Coleslaw
09-29-10, 14:30
Don’t want to be a dead horse and didn’t read the final post until yesterday morning when the SBR thread was closed, but in the interest of clearing the air……
I believe I see where the disconnect lies in that thread. Some were speaking as individuals and others dealers. The rules apply differently to dealers than to individuals. FFL’s/C3 dealers are required to keep records, an Acquisition and Disposition book. An individual doesn’t really need to keep anything other than a form 4 with the weapon with the short barrel on it. You can swap uppers at your leisure, and as the letter stated, as far as transporting the weapon across state lines, or even having the lower alone, it won't qualify as an SBR unless the upper is on it, in the same premises, or maybe the trunk of your car.
As long as it is in a dealer's books as an SBR, then that is what it is whether it has a short upper, a long upper, or no upper, and all NFA rules apply. In other words, if in a C3 dealer’s inventory, it can’t be changed from an SBR unless removed from the registry. I made a few calls to confirm what I thought. To be clear, examiners during audit expressed that exactly. That is the information I was given and it is best to err on the side of caution. Most guys tread lightly in areas that may ever be interpreted to be a bit grey.
I believe I see where the disconnect lies in that thread. Some were speaking as individuals and others dealers. The rules apply differently to dealers than to individuals. FFL’s/C3 dealers are required to keep records, an Acquisition and Disposition book. An individual doesn’t really need to keep anything other than a form 4 with the weapon with the short barrel on it. You can swap uppers at your leisure, and as the letter stated, as far as transporting the weapon across state lines, or even having the lower alone, it won't qualify as an SBR unless the upper is on it, in the same premises, or maybe the trunk of your car.
As long as it is in a dealer's books as an SBR, then that is what it is whether it has a short upper, a long upper, or no upper, and all NFA rules apply. In other words, if in a C3 dealer’s inventory, it can’t be changed from an SBR unless removed from the registry. I made a few calls to confirm what I thought. To be clear, examiners during audit expressed that exactly. That is the information I was given and it is best to err on the side of caution. Most guys tread lightly in areas that may ever be interpreted to be a bit grey.