Yes. Amended regulations 478.129(b), (d) and (e) require ALL licensees to retain ALL required records until the license is discontinued. Forms 4473 must be kept on paper or in an approved electronic format at the licensed business premises and accessible for inspection. A warehouse may be used to store paper records older than 20 years of age. That warehouse would be subject to inspection and cannot be used to conduct other firearms business activities without obtaining a separate license.

Licensees can no longer send their records older than 20 years to the Out of Business Records Center, National Tracing Center. They can only submit their records upon discontinuance of business under the license.