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NHDaveK, I find the referenced 478.91 under "Subpart F - Conduct of Business"
In my IANAL interpretation, this would apply only to a dealer, as C&R FFLs are expressly forbidden to "conduct business" with said license.
Also, C&R FFL inspections can be held at the BATFE office and only require a paperwork inspection (not an inspection of the guns themselves), so the applicability of that section would be very unlikely.
That said, many BATFE agents doing inspections of C&R FFLs do not seem to understand the distinction between dealers and collectors and have demanded things in excess of their authority during audits.
In my IANAL interpretation, this would apply only to a dealer, as C&R FFLs are expressly forbidden to "conduct business" with said license.
Also, C&R FFL inspections can be held at the BATFE office and only require a paperwork inspection (not an inspection of the guns themselves), so the applicability of that section would be very unlikely.
That said, many BATFE agents doing inspections of C&R FFLs do not seem to understand the distinction between dealers and collectors and have demanded things in excess of their authority during audits.