Three situations take a transfer outside the background check requirement, and all three are narrower than the shorthand a dealer might carry in their head. The first is a state permit, and it has to satisfy four conditions at once: the transferee presents a valid permit or license that allows them to possess, acquire, or carry a firearm; it was issued not more than 5 years earlier; it was issued by the State in which the transfer is to take place; and the law of that State provides such a permit is issued only after an authorized government official has verified that the information available does not indicate possession would violate federal, State, or local law — with that information including NICS on and after November 30, 1998. A carry permit from a neighboring state, or one six years old, is not this exception.

The second is narrower still and belongs to a different regime. Where the firearm is subject to the National Firearms Act and has been approved for transfer under 27 CFR part 479, the check under this section does not apply — the approval process there has already done the work. This is the point Chapter 1 made about a licensee working under both parts at once rather than choosing between them, seen from the counter.

The third is not a category but a decision. On application of the licensee, in accordance with § 478.150, the Director may certify that compliance with the NICS contact requirement is impracticable. That is granted rather than claimed, and a dealer either holds the certification or does not. Whichever exception applies, the recordkeeping does not disappear with the check: where the transfer rests on a permit, the licensee either retains a copy of it attached to Form 4473 or records its identifying number, date of issuance, and expiration date on the form; where it rests on a certification, the certification is kept as part of the records for the period § 478.129(c) prescribes. § 478.131 says in terms that these requirements are in addition to any other recordkeeping in this part.