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Posted: 7/19/2023 3:23:59 PM EDT
Scenario: FFL 07/02 buys a stripped Aero Precision lower receiver from 'ABC Distributor', builds into a SBR, submits ATF Form 2, and sells complete gun online and ships to customer's FFL/SOT 'Tom's Guns'.

What I'm not clear on is what it would look like in the FFL 07/02's A&D book.

Would it be 2 different lines in the A&D book as follows?

1st line: Manufacturer: Aero Precision | Type: Receiver | Acquisition: ABC Distributor | Disposition: My FFL
2nd line: Manufacturer: My FFL | Type: Short barreled rifle | Acquisition: My FFL | Disposition: Tom's Guns

Thank you
Link Posted: 7/24/2023 6:56:52 PM EDT
[#1]
Originally Posted By nskate22:
Scenario: FFL 07/02 buys a stripped Aero Precision lower receiver from 'ABC Distributor', builds into a SBR, submits ATF Form 2, and sells complete gun online and ships to customer's FFL/SOT 'Tom's Guns'.

What I'm not clear on is what it would look like in the FFL 07/02's A&D book.

Would it be 2 different lines in the A&D book as follows?

1st line: Manufacturer: Aero Precision | Type: Receiver | Acquisition: ABC Distributor | Disposition: My FFL
2nd line: Manufacturer: My FFL | Type: Short barreled rifle | Acquisition: My FFL | Disposition: Tom's Guns

Thank you
View Quote


yes, 2 entries.
Link Posted: 11/19/2023 7:55:10 PM EDT
[#2]
Originally Posted By nskate22:
Scenario: FFL 07/02 buys a stripped Aero Precision lower receiver from 'ABC Distributor', builds into a SBR, submits ATF Form 2, and sells complete gun online and ships to customer's FFL/SOT 'Tom's Guns'.

What I'm not clear on is what it would look like in the FFL 07/02's A&D book.

Would it be 2 different lines in the A&D book as follows?

1st line: Manufacturer: Aero Precision | Type: Receiver | Acquisition: ABC Distributor | Disposition: My FFL
2nd line: Manufacturer: My FFL | Type: Short barreled rifle | Acquisition: My FFL | Disposition: Tom's Guns

Thank you
View Quote


In this case is there any a requirement to engrave the receiver?
Link Posted: 11/19/2023 8:00:47 PM EDT
[#3]
Discussion ForumsJump to Quoted PostQuote History
Originally Posted By Kota4bye:


In this case is there any a requirement to engrave the receiver?
View Quote


Not since 08/24/22
Link Posted: 11/19/2023 8:08:42 PM EDT
[#4]
Discussion ForumsJump to Quoted PostQuote History
Originally Posted By RenegadeX:


Not since 08/24/22
View Quote


Interesting, thanks!
Link Posted: 11/19/2023 8:19:25 PM EDT
[#5]
Follow up question that I've submitted to "Ask the Experts" with no response yet.....

I have a shotgun in my personal collection I want to SBS (actually have a form 1 pending since Jan).  

I could transfer to my FFL (me), form 2, and then hold in my A&D, or Form 4 back to myself or my trust.

Is there an engraving requirement there?

You can point me to the reference, I don't mind reading, but I haven't found it in the NFA handbook yet.
Link Posted: 11/19/2023 8:38:40 PM EDT
[#6]
Discussion ForumsJump to Quoted PostQuote History
Originally Posted By Kota4bye:
Follow up question that I've submitted to "Ask the Experts" with no response yet.....

I have a shotgun in my personal collection I want to SBS (actually have a form 1 pending since Jan).  

I could transfer to my FFL (me), form 2, and then hold in my A&D, or Form 4 back to myself or my trust.

Is there an engraving requirement there?

You can point me to the reference, I don't mind reading, but I haven't found it in the NFA handbook yet.
View Quote


You are not gonna find it either since it is well over a decade out of date and the rule is just a little over a year old. Throw the NFA Handbook away it is way out date and wrong on many things.

The Receiver Rule that became effective 08/24/22 is where the new engrave rules are  
Link Posted: 11/20/2023 12:07:29 AM EDT
[#7]
Discussion ForumsJump to Quoted PostQuote History
Originally Posted By RenegadeX:


You are not gonna find it either since it is well over a decade out of date and the rule is just a little over a year old. Throw the NFA Handbook away it is way out date and wrong on many things.

The Receiver Rule that became effective 08/24/22 is where the new engrave rules are  
View Quote


I’m a new 07 FFL waiting for my 02 SOT to arrive in the mail.  So I want to know this, not starting stupid internet wars.

Anyways, I’ve read the Receiver Rule Apr/Aug 2022 and open letter from Dec 2022.  For existing firearms (like his example), I don’t see where that rule relieves me (07) of the obligation to engrave my business name, city, and state on the receiver prior to submitting a Form 2 for SBR/SBS/MG.  My IOI and I just discussed this topic earlier this month.

I’m happy to be wrong since that saves me the hassle of getting things engraved.
Link Posted: 11/20/2023 2:30:05 PM EDT
[#8]
Discussion ForumsJump to Quoted PostQuote History
Originally Posted By romad99:


I’m a new 07 FFL waiting for my 02 SOT to arrive in the mail.  So I want to know this, not starting stupid internet wars.

Anyways, I’ve read the Receiver Rule Apr/Aug 2022 and open letter from Dec 2022.  For existing firearms (like his example), I don’t see where that rule relieves me (07) of the obligation to engrave my business name, city, and state on the receiver prior to submitting a Form 2 for SBR/SBS/MG.  My IOI and I just discussed this topic earlier this month.

I’m happy to be wrong since that saves me the hassle of getting things engraved.
View Quote


When Law/Rule changes it gets propogated to the CFR.

27 CFR § 479.102 - Identification of firearms.

(3) Adoption of identifying markings. You may adopt existing markings and are not required to mark a serial number or other identifying markings previously placed on a firearm in accordance with this section, as follows:

(i) Newly manufactured firearms. Manufacturers may adopt the serial number and other identifying markings previously placed on a firearm by another manufacturer provided the firearm has not been sold, shipped, or otherwise disposed of to a person other than a qualified manufacturer, importer, or dealer, and the serial number adopted is not duplicated on any other firearm.
Link Posted: 11/20/2023 4:50:36 PM EDT
[#9]
Discussion ForumsJump to Quoted PostQuote History
Originally Posted By RenegadeX:


When Law/Rule changes it gets propogated to the CFR.

27 CFR § 479.102 - Identification of firearms.

(3) Adoption of identifying markings. You may adopt existing markings and are not required to mark a serial number or other identifying markings previously placed on a firearm in accordance with this section, as follows:

(i) Newly manufactured firearms. Manufacturers may adopt the serial number and other identifying markings previously placed on a firearm by another manufacturer provided the firearm has not been sold, shipped, or otherwise disposed of to a person other than a qualified manufacturer, importer, or dealer, and the serial number adopted is not duplicated on any other firearm.
View Quote



Thanks, brother.  That does seem to relieve us of the requirement to mark it again.
Link Posted: 11/20/2023 9:39:19 PM EDT
[#10]
that is awesome to know !
I was about to start looking for an engraver locally ( while I wait on my 07 ) but scratch that !!

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