Look on the form 1 under change of description. If you sell or trade or no longer have the original upper and you are using one of a different caliber or length you are making a permanent change. If you keep the original and swap out uppers as desired but have the ability to revert back to the “dimensions” as noted on the form 1 then everything is OK. I believe the ATF wants to know of “permanent” changes to a registered NFA firearm.
Item 4 is the description with parts a-i. Those include caliber, barrel length, etc.
There’s no such thing as a permanent change on a modular platform.
They want to keep the registry accurate, but there’s no regulation that requires the end users to provide all those updates.
And I’ve seen multiple examiners ask people to stop sending in length/caliber change letters for ARs.
ETA: realize...
1. The forms are not the law; with a regulation to back it, there can be no enforcement
2. Recommend/want/suggest aren’t the same as require
Last edited by BigWaylon; 05-28-19 at 14:00.
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