I haven't seen this discussed here in the last decade.
I recently bought a Model 12 pump shotgun from 1939 that is on course to being my favorite gun ever, so now I've been looking into 50's and 60's vintage Auto 5's.

I never figured I'd be a C&R guy, but a lot of these old guns I've been looking at are "C&R eligible"... So why not? Is there a reason to NOT get a C&R license or do transactions as a C&R for eligible firearms?


My understanding of the process, please correct me if I'm wrong:
1) I apply for a C&R license from the ATF for $30.
2) Whenever I buy a C&R gun, I keep a record of it in a "bound book".
3) Whenever I buy a C&R gun, it doesn't need to go through a FFL, but it does need to be registered with the local PD. I'm on Maui... Would I need to physically take it to the police station, or can I email the forms? I don't imagine the "FIREARM REGISTRATION INFORMATION SHEET FOR IN-STATE ACQUISITIONS" I send in for everything else would be the right paperwork, unless I happened to buy it from an in-state vendor?
4) I need to pay a renewal $30 to the ATF every three years. If I don't, does it mean I just can't buy any new C&R's, or does something happen to the existing C&R's that I already have?

Is there anything else I need to be aware of? Is having one a free-standing invitation for the ATF to come and shoot my dog?

First, make sure your buying and selling activity doesn't rise to the level of being a dealer.  What is that level over a period of time?  The ATF is trying to redefine that that so almost anyone buying and selling their own personal firearms qualify.  At a minimum, the firearms you intend to acquire should qualify as C&R and retained as part of your personal collection.  Buying and selling your C&R guns too frequently or too quickly after purchase could raise a flag.

Second, with the onerous registration crap that HI makes us do, it having the license adds more work to selling a C&R firearm. Unless your buyers are also FFLs (dealer or collectors), they still have to go through the PTA process.

Third, when you purchase a C&R under your license, you have to record all the details of the firearm and transaction and have that available for inspection if the ATF shows up.  It's recommended ALL C&R firearms be tracked in your bound book (which is allowed to be in digital format) even if not purchased under the C&R license.  Basically, any transfers of your collection both in and out of your possession must be tracked and the records retained.

I found it best to handle local sales as a normal transfer (no C&R license involved).  The license offers no real benefit and simplifies the transfer process if/when you also sell it locally.

The only real benefits I found using my license were:

    A.  buying a C&R from another state:  it can be shipped directly to my house  -- no other FFL needs to be involved, hence no additional transfer fees.  Just send a signed copy of your C&R license to the seller the same way you would if sending them your local FFLs license.

    B.  having the ability to ship a C&R to any state without paying a local FFL dealer.  That's especially important in light of the tighter restrictions shippers implemented lately.  Most shippers are limiting handgun shipments to FFLs

    C.  No need to apply for a PTA for any C&R firearm including handguns.  You do, however, need to have a current long gun permit (yes, even for C&R handguns).  You use that when registering the C&R.  Avoids the hassle of getting handgun permits.  You'll also need some documentation proving the firearm is C&R qualified.  The ATF documents list a wide variety that are specifically covered, to include ceremonial and special edition models.  If the stamped date on the firearm makes it eligible, just show the part of the ATF rules that give the appropriate criteria ("over 50 years old," etc).

    D.  No ATF Form 4473 required when acquiring firearms under the C&R license.


The best benefit is being allowed to conduct interstate transactions without paying FFL fees.  As long as you're transferring at least one C&R every three years, the cost of the license is a wash versus FFL fees.  The real savings appear if you're an avid collector doing many transfers under your C&R license.  That can save hundreds in fees.  It really depends on how active your collecting activities are.

There's another benefit which may or may not apply.  If you buy any firearm from the CMP (Civilian Marksmanship Program) and have no other record of live fire marksmanship training, the program accepts C&R licenses, even expired, to show proof of marksmanship.

The license can also help when applying for a non-resident CCW license in some states.  I believe Maine asked for mine to speed up the identification and background check process.

There's no down side to having the license other than taking the time to renew, if you aren't doing transfers at least every three years, or if you're acting in a way which draws the ATF's or FBI's attention as I already mentioned.

First, make sure your buying and selling activity doesn't rise to the level of being a dealer.  What is that level over a period of time?  The ATF is trying to redefine that that so almost anyone buying and selling their own personal firearms qualify.  At a minimum, the firearms you intend to acquire should qualify as C&R and retained as part of your personal collection.  Buying and selling your C&R guns too frequently or too quickly after purchase could raise a flag.

From my understanding a 03 FFL doesn’t allow you to sell (be a dealer in a business sense). It’s for collectors so you can get as much as you want.  If you want to buy and sell its a whole different FFL you need.

From my understanding a 03 FFL doesn’t allow you to sell (be a dealer in a business sense). It’s for collectors so you can get as much as you want.  If you want to buy and sell its a whole different FFL you need.

I believe I said that more than once. 

FFL-03 C&R is for collectors, not dealers.

From my understanding a 03 FFL doesn’t allow you to sell (be a dealer in a business sense). It’s for collectors so you can get as much as you want.  If you want to buy and sell its a whole different FFL you need.

To expand on my reply ....

The primary purpose of the C&R license is to allow collectors similar economic protections afforded to dealers, specifically interstate commerce.

Collectors licenses provide the right to send and receive collectable firearms to/from unlicensed out-of-state buyers/sellers without a dealer FFL doing the transfer.

The ATF website describes the features of an FFL-03 pretty well:

https://www.atf.gov/qa-category/collectors

I probably wouldn't be selling, and I'm only planning on buying a couple shotguns. (Although I've said that before...)


So what happens when your C&R license expires? Can you just not get any more C&R's at that point, or do you need to get rid of your C&R's?

I probably wouldn't be selling, and I'm only planning on buying a couple shotguns. (Although I've said that before...)


So what happens when your C&R license expires? Can you just not get any more C&R's at that point, or do you need to get rid of your C&R's?

Nothing.  If you let it lapse, just keep your disposition records up to date for those you bought under the license.  Mark it down when you sell any of them.

Also, unlike a dealer FFL, you aren't required to forward your records to anyone (not a business).

You're still able to buy C&R firearms without a current FFL-03 license, but you'd have to follow the rules as if they are regular sporting and defensive firearms which might require using a local FFL to perform the transfers.

Anything you owned at expiration is still your property.  The license isn't a permit.  It's a license to engage in interstate commerce involving curios and relics.  Nothing more.

Cool, thanks.

I have a C&R and used it a lot on the mainland for firearms purchase etc. it also got me significant discounts for ammo and reloading supplies. Now here in Maui, I am skeptical that the good folks at the police registration know what it is, so I have not really used it for direct mail purchases yet. Flapp, do you have a citation I can fall back on to help educate them if need be?

I have a C&R and used it a lot on the mainland for firearms purchase etc. it also got me significant discounts for ammo and reloading supplies. Now here in Maui, I am skeptical that the good folks at the police registration know what it is, so I have not really used it for direct mail purchases yet. Flapp, do you have a citation I can fall back on to help educate them if need be?

Detailed notes of some C&R experiences.

As for citations, if you mean what qualifies as C&R, it's case by case.  Easiest criterion is age of firearm > 50 years.

https://2ahawaii.com/index.php?topic=17226.msg158387#msg158387

Yes, thanks, the applicable law and list of eligible items is pretty clear.  I do not have confidence that my local MPD office will know or understand any of that, that is my concern.

Yes, thanks, the applicable law and list of eligible items is pretty clear.  I do not have confidence that my local MPD office will know or understand any of that, that is my concern.

It's not your job to educate, just document.  if you have the facts on the firearm and can show in the rules that it qualifies, the rest is up to them to know how to register it.

If they try to treat you like a non-FFL, then you might need to have them get in touch with the ATF and let them do the educating.

Detailed notes of some C&R experiences.

As for citations, if you mean what qualifies as C&R, it's case by case.  Easiest criterion is age of firearm > 50 years.

https://2ahawaii.com/index.php?topic=17226.msg158387#msg158387

In my experience HPD does not accept the >50 yr old allowance.
If it was not specifically on a line by make and model in the C&R list they would not accept the firearm as being a C&R.

Also had someone from HPD call twice asking the whereabouts of a C&R firearm and if I still had it in my possession.

In my experience HPD does not accept the >50 yr old allowance.
If it was not specifically on a line by make and model in the C&R list they would not accept the firearm as being a C&R.

Also had someone from HPD call twice asking the whereabouts of a C&R firearm and if I still had it in my possession.

It's simple to show documentation of the rules.  You should have received a book from the ATF explaining all the rules when you received your FFL in the mail.

You can also print the rules from the ATF website.  For example:

Firearms automatically attain C&R status when they are 50 years old.
Any firearm that is at least 50 years old, and in its original configuration,
would qualify as a C&R firearm. It is not necessary for such firearms
to be listed in ATF's C&R list. Therefore, ATF does not generally list
firearms in the C&R publication by virtue of their age.

https://www.atf.gov/firearms/curios-relics

As I said, it's your responsibility to provide documentation that shows your firearm qualifies. 

If the police department tells you they don't accept the criteria/rules you provided, you should file a formal complaint against them.  To violate your rights under your valid FFL could be considered a lawsuit situation.

Had the book, documentation, date of manufacture, all of it.

Showed them exactly in the book about >50 years.

Had 2 officers and their supervisor. They insisted it had to be on a specific line. Gave me a hard time about it.

Just stating my experience with it. Your mileage may vary.

Cause you know HPD always follows the rules.

Had the book, documentation, date of manufacture, all of it.

Showed them exactly in the book about >50 years.

Had 2 officers and their supervisor. They insisted it had to be on a specific line. Gave me a hard time about it.

Just stating my experience with it. Your mileage may vary.

Cause you know HPD always follows the rules.

That's when you gather names, place, date, time, and a written rejection for attempting to register a valid C&R.  If law enforcement ever tries to charge you with possession of an unregistered firearm, sue their butts.

If they confiscate it while trying to register, that's a civil rights violation (2A) as well as federal law (FFL-03).

I can now confirm the C&R can be used in place of a specific handgun PTA if the pistol you intend to acquire is old enough to be on the list. Very easy and straightforward process and it is recognized for its intended use in Maui County.
Definitely worth the $30 for 3 years if you intend to buy older collectibles.