The legality of making SBR in WA is in limbo due to ambiguity in a recent amendment that was originally "intended" to enable SBR conversions, but did not explicitly state such. Until the law is amended.  So for now, WA ATF won't approve form 1 SBR apps. However, F4 transfers are legal, since that part of the law is uncontested.

Thus, given the situation, I am looking into utilizing an out-of-state NFA dealer who I could send my rifle to, to perform the conversion & send it back to my local FFL on a form 4 transfer. I'm also posting this in other state forums to get a list of potential FFL's who might be interested in doing this. My local dealer (no proessional affiliation) would also be potentially interested in making an arrangement with said out-of-state dealer to offer this as a service to other WA SBR applicants until the state law is remedied. With 41p looming, it would be an opportunity for those of us who want to get SBR ocnversoin if/before the NFA rule changes.

I need to expedite this ASAP, as I don't expect the legislature to beat the timetable for 41p implementation.

To make your rifle into an SBR, you'll need to use a Class 2 SOT manufacturer (07/C2), not just a Class 3 SOT dealer.

Are there no Class 2 manufacturers in Washington? And by the wording of your post, you may not understand that your local gun store is probably not licensed to deal in NFA firearms. Also that an NFA "dealer" is not necessarily licensed to manufacture NFA firearms. They are two totally different types of licensees.

You'll need a Class 2 Manufacturer to actually create and register the SBR, then a Class 3 dealer in your state to receive the SBR from the C2 and handle the Form 4 transfer to you. A regular FFL can legally do the transfer, but it'll cost and additional $200 tax for the C2 to transfer to him. It'll also add months to the whole process.

Assuming you find the right licensees, what you are suggesting is going to be exceedingly expensive and time consuming. Better to simply find a factory or existing SBR and buy it on a Form 4. A C2 out of state will not do this for free as his time and engraving work will cost money, and there will be shipping charges both directions. He will then have to Form 3 it to your local C3 dealer who will then Form 4 it to you. There will be a fee here as well.

The issue is with the state law.  Specifically, it was amended to allow for SBR's, but was poorly worded, such that "making" is not clearly defined, so ATF will not approve SBR F1 apps.  A F4 transfer is, however, & so I can legally send a rifle to an out-of-state C2, have them perform the "making" conversion, & then send it back to me in my state to register it via F4.

I know it sounds messed up, & it is, but that's the situation in WA right now.  Work is already underway to amend the law yet again, but for a block on 41p, I don't see the fix coming in before the anticipated implementation this Dec.

I'm looking at converting both an ARX & a CZ EVO 3.  The factory SBR is an option with the ARX, but not the CZ.  Really, would require only paperwork & engraving, since the ARX uses a QD bbl., & the CZ just needs a stock.  Both parts are (or soon will be) available from the factory.

Completely unfamiliar with WA state law, but does this law prohibit a Washington-based C2 from manufacturing an SBR, then Form 4ing it to you? "Making" and "manufacturing" are two different things.

In-state C2 FFL's are restricted to making an SBR for gov't or export sales.  No in-state.

Since you already own the rifle in question, the out-of-state 02/07 can SBR the rifle and Form 4 it directly to you.
Noveske did this a while back if you bought a lower and complete upper. You could send the Noveske lower to them, buy the complete upper from them and they would register it and form 4 it directly to the out of state customer. I know a few people who have done this for SBS' and AOW's too.
Unless, of course, something with the ATF has changed. The other problem, if the ATF still allows this, will be finding a 02/07 that is in the know enough to do it without thinking that you can't.

Both are peculiar & distinct from the AR in that the upper is the serialized part.  I just need to send them out of state to have them registered & engraved, then returned back on a F4.

I don't understand what you are saying here. I'm just saying that if you find an 07 that will SBR the rifle for you, they can Form 4 it directly to you without going through a local dealer. So, you could avoid the Form 3 transfer time and the local dealer's transfer fees.

I was responding to what you said about the service offered by Novesk.  I don't have need of an additional part or product for this purpose, unless they would do it for a service fee.  I will have to inquire about this.

As far as transferring to me, that sounds fine, but will delivery co's transport firearms to/from private residences?  I was under the impression that all firearms transfers had to go through a FFL.

UPS and FedEx will.
CMP ships Garands right to your door via FedEx. Glock repairs handguns and ships them to customers every day (Mine shipped via UPS). Remember, it's not a transfer. The Gunsmith is working on the gun and shipping it back to the owner. Think about if you Form 1'ed the lower. You would have to ship it to an engraver and they ship it directly back to you, not to an FFL.



I was just using them as an example of a company that would SBR a rifle for you (They don't do it any more). Not that you needed an upper.

The direct interstate transfer would have to be to a trust too. Not to an individual.

That makes sense.  Our state law might affect whether I can transfer it myself (Google up "WA State I594".  You won't believe it.) or have to use a FFL.  I do have a trust, so that should help.  Regardless, I need to find an out-of-state SOT who will do this for me.

Surprisingly, I've posted this msg on 5-6 different hometown forums, & no one has recommended a FFL.  I don't know what to make of that.

Yes, that law certainly could muck up the works.

Unfortunately, I don't know of any 07's that do SBR's. Most I know really only do silencers. There are a few 07's that hang out on NFATalk, you might want to check there.

If you have a trust, why not find an out of state trustee, amend the trust to their location and have them form 1 for the trust in their state?

THIS!  ^^^^

You will want to add the Title I (non-nfa) firearms to the trust prior to taking them to the trustee so that no out of state transfer takes place, which would require a FFL.  The out of state trustee could submit the Form 1 and, upon approval, make the SBRs.  Then submit a Form 20 and you come get them when it is approved.  Or find a way to ship them, I have been unable to find a common carrier that will ship NFA items from a non-FFL to another non-FFL as of this year.

Lots of stupid hoops to jump thru because your legislators screwed y'all.

Oh, we got bent good.  Snce the law is so whacked, I can't be sure if there might be some issue with a F20, so I'd have to look into it.  The other thing is I don't want to have any problems with putting some Joe I don't know into my trust.

Contact Code 4 LE Sales in WA and buy a factory Colt SBR. Tom Liemohn at
Liemohn Manufacturing is a good 07 FFL/SOT in WA.

http://liemohnmfg.com/sample-page/

I would only put people in my trust that I know well and TRUST.  Putting someone you don't know in the trust is opening yourself up to lots of potential legal problems, not to mention theft.

In order for the 07/02 to "manufacture" an SBR, they are going to need the entire thing. You won't be able to just send the reciever to be engraved. Similar to how you cant buy a stripped lower from an 07/02 already registered as a SBR.

I've never heard of the direct from the manufacturer before but I'd be willing to bet that only works with the "original" manufacturer, so sending your rifle to a manufacturer other than the gun's original manufacturer probably negates this from being an option.

Anyway your best bet is to likely call around to different ones and get some quotes.

My suggestion is One Shot in Newtown OH. They built an SBR for me a few years back. They recently built a new indoor range so their website is more geared to that with the new "Ready Line" name here

Ask for Chris and tell him what your looking to do. If you get his mom hang up and try again - she can be a handful if she's in one of her moods!

I can vouch for Tom Liemohn at Liemohn Mfg. in Kent, WA.  He is a C2/SOT.  
Just spoke to him recently about this SBR issue.

Contact him at 253-632-5643  ([email protected])

The idea with Noveske registering title I lowers they had previously manufactured and sold was that then Noveske wouldn't have to re-engrave their name and location on the gun when registering it, as that info was already engraved on the gun when it was manufactured as a title I firearm.  Less ugly engraving on the receiver, and it's a factory gun.

Under current federal regulations, any C2 is capable of receiving a title I firearm from an unlicensed individual and making it into a title II firearm, and then returning it to the owner (whether out of state or not) on a form 4.  It doesn't matter if the C2 is the OEM of the title I firearm or not.  I had Tromix (in Oklahoma) make a Saiga 12 into an SBS a couple years ago and it came directly back to me on a form 4.  And that was even coming from me personally and returning it to me while I was acting as a member of my LLC.