Reporting Theft or Loss of Firearms — ATF Form 3310.11 and the 48-Hour Rule
It is one of the worst phone calls an FFL holder ever has to make: a firearm is missing from inventory. Maybe it was stolen during a break-in, maybe it disappeared during a transfer event, maybe a physical inventory revealed it is simply not where the bound book says it is. The federal regulations are unambiguous about what comes next — and the timeline is shorter than most dealers realize. Here is how the theft and loss reporting framework actually works.
The 48-Hour Reporting Window
Under 18 U.S.C. § 923(g)(6) and 27 CFR 478.39a, a federal firearms licensee who has a firearm stolen or lost from inventory must report the theft or loss to the ATF and to local law enforcement within 48 hours of discovery. The clock starts at discovery, not at the time of the underlying theft or loss. If you find on Tuesday morning that a serial number has been missing since some unknown date in the past, the 48 hours runs from Tuesday morning.
The reporting mechanism is ATF Form 3310.11 — Federal Firearms Licensee Theft/Loss Report. The form is filed online through ATF eForms or by phone to 888-930-9275 (the ATF Stolen Firearms Program), with a written follow-up. Local law enforcement is notified separately — typically by calling the local police department or sheriff's office and filing an in-person report with a case number.
What Counts as Theft or Loss
The definitions matter because they determine whether you are required to report.
- Theft. A firearm taken from licensed premises, from a transfer event, from a delivery vehicle, or from any location where the FFL was responsible for it, by a third party without authorization. Robberies, burglaries, and shoplifting all count.
- Loss. A firearm that cannot be accounted for after a reasonable search and that was last under the licensee's control. Common scenarios: a firearm logged into the bound book but never physically present, a firearm dispositioned to a buyer who never received it, a firearm misplaced during a move or remodel.
Importantly, "loss" is not "I haven't looked yet." Inventory shrinkage discovered during a casual walk-through is a discovery event — the 48-hour clock starts. You don't get to delay reporting while you "look harder."
What Goes on Form 3310.11
The form requires:
- Your FFL number and licensee name.
- The date and circumstances of the theft or loss (or the date of discovery if the underlying date is unknown).
- For each firearm: manufacturer, importer (if any), country of manufacture (if imported), model, serial number, type, caliber/gauge.
- The name and case number of the local law enforcement agency that took the report.
- A narrative summary of what happened.
The form is straightforward but unforgiving on accuracy. Wrong serial numbers, missing manufacturer information, or unrecorded importer details are common reasons forms come back for correction — and the corrections do not extend the 48-hour deadline. The clock is on the original discovery.
The Bound Book Disposition
A firearm reported as stolen or lost is dispositioned out of your active inventory in the bound book. The disposition entry uses your local law enforcement agency or "Stolen/Lost" as the transferee, with a reference to the case number and ATF Form 3310.11 incident number. Once entered, the firearm is no longer part of your live inventory — but the record persists in the bound book permanently per federal retention requirements.
If a stolen firearm is later recovered and returned to your inventory, you re-acquisition it back into the bound book with a clear notation referencing the original theft and recovery. Do not modify or strike-through the original disposition entry. The bound book is a chronological record, not a self-correcting register.
Local Law Enforcement Coordination
The local police report is independent of the ATF report. Both must be filed, and both should reference each other. When you call the local agency, ask for a case number on the spot and get the name and badge number of the responding officer. That information goes on Form 3310.11. If your local agency is slow to issue a case number, document your initial contact (date, time, person spoken to) and submit Form 3310.11 with that information — the federal deadline does not pause for local response times.
What Inspectors Look For
During an ATF inspection, theft and loss handling is closely audited:
- Was Form 3310.11 filed within 48 hours of discovery?
- Is there a corresponding bound book disposition?
- Is there a local law enforcement report referenced?
- Are firearms reported as lost actually missing, or did they reappear and never get re-acquisitioned?
- Are recovered firearms properly re-entered with clear traceability?
The pattern that draws inspector attention is a long list of "missing" firearms with no corresponding 3310.11 filings. That suggests either chronic inventory mismanagement or — worse from the ATF's perspective — possible diversion to prohibited persons. Either way it is a license-threatening finding.
Practical Prevention
Most theft/loss incidents in licensed FFL operations are not break-ins. They are inventory drift — a firearm logged in but never physically received, a firearm shipped out but never dispositioned, a firearm carried home for a smith repair and forgotten. The single most effective prevention is a regular physical inventory cross-checked against the bound book, with documented results. Quarterly is the minimum cadence we recommend; many high-volume dealers do monthly walk-throughs.
Our physical inventory audit guide walks through the cross-check procedure that turns up most theft/loss situations before they become 48-hour reporting events. And our electronic bound book platform makes the disposition side of the process — including post-incident bound book updates — straightforward and auditable.
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