultaneously:
- Two or more pistols or revolvers — handguns only. Rifles and shotguns do not count toward the threshold (with one exception, covered below).
- Same buyer (transferee) — the same unlicensed individual is the actual transferee on each transaction.
- Within five consecutive business days — calendar business days, not seven calendar days. Weekends and federal holidays your store is closed do not count.
Examples That Trigger Reporting
- Customer buys two handguns in a single transaction on Monday → report required
- Customer buys one handgun Monday, another handgun Thursday → within five business days → report required
- Customer buys one handgun Monday, returns Friday, buys another the following Monday → count the business days — if it's within five, report required
- Customer redeems two pawned handguns on the same day → pawn redemptions are dispositions → report required
Examples That Do NOT Trigger Reporting
- Customer buys two rifles → rifles are excluded (unless in a border state under the demand letter program)
- Customer buys one handgun and one rifle → only one handgun, threshold not met
- Two different customers each buy one handgun → different buyers
- Customer buys one handgun, then buys another eight business days later → outside the five-day window
The five-day window spans across separate transactions and separate 4473s. Many FFLs only flag same-day multi-gun purchases but miss the scenario where a buyer returns two days later for a second handgun. Your system needs to track buyers across transactions, not just within a single sale.
Border State Demand Letter: Rifles Count Too
In 2011, the ATF issued Demand Letter 3, which requires FFLs in four border states — Arizona, California, New Mexico, and Texas — to report multiple sales of certain rifles in addition to handguns.
The rifle reporting requirement applies when:
- The rifles are semi-automatic
- They are greater than .22 caliber (including .223/5.56)
- They accept detachable magazines
- Two or more are sold to the same buyer within five consecutive business days
This means in border states, an AR-15-pattern rifle sale can trigger the same reporting requirement as handguns. The report is filed using the same Form 3310.4.
How to Complete Form 3310.4
The form itself is straightforward — simpler than a 4473. But it must be completed accurately and filed on time.
What the Form Requires
- FFL information — your license number, business name, and address
- Buyer information — full name, date of birth, address, height, weight, race, sex, and government-issued ID number. This should match the corresponding 4473(s).
- Firearm information — for each firearm: manufacturer/importer, model, serial number, type, and caliber. All firearms in the reportable window must be listed.
- Transaction dates — the date(s) of the sale(s)
- NICS transaction number(s)
Filing Deadlines and Recipients
The completed form must be transmitted no later than the close of business on the day the multiple sale occurs. That means the day the second (or subsequent) qualifying handgun is transferred — not when you realize the reporting threshold was met.
The form must be sent to two recipients:
- ATF — the original goes to your local ATF office (or via the designated submission method)
- State or local law enforcement — a copy goes to the chief law enforcement officer (CLEO) in the buyer's place of residence. This is typically the local police chief or county sheriff.
You retain a copy for your records.
The filing deadline is the day of the triggering transaction. If a customer bought one handgun Monday and returns Wednesday for a second, the 3310.4 must be filed by close of business Wednesday — not Monday, and not "within a few days."
How to Count Five Consecutive Business Days
The five-business-day window is where most FFLs make mistakes. The counting method is similar to the NICS 3-business-day rule but applied differently.
The Rules
- Start counting from the first transaction. The day of the first sale is Day 1.
- Business days only. Exclude Saturdays, Sundays, and days your business is closed for federal holidays.
- Any qualifying handgun sale to the same buyer within that window triggers the report.
Example
Customer buys a Glock 19 on Monday (Day 1). The five-business-day window runs through Friday (Day 5). If that same customer purchases any additional handgun Monday through Friday, you must file Form 3310.4 listing both firearms.
If instead the customer returns the following Monday (Day 6), you're outside the window. No report required for those two transactions — but the new Monday starts a fresh window for future purchases.
Pawn Shops: Why Redemptions Count
This is the section that catches pawn-heavy FFLs off guard. A pawn redemption is a disposition from your A&D book. When a customer redeems two or more pawned handguns within five business days, that triggers the reporting requirement — even though the customer originally owned those firearms.
It doesn't matter that the guns were already theirs. The legal framework treats the redemption as a transfer from FFL to non-licensee, which is why a 4473 and NICS check are required for each one. The same logic applies to the multiple sale report.
If a customer pawns three handguns and redeems all three on the same day, you need three 4473s, three NICS checks, and one Form 3310.4. This is one of the most frequently missed compliance requirements in pawn operations.
What Happens When You Miss a 3310.4
Failing to file Form 3310.4 — or filing it late — is a federal violation under 18 U.S.C. § 924(a). During ATF compliance inspections, IOIs cross-reference your A&D records and 4473 files to identify multiple handgun dispositions to the same buyer within five-day windows. If they find unreported transactions, that's a finding.
Consequences range from a warning letter to license revocation, depending on the number of missed reports, whether a pattern exists, and whether the missed reports correlate with firearms later used in crimes.
Common Inspection Findings
- No 3310.4 filed — the FFL didn't realize the threshold was met
- Late filing — the form was filed days or weeks after the triggering transaction
- Incomplete form — missing firearms, wrong buyer info, or missing CLEO copy
- Only one recipient — the ATF received a copy but the CLEO did not, or vice versa
Building a 3310.4 Workflow for Your Store
The biggest risk factor isn't complexity — it's awareness. Most missed reports happen because the FFL didn't realize the threshold was met. Here's how to prevent that:
1. Flag at the Point of Sale
Every time a handgun sale is processed, check whether the same buyer has purchased another handgun within the past five business days. This is a manual step on paper systems and an automated one in digital systems.
2. Maintain a Multiple Sale Log
Keep a separate log — physical or digital — that tracks all handgun dispositions with buyer name and date. Review it daily. When a name appears twice within the window, that's your trigger.
3. Complete and File Same Day
Don't set the form aside to file later. Complete it immediately when the triggering transaction occurs. Mail or transmit the ATF copy and the CLEO copy before close of business.
4. Keep Your Copy Organized
Your retained copy should be filed with or cross-referenced to the corresponding 4473s. During an inspection, the IOI will want to see the 3310.4, the 4473s, and the A&D entries — make it easy to connect all three.
5. Train Every Employee
Everyone who processes a handgun sale needs to understand the five-day window, the reporting trigger, and the filing procedure. Post the workflow at the counter. Include it in new-hire training.
E4473's digital platform automatically flags when a buyer's handgun purchase triggers the five-business-day reporting threshold. No manual tracking, no missed reports. The system cross-references buyer data across all transactions and alerts your staff before the transfer is completed. Schedule a demo →
Record Keeping Requirements
You must retain a copy of every Form 3310.4 you file. The ATF does not specify a separate retention period for 3310.4 — the standard practice is to retain them alongside your 4473 records for the 20-year retention period (per 27 CFR 478.129) or until you discontinue business.
Organize your retained copies so they're cross-referenced to the corresponding 4473s. An IOI shouldn't have to ask you to find the 3310.4 that goes with a set of transactions — it should be immediately apparent.
Frequently Asked Questions
Does a 3310.4 replace the 4473?
No. Each firearm transfer still requires its own Form 4473 and NICS check. The 3310.4 is an additional reporting requirement on top of those.
What if the customer buys a handgun and a rifle in the same transaction?
Rifles don't count toward the handgun threshold (unless you're in a border state and the rifle meets the Demand Letter 3 criteria). One handgun plus one rifle does not trigger a 3310.4.
What if I sell two handguns to the same buyer exactly five business days apart?
Day 1 through Day 5 is within the window. If both transactions fall within that range, the report is required.
Does the buyer know a report is being filed?
There is no federal requirement to notify the buyer that a 3310.4 is being filed. Some FFLs inform customers as a courtesy; others do not. It's your call.
Can I file the 3310.4 electronically?
The ATF accepts electronic submissions through certain channels. Check with your local ATF office for current submission methods. The CLEO copy may still need to be mailed or delivered.
What about private party transfers through my FFL?
If you facilitate a private party transfer and the recipient receives two or more handguns within five business days — even from different sellers — the reporting requirement applies because you are the transferring FFL on record.
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