This article appeared on the web on 19 Nov.

http://www.shootingsportsretailer.com/2014/11/19/could-this-mean-the-end-of-the-sig-brace/

Since only the third page of the letter appears in the article, we don't know for sure what was actually
submitted.  From the wording, it appears to have been a shotgun with a barrel under 18", with a VFG
and a Sig SB-15.

While the weapon is undoubtedly a shotgun, the discussion here should be whether this new letter
may affect usage of the SB-15 on AR firearms.  The ATF may be ruling on this specific type or
instance of firearm, or it may be positioning for a reversal of its original "using the brace improperly
does not constitute a design change" ruling.   (05 March 2015 Earl Griffith letter to Greenwood, CO
PD).

The article specifically states the submitted firearm is "a short-barreled shotgun design that incorporated
the SB15 brace ".  I'm surprised the ATF didn't classify it as an SBS immediately.

If anyone else finds the complete letter, please post.

In accordance with a letter from ATF to Sig in regards to the legality of their "brace platform" for AR pistols " https://www.sigsauer.com/upFiles/ATF-Compliant-Letter.pdf " the firearm is not considered a SBR or subject to NFA Tax unless designed for or equipped with modifications designed for use of the weapon with two(2) hands. Provided the weapon has NO vertical fore-grip, collapsible/fixed stock,  modified "brace", or any other modifications to utilize both hands it is considered a pistol. My understanding of this particular letter is that; "Black Aces Tactical" wished to retail a Short-Barreled Shotgun possibly with a forward vertical grip which would negate the original letter from the ATF.

Hopefully this doesn't get too far out of hand and they post the entire letter and preferably design so we can all sleep peacefully with our 10" AR Pistols with no stamp.

Thanks AJ.  That's along the lines of what I was thinking.

Still, the wording in the letter fragment is quite confusing (what else is new), and ATF refrains - possibly deliberately -
from actually stating what exact class the submitted weapon falls into.

I think the concern in this case stems from the fact it's the first time ATF has issued words suggesting the
classification of a firearm can be altered by how it (or a part of it) is used.

Which I opine would not survive the first lowest court challenge. Might as well go whole hog with the concept, and claim that firing any handgun with two hands is unlawful, or firing a stocked weapon from the hip is. Etc.

Hell, that feller that shoots his 1911 with his feet would be in Leavenworth for life!

- OS

If there isn't a law against it, it's not illegal. People should stop asking the ATF all these silly questions. Do we really want them thinking about this stuff?

It changes nothing and applies only to 'firearm' shotguns with the sig brace, of which I'm only aware of three (Black Aces, Arfcom's NWRed, and myself) who've made one.

All other uses in non-shotgun variants are still good to go.

This is the first I've heard that you can't have a vfg and a sb15. Even if over 26"?

You can. It just changes classification from pistol to firearm.

I think the reason the ATF said what they did here is because of how they interpret "intented usage".

The previous ATF letters we've seen were  responses the END USERS asking if their improper usage of the brace would cause a reclassification into NFA territory. An end user asking about improper usage only speaks to the intent of that end user, and not to the intent of the seller/manufacturer.

Sig, and all of the companies selling similar braces, are selling the product as an arm brace (never stating any intent for it to be misused as a makeshift stock, and sometimes actually recommending against it). This is IMPORTANT.

This is the first ATF letter responding to the question of shouldering a Sig brace equipped firearm that has been posed by a seller/manufacturer. By this guy asking the ATF about the legality of misuse of the brace he is admitting there is intent in his mind to sell it as a product that can be used as a stock.... which eliminates the ability for his customers to claim "well this thing on my rifle is sold as an arm brace and the manufacturer doesn't intend it to be used like this".

So, as long as the manufacturer of your firearm doesn't do something stupid like print an advertisement or otherwise market the arm brace with any hint of it being misused as a stock then we're fine. The moment they do that manufacturer is out of the "intent loophole" club.

Now, this is just my take on this, based on everything I've seen from the ATF on this and previous issues.

What we need to do is make more companies that sell and market arm braces aware of this to prevent it from becoming any more of a problem.

Well, well well.  Look at this shit.

So they're basically just going to manufacture and sell these regardless, and any consumers that happen to be caught firing it from a shouldered position will be in some potential trouble with the ATF? If so, I hope they include some type of large disclaimer to not use it in that manner.

So there is always going to be someone to ruin it for the rest of us.  Can't folks just let sleeping dogs lie?