Quote History Originally Posted By bigbore:
That's the confusing part. If a local speed shop (not an FFL) makes an aluminum intercooler connector tube that is threaded in the ID on both ends. Would it not be legal for an FFL/SOT manufacturer to buy those tubes than mill a monocore baffle that threads into that tube and form 2 suppressors that way?
How is that different than the oil filter adapters. It's a registered endcap made and registered by the FFL/SOT and FRAM is making the tube and baffles.
View Quote
I don't disagree with you and I presume like a lot of thing with the BATFE it comes down to their interpretation on how things went and whether they choose to make your life a nightmare as a result.
Technically sure if an FFL/SOT wants to buy maglights from home depot, harvest the tube bodies, make baffles and endcaps that fit them, and register it as suppressor its probably more difficult for the BATFE to come after you given how common and multi-use a maglight is. if you choose to use maglight bodies as your tube raw material source because they are cheap, come in a variety of colors and sizes, and are available at the corner store on a moments notice that might make sense.
Now lets say in this hypothetical, the same FFL contacts the local speed shop and says....hey, bob....can you make some "inter-cooler connector tubes" out of this specific grade titanium, exactly 11.5" long, threaded to this specific spec and then let me buy them sell them to me as unrestricted inter-cooler tubes. I then register and sell them and we all make money.
One day and the BATFE comes in to so an inspection and finds a stack of these threaded titanium tubes and no clear in house capability to make them and asks where you got them from. The ATF then goes and squeezes the speed-shops guys nuts until he coughs up that you gave him the tube specs and that you effectively colluded with the speedshop to do offsite NFA manufacturing with a non-FFL/SOT under the guise these were inter-cooler tubes. The BATFE probably come back to you and say, Bob spilled the beans on your silencer manufacturing collusion scheme and gave us the text messages proving it. You can surrender your license or we can throw all these criminal charges at you...at which point you can go out of business or cough up a $50K attorney retainer to get started.
Obviously there is a lot of gray somewhere in between these two scenarios. However, given the BATFEs seemingly almost endless ability to regulate FFLs and manufacturer activity and to make FFLs lives difficult if you do something they don't feel is above board, it seems like the best option is to genuinely make everything yourself from true raw stock or get approval to sub-contract restricted parts before you do so.
There is probably also some level of selective enforcement where say FN or Colt the BATFE doesn't really hassle them when they bring on a new sub-contractor for parts or work vs. a sole prop barn based FFL/SOT who is buying "80%" drop in auto sears, solvent traps kits or oil filter adapters to build regulated NFA firearms with.