Record-Keeping Requirements for Dealers

Connecticut imposes detailed record-keeping obligations on persons who sell, deliver, or transfer firearms, apart from listed exceptions such as transfers between federal licensees and transfers of antique 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]

Transfer Document Requirements

Before a pistol, revolver or long gun is sold, delivered or transferred under CGS 29-33 or 29-37a, the transferor must complete a transfer document on a form prescribed and furnished by the Commissioner of the Department of Emergency Services and Public Protection (DESPP) and obtain an authorization number from the commissioner. The transfer document must contain the following information.^[2]

• Name and address of the transferor (seller)
• Name and address of the transferee (buyer)
• 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 number of the firearm
• A general description of the firearm
• The DESPP authorization number

For handgun and long gun sales, the buyer must be personally known to the seller or provide evidence of identity in the form of a motor vehicle operator's license, an identity card issued under CGS 1-1h, or a valid passport.^[1]

20-Year Retention Period

If the transferor or transferee is a federally licensed firearms dealer, the dealer must retain the transfer document for at least 20 years or until the dealer goes out of business. Federal rules require licensees to retain Form 4473 and dealer acquisition and disposition records until business or licensed activity is discontinued.^[1]

Both handgun transfer documents (CGS 29-33) and long gun transfer documents (CGS 29-37a) are subject to the same 20-year retention requirement for federally licensed firearms dealers. Other transferors must retain one copy of the transfer document for at least five years.^[2]

Inspection by Law Enforcement

Transfer documents must be available for inspection during normal business hours by law enforcement officials.^[1]

Annual Inventory Reconciliation (HB 6667)

Effective October 1, 2023, HB 6667 imposed new inventory management obligations on licensed firearms dealers. Holders of a Connecticut permit to sell firearms at retail must cause a physical inventory reconciliation to be performed that compares the physical inventory of firearms with the acquisition and disposition records required under chapter 529 and 27 CFR 478.125(e). 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 retail permit holder must submit an attestation to the Commissioner of DESPP confirming the following.^[3]

• The inventory reconciliation was conducted
• Any missing firearms were reported to the Attorney General and appropriate local authorities

Consequences for Non-Compliance

Failure to conduct the required annual physical inventory reconciliation may provide grounds for a notice of violation issued by the Commissioner of DESPP or the local permitting authority for the municipality in which the permit holder resides. If the period specified in the notice to cure the violation has expired and the violation remains uncured, the officials authorized by CGS 29-28b(c)(2) may issue a stop-sales order temporarily prohibiting further firearms sales at the permitted premises.^[3]

What This Means for Dealers

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 to holders of a Connecticut permit to sell firearms at retail.