User Panel
Posted: 1/3/2015 3:18:24 PM EDT
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View Quote Annoying, but foreseeable. Thanks for the link. |
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Seems like they just opened the door for any Joe Blow to be free to be able to be an 01 FFL. All the usual expectations of a manufacturer to be able to justify a license just went out the door. "Yes Sir, I want my 01 FFL because I plan on allowing my friend to complete one 80% AR15 lower on my drill press, since by your definition one lower made by someone on my machine constitutes a manufacturer, give me my license."
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Shitty.
I knew they had a problem with the CNC deal, which I can understand. But the prohibition on loaning/renting manual equipment where the individual really is doing the work I don't understand. I had just finished drafting a waiver for renting out my mill, and had several interested individuals. Oh well. Just one more way for the .gov to restrict rights and limit income earning potential. |
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I figured this was gonna come down sooner or later but I haven't heard anything before this.
I like the part in the letter that states that they have received many inquiries about if it is legal or not. Sounds like a letter writing campaign from you know who to get this passed in front of the ATF. Did you also notice they added in the "additive manufacturing", i.e. 3D printing, in there? |
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I figured this was gonna come down sooner or later but I haven't heard anything before this. I like the part in the letter that states that they have received many inquiries about if it is legal or not. Sounds like a letter writing campaign from you know who to get this passed in front of the ATF. Did you also notice they added in the "additive manufacturing", i.e. 3D printing, in there? View Quote My guess is this is fallout from the California "build parties" that were "push the button and stand there". |
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My guess is this is fallout from the California "build parties" that were "push the button and stand there". View Quote View All Quotes View All Quotes Quoted:
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I figured this was gonna come down sooner or later but I haven't heard anything before this. I like the part in the letter that states that they have received many inquiries about if it is legal or not. Sounds like a letter writing campaign from you know who to get this passed in front of the ATF. Did you also notice they added in the "additive manufacturing", i.e. 3D printing, in there? My guess is this is fallout from the California "build parties" that were "push the button and stand there". Well, that too. I doubt any of the guys doing the builds wrote the ATF. I'm sure it was the "good guys that watch out for everybody's best interests". |
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It was probably machine shops looking to get in on that business after the first cockup in the SF Bay Area. View Quote View All Quotes View All Quotes Quoted:
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Well, that too. I doubt any of the guys doing the builds wrote the ATF. I'm sure it was the "good guys that watch out for everybody's best interests". It was probably machine shops looking to get in on that business after the first cockup in the SF Bay Area. Oh, I apologize. I thought we were referring to the general lunacy in Cali. I didn't realize there was an event that could have triggered this. |
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View Quote Thanks. I've missed all that somehow, got a little egg on my face now. |
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And how do you know that a friend is using the borrowed drill press to make a lower? Didn't he borrow it for some auto/home repair project? Just sayin.
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Thanks. I've missed all that somehow, got a little egg on my face now. View Quote View All Quotes View All Quotes Quoted:
Thanks. I've missed all that somehow, got a little egg on my face now. No egg, you're good. Not everyone obsessively follows all activity in and around the firearms world. I waste my time in that way. Plus, as a California expat, I try to keep an eye on any outbreak of freedom down there. |
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Shitty. I knew they had a problem with the CNC deal, which I can understand. But the prohibition on loaning/renting manual equipment where the individual really is doing the work I don't understand. I had just finished drafting a waiver for renting out my mill, and had several interested individuals. Oh well. Just one more way for the .gov to restrict rights and limit income earning potential. View Quote And another way to increase our flow of dollars to China as many more people purchase their own mini-mill. I've been looking for a mill I could rent in the St. Louis area but I guess that is now out of the question. If a business consists of stationary tool rental: table saws, lathes, mills, shapers, etc., how can the government come after them if some customer completes a lower? It seems unreasonable that the courts would uphold the requirement that a such a business owner would have to inspect every individual item a customer worked on and only handful of people in the country even know about this new regulation. It's enough to make one feel hemmed in and confined. |
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am i missing something?
I dont see how this changes anything with regard to BUILD parties so long as the build party isn't held at a business or other "profit oriented machine shop". ie. I can still have 3 buddies over to my house (since I have a drill press with a milling table and they dont).. so long as they all finish their OWN blank and I dont receive any type of compensation for that or other work conducted on that drill press (as though I were a cabinet maker or used the equipment for a profit seeking venture.) so I can't charge my buddies a beer for use of my drill press I cant make furniture that I sell using the drill press (or CNC machine/3d printer, etc) If I just have a CNC machine for my own personal use and I dont ever sell anything I use to make with it, then I can have any INDIVIDUALS I want come over and use it.. if I sell things I build in my shop or I sell time on my equipment, then I cannot have other people over for the purpose of finishing their own AR blank. |
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am i missing something?
I dont see how this changes anything with regard to BUILD parties so long as the build party isn't held at a business or other "profit oriented machine shop". ie. I can still have 3 buddies over to my house (since I have a drill press with a milling table and they dont).. so long as they all finish their OWN blank and I dont receive any type of compensation for that or other work conducted on that drill press (as though I were a cabinet maker or used the equipment for a profit seeking venture. so I can't charge my buddies a beer for use on my drill press I cant make furniture that I sell using the drill press (or CNC machine/3d printer, etc) If I just have a CNC machine for my own personal use and I dont ever sell anything I use to make with it, then I can have any INDIVIDUALS I want come over and use it.. View Quote I have a lawyer friend digging into this ruling, seeing what kind of exemptions and workarounds are possible. Until then, I'm going to err on the side of caution. WRT to your friends, because of this language: A business (including an association or society) may not avoid the manufacturing license, marking, and recordkeeping requirements under the GCA simply by allowing individuals to initiate or manipulate a CNC machine, or to use machinery, tools, or equipment under its dominion or control to perform manufacturing processes on blanks, unfinished frames or receivers, or incomplete weapons. In these cases, the business controls access to, and use of, its machinery, tools, and equipment. Following manufacture, the business “distributes” a firearm when it returns or otherwise disposes a finished frame or receiver, or complete weapon to its customer. Such individuals or entities are, therefore, “engaged in the business” of manufacturing firearms even though unlicensed individuals may have assisted them in the manufacturing process. Held, any person (including any corporation or other legal entity) engaged in the businessof performing machining, molding, casting, forging, printing (additive manufacturing) or other manufacturing process to create a firearm frame or receiver, or to make a frame or receiver suitable for use as part of a “weapon ... which will or is designed to or may readily be converted to expel a projectile by the action of an explosive,” i.e., a “firearm,” must be licensed as a manufacturer under the GCA; identify (mark) any such firearm; and maintain required manufacturer’s records. Until we get some answers from the legal eagles, I wouldn't chance it unless those friends have unfettered access to your equipment whenever they want (hence they also "maintain dominion and control"). |
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that's not even an issue.. (having friends over to use your equipment)
SO LONG as you dont operate a business out of that same shop.. or charge them to use your machines. |
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that's not even an issue.. (having friends over to use your equipment)
SO LONG as you dont operate a business out of that same shop.. or charge them to use your machines. View Quote Don't be so sure. A legitimate business or generating revenue are not necessarily a component of "being engaged in the business of" Let's wait until some attorneys weigh in before advising/assuming that it is OK to proceed under certain circumstances. As has been said regarding other things, you might beat the rap, but you won't beat the ride. |
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The GCA, 18 U.S.C. § 921(a)(1), defines a “person” to include “any individual, corporation, company, association, firm, partnership, society, or joint stock company.” Section 921(a)(10), defines a “manufacturer” as any person engaged in the business of manufacturing firearms or ammunition for purposes of sale or distribution. As defined by section 921(a)(21)(A), the term “engaged in the business” means, as applied to a manufacturer of firearms, “a person who devotes time, attention, and labor to manufacturing firearms as a regular course of trade or business with the principal objective of livelihood and profit through the sale or distribution of the firearms manufactured.”
If your not engaged as a business for purposes of sale or distribution, wouldn't build parties still be safe? |
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I was just coming here to say this. I believe that language in the context of the document allows an individual to let a friend borrow your equipment so long as you don't charge him for it. I will wait for someone more qualified to speak on the matter before acting, however.
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Quoted:
The GCA, 18 U.S.C. § 921(a)(1), defines a “person” to include “any individual, corporation, company, association, firm, partnership, society, or joint stock company.” Section 921(a)(10), defines a “manufacturer” as any person engaged in the business of manufacturing firearms or ammunition for purposes of sale or distribution. As defined by section 921(a)(21)(A), the term “engaged in the business” means, as applied to a manufacturer of firearms, “a person who devotes time, attention, and labor to manufacturing firearms as a regular course of trade or business with the principal objective of livelihood and profit through the sale or distribution of the firearms manufactured.” If your not engaged as a business for purposes of sale or distribution, wouldn't build parties still be safe? View Quote BATF has stated that they aren't. I know I don't have deep enough pockets to challenge them. |
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What if someone happened to have a highly portable CNC machine dedicated to milling 80%s like the GG mill?
Ghost Gunner |
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What if someone happened to have a highly portable CNC machine dedicated to milling 80%s like the GG mill? Ghost Gunner View Quote I haven't been able to find if these actually exist. |
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I haven't been able to find if these actually exist. View Quote View All Quotes View All Quotes Quoted:
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What if someone happened to have a highly portable CNC machine dedicated to milling 80%s like the GG mill? Ghost Gunner I haven't been able to find if these actually exist. They are supposed to be shipping soon. Apparently they had some supply issues. I may or may not have bought one. |
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What if someone happened to have a highly portable CNC machine dedicated to milling 80%s like the GG mill?
Ghost Gunner View Quote Interesting. I have always liked the thing Cody Wilson comes up with, although this unit is a hefty chuck of change for a pretty dedicated and very limited piece of equipment. I would also seriously question the rigidity of such a small and lightweight unit, and I certainly wouldn't trust the auto locating feature unless it indexes off of several points and calibrates; I have personally seen forged lowers anywhere from .883" to .915" wide. Personally, I think anyone ready to drop $1,500 would be better served with a used Bridgeport or similar knee mill, which can be found in that price range if you look hard and are patient. If one lacks the space for a full size mill, the HF/Sieg/LMS mini mills can be bought and pretty decently tooled up for quite a bit less than that figure. But then, Cody's thing is to cater to the crowd who is much more adept with software than hardware. People like me appreciate what he's doing, but prefer conventional manufacturing for our own toys. |
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the ATF hasn't said that build parties are frowned upon.
if you read the declaration, it says that "build parties held by a guy who sells 805 blanks" is frowned upon. that's the thing about the ATF, as long as you are outside of (or within depending on your goal) their definitions of "individual" "manufacturer" and "business" then you're g2g. Quoted:
What if someone happened to have a highly portable CNC machine dedicated to milling 80%s like the GG mill? Ghost Gunner View Quote |
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If you are not a business, letting friends use the equipt and not charging them I don't see the problem.
JUST KEEP YOUR MOUTHS SHUT! Problem solved. It's not like the ATF has bugged you and your friends bodys and put secret cameras every where. Don't help someone you can't trust and they can drop the case of beer on your doorstep one night 2 weeks later when you aren't home. |
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If you are not a business, letting friends use the equipt and not charging them I don't see the problem. JUST KEEP YOUR MOUTHS SHUT! Problem solved. It's not like the ATF has bugged you and your friends bodys and put secret cameras every where. Don't help someone you can't trust and they can drop the case of beer on your doorstep one night 2 weeks later when you aren't home. View Quote THIS is EXACTLY why the ATF had to issue a ruling. people were breaking the law so they had to clarify. I would NEVER recommend this type of obfuscation to anyone... |
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Well that's where we differ, I don't consider it breaking the law unless you are charging for it or selling them.
In fact I'd say the ATF is breaking my constitutional rights with most of their gun laws. Do what you want but I would just keep the facts between me and the fence post. I have a feeling I wouldn't be the only one. |
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Do what you want but PLEASE be smart, or quiet about it. Showing all of your facebook friends how cool you are by attending a build party is IMO dumb as hell, God forbid some bozo shows up with a camera to make a youtube video. No one needs that type of attention in this culture. We are already unfairly regulated and underrepresented, little gimmicks like these will be our down fall. Always remember that they hate our right and will chisel away at it until it's gone.
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What if someone happened to have a highly portable CNC machine dedicated to milling 80%s like the GG mill? Ghost Gunner View Quote Nobody has one of those yet. It's a webpage on the internet; nothing more. |
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Well that's where we differ, I don't consider it breaking the law unless you are charging for it or selling them. In fact I'd say the ATF is breaking my constitutional rights with most of their gun laws. Do what you want but I would just keep the facts between me and the fence post. I have a feeling I wouldn't be the only one. View Quote I agree with what you said there completely. recognize that receiving a random case of beer a week later is no different than paying an invoice a week after you receive a product. I also agree with you on the ATF in it's entirety, but seeing as i personally dont have the upper hand where they are concerned, I abide by their laws. |
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I was just kidding about the case of beer.
There is only one thing I despise more than the ATF, that would be the IRS. Well make that two things, I forgot Obama and he is a strong #1. Any way I get where you are coming from. Thats why I just bought 2 receivers for $39.95 ea from AIM. At that price why even mess with milling my own since I don't mind having them in my name. |
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Equipment "Under its dominion or control" is key - One could conceivably "rent" out a portable table-top CNC, mini-mills, for renters/operators to use under their own Dominion/control and not the dominion of the rental institution. |
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Equipment "Under its dominion or control" is key - One could conceivably "rent" out a portable table-top CNC, mini-mills, for renters/operators to use under their own Dominion/control and not the dominion of the rental institution. View Quote wha? If you're the one renting it out, it's under your control. so you'll be the one "manufacturing" the lower (even if someone else is pushing the controls) and therefore be the one in jail. |
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If you're the one renting it out, it's under your control. so you'll be the one "manufacturing" the lower (even if someone else is pushing the controls) and therefore be the one in jail. View Quote That's the crux of it. If you were renting out a machine and someone happened to build a gun with it unbeknownst to you, then technically there would be no violation. But renting the equipment for the purpose of or with knowledge that it would be used for manufacturing firearms runs afoul of this new edict. Long term leases to a licensed manufacturer would be a different story, as many manufacturing firms lease expensive CNC equipment. But that's a whole different genre, and not at all the subject of this ruling. The motivation behind this ruling is simple: until the "80% receiver" and the extreme popularity of the AR this last few years, home built firearms were pretty uncommon, and not really on the radar. There were a few of us with machining equipment doing scratch builds, and the occasional guy who bent up AK receiver flats for his parts kit, but on the whole, very few guns were manufactured by private individuals. The 80% receiver changed all that. It is one of the easiest ways to "build" a functional quality firearm, and with the jigs, a chimpanzee could almost do it. That fact was not lost on ATF, but they do not have the executive power to arbitrarily determine that home builds are now illegal, so got as close as they could by making it unlawful for the owner of equipment to allow others use of it. By doing it that way instead of making it a violation on the part of the person using the equipment, they more or less accomplished their goal; if the risk was all on the person making the lower, I'd still be letting people use my machines at their own risk. But since it is me, the owner of the mill, who would face criminal charges, I'm absolutely not going to risk it It sucks, because I really did enjoy teaching people how to run the machines and watching the satisfaction flow over their face as they watched the chips flying, realizing they were actually making something. There's a level of gratification in machining that cannot be explained, only felt. |
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This doesn't apply to engraving right? That's all I've eeverhad done anyway. I mill my own.
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The ATF is going to slowly continue to do everything they can to curtail home builds of receivers.
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That's the crux of it. If you were renting out a machine and someone happened to build a gun with it unbeknownst to you, then technically there would be no violation. But renting the equipment for the purpose of or with knowledge that it would be used for manufacturing firearms runs afoul of this new edict. Long term leases to a licensed manufacturer would be a different story, as many manufacturing firms lease expensive CNC equipment. But that's a whole different genre, and not at all the subject of this ruling. The motivation behind this ruling is simple: until the "80% receiver" and the extreme popularity of the AR this last few years, home built firearms were pretty uncommon, and not really on the radar. There were a few of us with machining equipment doing scratch builds, and the occasional guy who bent up AK receiver flats for his parts kit, but on the whole, very few guns were manufactured by private individuals. The 80% receiver changed all that. It is one of the easiest ways to "build" a functional quality firearm, and with the jigs, a chimpanzee could almost do it. That fact was not lost on ATF, but they do not have the executive power to arbitrarily determine that home builds are now illegal, so got as close as they could by making it unlawful for the owner of equipment to allow others use of it. By doing it that way instead of making it a violation on the part of the person using the equipment, they more or less accomplished their goal; if the risk was all on the person making the lower, I'd still be letting people use my machines at their own risk. But since it is me, the owner of the mill, who would face criminal charges, I'm absolutely not going to risk it It sucks, because I really did enjoy teaching people how to run the machines and watching the satisfaction flow over their face as they watched the chips flying, realizing they were actually making something. There's a level of gratification in machining that cannot be explained, only felt. View Quote View All Quotes View All Quotes Quoted:
If you're the one renting it out, it's under your control. so you'll be the one "manufacturing" the lower (even if someone else is pushing the controls) and therefore be the one in jail. That's the crux of it. If you were renting out a machine and someone happened to build a gun with it unbeknownst to you, then technically there would be no violation. But renting the equipment for the purpose of or with knowledge that it would be used for manufacturing firearms runs afoul of this new edict. Long term leases to a licensed manufacturer would be a different story, as many manufacturing firms lease expensive CNC equipment. But that's a whole different genre, and not at all the subject of this ruling. The motivation behind this ruling is simple: until the "80% receiver" and the extreme popularity of the AR this last few years, home built firearms were pretty uncommon, and not really on the radar. There were a few of us with machining equipment doing scratch builds, and the occasional guy who bent up AK receiver flats for his parts kit, but on the whole, very few guns were manufactured by private individuals. The 80% receiver changed all that. It is one of the easiest ways to "build" a functional quality firearm, and with the jigs, a chimpanzee could almost do it. That fact was not lost on ATF, but they do not have the executive power to arbitrarily determine that home builds are now illegal, so got as close as they could by making it unlawful for the owner of equipment to allow others use of it. By doing it that way instead of making it a violation on the part of the person using the equipment, they more or less accomplished their goal; if the risk was all on the person making the lower, I'd still be letting people use my machines at their own risk. But since it is me, the owner of the mill, who would face criminal charges, I'm absolutely not going to risk it It sucks, because I really did enjoy teaching people how to run the machines and watching the satisfaction flow over their face as they watched the chips flying, realizing they were actually making something. There's a level of gratification in machining that cannot be explained, only felt. I dont really see it as a crux, lets face it, any equipment small enough to "loan OUT to someone" will be a desktop router system like the ghost gunner.. otherwise, you're going to be "supervising" someone working in YOUR shop.. if you own a machine shop and you let someone come work in it, you're going to make sure you know EVERYTHING about what they'll be doing including their experience and what they're making. like I said, I don't really think there is a crux... it's easily black and white... in my opinion.. Quoted:
This doesn't apply to engraving right? That's all I've eeverhad done anyway. I mill my own. correct. Quoted:
The ATF is going to slowly continue to do everything they can to curtail home builds of receivers. I agree... it would be advisable for all of us to "smoke them while we can"... |
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This is the reason we need to be concerned...LINK
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After reading that article.. I'm thinking that I should start that 80%'er sooner rather than later...
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I dont really see it as a crux, lets face it, any equipment small enough to "loan OUT to someone" will be a desktop router system like the ghost gunner..
otherwise, you're going to be "supervising" someone working in YOUR shop.. View Quote The Seig/HF/LMS/Grizzly mini mills weigh about 100 lbs and fit easily in the trunk or back seat of any any commuter vehicle. Yes, generally you're talking about a stationary machine and yes, generally the owner would have some oversight to ensure that it is being used properly. The point I was trying to make is that renting to someone else, whether the thing leaves the premises or if you are not supervising, does not exculpate you if you have knowledge that the purpose is for a non-licensee to manufacture a firearm. But..if you sell that milling machine to your buddy.... View Quote I don't have the capital to challenge ATF on an accusation of violating this policy due to a law-skirting "he owned it for two hours" kind of deal. Do you? Temporary "on paper" transfers of property don't work for bankruptcies, which definitely has precedent where this is concerned. |
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we ran build parties for a couple years. we invited the ATF FTB to come down and 3 agents went through our process. they said it was good to go and we never had any issues.
about 6 months later we had to shut them down because ATF Admin side didnt like the idea of build parties. We changed up our process a few times and the ATf finally decided to send us a cease and desist letter. They referenced a case from around 2007 about a store that sold cigarettes. the store had a rolling machine on the counter and people would buy their own papers and loose tobacco. for a small fee you could roll your own cigarettes. this store did not have a manufacturing license to make cigarettes. long story short, the supreme court ruled that the store owners were in control of the machine, therefore anything that came out of it belonged to them and they were manufacturing without a license. they were basically told they have to leave the machine out in a place accessible to anyone at any time to avoid getting a manufacturing license. |
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O.K., so if I loan someone (no money or other considerations exchanged) my 1/2", 3/8" and 5/32" drill bits knowing they plan to take them home with them and complete a lower, according to BATFE _I_ manufactured their lower? Even if the lower was never on my premises and I never touched it? REALLY?
If I loan someone my trim router and 1/2" end mill bit? Is that any different from if I buy a AR lower jig and loan it to someone? BATFE is F'ing out of control with these arbitrary rulings. Not reasonable at all. |
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I don't have the capital to challenge ATF on an accusation of violating this policy due to a law-skirting "he owned it for two hours" kind of deal. Do you? Temporary "on paper" transfers of property don't work for bankruptcies, which definitely has precedent where this is concerned. View Quote View All Quotes View All Quotes Quoted: But..if you sell that milling machine to your buddy.... I don't have the capital to challenge ATF on an accusation of violating this policy due to a law-skirting "he owned it for two hours" kind of deal. Do you? Temporary "on paper" transfers of property don't work for bankruptcies, which definitely has precedent where this is concerned. No. But say you buy a Ghost Gunner. You and all your friends were going to go in on it, but now that would be an "association" and you'd have to get a manufacturer's license, pay ITAR fees, etc. Instead, you pay the full price of the Ghost Gunner, make your 10-15 lowers, and then sell it to your buddy for $1499. He makes his 10-15 lowers, then sells it to his buddy for $1498. Etc, etc. There are now receipts for real money, the machine changes physical hands, and you don't get it back. |
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I don't see how I can be considered "in control" of equipment like an AR lower jig, bits or a router if I loan it/them out to someone and they take it/them off my premises. I also don't see how I can be considered the "manufacturer" if the blank is never on my premises and I never physically touch it.
The direction BATFE is going, they aren't far from extending their current line of reasoning to the point where creating a video showing how to mill a lower, distributing plan drawings or even selling jigs makes you the "manufacturer" and anyone using your products isn't doing it themselves. Obviously that would essentially end the 80% receiver market which is politically what BATFE wants to do. |
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There are precedents in other hobbies and have been forever like flying and home-brewing. If you get any consideration at all, other than equal expense sharing, it is verbotten.
So, you should be able to go in with a group on a Ghost CNC machine and assemble for personal use to your heart's content. Nobody is making any money, it cost everyone their equal share of the machine and they use it to make their own guns. No business is set up, no profit in money or favors or products. If an outsider wants to use it, fine, but they can't be charged so much as a favor, nothing at all in exchange. Private build parties, same thing. As long as nobody makes any money (gets any consideration), there is no manufacturing business, licensed or otherwise. That would be like if I took my motorcycle to a friend's house who has tools and expertise to help me fix it, that doesn't make him a mechanic business operating w/o a license, especially with no payment. The ATF letter defines what they mean by "business" and "in the business of" and loaning of machines and private build parties w/o any consideration given aren't even close to being considered "business" in that letter. |
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