Ca 3 in 30 new rule, FFL03/COE Exemption

[jbl5150]

I think a number of the readers have their FFL03/COE. With the new 3 in 30 firearm purchase limit, there is language that exempts FFL03 holders from this limitation (same as when 1 in 30 was in effect).
As a suggestion, it would be helpful to have a list of stores that honor the exemption for either a new sale or PPT. I can start as I was just informed today that Poway range (PWG) does not honor that exemption. Thoughts and feedback appreciated.

 

[Wolkenflieger]

Its highlighted in post too...you need both for CA to consider you a collector

Makes sense.

 

[Skilly]

Its highlighted in post too...you need both for CA to consider you a collector

Key part of this statement is the "CA" part. FFL-03 is Federal and the COE is essentially the permission slip that you can operate it in CA.

 

[BONECUTR]

COE is essentially the permission slip that you can operate it in CA.

Not exactly. The CADOJ can not run a NICS check on you unless you buy a gun. The COE does the same background as if you do a PFEC but people have been cleared by CADOJ on PFEC's and then denied via NICS when they try to buy. So when you have a 03 they know you have passed NICS and a COE you have passed all the state backgrouds.

Having one doesn't mean you would pass the other.

 

[Skilly]

Not exactly. The CADOJ can not run a NICS check on you unless you buy a gun. The COE does the same background as if you do a PFEC but people have been cleared by CADOJ on PFEC's and then denied via NICS when they try to buy. So when you have a 03 they know you have passed NICS and a COE you have passed all the state backgrouds.

Having one doesn't mean you would pass the other.

I think we are saying the same thing. CA is essentially saying you need to COE to operate the FFL-03 in CA because they require additional state level scrutiny - aka, their 'permission slip'.

 

[BONECUTR]

I think we are saying the same thing. CA is essentially saying you need to COE to operate the FFL-03 in CA because they require additional state level scrutiny - aka, their 'permission slip'.

No we are not saying the same thing. You can have an 03 FFL and do 03 FFL things with it and not have a COE. That is not a requirement.
Just like you can have a COE and not have an 03FFL because its needed to work in the firearms/ammo industry.

If you want the perks of being able to be exempt from 3 in 30, and have ammo shipped to your door, bypass 10 day waits on C&R firearms you need both.

 

[Skilly]

No we are not saying the same thing. You can have an 03 FFL and do 03 FFL things with it and not have a COE. That is not a requirement.
Just like you can have a COE and not have an 03FFL because its needed to work in the firearms/ammo industry.

If you want the perks of being able to be exempt from 3 in 30, and have ammo shipped to your door, bypass 10 day waits on C&R firearms you need both.

OK so, this is a little confusing.

Starting with the COE, without working in the Firearms industry, you cannot obtain an COE without an FFL-03. They are linked, at least earlier this year were (Ive seen a recent thread saying that might have changed). And having an FFL-03 in CA without a COE has little to no benefit. Meaning you would still have to DROS a C&R would you not? And, of course, all of the other perks this thread is discussing, no ammo access, direct shipping etc.

 

[Bobalover209]

OK so, this is a little confusing.

Starting with the COE, without working in the Firearms industry, you cannot obtain an COE without an FFL-03. They are linked, at least earlier this year were (Ive seen a recent thread saying that might have changed). And having an FFL-03 in CA without a COE has little to no benefit. Meaning you would still have to DROS a C&R would you not? And, of course, all of the other perks this thread is discussing, no ammo access, direct shipping etc.

Legally the CADOJ should not have required the ffl03 number to process a COE, but they made it their policy anyways. The reason they will process it now without the ffl03 information is because they got sued.

 

[Skilly]

Legally the CADOJ should not have required the ffl03 number to process a COE, but they made it their policy anyways. The reason they will process it now without the ffl03 information is because they got sued.

OK but again, it serves no practical purpose by itself is my point. For someone not in the firearms industry, it doesn't do anything. Its the FFL-03 being linked that affords any benefit to an 03 holder. And, the FFL-03 in CA without a COE is kinda useless as well.

So even getting them independently, I don't see a single benefit that activates until you link them together.

 

[BONECUTR]

OK so, this is a little confusing.

The COE's were only suppose to be for people who handle firearms there really is no point for people not in the industry to get them with the sole option of 03FFL holders to get the exemptions. They are used as a way for business that handle firearms to know the employees are not prohibited on a state level from being around firearms. Its more than just gunstores... prop houses.. manufacturers.. guns show promoters....explosive permit holders...the people who do fireworks at Disneyland...

As for as a 03FFL without a COE some of the 03 perks still apply. Face to face C&R is allowed if you leave the state you just need to report it to CADOJ.

 

[BONECUTR]

I don't see a single benefit that activates until you link them together.

You have just a 03 in Reno at the gunshow... you see a C&R you like. Your hand him a copy of your 03 and your id.... he hands you his...you give him cash and walk away in seconds.... thats a "slight" perk.

I have customers who have an 03 only cause thats all they do is look for old gems.

 

[Skilly]

The COE's were only suppose to be for people who handle firearms there really is no point for people not in the industry to get them with the sole option of 03FFL holders to get the exemptions. They are used as a way for business that handle firearms to know the employees are not prohibited on a state level from being around firearms. Its more than just gunstores... prop houses.. manufacturers.. guns show promoters....explosive permit holders...the people who do fireworks at Disneyland...

As for as a 03FFL without a COE some of the 03 perks still apply. Face to face C&R is allowed if you leave the state you just need to report it to CADOJ.

It would be interesting to see how many FFL-03 holders in CA are in place for the pursuit of C&R acquisitions vs in place to manage through access to ammo and incoming laws like the 3 in 30.

Im sure that there are people out there collecting and very happy they can go to a free state and take a C&R home without issue but Im guessing a lot of holders are the other, looking to navigate more affordable ammo and not have their gun purchases throttled more than they already are. For that purpose, I go back to my original statement that the FFL-03 is the Federal unlock and the COE is that permission slip and only together give a lot of us the unlock we want.

 

[BONECUTR]

I go back to my original statement that the FFL-03 is the Federal unlock and the COE is that permission slip and only together give a lot of us the unlock we want.

I think you would be shocked to find out how little people care about certain things. Remember there are people who have had 03's in CA long before these new rules and still maintain them without COE's

I have customer who order 1000's months on ammo....some from me and much more shipped in. I've told them about the C&R/COE exemption cause im honest and they just shrug their shoulders and keep buying.

I have people who buy guns every week (now 3 a month) and almost never buy ammo cause the collect and rarely shoot.

I have people who have bought 1 firearm and shoot 500-1000 rounds a week.

I have people who buy a single gun and spend the next year tricking it out....and they start again the following year.

These trends stay the same with many people regardless of the 1in30, 3in30, Ammo Checks, 11% tax. Freedom Week. SSE1, SSE2.

Changes don't really effect the average customer IMHO.

 

[Dvrjon]

Legally the CADOJ should not have required the ffl03 number to process a COE, but they made it their policy anyways. The reason they will process it now without the ffl03 information is because they got sued.

No.

The state was sued over the 1-in-30 rule. They lost and the Legislature passed a 3-in-30 rule.

The state was running an underground regulation requiring applicants for COE to have an FFL-03. That wasn’t required under the law, so an individual challenged the practice through an administrative remedy with the Office of Administrative Law (OAL) which found the process improper requiring DOJ to cease the activity. No law suit was filed.

 

[OCGunCollector]

I thought PPT was exempt from this law anyways?

 

[BONECUTR]

I thought PPT was exempt from this law anyways?

PPT's are not exempt from 3 in 30 unless the seller has a court order to get rid of firearms or specific estate transfers

 

[Bobalover209]

No.

The state was sued over the 1-in-30 rule. They lost and the Legislature passed a 3-in-30 rule.

The state was running an underground regulation requiring applicants for COE to have an FFL-03. That wasn’t required under the law, so an individual challenged the practice through an administrative remedy with the Office of Administrative Law (OAL) which found the process improper requiring DOJ to cease the activity. No law suit was filed.

Thanks for the clarification.

 

[jbl5150]

I go to the Santee one and they've taken care of me just fine using my C&R. Sometimes you may get one of the newer guys who isn't familiar with the process, but they can grab one of the more experienced ones and they'll get you taken care of.

Reaper;
Just passing along my thanks. DGM in Santee took care of me and great people.

 

[ReaperCustom45]

Reaper;
Just passing along my thanks. DGM in Santee took care of me and great people.

No problem, they are always good folks to deal with!

 

[Specialist_muted]

People with FFL 03 and COE are real try hards can't lie

You don't like spending less on ammo and having it delivered to your door? Weird take.

 

[9Cal_OC]

You don't like spending less on ammo and having it delivered to your door? Weird take.

This wasn’t needed a few years ago. Just CA making people jump through more hoops and pay a livescam.

People in free states don’t have to do this at all and can get stuff delivered without the scrutiny.