04/13/2020
ATF Authorizes Drive-Through Gun Sales to Maintain Social Distancing
(1) An FFL may carry out the requested activities through a drive-up or walk-up window or doorway where the customer is on the licensee’s property on the exterior of the brick-andmortar structure at the address listed on the license.
(2) An FFL may also carry out the requested activities from a temporary table or booth located in a parking lot or other exterior location on the licensee’s property at the address listed on the license, but any such activities must occur in a location where the licensee has the authority to permit ATF’s entry for inspection purposes. Whether the FFL has the authority to permit such entry, and whether a location constitutes the FFL’s property, is likely to be a factspecific inquiry. An FFL carrying out the requested activities from an exterior table or booth should maintain its inventory and records securely in the interior of the brick-and-mortar structure and ensure that the records of each fi****ms transaction are stored in the interior.
(3) An FFL may not carry out the requested activities from a nearby space that is not located on the licensee’s property at the address listed on the license, unless such activities are at a qualified in-state gun show or event, pursuant to 18 U.S.C. § 923(j) and 27 C.F.R. § 478.100, or other provision of federal law.
(4) An FFL may conduct non-over-the-counter firearm sales to unlicensed in-state residents who are exempt from NICS requirements in accordance with 18 U.S.C. § 922(c), 27 § C.F.R. 478.96, and ATF Procedure 2013-2.
