Originally Posted by
Munch
Jason...
I would be very careful about configuring a registered lower contrary all aspects of the approved application.
A "Letter of Exception" allows the owner to legally alter a NFA device from the configuration approved by NFA Branch without resubmitting an additional form and paying another $200. A device not in the configuration so stated on your approved registration can easily be defined as a violation. Granted not as serious as possessing without an approved form, but, a violation none-the-less. The key BATF phrase is "registration depends upon the stated intent of the applicant". You state barrel length, overall length and caliber on the form. To deviate from your registration is not in keeping with your stated purpose which includes ALL blocks, not simply the narrative section. To my knowledge, there is no BATF provision for a "temporary" configuration.
A "letter of exception" amends your original application to include a new barrel length. Same holds true if you use a different caliber. The letter becomes part of your official application for that registered device.
You can install a barrel of 16" or longer anytime and not be in violation.
Years ago, one could offer vague details on the registration form; block 4c could state "5.56, 6.8, .458" etc., and block 4e could state "<16 inches". Today, NFA Branch will return your form if you make such entries. Branch will only accept a specific stated configuration on the application.
ATF rulings and interpretations change daily, simply based on political winds. Have you heard about the enhanced/additional dealer reporting requirement for the purchase of multiple and specific weapons in the southern border States? Not voluntary and an administrative implementation. This ruling simply went viral, most do not.
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