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That's interesting, especially the claim that someone at DOJ instructed dealers not to recognize the FFL-03 + COE exemption. I'd really like to know what DOJ actually said, because PC 27535 doesn't limit that exemption to C&R firearms.1. "My supervisor told me that this is for C&R guns only" - Sacramento Gun Range
2. "I read the law as you are exempt just for C&R guns." - Sacramento Gun Range, superviser
3. "I was on a training and DOJ contact person told me to not accept FFL03+COE, I'm not going to jeopardize my business" - few other stores including Sacramento Gun Range
It's a private businesses, they put whatever rules they want and you either take it or leave. It's a waste of time to argue with them.
- Some don't transfer semi-auto AR pistols
- Some don't transfer Glocks
- Some don't transfer Vepr shotguns
Therefore I always call a store and ask will they make a PPT of a maker/model gun in advance. If they say no, I call another store.
Again they may have a stronger case with New sales but for PPT's I disagree that private businesses can simply establish whatever rules they want. CA law specifically requires licensed dealers to process lawful PPTs, and failure to do so is an identified dealer violation.
If a dealer is refusing a PPT solely because the buyer is invoking a valid FFL-03 + COE exemption, I'd suggest documenting the refusal and requesting clarification from DOJ.
Xfers are a different matter. I believe they are treated like new purchases and can be refused, but I would still try to capture in writing the reason.