Firstly:
A. I work for a company that has a manufacturing SOT and will Form 2 all competed MGs.
B. I understand post-86 MGs can never be owned by me as an individual and I can't keep them if I leave the company.

I just hired on to manage sales for a company that just got a manufacturer SOT and we'd like to build some machine guns instead of getting demo letters and such. I'm not new to the NFA game and I understand the laws, but I am new to the technical part of making an MG.

I'm interested in doing either an LL or DIAS for an AR-15 and a Glock auto-sear to start off with. I've seen several partial kits for both applications, but am curious if anyone has experience with actually completing them?  Also if there's any to be recommended?

Also are there any MGs like Stens or such that are easy to make from a parts kit?

I'm an ADD sales type, so I'm looking for something simple, until we bring on the technical expertise for more advanced work.

Once again, I'm doing this 100% legally, not in my basement for Los Zetas.

Its actually not at all difficult to convert a semiauto AR15 to a full auto, there is very little work required if you have all of the correct parts. A DIAS and LL would be a bit more work but would not require permanent modifications to the host rifle.

If you have a Bridgeport the conversion on an AR lower takes about a half hour. You'd probably have significatly more time in making a DIAS. If you don't have a wire EDM it's difficult to make a nice LL.

Making a registered HK pack will be your easiest option. A factory C93 will run right out of the box with a registered pack.

Machine guns can only be made for sale to LEO/MIL, since you claim, "doing this 100% legally" which PD/MIL are you hoping to sell them to?

And IBTL.

Someone in a department legitimately expressed an interest in converting a semi-auto lower into select fire. I'd like to hands-on understand what the options are. Granted, just buying post-sample M16 lowers is probably the best option, but I've never done anything like it before and before I go make a sales call I'd like to understand how any machine-gun I could potentially sell, even if it's a Sten or other non-modern gun.

I'm no lawyer, but my understanding is that if you have the SOT, there's nothing prohibiting you from making NFA items, even if you can't say it's for X, Y and Z, though I could be wrong and if I am, I certainly wouldn't.

For legal reasons i dont think anyone here is going to give you a how to guide to convert a AR15 to a M16. As i said earlier its not that difficult if you know what you are doing, i mean just put a M16 next to a AR15 and compare the internal components and its pretty obvious what the difference is. It will involve some machining work and replacement of the FCG, which can be purchased from companies like Brownells. I shouldn't have to say this but i will, keep in mind possession of these parts without a proper SOT or ownership of a transferable M16 via trust/individual will land you in jail.

Manufacturing firearms, especially full autos is not something i would just toy with for fun. You need to do more research, verify your intentions with the ATF, contact a lawyer who is knowledgeable in firearms laws, get information from a gunsmith familiar with full autos, have a gunsmith lined up to test and inspect all firearms that are manufactured, contact your insurance agency to make sure you are covered for such activities in the event something goes wrong like a M16 explodes during testing. Do you have a shooting range where you can test/shoot for business related activities? Can you shoot full auto there? Thats just the tip of the ice burg, there are probably dozens more questions that need answered and conditions that need met.

You also mentioned being able to offer services for other MGs. Some MGs are very complicated and will require a great deal of work, are you ready and capable of doing that? No offense but if you dont know how to convert a AR15 to full auto you probably arent ready to manufacture other full autos. You are at a point where you either need to hire someone who are worked as a armorer for the military or take a professional course designed for full auto work.

Im not trying to discourage you from doing it, im just making you aware of all of the pitfalls of not taking this seriously. People are always baffled when they first learn you can just form a SOT and convert a AR15 to full auto rather than buying a transferable $20k+ M16, seems silly right?! well the SOT route is a lot of work and a lot of legal responsibility vs the pre86 transferable route which is pretty much just pay the cash and whatever you want with it with minimal legal worries and the stress of having to operate a legitimate business that does look like you made it just to make/buy a collection of machine guns for personal use.

Since when does an SOT need a department letter to BUILD a shop MG?

You can build whatever you want as an SOT, you just can't order a post sample without a department letter.

You seem a little out of your league.  Converting an AR to an M16 is pretty basic machine work.  Their are blueprints available on google if you need the precise size to cut the lowers.



Why would you get a SOT if you didn't already understand how to make a MG?

       
 

They don't, but ATF has stated R&D is not a legitimate reason to build a MG.



 

Do you have a letter on that pertaining to SOTs?  Every letter I've seen to that effect pertained to Form1's for non-SOTs.

Pretty sure the 1919 or UZIs my local SOT built from kits won't be bought by a local department.

There is no limit to what the SOT can build, the limitations are only on who it can be sold/transferred to.

Now your going to make me do work  Pretty sure it's in one of the QA handbooks.  I'll go look for it.



 

Not saying I don't believe you, I've just never seen it pertaining to SOT's.
How would an SOT bring new designs to the table if they can't build them except under government contract?

7.6.2 Manufacture of machineguns solely for purposes of testing. The manufacture of machineguns

solely for testing or research purposes is not recognized as a legitimate exception to the ban on

possession or transfer of firearms under 18 U.S.C. 922(o). As previously stated, manufacturers may

only manufacture machineguns on or after May 19, 1986 and stockpile the same if they are

manufactured and held for sale to Federal or State agencies, for distribution as "sales samples,” or for

exportation.



That is taken from https://www.atf.gov/files/publications/download/p/atf-p-5320-8/atf-p-5320-8-chapter-7.pdf
 

The way I read that, the "and stockpile the same" is the operative phrase.
A couple here and there isn't "stockpiling" in my opinion, but I don't work for an alphabet soup agency.
In typical ATF fashion, there is room for interpretation and "opinion letters"

I will say that every SOT I've dealt with has at least a couple "shop guns" that were built for customers to look at and shoot on their range, LEO or not.  Could that be interpreted as "sales samples" to demonstrate the services/capabilities of the shop?

As long as the SOT puts it up for sale to LE/MIL then I think he is good.  It may be a bad business plan, but it meets the letter of the law.        
 

Good. The wrong answer would have been to rent them, play with them, for my own use, etc.

Perhaps you can highlight in BLUE where anyone claimed you needed an Demo Letter build machine guns?

That was what I was getting at, you can make all you want, but the intent of making must be to sell to LEO/MIL.

That makes sense.

The potential problem nowadays is who has the burden of proof should the "intent" come into question.

Don't forget you also can't send them to anyone else unless You and the company you are sending post sample MG's to have letters from a Gvt. agency stating its OK to do so . If you can't get your postie AK or belt fed to run right , seems like you up a creek unless you can take it to a local guy and maintain control of it .

Or in the case of the place I used to work at, fly the guy in for a couple days.

Can I get clarification on that? Say I have a gun that needs ceracoating or hot bluing. I cannot to either one with my facilities. Are you saying I cannot send it to another SOT or even just a FFL for that gunsmithing work?

That seems to go contrary to the "normal" advice I have always read for gunsmithing work. I remember that it was even stated that a gunsmithing repair could be done by a non-SOT since the gan was only being worked on, not transferred (similar to the fact that I can return a gun to the customer that initially brought it in for gunsmithing without doing a 4473 on him. The gun was not transferred, and was not logged into my A&D book, but was logged into my gunsmithing records).

Here ya go.....can't farm-out work on  posties anymore....unless you transfer it to another SOT with a LE letter......specifically mentions coatings/finishing as well
https://www.atf.gov/sites/default/files/assets/Library/Rulings/Firearms/atf_ruling_2014_-_manufacturing-inventory_of_machineguns_for_le_and_military_2.pdf

there was a thread over at sturmgewehr a few weeks back about it....

eta: link.....
http://www.sturmgewehr.com/webBBS/semiforum.cgi?page=4;read=119055

Ugh. Gotta love the ATF rulemaking process.

Their letter seems to disagree with the one from 2010

https://www.atf.gov/regulations-rulings/rulings/atf-rulings/atf-ruling-2010-10.htm

Only in government and monopolies would you be able to get by with such major discrepancies without someone deciding to shop somewhere else.

I guess the question is, at what point does "manufacturing" end, and "repair/refinishing" begin????

(sorry for the partial thread derail.....but it's somewhat relevant, as ATF is obviously taking steps to limit the "recreational" (for lack of a better term) manufacture of post-86 MG's)