Record-Keeping Requirements for Dealers

Connecticut imposes detailed record-keeping obligations on all persons who sell, deliver, or transfer firearms. These obligations apply to licensed dealers (Federal Firearms Licensees, or FFLs) and, in many respects, to private sellers as well. The requirements are found primarily in CGS 29-33 (handguns) and CGS 29-37a (long guns), with additional dealer-specific obligations added by HB 6667 in 2023.^[1]

Application Form Requirements

Every firearms sale must be documented on a form prescribed by the Commissioner of the Department of Emergency Services and Public Protection (DESPP). The form requires the following information:^[2]

• Name and address of the transferor (seller)
• Name and address of the transferee (buyer)
• Date and place of birth of the transferee
• Firearm permit or certificate number of the transferee
• Firearm permit or certificate number of the transferor, if applicable
• Date of the sale, delivery, or transfer
• Caliber, make, model, and manufacturer's serial number of the firearm
• A general description of the firearm
• The DESPP authorization number

For handgun sales, the seller must also verify the buyer's identity through personal knowledge, a motor vehicle operator's license, a state-issued identity card, or a valid passport.^[1]

20-Year Retention Period

All completed sale applications must be attached to the corresponding federal sale or transfer document (ATF Form 4473) and retained for at least 20 years, or until the vendor goes out of business. This retention period is among the longest of any state, exceeding the federal ATF requirement of 20 years for dealer records.^[1]

Both handgun sale records (CGS 29-33) and long gun sale records (CGS 29-37a) are subject to the same 20-year retention requirement.^[2]

Inspection by Law Enforcement

All sale and transfer records must be available for inspection during normal business hours by law enforcement officials. This allows police and DESPP investigators to trace firearms used in crimes back to their point of sale and verify dealer compliance with state and federal law.^[1]

Annual Inventory Reconciliation (HB 6667)

Effective October 1, 2023, HB 6667 imposed new inventory management obligations on licensed firearms dealers. FFLs must conduct a physical inventory reconciliation by comparing their physical inventory of firearms against their Acquisition and Disposition (A&D) Book. This reconciliation must be completed no later than the fifth business day of October each year.^[3]

Within five business days of completing the inventory reconciliation, the FFL must submit an attestation to the Commissioner of DESPP confirming that:^[3]

• The inventory reconciliation was conducted
• Any missing firearms were reported to the ATF and to local law enforcement

Consequences for Non-Compliance

Failure to submit the annual inventory attestation may provide grounds for a violation issued by local authorities. If the dealer fails to timely cure the violation, the local authority may seek a stop-sales order, which would halt all firearms sales at the dealer's premises until compliance is restored.^[3]

What This Means for Dealers

Connecticut's record-keeping requirements create a comprehensive paper trail for every firearm sold in the state. Dealers should ensure that their record systems accommodate the 20-year retention period, that records are organized for law enforcement inspection, and that the annual October inventory reconciliation is completed on time. Private sellers who transfer firearms are also required to retain sale documentation, though the inventory reconciliation requirement applies specifically to FFLs.