DEPARTMENT OF THE TREASURY
             BUREAU OF ALCOHOL, TOBACCO AND FIREARMS

                           OCT 14 1999

                                            901040:GS
                                           5320/990300

Dear Mr. Bardwell:

This is in response to your letter dated September 7, 1999,
regarding certification required on the Form 4 application.  You
asked specifically about certificates from the chief of the
Colorado State Patrol and the head of the Colorado Bureau of
Investigation (CBI).  You also asked about general guidelines used
by the Bureau of Alcohol, Tobacco and Firearms (ATF) to determine
whether an official is authorized to sign the certificate.

As you know, Title 27, Code of Federal Regulations section 179.85,
requires that the Form 4 transfer application include, "A
certificate of the local chief of police, sheriff of the county,
head of the State police, State or local district attorney or
prosecutor, or such other person whose certificate may in a
particular case be acceptable to the Director."  To determine if an
official other than those mentioned above is authorized to sign the
certification, two factors are considered.  First, the official
must have jurisdiction over the area where the transferee resides. 
Second, the official muse have access to law enforcement records
under State or local law, as he must confirm that no law
enforcement information exists that indicates that the transferee
may use the firearm for other than lawful purposes.

                                 - 2 -

Mr. James O. Bardwell

In several cases, ATF's Director has approved certifications from
judges who were from the district where the transferee resides, and
who presided over courts of general jurisdiction.  ATF also
determined that CBI's Director is authorized to certify the Form 4
application.  However, ATF has not determined if the head of the
Colorado State Patrol has the authority to sign the certification.

Should additional information be required, please contact Gary
Schaible at (202) 927-8330.

                       Sincerely yours,


                            [signed]
                       Kent M. Cousins
             Chief, National Firearms Act Branch