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So the setup pictured above would be considered an SBR?
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There were several hundred pages of FOIA ATF documents recently released which included letters to prosecutors who asked the ATF to evaluate guns used in potential crimes. In those letters, the SBA3 brace was considered a "shouldering device", not a brace, so according to them it's an SBR even without the LAW. Released internal documents seem to indicate the same.
This is from the latest ATF FOIA dump, for what it's worth....
FOIA dumpAround page 67 (labeled p.484).
Also, if the distance between the center of the trigger and the back of any brace is over 13.5 inches at full extension (or if they can force it to that length), again, they considered it an SBR. The LAW folder pushes adjustable braces over that length.
Funny, though, they haven't arrested any manufacturers for selling completed firearms with the SBA3...
Do what you want. I am not a lawyer, this is not legal advice.