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FFL03 and COE 3 in 30 Rule Exemption? Seems like no one knows if it's yes or no!

sjctactical

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CAguns Supporter
2026 10+
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Any know definitively, if COE and FFL03 exempts you from 3 in 30 for MODERN handguns as well as curio? Went to Sac Gun Range today and they said it does not. Other places say it does. Google and Chatgpt say it does, for whatever that's worth. Contacted Cal DOJ, waiting to hear back.
 
27535.(a) A person shall not make an application to purchase more than one firearm one or more firearms that would result in the purchase of more than three firearms cumulatively within any 30-day period. This subdivision does not authorize a person to make an application or applications to purchase a combination of firearms, completed frames or receivers, or firearm precursor parts within the same 30-day period.

(b) Subdivision (a) does not apply to any of the following:
...
(10) Any person who is licensed as a collector pursuant to Chapter 44 (commencing with Section 921) of Title 18 of the United States Code and the regulations issued pursuant thereto, and has a current certificate of eligibility issued by the Department of Justice pursuant to Article 1 (commencing with Section 26700) of Chapter 2.

Yes, the FFL03 and COE exempt you from the 3 in 30, regardless of whether your 3 are C&R or not. But as you already experienced, some places will for whatever reason refuse to accept it, even though it's an option on the drop down list of exemption reasons. You'll just have to find another place that knows what they're doing.
 
Any know definitively, if COE and FFL03 exempts you from 3 in 30 for MODERN handguns as well as curio? Went to Sac Gun Range today and they said it does not. Other places say it does. Google and Chatgpt say it does, for whatever that's worth. Contacted Cal DOJ, waiting to hear back.
Exempts you from limits for all modern and curios.

Sac Gun Range is a garbage store. I don’t recommend them.

Most gun stores do not know what a FFL03 and COE are and even fewer are educated and willing to help Californians go through the process with these exemptions. Sad
 
You are absolutely exempt from the 3 in 30 rule with an FFL03 and COE for any modern or curio firearm. You need to find someone who knows how to enter it into the DROS as a collector using your FFL03 and COE license numbers.
 
Any know definitively, if COE and FFL03 exempts you from 3 in 30 for MODERN handguns as well as curio? Went to Sac Gun Range today and they said it does not. Other places say it does. Google and Chatgpt say it does, for whatever that's worth. Contacted Cal DOJ, waiting to hear back.
Yep! Can confirm! But I guess it just depends on where you go.
 
There was a DES bulletin about this.

There is no doubt, 03+COE exempts you from 3-in-30 for all firearms. Heck, the largest and most risk-averse dealer in the state (Turners) accepts 03+COE for 3-in-30 exemption.

Amazing that we’re still getting this nonsense from FFLs in 2026, haha!!
 
I have posted about this at least twice including the DOJ Bulletin, please search the Forum and you will find it. (or ask me when I'm not too tired from a range trip).
You are absolutely exempt but the FFL must enter it correctly in the DES system. You should print out and carry the Bulletin with you for FFL's that may be unaware.
 
There was a DES bulletin about this.

There is no doubt, 03+COE exempts you from 3-in-30 for all firearms. Heck, the largest and most risk-averse dealer in the state (Turners) accepts 03+COE for 3-in-30 exemption.

Amazing that we’re still getting this nonsense from FFLs in 2026, haha!!
Well it did take effect in April 2026, so they've only had 6 months to figure it out 🙄
 
Far beyond Sacramento Gun Range refused my FFL03+COE exemption. I'd say more stores refused to honor it than accepted it, based on last 6 months experience and about 10 PPTs.
 
Far beyond Sacramento Gun Range refused my FFL03+COE exemption. I'd say more stores refused to honor it than accepted it, based on last 6 months experience and about 10 PPTs.
This is wild to me, it is the law; how can they refuse? Do they argue it's not legal or just simply don't care and exclaim they won't do it regardless? I would love to hear the rationale.

One other question, is this primarily for new purchases or PPT's in particular? (actually you said PPT's) I think they'd have a tough argument on PPT's. PC 26825 and 28050: Dealers generally must conduct lawful PPTs. And dealers can be cited/fined for failure to conduct proper PPTs
 
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If any shops give you a problem, you can let them know there is a bulletin on DES for them to look at that very plainly states it is an exemption to the 3 in 30, and that they do not need to be C&R firearms to qualify. I had one shop turn me down, they brought up the bulletin and saw they were mistaken, and then changed their policy. I wont shop anywhere that just refuses, it's plain as day direct from DOJ, which means they are just screwing us over on it.
 
If any shops give you a problem, you can let them know there is a bulletin on DES for them to look at that very plainly states it is an exemption to the 3 in 30, and that they do not need to be C&R firearms to qualify. I had one shop turn me down, they brought up the bulletin and saw they were mistaken, and then changed their policy. I wont shop anywhere that just refuses, it's plain as day direct from DOJ, which means they are just screwing us over on it.
Same thing happened to me. It also means they don't read/review DOJ bulletins - not a good look.
 
This is wild to me, it is the law; how can they refuse? Do they argue it's not legal or just simply don't care and exclaim they won't do it regardless? I would love to hear the rationale.

One other question, is this for new purchases or PPT's in particular? I think they'd have a tough argument on PPT's. PC 26825 and 28050: Dealers generally must conduct lawful PPTs. And dealers have been cited/fined for failure to conduct proper PPTs

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.
 
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