Type 1 and 8 FFL SOT Question

[Austringer]

I have a Type 1 FFL with a Class 3 SOT and a few pre-mays on the Type 1 FFL, I've had a Type 8 FFL for a few years and was thinking getting an Class 1 SOT for my Type 8 FFL.  My questions are:

1) Will the Class 1 SOT cover both the Type 1 FFL as well since the Class 1 SOT is "a higher level SOT".

2) I am under the impression that a business only needs one SOT per location and it would cover the FFLs there provided it is the right class, such as the Class 3 SOT I currently have would not cover the Type 8 as the Type 8 FFL would be a Class 1 SOT but the Class 1 would cover the Type 1 FFL as if you are importing, you are also dealing etc and the Class 1 is encompassing enough to cover both import and dealing activities.

3) If I drop the Class 3 SOT, do I need to transfer the Pre-Mays to my Type 8 FFL or since they are Pre-Mays, I could just leave them on the current FFL or LLC the FFL is under since even if you drop your SOT, you can keep the Pre-Mays as long as what ever entity that houses them still exists. 

Just want to make sure I have all lined up before paying for the Class 1 SOT and dropping the Class 3 SOT.

 

Thanks

[Uncle Zeek]

I can't answer the other questions, but regarding #3, since the guns are pre-may samples, then you simply keep them under the LLC name that currently owns them when you let the 01/03 expire.  No need to transfer them to the 08/01 license.  Might even be a good time to consider forming a new LLC for the 08/01 altogether.

[United Surplus Arms]

The class 1 is not a "higher" category of SOT, just a different classification.  You need a 03 SOT for a 01 FFL.  The 01 SOT will not work for both licenses, even if they are at the same location. Even if the underlying FFL is the same LLC or business name.

You are correct that an 08FFL (and corresponding 01 SOT) permits you to both act as an importer and as a dealer under the same license.

it is not required to transfer the premays from the 01FFL to the 08FFL , but you may want to consider it.  If a pre-may is transferred to an active SOT, it can be sold for a (slightly) higher premium; and in a quicker/easier time.  there is no down side to doing this and it costs nothing.

Edited yesterday at 11:25 AM by United Surplus Arms
sp

[Austringer]

@United Surplus Arms thanks for the info, I'm going to drop my Class 3 SOT and pay the $500 (reduced bc i move less that .5M) through the Type 8 SOT.  Thanks again for the info. 

[Nick L]

@Austringer

sent u a message about DM1 belts, never heard back, is your inbox full?