Currently moving some individual NFA items into a pre-existing trust where other NFA are already held, just consolidating to simplify the paperwork in the future. So basically I'm transferring from one entity I am a part of to another entity that I am part of (ie, "me to me").

None of the transfers are approved yet but today I received an ATF notice with a couple of questions before they can proceed.

One item in question is a Group Industries UZI MG, just the standard HR4332 model in fullsize configuration stamped as "9mm/45ACP/22" on the receiver.

For the transfer I copied ALL information EXACTLY as written on my existing Form 4 (approved 12 years ago).

ATF Question 1- "multiple calibers are not accepted. additional configurations must be listed on a separate letter stating caliber. - Caliber registered as 9. please verify.
"
ATF Question 2- "firearm description varies with our records, see highlighted section. - Overall length registered as 26. If different, please submit a photo or memo attesting to a measurement from the end of muzzle to the rear of fully extended stock".

I'm kind of baffled since this is approved paperwork and I plan to call them before sending the approved Form 4 in with a letter explaining these points.

Regarding question 1- my approved form 4 states "caliber" as ".45/22/9mm" and this is what I entered into the new form 4. Also happens to be stamped on the receiver.
Regarding question 2-  my approved form 4 states "overall length 18.5" which is what I entered into the new form 4.  

Any thoughts from you guys?

Help me out here, thanks.

What barrel is installed in it right now? That's the caliber and length that needs to go on your form 4.

Put a tape measure next to it with the stock extrnded and check OAL. Send back a picture if its different from 26".


At least if you want your form processed in a timely manner.

I bet they're basing the OAL on whoever originally manufactured it. I had a can delayed for 6+ months (total wait time of a year) because of a length discrepancy between what was on the Form 3 and what was in their records.

I ran into the same issues with an interstate move.  Submitted the 5320? , I think that is the form, and had one questioned on caliber even though I had previously sent them a letter changing caliber on an SBR, the other was overall length on a MG.  Sometimes they dig deep, on the MG, it was on how it was originally registered, even though the transfer to me showed a different barrel length.  Easiest thing to do is just comply with what they ask, including photo with a tape measure.  When I did, form was back in a few days approved.

EASY BUTTON - Confirm the info they have on file and want to hear.

HARD BUTTON - Argue with them and try to submit something other than what they have on file.

Just because you slipped some bad info past them before ("9mm/45/22") Does not mean it is correct. As you found out, they are not making this error a second time. Same for OAL.

Remove the barrel - What caliber is the gun now? Put the gun in a box with 4 different barrels in 4 different calibers - what caliber is the gun now?  Is "all calibers" better? Or how about "N/A" caliber?

Not picking on jaq, just pointing out the absurdity of ATF's request.


It's not "bad" info. That's how Group originally registered the gun. And it's not a matter of "slipping anything by" ATF. What they seem to want is a moving target. Tomorrow they might want to say they require any and all calibers the gun could possibly be registered in.

The only "bad" info is when ATF requests incorrect or incomplete info, because they did a poor job designing their database.

I got an approved Form 4 back for a can with no model listed. I made a copy, hilighted it, and framed it.
 

What was done 30+ years ago is irrelevant. It has been known for years one caliber was Best Practice. But hey, it is not my xfer being delayed.

Amateur.

Send in a few more, wait till you get one with no stamp or no signatures. Bonus points if it is the same form!

I'm at about 16 now with more pending. That's the only error I've seen. We'll see if anything more comes back.

Short barrel, long barrel, or no barrel, it's still not any kind of rifle.



OP has a machine gun.

I disagree.  How a gun was originally registered 30+ years ago can be very relevant.  Sometimes it's little details from 30+ years ago that determine if a gun is worth tens of thousands of dollars or... a fine and imprisonment.  Caliber may not be a big deal today, but what about tomorrow?  Today ATF says to only do it one way.  A few years ago, "best practice" was to register it in every caliber it might possibly be configured in.  And in '86 I understand there was a very real fear that ATF would only allow MGs to be used in the "registered" caliber.  We have seen other examples where they make up regulations of when and how certain guns and conversion parts can be used.  

ATF claims they are "cleaning up" the registry.  But in doing so, they are altering details about the way many guns were originally registered.  And now it's causing problems for the end buyers and sellers.  For example, I've got an SBR that was originally registered in 4 or 5 different calibers.  I've got the original Form 1 from when it was registered.  If I were to sell it, what caliber do I list.  I've got a 4 out of 5 chance of getting it wrong.  Inquiries to ATF often go unanswered for months or years (or sometimes, they don't answer them at all).  

Yes, when I bought my Group Uzi 10+ years ago, ATF was just getting into the "only one caliber" thing.  I listed it in 9mm, and put a notation in one of the boxes about it also being registered in .22 and .45.  The transfer was approved and I picked up my gun.  I read somewhere recently that ATF is now kicking back forms for listing things this way as well.  

And all of these changes from the original registrations are merely for ATF's convenience.  

I wonder what ramifications this will have in another decade or two.  

I need to frame my post 86 approved form 1 machinegun paperwork.


 

No it is compliance with the Law/CFR, which requires the caliber of the firearm to be listed on the form. It does NOT ask for all the possible calibers you may want to shoot someday. By law they are also required to maintain an accurate NFTR, and this is part of complying with that law.

Many of the changes we see from ATF today are to fix incorrect procedures from long ago.

I also have a form 4 with 3 calibers and 18.5 in length . I have all 3 caliber conversions .. 18.5 is the folded stock length which the ATF used to want . I guess they want open length which would put NFA the same as title 1 guns which are measured stock extended .

LoL.  

Thanks for those who helped. Exact same setup as whiskerz.

It's a particularly ignorant implication that I am the party responsible for initiating the error "Just because you slipped some bad info past them" but hey GFY.

Nothing was "slipped" past anyone since it's printed on the front page in black-and-white and it's been listed exactly the same on multiple approved ATF forms I've seen (form 4's, one form 3, 5320.20's) since at least prior to 2004 and they've specifically reviewed and approved the firearm data multiple times since then, most recently 2 yrs ago.

I recognize that NFTR is being "cleaned up" in some fashion and ATF appears to be operating on the assumption that whatever is in their "source" (?) data is accurate but since I have no idea where their source data came from, when it was populated or what it shows, I cannot make this assumption and must rely on my own ATF approved documentation and tax stamps. Normally these kinds of written changes to records and differing interpretation by government authorities represent considerable risk and are not taken without regard to the consequences.

It's the height of ignorance to posit that what happened "30+ years ago is irrelevant" because one single day in May 1986 clearly made quite a lot of difference to a great many people.

Dude, don't bring it to anyone's attention, as you will find out, the ATF can and will revoke approved post 86 forms. Assuming you were not a dealer at the time.

They know about it. You can listen to the phone call on youtube. I kept the form, but of course never drilled the third hole

 

Link?

http://youtu.be/4s9GKoxnGcM



 

The form 4 for my M-10/45 was approved in February 2013 with the OAL listed as 11".  That is clearly with the stock closed, but that is what was on the previous owner's form 4 and what he wrote on mine.  Of course it also had a Lage upper on it when I got it, and with that upper it is longer than 11" even without a stock.  The original upper was included, though I have never installed it.