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Posted By FFL Dealer Network on 03/21/2021 in FFL Business

Collector of Curios or Relics Federal Firearms License

Collector of Curios or Relics Federal Firearms License

If you like guns and want to collect them, especially collectible firearms, a Type 03 Federal Firearms License may be for you. 

The Type 03 is nicknamed Cruffler, a crunched version of the full name. Like the full name says, it is a federal license to collect firearms that the BATF designates as unique or special or guns that are at least 50 years old. 

IS IT A TYPE 03 FFL ANY GOOD?

The biggest question most people have about the Type 03 license is "Is it any good?" This is often followed up with some reference to buying old and worn-out guns. 

The short answer is yes, it is good. 

A longer answer is, the license is only a federal permit to buy and sometimes sell guns across state lines. When you buy a used firearm, you take a risk.  

Some of these risks are the exact same risks you take when you buy a 10-year old gun at a pawn shop. Three big risks to buying any used gun are: 

  1. You may not be able to get parts if something breaks. Gun makers do go out of business. For instance the Zip 22 was made from 2013-2017. Good luck finding parts short of milling them or cannibalizing another Zip.
  2. The gun may be so worn out that repairing it will cost more than it is worth.
  3. The gun is about as accurate as throwing rocks because the barrel simply sucks. 

Old guns are not bad guns. One of our staff, Ben Baker, personally owns a few guns more than 100 years old, including a 1918 Mosin-Nagant that will still anchor a deer to the spot if he upholds his end of the shot. His Ruger M77 is close to 50 and will still do sub MOA groups with his handloads. 

Look at it this way. 1971 was 50 years ago in 2021. 50 years is a constantly moving target. By 2030, any gun made before 1980 will fall under the Cruffler requirements. 

Right now, many guns made in the 60s are still out there bringing home meat, taking trophies, winning awards and protecting people. Here are some examples: 

  • The first AR15 hit the market in 1965.
  • Most Belgian-made Browning shotguns were made before 1971.
  • The Ruger 10/22 came out in 1964.
  • Remington Model 700, in various calibers, was introduced in 1948.
  • Pre-65 Winchesters are a very hot collectible. Many of these fine guns still take deer, bear, elk and birds.
  • The Mossberg 500, one of the two most popular shotguns in the world, debuted in 1961.

 WHAT THE TYPE 03 FFL IS NOT

Critically, the Cruffler is NOT a federal license to do business in buying and selling firearms. The BATF has not set a firm rule on what constitutes a business of selling guns where the Type 03 is concerned. 

The federal agency does have some rules about FFLs and being in business. Get some of the business rules here.

Business rules and the Cruffler are nowhere near as clear. The following is not legal advice, but it is a good rule of thumb.

  •  If you keep the guns you buy, that is not a business. In fact, using a Type 01 or 02 license to build a collection is not allowed.
  • If you buy a gun and keep it for several years, then sell it, that is not a business. BATF does not have a rule on how long you have to keep the gun before you sell it and so are operating a business.
  • If you buy a few guns a year and sell a few to other collectors, that is probably not a business. Again, BATF will not hand down a definite ruling or opinion on how many guns you can buy and sell before you are in business.
  • If you go to gun shows and set up a booth to buy and sell, that is certainly pushing the limits on what a Type 03 allows. As a C&R holder myself, I would not do this.
  • A Type 03 FFL is not a loophole to get around state laws. If your state or community does not allow you to have a certain gun, then you cannot have it, even with this license.
  • Some Class 3 weapons, full auto and short barrels being the best examples, can be C&R eligible. These guns still fall under the National Firearms Act regulations. Transferring these guns still has to go through a Class 3 dealer. You also have to pay the NFA tax. 

WHAT The Type 03 FFL IS

In short, the Cruffler is a license to buy and occasionally sell firearms across state lines without going through a background check. 

For instance, many gun import companies list guns as "C&R Eligible." If you have a Cruffler, mail, fax or email a copy of your license to the company. Once it is on file, you can buy C&R guns and have them shipped directly to you, subject to the regulations noted above. 

The Cruffler has some distinct differences from the rest of the FFL lineup. They are: 

  1. No business license. All other FFLs require you to get a local business license, if required in your community. The Cruffler does not simply because you are not going into business.
  2. No zoning concerns. With the other FFLs, your property must be zoned to allow businesses and gun sales. Not so for the Type 03.
  3. No interview. Getting one of the other FFLs means an in-person interview with a BATF agent where the license is located. These interviews take about 2 hours. 
  4. No inspection. Again, other FFLs require a premises inspection. Not so with the Cruffler.
  5. No picture. The other licenses require a fingerprint card and a picture with the application. You only need the fingerprint card for the Type 03 FFL.
  6. Records keeping is a bit less. You do need to keep a log of any gun you buy under your Type 03. That log also must have information about the person who buys any gun from you. 
  7. No background check. As a Type 03 license holder, you are not legally required to fill out Form 4473. A dealer can still require you to do this. It happens to me.
  8. You cannot do background checks on a potential buyer. You should ask questions. Definitely get driver's license information and concealed carry permit info if the buyer has one.

The Cruffler also has things in common with the other licenses. The top ones are:

  • ATF agents can make an appointment to come and inspect your records.
  • You license has to be renewed, in this case every 3 years.
  • You need to keep clear records.
  • You can refuse to sell a gun to anyone without giving a reason.
  • You have to send a copy of your application to the local chief law enforcement officer. That's it. The officer does not have to sign any paperwork. As with all licenses, the officer can advise the BATF that you should not have the license. 



TYPE 03 FFL APPLICATION PROCESS

If you can legally buy a handgun from an FFL dealer, then you can get an FFL, subject to the above requirements.

Go online to get the application

You need a fingerprint card. Many county jails offer this service. Many states require fingerprints for CCWs. Whoever does that fingerprinting can do the same for you. 

You need a passport-sized and quality photo. 

Make a copy of the application and fill it out with a pencil. It is easier to make corrections that way. Or, fill it out with Adobe Acrobat. Go over it several times. Make needed corrections. When you have everything in order, transfer everything to the original application. 

Make out your check for the application fee. Put your fingerprint card, picture, check and application into an envelope. 

Mail it in and wait. 

BATF will send you a reminder a few months before your annual renewal is due.

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