NFA Engraver Pensacola / Milton

[John B.]

Question for you gentlemen with an SBR AR, do you have to have the caliber stamped on the lower? I intend on using a Spike's multi caliber lower, but it will be for a .300 Blackout, do I need to have ".300 Blackout" engraved as well?

 

[Daezee]

The caliber is a required marking, but it may be on the receiver, frame, or bbl. Typically the bbl will come with the caliber marking already.

https://www.atf.gov/firearms/national-firearms-act-handbook

 

[John B.]

The caliber is a required marking, but it may be on the receiver, frame, or bbl. Typically the bbl will come with the caliber marking already.

https://www.atf.gov/firearms/national-firearms-act-handbook

Perfect! Thank you! I figured it would be a bit redundant to have it on the receiver, and the bbl, but nothing makes sense with the NFA or ATF. LOL

 

[bigbulls]

Maybe one day I'll do an sbr but I do have a question. Did anyone that is dropping off their receivers over night verify that the jewelers and trophy shops have a valid FFL?

 

[daehawc]

Maybe I am wrong about the law but I dont see how they would need one. You arent transfering it to them nor are you mailing it or having them mail it back. How is it any different than just dropping it off to a friend?

 

[wildrider666]

Non expert opinion from what I have read: You have the Stamp and are in the process of "Making" but the NFA item is incomplete such as pistol receiver being engraved for SBR application and other parts are at home it is a none issue. However, if the receiver contains a full auto sear; then full possession/access/transfer restrictions would apply. Hence, you should "be in possession" at the engravers shop as the work is being done. Once its a NFA item, it remains so even if you change it to a Non NFA configuration. Put a 20 inch rifle upper on your SBR stocked pistol receiver and possession, transport across state lines: NFA rules still apply.

Duty expert builders: please provide how you handle this issue.

 

[wildrider666]

Maybe I am wrong about the law but I dont see how they would need one. You arent transfering it to them nor are you mailing it or having them mail it back. How is it any different than just dropping it off to a friend?

If you have your buddy's registered NFA weapon dropped off for the weekend thats 10 years in the Pen and $250,000 fine. NFA 5861 (d). Better to have a sleep over. Lol

 

[John B.]

What bigbulls is referring to, is the "gunsmithing" clause, where if you are altering the firearm in any way, shape, or form, and you are in possession of it for 24 consecutive hours, you are required to have an FFL...

 

[wildrider666]

Below is the link to PDF doc. Chapter 9 transfers of NFA. It covers:
During Mfg and for repairs separately.


https://www.google.com/url?sa=t&rct...=kavX6h9t1jc5TuPs81ufsw&bvm=bv.99804247,d.eXY

 

[daehawc]

But it's not an Nfa item as a receiver (sbr specifically) it's just a rifle unless configured. The stamp allows you to configure it as such but you don't have to


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[bigbulls]

What I am talking about has nothing to do with whether or not the receiver is NFA. If a person or business takes in firearms (receivers in this case) and performs work for profit as a regular part of their business practice then they are required to have an ffl and log them in and out of their A&D books.

If a person or company is doing this as few as three times per year the ATF considers this to be part of their normal business practice.

 

[John B.]

What I am talking about has nothing to do with whether or not the receiver is NFA. If a person or business takes in firearms (receivers in this case) and performs work for profit as a regular part of their business practice then they are required to have an ffl and log them in and out of their A&D books.

If they have it in their possession for 24 consecutive hours.

 

[bigbulls]

If they have it in their possession for 24 consecutive hours.

I think that is correct. I'd have to double check but it may apply to less than 24 hours if the owner of the firearm leaves the business and leaves the firearm there. I can tell you that if a person drops off a firearm to me and leaves then it gets logged in.

 

[John B.]

It may be "overnight" or something similar. I know there are loopholes to the clause.

 

[bigbulls]

Yeah, I'd have to read the law again to get all of the specifics.

Either way, if you are dropping off a firearm and not staying with it while the work is being performed make sure the business has a valid FFL. An agent will not care if you left the store five minutes ago or a week ago. That business has possession of your firearm and you are no where around, is doing work on it, and has no FFL. This = bad news.

There is a local ATF branch here in Pensacola and I assure you all they do monitor these forums. I'd hate to see good people and business get in hot water because of something like this.

 

[wildrider666]

Since ATF has has published there opinion that shouldering a Sig brace equipped pistol is "Redesign" it to a NFA weapon, their mandated engraving must now be considered "manufacturing" .

On the serious side, there were changes to "manufacturing" in 2010 and 1-2015. The 2015 was a push to close machine shops from helping you with your build even though it had been allowed since 1939! NOW, a machine shop must have a Manufacturing Lic. If your private build is done, assisted or if you use their equipment. That shop ID must also be engraved Plus a ser#. All this to cut down the mfg "finishing" unserialized 80% lowers.

I also found several listings for ATF licensed engravers who quote the engraving requirement for NFA and samples of Trust and individual NFA work.

I also checked several gun lawyer sites. Everyone I read was hung up on possession to the point that only the individual approved or those listed in the Trust could have access, handle or fire the NFA item! They are interpreting the Law to its most extreme possible application to keep clients well above the fray.

All I have researched on the ATF site. It only listed the specification for engraving and the types needed in different circumstances. It does not state that any type of license is required for this particular task. It DOES SAY that coatings "and changeing the appearance" IS MANUFACTURING. Isn't putting on a scope changing appearance too?

I think this is another BATFE Twilight Zone issue that they can bite you on the ass if they want to.

Key here is: is the business working on firearms for profit? It may well be only a very small percentage of the revenue compaired to their primary services. If a license is required then the type licence depends on the category of the firearm or part taken in for work.

 

[wildrider666]

Found the ATF Reference regarding a Business that engraves firearms. There is no exemption by number of firearms engraved, physical possession (firearm owner present) or overnight possession. Business + Engraving = License Requirement. The link provides an overview and a sub link to the actual document.

https://www.atf.gov/firearms/docs/2...activities-camouflaging-or-engraving-firearms

 

[Dan1612]

WR, I would imagine that references full engraving, which as numerously repeated "changes the appearance"

2 lines of text does no such thing.

JMHO.


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[wildrider666]

Got it. I was thinking that changes to apperance (how you recognize a item) would apply the same way to how you identify a item by its markings. In the Rule for Marking NFA items it says "YOU" the manufacture, importer or maker must......bla... bla... mark, engrave, stamp.... bla.. bla... Taking it to have the work done by someone else/business is not "you". If I want to embellish a firearm receiver with "Khe Sanh 1968" and the person/business does it for profit, ATF Rule says the engraver needs a License. Thats the only refrence on engraving license requirements. The ATF has a bad habit of ignoring gray areas until they want to make an example of someone and set a precedent on "their interpretation" of the Law. I'll go back to ignoringg this.