https://www.atf.gov/sites/default/files/assets/Library/Rulings/Firearms/atf_ruling_2014_-_manufacturing-inventory_of_machineguns_for_le_and_military_2.pdf

Am I reading this correctly in that if I am a 02 holder and manufacture a MG, and want to send it to another 02 who does anodizing I can no longer do this unless I have what amounts to a law letter from a PD, or Gov contract?
If I'm reading this correctly the only way to do this from now on is to send a employee with the items to be treated, finished, tested, or examined and then have them stand there while the second SOT holder preforms the task.  And if that isn't bad enough now the second SOT holder can not lock up the MG's at night the employee would have to have a safe that only he can access.
This really doesn't make sense on a bunch of levels.

That ruling says nothing about a safe.

Well you are correct in that but only a "area" that the employee can access.

Wouldn't anodizing fall under 'gunsmithing'?

Why the fuck are you are inventing language that isn't in that ATF Ruling? The word "area" isn't used in that document.


The actual text is: "If the process takes longer than a day, the machineguns must be stored in a manner so that only the registrant has access to them during the overnight period."

A simple gun locker or chain and padlock (with only one key) would seem to meet that requirement. No big deal.

They seem to be differentiating between anodizing when a gun is made (part of the MFG process), and later in its life (gunsmithing process).

Ok fine I get your point and to that you are correct, there are multiple ways to disbar anyone from accessing the guns.
That isn't the part that really jumps out at me in this whole thing.  The fact you can't or at least the way it appears you can no longer work on a MG for whatever reason with out what amounts to a "law letter" unless a employee of the original manufacture is present is some what of a big change from the past.  
This will end up driving up all cost associated with anyone manufacturing MG's.  
No more testing and evaluating with out a letter.  Yes, there are ways to do it but all seem to be much more costly than the previous way.
And I wanna know what idiot asked for clarification on this matter in the first place!

Read it again, it only applies to MFG process.

As stated above, under the GCA, a machinegun transfer would occur if there was a change in dominion or control of the machinegun. Thus, a transfer would occur if the manufacturer relinquished control over a machinegun by leaving it at the contractor’s premises for further manufacture, or otherwise disposed of the machinegun to another manufacturer.

Held further, a manufacturer may transfer machineguns it has manufactured for present or future sale to a Federal, State, or local government agency to another qualified manufacturer for assembly, development, testing, repair, other manufacturing processes, or storage on behalf of that government agency; provided, the first manufacturer has a specific government contract or official written request stating that it is an agent of the government agency requesting and authorizing such transfer and in the case of a written request, it is on official government letterhead signed and dated by an authorized government official, includes the official’s title and position, and includes the following statements to document government approval:


I hope I am wrong, but it appears to cover development and testing/R&D