Don't know about the original question as I've never given a firearm over to a dealer on consignment but the above quoted statement, at least as far as federal law is concerned, is wrong. Ask anyone who's sent a LCP or SR9 back to Ruger on the recalls. The gun is returned directly to you (assuming you sent it in personally). I've sent several cowboy guns to a gunsmith in Montana and they were all shipped directly back to me, no FFL involved on my end.
Originally Posted by Astute
From the ATF faq section:
(I7) Is a licensed gunsmith’s return of repaired or customized firearms to their owners subject to the Brady law, including the provision for making background checks on transferees?and
No, but it is unlawful to transfer a firearm to any person knowing or having reasonable cause to believe that such person is a felon or is within any other category of person prohibited from receiving or possessing firearms. (See also Question P24.)
(P24) A firearm is delivered to a licensee by an unlicensed individual for the purpose of repair. Is the return of the repaired firearm subject to the requirements of the Brady law? Would the transfer of a replacement firearm from the licensee to the owner of the damaged firearm be subject to the requirements of the Brady law?
Neither the transfer of a repaired firearm nor the transfer of a replacement firearm would be subject to the requirements of the Brady law. Furthermore, the regulations provide that a Form 4473 is not required to cover these transactions. However, the licensee’s permanent acquisition and disposition records should reflect the return of the firearm or the transfer of a replacement firearm.
[27 CFR 478.124-25]
[18 U.S.C. 922(d), 27 CFR 478.32(d)]
and to answer the OP's question:
(P25) Is a licensee’s return of a consigned firearm to an unlicensed individual subject to permanent Brady? Hoss