922(r) status has nothing to do with capacity.
I believe all 11724 models are imported for LE use, which is why their first sale (or shipment) must be to a LEO or agency. Once that occurs, they may be re-sold to anyone, and are permanently exempt from 922(r), pursuant to
18 USC §925.
Quote History (1) The provisions of this chapter, except for sections 922 (d)(9) and 922 (g)(9) and provisions relating to firearms subject to the prohibitions of section 922 (p), shall not apply with respect to the transportation, shipment, receipt, possession, or importation of any firearm or ammunition imported for, sold or shipped to, or issued for the use of, the United States or any department or agency thereof or any State or any department, agency, or political subdivision thereof.
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As a post-1968 NFA item, they're only importable for LE or government use. Any firearm (including Title I 18" Benellis) could fall under the 925 exemption. You might find a used gun a cop's selling that they don't even realize is exempt. This is one reason 922r violations are rarely prosecuted. No records proving the exemption status are kept (nor required), so it's generally impossible to prove "beyond a reasonable doubt" that most random used guns weren't possessed by or shipped to LE for official use at some point.
With Benelli M4 Entry guns, the dealers are getting them in knowing the demand to re-sell to private citizens, hence the high prices. Sometimes LEOs also cash in on their lucrative exempt status, although purchasing with the intent of resale is prohibited.
OP, to answer your question... If your gun has never fallen under the 925 exemption then yes, it is still subject to 922(r) regardless if you register it as an SBS or not.