Address and name
Changing the business address or the trade name
These two changes feel like the same kind of administrative housekeeping and behave quite differently, because only one of them moves the thing the license is attached to. A license covers the class of business specified in it at the address specified in it. Change the address and you have changed a term of the license itself. Change the trading name above the door and you have not — the licensed premises, and the business conducted there, are where they were.
So an address change is done in advance. A licensee may remove the business to a new location where they intend regularly to carry it on by filing an Application for an Amended Federal Firearms License, ATF Form 5300.38, in duplicate, not less than 30 days prior to the removal. It goes to the Chief of the Federal Firearms Licensing Center, executed under the penalties of perjury and the penalties imposed by 18 U.S.C. 924, and accompanied by the original license. The Chief may also require a completed Form 7 or Form 7CR, or portions of one, in the manner § 478.44 requires. On finding the applicant qualified at the new location the Chief issues the amended license and returns it — and here is the part a new document invites you to get wrong: it is valid only for the remainder of the term of the original license, not for a fresh term of its own. An applicant found not qualified at the new location is referred to the Director of Industry Operations for denial under § 478.71.
A trade name change runs the other way. A licensee continuing to conduct business at the location shown on the license does not need a new license by reason of a mere change in trade name, provided they furnish the license for endorsement of that change to the Chief within 30 days from the date they begin business under the new name. Both provisions say 30 days and the resemblance ends there: one is a period you must wait through before acting, the other a period you have after acting. Read them quickly and it is easy to carry away a single 30-day rule that does not exist.
Change of address
Files an Application for an Amended Federal Firearms License, ATF Form 5300.38, in duplicate, with the Chief, Federal Firearms Licensing Center.
Not less than 30 days PRIOR to the removal. Executed under the penalties of perjury and those imposed by 18 U.S.C. 924, and accompanied by the licensee’s original license.
The Chief may in writing require a completed ATF Form 7 or 7CR, or portions of one, in the manner § 478.44 requires. The amended license that issues is valid only for the REMAINDER of the original license’s term.
Change of trade name
No new license is required, provided business continues at the location shown on the license — a mere change of trade name does not move the licensed premises.
The license is furnished for endorsement within 30 days FROM the date business begins under the new name.
Nothing is filed in advance, and no amended application is triggered by the name alone.
Key terms
ATF Form 5300.38amended licenseremovaltrade nameendorsement