I'm sorry, but I don't agree. I do not at all see the same thing you do in reading that regulation. No wiggle room? HA!!! There's TONS of it in that sentence. It seems just common sense that the regulation refers to guns acquired by using the license. Like I said before, FFLs are allowed to have guns off the book, why not C&R holders? The ATF is ONLY legally interested in tracking guns bought via the license. That's MY interpretation. You do what makes you feel comfortable, but I only log those guns I purchased using the C&R license. Again, like I said before, if the ATF doesn't like it they can take back the license.
Actually, the BATF can get a warrant and come into your house if they have reasonable evidence you are in violation of the C&R regulations. Your post is admission of violation of the C&R regulations. Worst case, they might seize all of your guns. If I were not following the rules, the last thing I would do is post it on the internet.
http://www.atf.gov/firearms/curios/intro.htm
§ 178.23 Right of entry and examination. (a) Except as provided in paragraph (b), any ATF officer, when there is reasonable cause to believe a violation of the Act has occurred and that evidence of the violation may be found on the premises of any licensed manufacturer, licensed importer, licensed dealer, or licensed collector, may, upon demonstrating such cause before a Federal magistrate and obtaining from the magistrate a warrant authorizing entry, enter during business hours (or, in the case of a licensed collector, the hours of operation) the premises, including places of storage, of any such licensee for the purpose of inspecting or examining:
1.) Any records or documents required to be kept by such licensee under this part and
2.) Any inventory of firearms or ammunition kept or stored by any licensed manufacturer, licensed importer, or licensed dealer at such premises or any firearms curios or relics or ammunition kept or stored by any licensed collector at such premises.
(c) Any ATF officer, without having reasonable cause to believe a violation of the Act has occurred or that evidence of the violation may be found and without demonstrating such cause before a Federal magistrate or obtaining from the magistrate a warrant authorizing entry, may enter during hours of operation the premises, including places of storage, of any licensed collector for the purpose of inspecting or examining the records, documents, firearms, and ammunition referred to in paragraph (a) of this section (1) for ensuring compliance with the recordkeeping requirements of this part not more than once during any 12-month period or (2) when such inspection or examination may be required for determining the disposition of one or more particular firearms in the course of a bona fide criminal investigation. At the election of the licensed collector, the annual inspection permitted by this paragraph shall be performed at the ATF office responsible for conducting such inspection in the closest proximity to the collector's premises.
