I'm looking at getting my FFL or getting something at least to allow me to do gunsmithing and the duracoating and stay legal and keep the guns at my place over night to simplify things. I would be getting a license that would be out of my residence. I was told I would need a safe and a separate building from my residence to do and keep the guns in. I work a hectic schedule but also was told they are not issuing as many permits for part time people. Is there anyone out there who might be able to help me out understanding what I would have to do? I'm getting in way over my head on this. I did the default look it up on the internet and its more one persons opinion, but I'm looking more for facts. Any advice would be really appreciated, thanks again. I'm not really getting a FFL for manufacturing or dealing right now, since I don't think there is really any money in that, and really I just enjoy the duracoating I do and am just trying to make it simpler to do what I do, while staying legal.

When I looked into it you had to have a manufacturer's FFL to do any real work, and there was a $2400 yearly tax associated with it regardless of your volume of business. That's why I didn't...

Gotta be a better deal, man! May be a far reach, but why not question NRA or someone high like that for direction?

Why do you need an FFL to Duracoat?
As long as you are not shipping, or receiving firearms I do not think there is an issue. You are not making a profit on the gun, but a service. No different then people on here doing trigger jobs without a FFL.

The way I understand it unless you are planning on becoming a volume dealer, you will be nothing more than a record keeper for the feds. Small time dealer discounts from the wholesalers are not that much of a savings. The record keeping, the extra tax forms, etc. are a pain.

I know they have ruled that duracoating is not manufacturing and does not require the same license. There are 7 types the one I am looking at would be a type 1.

If you are keeping someone elses firearms overnight, doing anything to it, and receiving anything for it, you are in the firearms business.

I know a jeweler who used to do engraving, who had to pay a fine and nearly went to jail, and all he ever did was engraving firearms like for retirements and stuff.

I think your buddy should have got a better lawyer.

Wrong again.

You don't need a manufacturers license, but if you are doing work for others, and charging, and keeping guns overnight that are not yours, you are "engaged in the business", and need a license.

Google that too, don't just look for something that supports your idea.

Here, I'll do it for you:

http://www.atf.gov/firearms/faq/gunsmiths.html

Question 1:
Q: Is a license needed to engage in the business of engraving, customizing, refinishing or repairing firearms?
Yes. A person conducting such activities as a business is considered to be a gunsmith within the definition of a dealer

And to answer trigger jobs.....

10.A gunsmith buys government model pistols and installs “drop-in” precision trigger parts or other “drop-in parts” for the purpose of resale.

This would be considered the manufacturing of firearms, as the gunsmith is purchasing the firearms, modifying the firearms and selling them. The gunsmith should be licensed as a manufacturer

Here's your link in its entirety:
http://www.atf.gov/regulations-rulings/rulings/atf-rulings/atf-ruling-2010-10.htm

Read a little past what you quoted:
......If the person is performing such services only for a customer on firearms provided by that customer, and is not selling or distributing the firearms manufactured, the person would be a �dealer� as defined by 18 U.S.C. 921(a)(11)(B) and 27 CFR 478.11, requiring a dealer�s license, assuming the person is �engaged in the business� as defined in 18 U.S.C. 921(a)(21)(D) and 27 CFR 478.11 (i.e., �gunsmithing�).

Here's "engaged in the business" defined:

Gunsmithing



A dealer is �engaged in the business� of gunsmithing, as defined in 18 U.S.C. 921(a)(21)(D) and 27 CFR 478.11, when he/she receives firearms (frames, receivers, or otherwise) provided by a customer for the purpose of repairing, modifying, embellishing, refurbishing, or installing parts in or on those firearms. Once the work is completed, the gunsmith returns the firearms, and charges the customer for labor and parts. As with an individual customer, a licensed dealer-gunsmith may receive firearms (properly identified with a serial number and other information required by 27 CFR 478.92) and conduct gunsmithing services for a customer who is a licensed importer or manufacturer.

Sig226 is spot on.

Easiest way I explain it to people is that if you do anything to the serialized part of the gun you need to be licensed, even if part time.

An 01 can duracoat for a customer, but can't buy a beat up gun and duracoat to resell. Thats manufacturing and need to be an 07.

Thanks you guys didn't mean to start an argument between people, I was thinking the one I would need was an 01 FFL. Now to start on all the paperwork and getting setup, I suppose that may take a while.

Anyone know personally if it is more complicated to get a type 01 FFL for me to do duracoating if I am not planning on having regular business hours? My plan is to do it mostly local or over the internet. I have no intention of selling guns just duracoating or perhaps gunsmithing. I am just trying to establish the simplest way to do this.

You will need to have some sort of regular hours. They are getting very strict on this. Even if its at night, but they will require you to list what hours you will be open. There are less and less "kitchen table" FFL's now because of this.

Thanks I am trying to establish how I can accomplish this with success, because I may be working a rotating schedule so it may be more complicated to have regular hours at a shot while working my regular job.

Funny how non FFL holders get on here and try to tell the FFL holders the law. Amusing to say the least.

I am pretty sure that on my most recent FFL I listed the hours on Saturday from 6-7pm. That FFL is in a business location (office park where I can come and go). My kitchen table FFLs are about the same. On my 1st FFL, I listed "By Appt. Only." It was accepted that way. Round 2...I had to have at least one day and time.

The BATFE will still issue "kitchen table" FFLs. It is up to your municipality on weather or not they will allow it. As long as the city code allows it, you should be good to do it from home. You don't need a security system or anything like that. Basically, all you need is a door that locks.

When they come for your interview, they really don't demand much of you. They inform you of the requirements and take questions. It is really pretty simple.

First, check the city ordanance and ensure that your municipality allows for a home based FFL. I think you should further define the "gun smithing" work you plan on doing as well. If you put an AR lower on an AR upper, the ATF considers that "manufacturing" and you need a type 7. You can always submit the app, ask some questions at the interview, and the ammend the app per the guidance of the ATF inspector.

Thanks for the info, this is more what I was trying to establish, the only "gunsithing" I would be doing is duracoating. I don't do any actual gunsmithing other than for free on a friends gun with them there. Thanks again for the info, its what I was looking for in someone who knew from experience and not personal opinion.

Call your local ATF office they will guide you in the right direction. The ATF has clearly posted what is required on the website.

http://www.atf.gov/firearms/how-to/become-an-ffl.html

That should get you started.

Yeah that was the next thing I was going to do, I just wanted to be thanks be informed by other ffl holders prior to contacting them. Thanks for the info, I appreciate it.