Summary of ATF Requirements for Notification of Change of Control for a Federal Firearms License (FFL)

A “change of control” occurs when the licensed entity (e.g., a corporation or association) remains the same, but actual or legal control shifts—directly or indirectly—through mechanisms like stock ownership changes, operation of law, or other means.atf.gov This does not require an immediate new FFL application, but specific notification and follow-up steps are mandatory to maintain compliance under 27 CFR § 478.54.

Key Notification Requirements:

• Timeline: The licensee must provide written notification to the ATF within 30 days of the effective date of the change.
• Recipient: Send the notification to the Chief, Federal Firearms Licensing Center (FFLC), Bureau of Alcohol, Tobacco, Firearms and Explosives, 244 Needy Road, Martinsburg, WV 25405.
• Format and Content: The notification must be in writing, executed under penalties of perjury. It should include:
  • A description of the change (e.g., stock purchase, new controlling interest).
  • Details of previous and new owners/responsible persons (RPs), including full names, addresses, dates of birth, places of birth, citizenship status, and other identifying information.
  • A statement confirming the change and effective date.

Additional Submissions for New Responsible Persons:

If the change introduces new RPs (individuals with power to direct management and policies related to firearms), submit:

• ATF Form 7/7CR (Application for Federal Firearms License), Part B – Responsible Person Questionnaire (RPQ) for each new RP.
• Current passport-style photographs of each new RP.
• Completed FBI Fingerprint Cards (FD-258) for each new RP, with fingerprints taken by a qualified individual.
• A signed written request from a current/existing RP authorizing the addition of the new RP(s).

Post-Notification Steps:

• ATF may conduct a qualification inspection of the new owners/RPs upon receipt.
• The existing FFL remains valid until its expiration date. However, upon expiration, the entity must file a new ATF Form 7/7CR as a renewal, incorporating the changes.
• If the change involves creating a new legal entity (e.g., full business transfer), such a transaction does not qualify for this type of notice; a new FFL application is required instead of a notification.

Best Practices and Notes:

• Retain copies of all submissions and consider sending via certified mail for proof of delivery.
• Consult ATF regulations (27 CFR §§ 478.21, 478.44, 478.51, 478.53, 478.54) or contact The Davis Law Firm for case-specific guidance, as non-compliance can result in license revocation or penalties.
• This process applies to FFLs other than collectors; for NFA items or explosives permits, additional rules may apply.

SAMPLE LETTER NOTIFICATION OF CHANGE OF CONTROL FOR A FEDERAL FIREARMS LICENSEE

[Your Company Letterhead or Name and Address]
[Your Full Address]
[City, State, ZIP Code]
[Email Address]
[Phone Number]
[Date]

Chief, Federal Firearms Licensing Center
Bureau of Alcohol, Tobacco, Firearms and Explosives
244 Needy Road
Martinsburg, WV 25405

Subject: Notification of Change of Control for Federal Firearms License [FFL Number]

Dear Chief, Federal Firearms Licensing Center:

I am writing on behalf of [Your Company Name or Legal Entity Name], the current holder of Federal Firearms License (FFL) number [Insert FFL Number Here], to formally notify the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) of a change of control in the ownership of the licensed entity, as required under federal regulations. This change became effective on [Insert Effective Date of Change, e.g., MM/DD/YYYY].

Details of the Change:

• [Provide a brief description of the change, e.g., “The change involves a stock purchase where [New Owner’s Name or Entity] has acquired controlling interest in the company. The legal entity remains the same, but control has transferred to new owners.”]
• Previous Owner(s)/Responsible Person(s): [List names, titles, and any relevant details of the prior owners or responsible persons].
• New Owner(s)/Responsible Person(s): [List full names, addresses, dates of birth, places of birth, citizenship status, and any other identifying information as required on ATF Form 7 (Application for Federal Firearms License)].

In accordance with ATF guidelines, enclosed with this letter are:

• ATF Form 7/7CR (Application for Federal Firearms License), Part B – Responsible Person Questionnaire (RPQ) for each new RP.
• Current photographs (passport-style) of each new responsible person.
• Completed FBI Fingerprint Cards (FD-258) for each new responsible person, including fingerprints taken by a qualified individual.
• A signed written request from a current/existing RP authorizing the addition of the new RP(s).

We understand that upon receipt of this notification, ATF will conduct a qualification inspection of the new owner(s) and responsible persons. Please contact me at [Your Phone Number] or [Your Email Address] to schedule the inspection or if any additional information is required. We are committed to full compliance with all ATF regulations and look forward to your guidance.

Thank you for your attention to this matter.

Sincerely,

[Signature]
[Your Full Name]
[Your Position/Title, e.g., Owner or Authorized Representative]

Enclosures:

• Photographs of new responsible persons
• FBI Fingerprint Cards (FD-258) for new responsible persons
• [Any other supporting documents, e.g., copies of stock transfer agreements or legal documents evidencing the change, if applicable]

Signed Request:
I [current/existing Responsible Person] hereby request the addition of the new Responsible Person(s), as described in this letter.

Sincerely,

[Signature]
[Existing/Current Responsible Person’s Full Name]
[Existing/Current Responsible Person’s Position/Title, e.g., Owner or Authorized Representative]

.—————————

Note: This notification must be submitted within 30 days of the change of control. Retain a copy for your records and consider sending via certified mail for proof of delivery. If the change involves a complete transfer to a new legal entity, a new FFL application may be required instead of this notification. Consult the ATF website or contact The Davis Law Firm at 866-545-4867 or via e-mail at [email protected].