So what that is: SOT dealers have been filling out customers form 4's for them. The damn website does not work half the time, so to help customers out dealers will get customers user names and PIN numbers. They will then when it is time to certify at the end, will fill in the FFL in the customers user name and pin (effectively signing for the customer).
Now we have had dozens of them that where you will get through the whole process and just need to "final sign" both customer and dealer and the damn website will not work. It would take a week of trying to finally getting the submit to work, each time the customer has to return to the store, you have to go through as long as 30 min process to get. back to the end submit. Both we and the customer enter in the credentials and hit submit to only have the website time out.
I could see how some store would just say let me get your user and PIN number and I will get it submitted when the website cooperates. Forgot the name of the dealer but they did this for hundreds of customers and the ATF caught wind of it. They revoked the FFL, canceled all of the form 4's The Dealer had to pay for new 200 tax stamps, transfer fees to a new dealer and the customers had to start all over.