I received a call earlier today from one of my FFL clients asking about this topic.
Specifically, they wanted me to verify whether or not the owner of a consignment firearm needs to complete a 4473 and NICS check in order to have their firearm returned.
Apparently their customer was questioning the requirement and they wanted to be able to show him verification that it was based upon law and not just store policy.
Thankfully, the ATF has this very question answered on their Q&A web site (see the screenshot below).
The answer from the ATF is clear:
“Return of any consigned firearms by the licensee to the consignor must be entered in the licensee’s disposition record. An ATF Form 4473 and a NICS check must be completed prior to the return of such firearms.”