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Posted: 7/14/2016 1:39:46 PM EDT
According to our ATF Agent you can not buy a stripped lower and add your own LPK or buttstock According to her you have to have a license 7. According to her the code is in the 2012 FFL handbook and we explained to her why do they sell stripped then. We are finishing our Audit today and we are going to show us the code. Basically she is saying unless you are a manufacturer you can't alter a lower.
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Posted: 7/14/2016 11:18:21 AM EDT
[#1]
Well doesn't she sound like a special snowflake. Making up her own facts as she goes along.
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Posted: 7/14/2016 11:19:04 AM EDT
[#2]
She is a moron. Sounds like she is trying to equate adding triggers and components to manufacturing for the intent to sell.
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Posted: 7/14/2016 12:41:46 PM EDT
[#3]
lol. That's not how that works
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Posted: 7/14/2016 12:51:39 PM EDT
[#4]
Gotta love the ATF. Don't know shit, say stupid shit, make shit up as you go along.
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Posted: 7/14/2016 12:59:54 PM EDT
[#5]
Actually, this is the case for FFL-01 Dealers.
The ATF considers assembling a lower manufacturing, which requires a FFL-07. I was told by my local field office that "once in a while you can assemble a stripped lower, but don't make a habit of it". This is if course assembling a stripped lower that I plan to sell. This does not apply to personal builds, nor non FFL licensees. IANAL. ETA: I'm assuming the OP meant to post this in the FFL forum. |
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Posted: 7/14/2016 1:01:38 PM EDT
[#6]
Quoted: According to our ATF Agent you can not buy a stripped lower and add your own LPK or buttstock According to her you have to have a license 7. According to her the code is in the 2012 FFL handbook and we explained to her why do they sell stripped then. We are finishing our Audit today and we are going to show us the code. Basically she is saying unless you are a manufacturer you can't alter a lower. An 01 FLL is limited on what they can change or add to a firearm pre-resale without it being considered manufacturing. |
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Posted: 7/14/2016 1:45:00 PM EDT
[#7]
Page numbering bump.
ETA: If I click the green arrow, apparently I'm @ the top of Page 2 in a thread w/ no page 1. 
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Posted: 7/14/2016 2:31:10 PM EDT
[#8]
but if i am correct you can sell the stripped lower and LPK do the transfer and then assemble as a gunsmith
way around it |
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Posted: 7/14/2016 2:52:15 PM EDT
[#9]
Quote HistoryQuoted:
Actually, this is the case for FFL-01 Dealers. The ATF considers assembling a lower manufacturing, which requires a FFL-07. I was told by my local field office that "once in a while you can assemble a stripped lower, but don't make a habit of it". This is if course assembling a stripped lower that I plan to sell. This does not apply to personal builds, nor non FFL licensees. Exactly if you are a FFL and sell at gun shows then this applies. IANAL. ETA: I'm assuming the OP meant to post this in the FFL forum. |
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Posted: 7/14/2016 3:22:06 PM EDT
[#10]
Quoted:
According to our ATF Agent you can not buy a stripped lower and add your own LPK or buttstock According to her you have to have a license 7. According to her the code is in the 2012 FFL handbook and we explained to her why do they sell stripped then. We are finishing our Audit today and we are going to show us the code. Basically she is saying unless you are a manufacturer you can't alter a lower. This is correct. Manufacturing firearms requires an 07 FFL. |
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Posted: 7/14/2016 3:24:46 PM EDT
[#11]
Quoted:
Well doesn't she sound like a special snowflake. Making up her own facts as she goes along. Quoted:
lol. That's not how that works Quoted:
Gotta love the ATF. Don't know shit, say stupid shit, make shit up as you go along. Only on ARFCOM can so many people be so wrong, and unable to spend 10 seconds googling the correct answer. |
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Posted: 7/14/2016 4:18:00 PM EDT
[#12]
She is correct if she is referring to an 01 assembling a stripped lower and selling it. You'd need to be an 07 to do that and you'd have to mark it.
If the 01 sells it to a customer, transfers it and then the customer wants the 01 to perform gunsmithing and assemble the lower, that is fine. |
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Posted: 7/14/2016 4:25:39 PM EDT
[#13]
Quote HistoryQuoted:
Only on ARFCOM can so many people be so wrong, and unable to spend 10 seconds googling the correct answer. Quote HistoryQuoted:
Quoted:
Well doesn't she sound like a special snowflake. Making up her own facts as she goes along. Quoted:
lol. That's not how that works Quoted:
Gotta love the ATF. Don't know shit, say stupid shit, make shit up as you go along. Only on ARFCOM can so many people be so wrong, and unable to spend 10 seconds googling the correct answer. I meant IF YOU have a FFL you can NOT assemble a stripped lower for a gun show. You can build your own lowers IF you have a license 7 to install the LPK and buffer on your stripped lower. This Lady ATF even called Virginia to verify but not sure how they would prove it. I know it sounds crazy but it is stupid but factual. I would love for someone to prove her wrong. |
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Posted: 7/14/2016 4:42:21 PM EDT
[#14]
Unfortunately, I believe she's correct.
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Posted: 7/14/2016 4:55:29 PM EDT
[#15]
Quote HistoryQuoted:
I meant IF YOU have a FFL you can NOT assemble a stripped lower for a gun show. Correct you need a MFG to assemble lowers. Non-mfgs can only perform gun smithing. |
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Posted: 7/14/2016 7:12:22 PM EDT
[#16]
Quote HistoryQuoted:
I meant IF YOU have a FFL you can NOT assemble a stripped lower for a gun show. You can build your own lowers IF you have a license 7 to install the LPK and buffer on your stripped lower. This Lady ATF even called Virginia to verify but not sure how they would prove it. I know it sounds crazy but it is stupid but factual. I would love for someone to prove her wrong. You want her to prove that you can't manufacture without being a manufacturer? If you are standing there telling her that you build up lowers all the time and sell them at the gun show, you may have just screwed your employer in larger ways that you can imagine. It sounds like she was being nice, I hope you didn't pull an attitude with her. |
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Posted: 7/14/2016 8:24:52 PM EDT
[#17]
Quote HistoryQuoted:
You want her to prove that you can't manufacture without being a manufacturer? If you are standing there telling her that you build up lowers all the time and sell them at the gun show, you may have just screwed your employer in larger ways that you can imagine. It sounds like she was being nice, I hope you didn't pull an attitude with her. Quote HistoryQuoted:
Quoted:
I meant IF YOU have a FFL you can NOT assemble a stripped lower for a gun show. You can build your own lowers IF you have a license 7 to install the LPK and buffer on your stripped lower. This Lady ATF even called Virginia to verify but not sure how they would prove it. I know it sounds crazy but it is stupid but factual. I would love for someone to prove her wrong. You want her to prove that you can't manufacture without being a manufacturer? If you are standing there telling her that you build up lowers all the time and sell them at the gun show, you may have just screwed your employer in larger ways that you can imagine. It sounds like she was being nice, I hope you didn't pull an attitude with her. It wasn't me but a wholesaler I buy from and the only thing he does is add LPK, tube and buttstock. I assure you he is smart enough not to pull an attitude with her. She said 80 % of the FFL holders do not know code. He wasn't making the stripped lower but just adding LPK's. Etc. She the Hobbyist builder can build his own his own all day long. |
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Posted: 7/15/2016 10:14:38 PM EDT
[#18]
Quote HistoryQuoted:
It wasn't me but a wholesaler I buy from and the only thing he does is add LPK, tube and buttstock. Which requires either a Type 07 or Type 10 FFL. It's not rocket science, if you modify or upgrade a firearm in your business inventory then you better be licensed as a manufacturer. If you take in one for gunsmithing then it's not business inventory, the firearm belongs to someone else so only a Type 01 FFL is required. There's an excellent explanation of the difference between manufacturing and gunsmithing in the ATF NFA Handbook, it's in section 7.2.3 at https://www.atf.gov/firearms/national-firearms-act-handbook |
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Posted: 7/17/2016 7:57:47 PM EDT
[#19]
How did your IOI know that you are (were) assembling lowers?
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Posted: 7/22/2016 4:49:04 PM EDT
[#20]
Are you talking about less than 50 per year? or more?
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Posted: 7/22/2016 5:06:45 PM EDT
[#21]
Quote HistoryQuoted:
Are you talking about less than 50 per year? or more? The 50 per year exemption applies to 07 and 10 FFL's for the purpose of collecting and remitting FAET. Type 01's don't get a pass on engaging in manufacturing activities by limiting themselves to manufacturing less than 50 firearms per year. |
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Posted: 7/28/2016 2:31:47 PM EDT
[#22]
This is what I recall from the first inspection.. but you know how it is with different IOI's.
FFL 07 can assemble a stripped lower into a functioning firearm for resale. FFL 01 can not assemble a stripped lower for intent of resale FFL 01 can assemble a stripped lower for a customer that gives you the lower and parts (gunsmithing) FFL 01 can build a stripped lower in to a functional firearm if not intended for resale, ie demo rifle FFL 01 can sell said demo rifle but don't make a habit of it. (I always wonder what you have to put into your A/D books if you do this.. ie check it out as a receiver and then back in as a pistol/rifle.) At least that's what I remember.. but my memory is getting poor at my age.
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Posted: 7/28/2016 3:14:17 PM EDT
[#23]
Quote HistoryQuoted:
This is what I recall from the first inspection.. but you know how it is with different IOI's. FFL 07 can assemble a stripped lower into a functioning firearm for resale. FFL 01 can not assemble a stripped lower for intent of resale FFL 01 can assemble a stripped lower for a customer that gives you the lower and parts (gunsmithing) ^^^ This is the most correct answer. |
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