With all do respect,,no you do not have to go thru a 4473 and NICS check to get your gun back from from the FFL when the repair FFL ships it back to them.
I've kept both a Dealer (01FFL Buy/Sell) Bound Book,,,and a separate Gunsmithing/Repair (under the same 01FFL) Bound Book starting in 1971.
I've had many, many ATF compliance checks along the way.
The Dealer book keeps track of 'Transfer of Ownership' (That's the key,,when a Non-FFL, takes possession of the gun),,That requires a 4473/NICS
Gunsmiths Book keeps track of the gun during Repair and it can ONLY go betw other FFL's for work. There is NO transfer of Ownership. Sending the gun betw FFL's is NOT Transfer of Ownership. The 01FFL Gunsmith cannot send or give the gun(frame) to a Non-FFL for gunsmithing work
There is no 4473/NICS done.,,the gun always stays in the possession of an FFL as a "Repair'.
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There was no lobbying back in '67/68 or otherwise to get special treatment for Gunsmiths as far as record keeping. This is what the GCA came up with all on their own and has not changed since the '68 law came to be.
The only major things that have changed is that the requirement to keep a 3rd bound book of Ammunition Sales was dropped in 1986 (most people don't even recall or know that one even existed).
The only time I ever got a inspection of that Bound Book was during the Son of Sam spree. They were looking for purchasers of Western brand 44spl ammo.
The other change and the one that the Gunsmiths did speak up about in Congressional Hearings on the subject was the need to pay Fed Excise Tax on the 'mfg of a firearm' when doing some gunsmithing operations that the IRS (NOT BATF) had decided were 'mfg of a firearm'.
That whole thing started with the Fed lawsuit against contemporary muzzle loader rifle maker John Bivins and his Penn Bicentennial group of M/Ldr long rifles.
The IRS wanted FET on those muzzleloaders (non-firearms under Fed law). Bivins saw it otherwise and fought the Feds in court ...and lost. It broke him financially and probably helped him to an early death as well (the latter point only my opinion of course).
The IRS then decided that since they won the FET case against Bivins and M/Ldrs, that cartridge gun gunsmithing was also a target for FET $$. The IRS wanted small gunsmiths (01FFL's) to pay FET on gunsmithing work.
Such things as rebluing, re-bbling, engraving, restocking, ect were all classified as 'mfg of a firearm' and the FET was due on the new value of the 'mfg'd' firearm. The list was long.
The gunsmith community fought back and the result was a new exemption (might be what you are refering to) that exempts the first 50 units mfg'rd by a Gunsmith (01 or 07 FFL) from FET per calendar yr.
If you mfg 51+ units,,you owe FET on those 51+ units not just #51.
SDH who posts frequently on this forum was one who went before Congress on behalf of the Gunsmithing community .
Long story, I know, but that's the special exemption if you can call it that for gunsmiths.
It's not all for gunsmiths,,it's for their customers because that's who the FETax would be paid by,,just like salestax, the gunsmith would only be the collection agent and pass it along to the IRS.
A pain and paperwork for the Gunsmith,,and the FET an extra 10% on Handguns and 11% on your Longgun's 'New Value' after the work is done.
On a repair,,no 4473 or NICS is done upon the return of the firearm to the orig owner by the orig FFL that took it in.
Doesn't matter if the FFL is only a middle man or actually does the work.
He should log the gun in as a Repair,,not an Acquisition.
If one of the FFL/Gunsmiths that the work is farmed out to for some reason is going to return the gun to the orig owner,,then that FFL/Gunsmith has to send it to an FFL in the owners state where a 4473/NICS check is done to transfer is back over to the owner.
That FFL didn't orig recv the firearm from the owner,,can't send it back to the owner.
Guns taken in on Consignment or for a Pawn/Loan can not be returned to their orig owner unless a 4473/NICS check is done.
Those guns are booked in to the Dealers Book as an 'Acquisition'.
They are 'For Sale' or were exchanged for a cash loan.
If they don't sell, the owner wants it back, or what ever business agreement the shop does with the owner is outside anything the BATF regulates. All the BATF sees is that the gun is now 'transfering ownership' so a 4473/NICS check must be done.