Originally Posted by
TSO1973
"We recommend that you provide the key or combination to the security officer if he or she needs to open the container. You should remain in the area designated by the aircraft operator or TSA representative to take the key back after the container is cleared for transportation. If you are not present and the security officer must open the container, we or the airline will make a reasonable attempt to contact you. If we can't contact you, the container will not be placed on the plane. Federal regulations prohibit unlocked gun cases (or cases with broken locks) on aircraft."
But that would still require giving up the key or combination. The CFRs say that "only the individual checking the baggage retains the key or combination". What you quote requires that the individual checking the baggage take action that would result in a violation of the relevant CFR (as I read it the airline would be the one violating the CFR).
In the case of a combination lock, telling someone (other than a person with anterograde amnesia) the combination would result in them retaining the combination, and thus be illegal.
Similarly, if you give the key to an airline or TSA employee, you are not retaining the key.
I am not trying to be a wise@#$... mistakes regarding this kind of thing can easily get one into lots of trouble. For example, what if the TSA employee takes the key and forgets to lock the case? Who gets in trouble then?
(N.B. I've never checked a firearm, nor am I a lawyer.)