No. Records are never to be consolidated between distinct FFLs. Prior to the final rule’s effective date of August 24, 2022, licensed importers were required to maintain separate records of sale or other dispositions made of firearms to non-licensees pursuant to 478.122, and licensed manufacturers were required to maintain separate records of sales or other dispositions made of firearms to non-licensees pursuant to 478.123. Also prior to the final rule, licensed importers were permitted to consolidate their records pursuant to Ruling 2011-1, and licensed manufacturers were permitted to consolidate their records pursuant to Ruling 2016-3.

The final rule codified Ruling 2011-1 and Ruling 2016-3. However, unlike the optional rulings, the final rule amended the regulations requiring licensed importers to consolidate their records of acquisition and disposition into a single record, and licensed manufacturers to consolidate their records of acquisition and disposition into a single record.