Form 1 (SBR) Engraving Requirements
I realize we've discussed SBR and SBR-related engraving requirements about 10,000 times already, but I do have some lingering questions about some of the finer points of the law, and would be interested in the SOT/dealer/manufacturer view.
My purpose here is not to challenge the well-known 27 CFR 479.102 (ATF 5300.4) requirements, so I'm not looking for someone to re-post one of the enigmatic ATF compliance/interpretation letters that show up online every now and again. Instead, my question is this: what if I wish to do a Form 1 conversion without engraving the lower?
In the case of a Magpul or other unusually valuable lower, there will surely be instances where the owner is unwilling to engrave the receiver, but would still like to add the weapon to the NFA SBR registry for use with a short-barreled upper. The law would seem to allow engraving the barrel in lieu of the receiver or frame. I do understand that every barrel used with the weapon would have to meet this requirement, but a correctly engraved 10.5" or 11.5" barrel should still conform to the letter of the law.
Now, let's say that it is a very short barrel that is almost completely shrouded by a rail system. Would an inscription that is plainly visible through the vents/lightening cuts in the rail meet the legal requirements here, or would this likely be challenged by an examiner? Before you say it, I already know that "only an examiner could really answer the question," and that if I asked the question 10 times to 10 different examiners, I could probably get at least three "official" rulings that contradicted each other. This is not my first ride on the NFA bus.
What I'm really after is simply an informed opinion by those actually engaged in the business, in the hopes that you may have encountered a similar situation in the past, or have other insights to pass along. In an SBR barrel engraving situation, is a good faith effort to comply with the law (i.e. correct engraving visible through rail) generally going to be ruled as sufficient, or have you encountered situations where this technique proved problematic?
Clearly, it makes the most overt sense to just engrave the receiver, but when that isn't practical or possible, how deep into the woods is an alternate approach (barrel engraving) likely to take an NFA owner?
AC