Retention is not one period. It divides into records kept for a fixed number of years and records kept for the life of the business, and applying the wrong one in either direction is a real risk — destroy something early and the trail is broken, keep everything for ever and the premises fills with paper nobody needs.

The open-ended category is the larger. Each Form 4473 is retained UNTIL BUSINESS OR LICENSED ACTIVITY IS DISCONTINUED — on paper, or by an electronic alternate method approved by the Director — at the business premises and readily accessible for inspection. Paper forms over 20 years of age may be stored at a separate warehouse, which is then considered part of the business premises for that purpose and is subject to inspection. Records of importation, manufacture or other acquisition, including ATF Forms 6 and 6A, are likewise kept until the business or licensed activity is discontinued. One filing rule sits inside this: Forms 4473 for which a sale, delivery or transfer DID NOT take place are retained separately, in alphabetical order by transferee name or chronological order by the date of the transferee’s certification.

The fixed periods attach to the reports rather than the transaction records, and they are all five years measured from different events. A Statement of Intent to Obtain a Handgun, Form 5300.35, is kept not less than 5 years after notice of the intent was forwarded to the chief law enforcement officer. A Report of Multiple Sale or Other Disposition of Pistols and Revolvers, Form 3310.4, is kept not less than 5 years after the date of sale or other disposition. A Federal Firearms Licensee Theft/Loss Report, Form 3310.11, is kept not less than 5 years after the date the theft or loss was reported to ATF. The five years is the same in each case; the day it starts from is not.