By John Brown
For those of you who had the opportunity to read the last few articles on the “ATF Weight Loss Plan,” we promised you that we would provide you with enough information to help do away with some of the fears that incur with a typical inspection. For those of us who lay awake at night thinking, “Will they show up tomorrow?” this trepidation is from one thing, and one thing only: fear of the unknown. That simple issue has plagued mankind since time immemorial. When you have no idea what you are up against you have every reason to be afraid. So goes a typical inspection when Industry Operations Inspectors (IOIs) show up, show their credentials, and announce “we are here to do an inspection.” In any industry, an unannounced inspection will always bring out the fear in those of us that are being inspected. It is not necessarily because you have done anything wrong, that you know of, but it simply because of the break in your routine and most importantly, not knowing what to expect.
The NFATCA has been asking for a number of years for a little bit of notice of an inspection for dealers, but that request has yet to be granted. I often make the analogy of it’s kind of like your mother showing up at your house unannounced. Your wife first of all has a hissy fit and secondly everyone is running around trying to clean up everything at the last minute. If you had even a day notice you could at least tidy up before the inspection begins. On that front we will continue to try and work the magic to allow for at least a little bit of notice.
As we mentioned in our last article the final day of your inspection will entail what is routinely referred to as your “Closing Conference.” This is the official closing of your visit and serves as your report card on just how you fared during your inspection.
I often hear people refer to a “perfect inspection.” Ask any IOI in the country and unfortunately this is a rare and often unheard of event. We all make mistakes. The critical issue in a closing conference is to listen intently and make appropriate adjustments to whatever your IOI tells you about the results of your inspection. Everything from the minor details of simple violations to major violations – all are critical to understand and know how to correct. Keep in mind one very important issue. Most of the senior IOIs have been doing inspections for a long time and they generally know what they are doing. Therefore it is a good idea to pay attention to the details of the feedback. Every inspection will provide you with good feedback on changes you might want to think about with how you run your business on most every aspect of what you are required to do, in order to stay in compliance with regulations.
Your inspector will generally conduct the closing at your licensed premises. You should be prepared for this portion of your conference to last a couple of hours. In this portion of your inspection you will review any and all violations and discuss corrective action plans to fix any issues that need your attention. Don’t freak out at this juncture since a violation can be any minor issue, or in some cases can be rather serious which may lead to further action on the part of ATF personnel. These types of follow-on meetings are generally referred to as a “Warning Conference” and will require you to meet more senior ATF personnel at the local field office. If you are required to attend a warning conference the issues with your inspection are generally more serious and may require you to get some help. Most warning conferences are generally a more formal approach to violations and it is generally a good idea to get some advice on how you handle corrective action. We always recommend that you listen carefully to your local ATF advisors in the event of a conference and also seek outside advice. This is not a visit to the Principal’s office at school and is much more serious on how you move forward with any corrective action. There is a lot of help available to you from not only your ATF personnel but organizations like the NFATCA and many formidable attorneys that will assist you in more serious issues. If you are required to attend a warning conference seek outside help in making certain that you are prepared.
No matter what the outcome of your closing, or warning conference might be, remember one thing: The purpose of this closing segment is to assist in some type of “get well” plan. Most closing conferences will be the only chance you will have to see ATF personnel for quite a long time. They will present you with a lot of good information that will assist you in running your business. Pay attention, listen and learn from this conference, as some of the most important information you will receive about running a firearms business is available at this meeting. If you have questions, or issues that need resolution, your IOI can and will help you follow the regulations to the letter. Depending on your own attitude they can be your single largest asset or your single largest liability. Our advice is to listen and learn. This may be the most important two hours you spend in your business for many months to come. Make it count!
Given the fact that your inspection feels like it is finally over, make no mistake, it is not. As certain as the formal part of your inspection is over, the clock is ticking before your local inspectors will return and initiate the process once again. Use this time wisely to learn from your previous experience and prepare for your next inspection. Once again there are many resources available to assist you with learning how to deal with this process of running your business. There are specialists in the industry and a lot of information is available through the Internet. We would highly recommend that you socialize information from the Net with real experts in the industry.
If all else fails, call the NFATCA and we will gladly provide you with resources that can help your next experience be a little less painful.
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