Regarding my earlier post about record book entry of firearms acquired by legal means that do not utilize your license, it is a subject of great & heated debate. As a licensed C&R you must make your own decision. For more info, do a search over on
http://curioandrelicfirearmsforum.yuku.com. If you enter every C&R firearm you own, regardless of how it is acquired, into your bound record that is completely fine and is the most prudent course. I have never seen BATF guidance that requires that.
The key as I understand it is in section 478.41 - a C&R license entities the holder to acquire in interstate commerce, and only apply to transactions related to use of that license (you don't use your license to acquire an old gun where form 4437 is used).
Confusion comes from reading paragraph 478.125(f) as a stand alone without considering 478.41(c) & (d), and from ignoring the definition of collector as defined by the regulations.
If you want some boring reading, here goes from the AFT web site:
http://www.ecfr.gov/cgi-bin/text-idx?SID=70394195a3edf623eba7ce77a1bddff1&node=27:3.0.1.2.3&rgn=div5
Title 27: Alcohol, Tobacco Products and Firearms
PART 478—COMMERCE IN FIREARMS AND AMMUNITION
Subpart B—Definitions
Collector. Any person who acquires, holds, or disposes of firearms as curios or relics.
Licensed collector. A collector of curios and relics only and licensed under the provisions of this part.
Subpart D—Licenses
§478.41 General.
(c) Each person seeking the privileges of a collector licensed under this part shall file an application, with the required fee (see §478.42), with ATF in accordance with the instructions on the form (see §478.44), and pursuant to §478.47, receive from the Chief, Federal Firearms Licensing Center, the license covering the collection of curios and relics. A separate license may be obtained for each collection premises, and such license shall, subject to the provisions of the Act and other applicable provisions of law, entitle the licensee to transport, ship, receive, and acquire curios and relics in interstate or foreign commerce, and to make disposition of curios and relics in interstate or foreign commerce, to any other person licensed under the provisions of this part, for the period stated on the license.
(d) The collector license provided by this part shall apply only to transactions related to a collector's activity in acquiring, holding or disposing of curios and relics. A collector's license does not authorize the collector to engage in a business required to be licensed under the Act or this part. Therefore, if the acquisitions and dispositions of curios and relics by a collector bring the collector within the definition of a manufacturer, importer, or dealer under this part, he shall qualify as such. (See also §478.93 of this part.)
Subpart F—Conduct of Business
§478.93 Authorized operations by a licensed collector.
The license issued to a collector of curios or relics under the provisions of this part shall cover only transactions by the licensed collector in curios and relics. The collector's license is of no force or effect and a licensed collector is of the same status under the Act and this part as a nonlicensee with respect to (a) any acquisition or disposition of firearms other than curios or relics, or any transportation, shipment, or receipt of firearms other than curios or relics in interstate or foreign commerce, and (b) any transaction with a nonlicensee involving any firearm other than a curio or relic. (See also §478.50.) A collectors license is not necessary to receive or dispose of ammunition, and a licensed collector is not precluded by law from receiving or disposing of armor piercing ammunition. However, a licensed collector may not dispose of any ammunition to a person prohibited from receiving or possessing ammunition (see §478.99(c)). Any licensed collector who disposes of armor piercing ammunition must record the disposition as required by §478.125 (a) and (b).
§478.101 Record of transactions.
Every licensee shall maintain firearms and armor piercing ammunition records in such form and manner as is prescribed by subpart H of this part.
Subpart H—Records
§478.125 Record of receipt and disposition.
(f) Firearms receipt and disposition by licensed collectors. (1) Each licensed collector shall enter into a record each receipt and disposition of firearms curios or relics. The record required by this paragraph shall be maintained in bound form under the format prescribed below. The purchase or other acquisition of a curio or relic shall, except as provided in paragraph (g) of this section, be recorded not later than the close of the next business day following the date of such purchase or other acquisition. The record shall show the date of receipt, the name and address or the name and license number of the person from whom received, the name of the manufacturer and importer (if any), the model, serial number, type, and the caliber or gauge of the firearm curio or relic. The sale or other disposition of a curio or relic shall be recorded by the licensed collector not later than 7 days following the date of such transaction. When such disposition is made to a licensee, the commercial record of the transaction shall be retained, until the transaction is recorded, separate from other commercial documents maintained by the licensee, and be readily available for inspection. The record shall show the date of the sale or other disposition of each firearm curio or relic, the name and address of the person to whom the firearm curio or relic is transferred, or the name and license number of the person to whom transferred if such person is a licensee, and the date of birth of the transferee if other than a licensee. In addition, the licensee shall cause the transferee, if other than a licensee, to be identified in any manner customarily used in commercial transactions (e.g., a driver's license), and note on the record the method used.
(g) Commercial records of firearms received. When a commercial record is held by a licensed dealer or licensed collector showing the acquisition of a firearm or firearm curio or relic, and such record contains all acquisition information required by the bound record prescribed by paragraphs (e) and (f) of this section, the licensed dealer or licensed collector acquiring such firearm or curio or relic, may, for a period not exceeding 7 days following the date of such acquisition, delay making the required entry into such bound record: Provided, That the commercial record is, until such time as the required entry into the bound record is made, (1) maintained by the licensed dealer or licensed collector separate from other commercial documents maintained by such licensee, and (2) readily available for inspection on the licensed premises: Provided further, That when disposition is made of a firearm or firearm curio or relic not entered in the bound record under the provisions of this paragraph, the licensed dealer or licensed collector making such disposition shall enter all required acquisition information regarding the firearm or firearm curio or relic in the bound record at the time such transfer or disposition is made.
In conclusion, the BATF can decide if I'm absolutely wrong. I'll be the only one responsible in that case.