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THIRDHERD
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Posted: 10/3/2012 7:05:53 AM EST
I need to to have a few lower receivers engraved and am working with another 07FFL in a different city (same state).

All I need is my business name, city, and state engraved on the lowers. His ATF office there is telling him to submit when work is completed.

My ATF office is telling me a full application is needed for a marking variance prior to the work being completed.

Anyone deal with this situation? My engraver who is a new 07FFL is pulling his hair out. I haven't played with stripped lowers before and probably won't after this.

Any help is appreciated!
RyJones
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Posted: 10/3/2012 7:14:54 AM EST
Is he doing anything other than engraving? Is there a reason to use him, and not an established engraver, like Ident?
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THIRDHERD
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Posted: 10/3/2012 7:34:02 AM EST
Appreciate the reply.Not too many laser engravers in my area. He is in Reno and I am about 300 miles away and it's easy for me to get back and forth. He has experience in engraving etc..etc.. It's the process (ATF) that is turning out to be a pain in the ass.
Homeinvader
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Posted: 10/3/2012 8:44:06 AM EST
[Last Edit: 10/3/2012 8:46:25 AM EST by Homeinvader]
Assimg NFA marking requirement? nonetheless, this should not involve ATF directly at all. Ship him your lowers, he'll engrave as requested and ship them back to you. There is no requirement for a variance since this is simply NFA compliance.

He should never has gotten a license if he doesn't understand the rules and regs, very dangerous.

Local LE and local ATF Field Offices are not very familiar with NFA, so best not to involve them.
Ponyboy
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Posted: 10/4/2012 2:16:00 AM EST
If all he's doing is engraving unregistered lowers I'd forget about him and find someone else that knows what they're doing. Like has already been said, all he needs to do is mark them and ship them back to you. He shouldn't be concerned with variances or anything else, that's your problem, he just need to do what he's being paid to do and scratch some letters in the metal.
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Bubbles
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Posted: 10/4/2012 6:17:51 AM EST
[Last Edit: 10/4/2012 6:19:15 AM EST by Bubbles]
From your first post I'll assume that you are not making the lowers, you're buying Title I lowers from another vendor and having them marked with your information so that you can make them into an NFA firearm as an 07/C2. If so:

- Buy the Title I lowers and log them in to your A&D book, (or have them drop-shipped directly to save on shipping), then log them out to the other FFL.
- The other FFL engraves your name, city, and state on the Title I lowers.
- You get the Title I lowers back and log them into your manufacturing log.
- Build gun(s), updating your manufacturing log as needed during the manufacturing process.
- File Form 2(s) as guns are finished if they are Title II guns.

The only reason for a marking variance is if you were starting with an 80% (or less) receiver that the other FFL is finishing out for you and marking with your information.
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