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EFA10 & FFL01 vs FFL03

EagleScout17

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It is my understanding that if I sell a firearm to a traditional gun shop (FFL01), it does not count as one of my personal sales for the year (4 per year). If I sell a firearm to an FFL03, does this count as one of my personal sales for the year?
 
It is my understanding that if I sell a firearm to a traditional gun shop (FFL01), it does not count as one of my personal sales for the year (4 per year). If I sell a firearm to an FFL03, does this count as one of my personal sales for the year?
Yes.

The Commonwealth doesn't recognize 03s in the same way as other FFLs.
 
It is my understanding that if I sell a firearm to a traditional gun shop (FFL01), it does not count as one of my personal sales for the year (4 per year). If I sell a firearm to an FFL03, does this count as one of my personal sales for the year?

AND you must do an eFA-10 to an 03FFL holder. Their federal license does not negate the state eFA-10 requirement. You do not need to do an eFA-10 to an 01FFL though you certainly can and I always try to.
 
Yes.

The Commonwealth doesn't recognize 03s in the same way as other FFLs.
Yes, more specifically the MA law and FED law are separate worlds. From the MA law perspective the question is whether the transaction was with a “MA Dealer” who can buy and sell guns in retail commerce or a regular LTC with a 4x LTC-LTC sale limit (and FA-10 requirement).
(An FFL01 or FFL07 can get a MA Dealer license, and FFL03 can’t )
 
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Another clarification/nit:

You only need to use the eFA10 if the FFL03 buyer is a Mass LTC holder.

If the FFL03 is a resident of another state, no eFA10 is required and it does not count against your four/year limit.
 
How does one do this on "the portal"?
It's unnecessary but if you insist . . .

It can only be done if you have the MA Dealer's number (not the FFL #). If you don't have that, it is impossible to fill out the eFA-10 form. NOTE: No idea if you need the dealer's PIN as well.
 
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