DEPARTMENT OF THE TREASURY
		BUREAU OF ALCOHOL, TOBACCO AND FIREARMS

				SEP 23 1999

							901040:GS
							5320

MEMORANDUM TO:       Regional Inspector General for Audit
                     Office of the Inspector General

         FROM:       Assistant Director
		     (Firearms, Explosives and Arson)

      SUBJECT:       National Firearms Act Firearms
                     Registered to Persons Who May Be 
	             Deceased

Your reports OIG-99-009, dated October 26, 1998, and OIG-99-018, dated 
December 18, 1998, addressed an allegation that a significant number of 
National Firearms Act (NFA) firearms are registered to persons who may be 
deceased, and reported that estates may not have transferred these 
firearms in accordance with the law.  The latter report concluded that, 
as a result, the National Firearms Registration and Transfer Record 
(NFRTR) is less effective because it may not reflect the current owner of 
the firearm.  You recommended that we (1) determine the extent to which 
data can be obtained to update the registry, and (2) develop a course of 
action that takes into consideration the expense of updating the 
registry.

As we discussed earlier, my staff evaluated your recommendations even 
though there is no legal requirement to update registry information 
relating to deceased persons until we are advised of a registrant's 
death.  The fact that a registrant is deceased still does not affect the 
accuracy of the NFRTR since it still reflects the person entitled to 
possess the firearm.

On June 23, 1999, members of my staff met with you and your staff to 
discuss the results of our evaluation.  At that time, we reviewed the 
steps we had taken and our findings.  We found that while we can match 
names in our locator systems, such as decedent files maintained by the 
Social Security Administration, we cannot identify whether the record is 
for our registrant

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because some of the information (e.g., date of birth, social security 
number) is not on the registration documents.  Because of the amount of 
research involved, we determined that the benefits of the research are 
not worth the expense.  However, our study group feels that other options 
can be pursued to identify firearms involved in estates, and we offer the 
following recommendations:

--Include estate information in the ATF Internet Website.

--Publish a pamphlet on how to go about making changes after initial 
registration.

--Expand the information concerning estate transactions in ATF P 5300.4, 
_Federal Firearms Regulations Reference Guide_.

--Publish an article about estates in the "Federal Firearms Licensee 
Newsletter_.

--Include information in ATF registration documents about making changes 
to the registry following the death of a registrant.

--Send a notice concerning updating the registry to registrants we have 
complete addresses for.

During the June 23, 1999, meeting, you indicated that the above 
recommendations were reasonable and suggested that firearms-related media 
be asked to include estate information in their publications.  We will 
follow up on this suggestion.

Proposed completion dates for the implementation of our recommendations 
follow.

--Modifying the ATF Internet Website, which is scheduled for completion 
September 30, 1999.

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Regional Inspector General for Audit
Office of the Inspector General

--Addressing post-registration changes in a pamphlet, which is scheduled 
to be available March 31, 2000.

--Expanding the information in ATF P 5300.4; the information has been 
submitted forinclusion in next revision, which is tentatively scheduled 
for completion in September 1999.

--Submitting an article on estates for publication in the next _Federal 
Firearms Licensee Newsletter_, which is due in November 1999.

--Revising five registration forms, which are scheduled for completion on 
June 30, 2000.

Additionally, we are looking into the feasibility of sending a notice to 
registrants concerning updates to the registry.  We plan to make a 
decision on this issue by December 31, 1999.

We appreciate the opportunity to work with you and your staff to enhance 
our processes.  If you need additional information or have any questions, 
please contact Mr. Walfred A. Nelson, Deputy Assistant Director 
(Firearms, Explosives and Arson), (202) 927-7940.


			(signed---Jimmy Wooten)

				Jimmy Wooten