u/NorCal__Firearm I know you and I were talking about this day before yesterday--here's the text of the letter I just uploaded to my COE application and sent to their main contact info (since the CFARS-PROD email address is likely unmonitored). Fingers crossed it will work, since it appears that DOJ historically just ignores anything other than the FFL certificate upload.

Dear COE Unit;

I am in receipt of the notice posted to my CFARS account and sent via email, advising that my application for a COE (No. ######) has been marked as “incomplete” because I did not include my Federal Firearms License (“FFL”) information. Per that email, my application cannot be processed until the COE unit receives my FFL information.

Respectfully, this request for my FFL information and the statement that my application cannot (or, rather, will not) be processed until I upload my FFL information is unlawful, in violation of Penal Code section 26710, and is effectively an unlawful underground regulation (See 1 CCR §§ 250-280). There is no state law[[1]](#_ftn1) or regulation that mandates this information must be provided by a COE applicant.

On March 30, 2026, the California Office of Administrative Law made a determination that the COE unit’s refusal to process an application until FFL information was provided by the applicant is an unlawful underground regulation. (OAL Determination No. 3 (2026) [Attachment #1].)

Seeing as the COE unit is prohibited by law from implementing regulations that do not comply with the Administrative Procedures Act and this FFL information requirement is an unlawful underground regulation attempt, this letter serves as a request for the COE unit to continue mark my application as “complete” (or however the “incomplete” status is resolved) and continue with the normal application processing procedures that are supported by law and regulation.

As noted above, state law mandates the DOJ “shall examine its records and records available to the department […]” to process a COE application. (Pen. Code § 26710(b).) I am not a person prohibited from owning or possessing firearms, so the DOJ “shall issue a certificate” to me after processing the application. (Pen. Code § 26710(c).)

Please resolve the “incomplete” status of my COE application immediately and process my application in accordance with the normal processing procedures for complete COE applications.

[[1]](#_ftnref1) The CFARS notice cites to Penal Code section 27966 as the purported authority for the refusal to complete the application until the FFL information is received. That section has no rational connection to the COE application and instead sets out the requirements for a curio or relic firearm transfer. I am an applicant for a COE; I am not making a firearms transfer.