Speaking from a licensed FFL manufacturer's standpoint, it's critical to keep accurate records. Never mess with "the process" and keep everything straight in the books and you should be OK with the ATF. The thing is the records are held by the FFL holder and not by the ATF (unless the company goes out of business). To be honest, the process of record keeping is a joke right now if you want to consider it as "registration" so that the gub'mint can track down your stuff.