PMF and Ghost Gun Record Keeping Requirements for FFLs

If you're an FFL dealer or manufacturer, privately made firearms — commonly called "ghost guns" — are no longer a gray area. Since ATF Final Rule 2021R-05F took full effect, PMFs that pass through your business are subject to the same rigorous record keeping standards as any serialized commercial firearm. The consequences of getting it wrong range from warning letters to license revocation.

What Is a Privately Made Firearm (PMF) Under ATF Final Rule 2021R-05F?

ATF Final Rule 2021R-05F became effective August 24, 2022. It redefined what constitutes a "firearm frame or receiver" and introduced the term Privately Made Firearm (PMF) into the regulatory vocabulary.

A PMF is any firearm assembled or manufactured outside of a licensed manufacturer's production process — one that was not originally produced with a manufacturer-assigned serial number. This includes:

• Firearms built from 80% lower receivers or similar partially completed frames
• Firearms assembled from buy-build-shoot kits (now regulated under the rule)
• Homemade firearms of any type that lack a factory serial number
• 3D-printed firearms

Any time a PMF enters an FFL's inventory — whether through a transfer, consignment, pawn, estate, or trade-in — the FFL is legally required to serialize, record, and track it.

FFL Marking Requirements for PMFs

Before a PMF can be entered into your bound book or transferred to a customer, it must be permanently marked per 27 CFR § 478.92. Required markings include:

• Name of the FFL (or licensed trade name)
• City and state of the FFL's licensed premises
• A unique serial number assigned by the FFL

The serial number is the sticking point for many dealers. The ATF does not assign serial numbers — that responsibility falls entirely on the FFL taking possession of the PMF. A common compliant convention:

[FFL Trade Name Abbreviation]-PMF-[Year]-[Sequence]
Example: ACEGUNS-PMF-2024-001

The marking must be engraved, cast, stamped, or otherwise permanently affixed to a minimum depth of .003 inches in print no smaller than 1/16 inch.

Bound Book Entry Requirements for PMFs

Once marked, the PMF must be entered into your A&D bound book just like any other firearm. Under 27 CFR § 478.125, the acquisition entry must include:

Acquisition entries must be made no later than the close of the next business day after the firearm is received. Mark and log simultaneously — receiving a PMF and waiting days to assign a serial number is a compliance violation waiting to happen.

Form 4473 Requirements for PMF Transfers

When you transfer a PMF to a non-licensed individual, a Form 4473 is required just as with any other firearm. PMF-specific field entries:

• Box 29 (Manufacturer/Importer): Enter "PMF" or "Privately Made Firearm"
• Box 30 (Model): Use the best available descriptor — "AR-15 Style Pistol," "1911 Style," etc.
• Box 31 (Serial Number): Enter the serial number you assigned to the PMF
• Box 32 (Type): Select the appropriate firearm type
• Box 33 (Caliber/Gauge): Enter as marked or identified

The 4473 must be retained for 20 years from the date of transfer. NICS background check requirements apply equally to PMF transfers — there is no exemption.

6 Common Mistakes FFLs Make With PMF Records

1. Delaying Serialization

Accepting a PMF and waiting to assign a serial number is a violation. Marking and logging must happen before the firearm enters your inventory in any operational sense.

2. Using Non-Permanent Markings

Labels, stickers, paint markers, and stamped tape do not meet the depth or permanence requirements. Engraving or deep stamping is required.

3. Leaving "Manufacturer" Blank on the Bound Book

The correct entry is "PMF" or "Privately Made Firearm" — not blank.

4. Entering Your Own Name as Manufacturer

You are the entity assigning the serial number, not the manufacturer in the commercial sense. The manufacturer field should say "PMF."

5. Skipping the 4473 Because "It Was Already Owned"

If it passes through your FFL's inventory, a 4473 is required on transfer out — regardless of prior ownership history.

6. Inconsistent Serial Number Formats

Pick a format and stick with it. Consistency makes audits faster and demonstrates systematic compliance.

How Electronic Bound Book Software Handles PMFs

Logbooks for Guns has built-in PMF support that enforces compliance at every step:

• PMF-specific entry fields — auto-fills "PMF" as manufacturer, prompts for your assigned serial number
• Serial number format enforcement — keeps your numbering consistent
• Correction audit trail — every change tracked per ATF Ruling 2016-1 Method A
• 4473 cross-reference — links disposition to the corresponding form
• Inspection-ready reporting — generate a compliant bound book PDF filtered by PMFs on demand

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This article is provided for informational purposes only and does not constitute legal advice. FFLs should consult with a qualified attorney or ATF-licensed compliance consultant for guidance specific to their operations.