What the Heck is a Curio And Relics FFL?

by bills 1. September 2011 06:33

 

    Note: This article first appeared in the Shotgun News. It is reprinted here with permission. All the text is as it appeared in the original article with the exception of updates related to pricing, URLs and timing.  


 
 
OVERVIEW
 
"Yes. This rifle is C&R eligible..."
 
These are Happy words indeed to a person carrying a 03 FFL (Federal Firearms License). Being C&R (Curio and Relic) eligible, this particular firearm can be purchased with a specialized 03 FFL, which is also known as a C&R FFL.
 
Holding a C&R FFL does not make you a dealer; rather it is a special license for firearms collectors. The major advantage to having a C&R FFL is that you can purchase firearms across state lines and receive them directly, just as a standard 01 FFL holder can. However, the 03 FFL does not entitle you to be in the business of reselling these firearms as a standard 01 dealer would do.
 
This article will take you through the how and whys of having a C&R FFL.
 
We begin with the history of the C&R FFL, followed by how to get one. After this are collecting thoughts and tips from several well-known C&R FFL holders. Finally, we will wrap up the article with a list of websites of interest to firearm collectors.
 
 
ORIGINS
 
The C&R FFL was established, in 1968, as part of Gun Control Act (18 U.S.C. Chapter 44) of 68. A C&R FFL is a way for a collector of curios or relics (definition below) to "transport, ship, receive, and acquire curios or relics in interstate or foreign commerce, and to dispose of curios or relics in interstate or foreign commerce to any other Federal firearms licensee." The privileges conferred by this license extend only to curio or relic transactions.
 
It is an important point to note right up front, that one sentence in this legislation is "Subject to other applicable provisions of the law and regulations...". This means that local laws can and do impact what you can do with a C&R FFL.
 
If you are unsure of something, be sure to check the local and state laws. At the end of this article are some sites to help in looking for this additional information.
 
 
So What IS a Curio and Relic?
 
At a high level, the answer is a military firearm that is 50 or more years old. There are (of course) exceptions of inclusion and exclusion to this high level rule, which we will go into more depth below.
 
ATF defines a firearm as a Curio and Relic IF it "Has been manufactured at least 50 years prior to the current date, but not including replicas; OR, is certified by the curator of a municipal, state or Federal museum which exhibits firearms to be curios or relics of museum interest; OR derives a substantial part of their monetary value from the fact that they are novel, rare, bizarre, or from the fact of their association with some historical figure, period, or event."
 
The ATF refines this definition for us by providing a list of firearms, which Do and Do Not fall within the C&R rule. These lists are provided in the websites at the end of this article.
 



Figure 1: A sample of what can be purchased with a C&R FFL
 
 



Figure 2: Walther P38

HOW TO GET ONE
 
The starting reference point for all of this information is found at: http://www.atf.treas.gov/firearms/faq/faq2.htm
 
The basic idea is that you will apply for a license, by filling out a form from the ATF (and paying the appropriate fees, which are now $30 for 3 years).
 
Here are the steps to acquiring a C&R FFL:
 

1.       Download, or request by mail, ATF Form 7, Application for License, or ATF Form 7CR, Application for License (Collector of Curios or Relics).

Note: These forms may be obtained from the Firearms and Explosives Licensing Center in Atlanta, Georgia, (404) 417-2750, or your local ATF office; or the application form can be downloaded from the ATF site, shown below.

2.       Fill this form out and submit it, with the appropriate fee, according to the instructions on the form.

3.       You should sign a copy of the forms sent to the ATF and send it to the local CLEO (Chief Law Enforcement Officer) in your area, along with a short note letting them know that you have applied to the ATF to become a C&R collector.

4.       You will wait from 4 to 8 weeks from the time that you submit your application until you receive your license.

5.       Once you receive your license, you will be able to purchase C&R items. You will need to send a signed copy of your FFL to the dealer that you are ordering the item from.

6.       Do not sign the original copy of the license that you receive. Make a number of photocopies of it, and then sign them, in ink, as you send them to the places that you want to order firearms from. (The copies that the dealers receive must be signed in ink!)

The Bound Book
 
After you have received a C&R firearm, you will "Log it" into a bound book, which is a simple listing of the date of purchase and related information. The bound book, is also known as a Acquisition and Disposition Record. You can keep this information in an electronic format, such as a spreadsheet, but must receive ATF approval to do so. A place to download an electronic bound book, once you've determined that you can go that route, is shown under the legal sites below.
 
The Bound Book record for acquiring a firearm lists things the manufacturer, model, serial number, type, caliber, date and the name/address of whom you got it from. The disposition side includes the date, name, drivers' license or identification for non-licensees and residency documentation if it is going to an alien. See the picture of the bound book below.

 
8 THINGS TO KNOW AS A C&R HOLDER
 
1. Am I a Dealer?
 
A C&R FFL entitles you to collect firearms.

 
"While a licensed collector may acquire curios or relics and dispose of same from a personal collection, A LICENSED COLLECTOR IS NOT AUTHORIZED TO ENGAGE IN BUSINESS AS A DEALER IN ANY FIREARMS, INCLUDING CURIOS OR RELICS." -- ATF site.
 
 
2. How do I track purchases?
 
You need to log all firearms obtained via the C&R FFL, into a "bound book" (see things to track below).
 
 
3. What should I do first after I get my C&R FFL?
 
In order to purchase a C&R eligible firearm, you will need to send a signed copy of your FFL to the seller. Once you have your C&RFFL, you may wish to immediately send a signed (signed in ink, not a photocopied signature) copy of your FFL to some of the larger firearms dealers and wholesalers -- just so they have it on file. In many cases, this will also entitle you to 01 dealer-level discounts on other items, including parts, which are sold at these places.
 
 
4. If it's over 50 years old -- is it automatically a C&R?
 
Yes! But check!
http://www.geocities.com/Yosemite/Gorge/4653/cnrover50.htm
 
 
5. How do I Rate firearms?
 
When you talk to someone who is selling you a firearm, the condition of the firearm is critical in determining price. When the transaction is being done sight unseen, it can be difficult to know what it REALLY means when someone says that a rifle is in "Great shape". It is best to use the NRA guidelines on condition for a common denominator -- that way you will have a better chance of getting what you expect (and have paid for).
 
Some examples of the NRA guidelines, are:

FACTORY NEW CONDITION

All original parts; 100% original finish; in perfect condition in every respect, inside and out.

EXCELLENT CONDITION

All original parts; over 80% original finish, sharp lettering, numerals and design on metal and wood; unmarred wood; fine bore.
 
This page contains the full list of NRA conditions:
http://www.fundamentalobjects.com/cr-files/condition.htm
 
 

6. How can I be sure it is a C&R?
 
There are many nuances and variations in the models and makes of what appear to be C&R firearms. It is important to know for sure that the model that you wish to purchase is indeed a C&R firearm.
 
Take, for example, the SKS. The SKS was produced (or reworked) in many countries, including the Soviet Union China, Yugoslavia and even Albania. At various times (and for various reasons) different models of the SKS were prohibited from sale in the US, such as a Chinese SKS WITH a bayonet. Although it is relatively easy to add a bayonet to a SKS, doing so is not only illegal, but also alters the firearm from it's "original configuration". Only a military firearm in it's original configuration can be purchased as a C&R firearm.
 
This latter sentence is actually fuzzier in practice, as the definition of when a firearm's original configuration is identified varies. A good example of this is the German K-98 rifles, used by Israel after World War II. The Israeli K-98s were converted from 7.92mm to .308. The original configuration of 7.92mm is a C&R; AS IS the .308 "variation".
 
 
7. How can I be sure it is a C&R?, FOR SURE
(Collectors wanting a determination from the ATF)
 
There are thousands of types of guns, and tens of thousands of variations. If you would like an official ruling on whether a particular firearm is a C&R or not, and it is not found on the official ATF list (http://www.atf.treas.gov/firearms/curios/index.htm) you can submit a written request for a ruling. The letter should include (again, showing the text directly from the ATF site) the following:

·    "A complete physical description of the item; "

·    "Reasons the collector believes the item merits the classification; and "

·    "Data concerning the history of the item, including production figures, if available, and market value. "

 
Submit your request to:

Bureau of Alcohol, Tobacco and Firearms
Firearms Technology Branch
Room 6450 650
Massachusetts Avenue, NW
Washington, DC 20226
 
 
8. What records am I required to send to the ATF upon discontinuance of my business?
 
While the ATF site shows this quote, "The records consist of the licensee's bound acquisition/ disposition (A/ D) records, ATF Forms 4473, ATF Forms 5300.35 (the Brady forms), ATF Forms 3310.4 (Report of Multiple Sale or Other Disposition of Pistols and Revolvers), ATF Forms 3310.11 (Federal Firearms Licensee Theft/ Loss Report), records of transactions in semiautomatic assault weapons, and law enforcement certification letters. If the licensee was granted a variance to use a computerized record keeping system, the licensee is required to provide a complete print-out of the entire A/D records, and an ASCII text file (conforming to common industry standards) along with a file description. [27 CFR 178.127] "


In actuality, this has been updated with a letter from the ATF to explain that this is NOT a requirement of C&R holders. The following text was mailed to current C&R FFL holders in 2003:

"The GCA requires the delivery of required records to the Government within 30 days after a firearms "business" is discontinued. A license as a collector of curios or relics does not authorize any business with respect to firearms. This is in contrast to firearms importers, manufacturers, and dealers who are licensed to engage in a firearms business. Therefore, the records required to be kept by licensed collectors under the law and regulations are not business records and are not required to be turned in to ATF when collector's licenses are not renewed or collecting activity under such licenses is discontinued. [18 U. S. C. 923( g)( 4), 27 CFR 178.127]"
 

  

Figure 3: A page from the Bound Book

 
TIPS FROM C&R FFL HOLDERS
 
On a day-to-day basis, the information that will be the most valuable to you will come from others who hold C&R FFLs. A good place to ask questions and learn more about collecting is on the Cruffler Forum's moderated email list, which is described below under the web sites.
 
The following are some Tips (and also some traps) from a few of the better known 03 licensees from the Cruffler Forum, which will help you as you start out with collecting.
 
 
Greg Topp
NW Wisconsin
 
Why I like my C-R FFL
 
Before I had a C&R, adding a firearm to my collection by attending local gun shows or local shops just wasn't the best approach. While, I could use Shotgun News or Gunslist as a tool to find C&R guns; the steps from finding to holding were more costly. A local dealer can accept a firearm that you purchase for you, but will charge a percentage of the cost when you pick it up at the store. I like the C-R FFL as it allows the seller to ship any gun in the C&R class directly to me. I pay only the actual cost of the gun and the shipping. I also believe (and this is my own opinion) that as a holder of a C-R FFL, I may be a bit more "legitimate" in the eyes of the government than a gun collector without one is.

What to watch out for
 
Using the C&R FFL is convenient but it also entails some risk. When you contact sellers that you do not know, you are basically exposing the perceived location of your collection to him. Also, UPS drivers will be soon aware that you are getting a lot of long boxes with Adult Signature Required stickers on them. These are necessary exposures and usually don't create any difficulties.

My Quick Tip
 
You need a digital camera. Posting photos of your new finds to a web firearms group, by way of a photo site, is a real morale booster for you. It also encourages others to get into this hobby. Digital camera photos also make remotely trading firearms easier, as one of the best ways of determining condition is by a photo.
 
 
 
Andy Cobb
Roanoke, VA
[email protected]
 

Why I like my C&R FFL
 
I like my C&R license for several reasons. I like that I can order & receive eligible firearms direct to my door w/o going through a local dealer, most of which don't carry any surplus military firearms anyway. The license also gives me access to wholesale pricing from many vendors, which allows me to afford guns as a hobby. It has also introduced me to a whole group of people that share my interests in the historical aspect (the history also hooked my 3 daughters, who are now really into shooting). The history aspect also makes it easier to introduce shooting or collecting to someone who may have never shot any type of gun (or may think they are against private gun ownership) because they can see & hold something like their grandfather/uncle/father may have used when they were in the army.
 
What to watch out for
 
I am still trying to figure this part out! Before you lay down a lot of money for something, research it and ask questions. If you are in doubt about any aspect of a prospective purchase, do some more research and ask more questions. It is safer to pass on a purchase than be stuck with an expensive lesson. After a while, you will start to develop a sense when something doesn't look right.
 
My Quick Tip
 
Involve your spouse, significant other. and/or family as much as possible. It's no fun having to hide a $99 Garand because it's "...just another dirty old rifle..."
 
 
 
Kyrie Ellison
[email protected]
 
Why I like my C&R FFL
 
My C&R FFL permits me to buy and sell C&R firearms from and to other collectors all over the country. When I purchase a firearm from another collector he can ship the firearm directly to me.
 
What to watch out for
 
Be careful of "buying the story." As an example I recently saw a nickel-plated WWII Walther P.38 being offered for sale for over $1000. The story the seller told was this P.38 was one of seven pistols plated and personally presented by Adolph Hitler to his top generals. A plated WWII P.38 is worth maybe $250 - the seller wanted an additional $750 for the story. Which incidentally, was untrue. There were no original plated WWII P.38's and the presentation described by the seller never happened.
 
Quick Tip
 
Buy reference books, and maintain close contacts with other collectors with similar interests. Becoming and being knowledgeable about the firearms you may buy will save you from buying the story. And it will let you recognize rare firearms missed by the casual collector. Not too long ago I picked up a mint condition 1923 Commercial Luger with a six inch barrel for under $700, solely because I was the only bidder to recognize it was not the more common (and less valuable!) 1920 Commercial Luger variation.
 
 
 
Walter J. Kuleck, Ph.D.
[email protected]
 
Why I like my C&R FFL
 
The C&R FFL widens my perspective and horizons, both in scope of interest and in geographic terms. Via the Internet, Shotgun News and dealer mailings, I can find interesting specimens from all across the USA. Thus, I've filled many holes in my collection without even leaving the comfort of my home. Gun shows will never lose their serendipity-stumbling across a gem you had no business expecting-but you'll find the unexpected even more often when you can cruise the entire country.
 
What to watch out for
 
Acquiring Curios & Relics via the C&R FFL becomes a simple and easy process-in some ways, too easy! I'm certain that without my C&R FFL I would not have a fraction of the items I now have. Consequently, be wary of "accumulating," rather than "collecting." Conjure up a rationale for each acquisition If you can, or better yet, fit each acquisition into a theme or sequence. You can learn a lot from studying Lee-Enfields from the early Long Lees through the SMLEs to the penultimate 7.62mm Ishapore 2A, for example.
nbsp;
Quick Tip
 
Since most of the time the C&R FFL will be used to receive firearms "sight unseen," knowledge is power. Learn all you can prospectively, so that you are armed with the information you need to evaluate an offering. I'm continually astonished by those unwilling to buy and study a $50 book, but are willing to spend $500 on a mistake that the book would have helped them avoid. For example, before I bought my second Garand, I bought and read each of Scott Duff's Garand books and the complete sets of back issues of the three Garand journals. Much to my surprise, I have found that often a book will prompt me to purchase a Curio or Relic, rather than the other way 'round. Also, don't be reluctant to learn all you can from your collecting friends; most are eager to share their hard-won knowledge. Who knows, some day you may learn enough to write a book of your own!
 



Figure 4: ATF Site

SITES OF INTEREST


The following sites are some of the ones that I have been the most happy with. Included here are places to find firearms (such wholesalers, some dealers and some auction sites), informational sites (on specific firearms, or markings and production codes) and some legal sites of interest. There are many, many other sites on the web related to C&R collecting. You will find more via the links on the pages shown below.
 
 
W H O L E S A L E R S
 
AIM
http://www.aimsurplus.com/
P.O. Box 556
Springboro, OH 45066
voice: (513) 897-9860
fax: (513) 897-9951
 
 

CDNN Investments Inc.
P.O. Box 6514
Abilene, TX 79608
phone: (800) 588-9500
fax: (915) 695-4898
 
 
Samco Global Arms Inc.
http://www.samcoglobal.com/
P.O. Box 7323
Miami, FL 33152
Orders: (800) 554-1618
phone: (305) 593-9782
fax: (305) 477-1232
email: [email protected]
 
 
Southern Ohio Gun Dist.
http://www.southernohiogun.com/
100 S. Mechanic Street
P.O. Box 590
Lebanon, OH 45036
phone: (800) 944-4867
fax: (513) 932-8928
email: [email protected]
 



Figure 5: Southern Ohio Gun Site


 
Century Arms International
http://www.centuryarms.com
1161 Holland Drive
Boca Raton, FL 33487
phone: (800) 527-1252
fax: (561) 998-1993
email: [email protected]
 
 
Navy Arms Company
http://www.navyarms.com/
689 Bergen Boulevard
Ridgefield, N.J. 07657
phone: (201) 945-2500
fax: (201) 945-6859
 
 
Gun Parts Corp. (mostly parts)
http://www.gunpartscorp.com
226 Williams Lane,
W. Hurley, NY 12491
phone: (845) 679-4867
 
 
Brownells, Inc. (Parts)
200 S. Front Street
Montezuma, IA 50171
phone: (515) 623-5401
fax: (515)623-3896
http://brownells.com/
 
 
 
D E A L E R S
 
Treasure Hunt Arms
http://www.treasurehuntarms.com/index.htm
Treasure Hunt Arms
83A Mimosa Ave.
Luling, LA 70070
phone: (985) 785-0078
email: [email protected]
 
 
Collectible Firearms and Edged Weapons
http://www.collectiblefirearms.com/index.html
Kristopher Gasior and Kasia Matuszewska-Gasior
P.O. Box 8327
Fredericksburg, VA 22404-8327 USA
phone/fax: (540) 374-8124
email: [email protected]
 
 
OLD TOWN STATION, LTD.
http://www.armchairgunshow.com/
PO Box 14040
Lenexa, KS 66285
voice: (913) 492-3000
fax: (913) 492-3022
email: [email protected]
 
Make sure to read the aticle on how firearms can be faked (altered to increase their retail value) that can be found on this site at: http://www.armchairgunshow.com/fake1.html
 
 
 
A U C T I O N   S I T E S
 
GunsAmerica
http://www.gunsamerica.com/
P.O. Box 578
Windham, NH 03087
 
 
Gunbroker
http://www.gunbroker.com/
GB Holdings, Inc.
PO Box 19137
Atlanta, GA 31126
contacts: http://www.gunbroker.com/user/Contact.asp
 
 
 
R E S E A R C H    S I T E S
 
Sites with very detailed (read that very useful) specifics on markings.
 
Bryan's Home Page
http://www.radix.net/~bbrown/
A very early entry to the net, there is a great deal of information here on German WWII rifle & ordinance codes, Japanese Arisakas codes, Schmidt-Rubins and British & Commonwealth Bayonets markings.
 
Enfield Rifle Research
http://www.uidaho.edu/~stratton/en-page.html
Just about all that you will need to know about Enfields.
 
Fulton Armory Home Page
http://www.fulton-armory.com/
Dealer, rebuilder with FAQs on American military (M1, M1 Carbine, M14, and the AR15) firearms.
8725 Bollman Place #1
Savage, Maryland 20763
phone: (301) 490-9485
 
 
 
C O L L E C T O R  (and specific firearm)  S I T E S  
 
 
 
C&R Buds
A site geared towards helping collectors to locate hard-to-find firearms (includes standard for-sale ads).
http://www.fundamentalobjects.com/cr-buds
 
The Luger Forum
http://www.lugerforum.com/
 
The P38 Forum
http://www.p38forum.com/
 
Importers' Markings
http://www.northwest-denture.com/mauser1896/importmarks.html
Firearms now imported into the US have to have (at least a small) stamping into the metal to show what company imported it. This site lists out many of the known importers' markings (such as CAI ST ALBANS VT for Century Arms International), so that you can determine who the actual importer was (if any).
 
 
 
L E G A L   S I T E S
 
ATF -- the first stop.
http://www.atf.treas.gov/firearms/relics/
This page covers exactly what you can do (and what you can buy) with your C&R FFL. It is a Must Read for current or prospective C&R FFL holders.
 
ATF FAQS
http://www.atf.treas.gov/firearms/nlc/ffl/ffl_faqs.htm
 
on Collectors
http://www.atf.treas.gov/firearms/nlc/ffl/faqs_collect.htm
 
on General Questions
http://www.atf.treas.gov/firearms/nlc/ffl/faqs_genques.htm
 
State Laws and Published Ordinances - Firearms
http://www.atf.treas.gov/pub/fire-explo_pub/states.htm
 
 
ATF Online - Firearms FAQs
http://www.atf.treas.gov/firearms/faq/faq2.htm
Revised: 7/23/02
 
BATF publishes a list of what firearms qualify for purchase with a Curio and Relic (C & R) license.
http://www.atf.treas.gov/firearms/curios/index.htm
 
 
 
O T H E R  &nbspI M P O R T A N T  S I T E S
 
 
CMP - Civilian Marksmanship Program
The CMP was established by Congress in 1916 to promote marksmanship and firearms safety, and has long been helping to train and educate Americans. You can sign up here to purchase US military surplus rifles, such as the M1 Garand & now .22s from the CMP.
http://www.odcmp.com/
PO Box 576
Port Clinton, OH 43452
phone: (888) 267-0796
fax: (419) 635-2802
email: [email protected]
 
 
 
D I S C U S S I O N   A R E A S
 
There are many places where discussions are held related to C&R collecting on the web, ranging from the willy-nilly rec.guns newsgroup, where many topics (on firearms and not) are discussed, through more specfic bulletin boards, such as Tuco's Firearm Traders Forum (http://www.gunboards.com/trader/). There are several mailing lists available as well, where you send and receive standard emails to other list members. A moderated example of these lists, where the list's owner works to weed out non-firearm chaff, is the Cruffler Forum. Sign-up for this one at http://groups.yahoo.com/group/Cruffler_Forum/
 
 

Gun Boards
http://www.gunboards.com/
Forums for collectors, Mausers, French firearms, Czech firearms, Italian firearms, etc.
 
Culver's Shooting Pages (CSP)
http://www.jouster.com/CSP_forums.htm
Forums for discussions on the 1917 Enfield, FAL, M1, SMLE, 1911, Martini-Henry rifle, M1903 and more.
 
 
 
GLOSSARY
 
ATF:
ATF Is a s shortening of the phrase Bureau of Alcohol, Tobacco and Firearms (BATF). The ATF is the administering body of the C&R FFL.
 
Crufflers:
That which "C & R FFL-holders" often call themselves.
 
FFL:
Federal Firearms License
 
FFL types:
 
  Type 01 - DEALER IN FIREARMS
  Type 02 - PAWNBROKER
  Type 03 - COLLECTOR OF CURIOS AND RELICS (C&RFFL)
 
  Type 06 - MANUFACTURER OF AMMUNITION FOR FIREARMS
  Type 07 - MANUFACTURER OF FIREARMS
  Type 08 - IMPORTER OF FIREARMS / AMMUNITION
 
  Type 09 - DEALER IN DESTRUCTIVE DEVICES
  Type 10 - MANUFACTURER OF DESTRUCTIVE DEVICES
  Type 11 - IMPORTER OF DESTRUCTIVE DEVICES
 
FFL types are described in further detail at:
http://www.atf.treas.gov/firearms/nlc/ffl/ffl_types.htm
 
Auction terms:
http://www.auctionarms.com/help/help&info.cfm
This page contains descriptions of terms that are used in Auctions; from "Bid" to "Reserve Price".
 
 
NFA weapons:
Those "firearms" defined in § 5845(a) of the National Firearms Act (26 U.S.C. Chapter 53). These include machineguns, silencers, shotguns having a barrel less than 18 inches in length, rifles having a barrel less than 16 inches in length, smooth bore handguns, disguised weapons, certain firearms having a bore greater than one-half inch in diameter, destructive devices (e.g., bombs, grenades, and mines) and certain other firearms. A licensed C&R collector may not import NFA firearms.
 
 
 

ABOUT THE AUTHOR
 
Bill is a principal with Conservative Code (www.conservativecode.org), a software development company; and is an active participant in several online firearms-related forums. You can contact him throgh this site.

 

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