You’d think, being a completely digital system now, that photos with whatever identifying marks/foreign lettering and numbering would suffice if that photo is always latched to that firearm. For the purposes of identification it should be no different than a S/N. The only issue I guess would be the FSA searching for particular firearms in the data base and not being able to bring anything up if only a photo is provided, unless there was a category for photos vs S/N. Make, model, cal and location should narrow things down reasonably well if said firearm was stolen/recovered etc.
I also hope there’s an “auto save” function on their site in case of failures while entering details.
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