"Technically, it would probably be illegal for you to sell the gun with a non-HBar upper w/out going through an FFL, since this would be a Regulated Weapon configuration"
Thats exactally the catch-22 I don't want to get caught up in. Am I creating a "regulated weapon" by installing the non-HBAR upper, thus committing a crime?
Also a good point about it even being an AR15 with the .22 upper, but I think so, since as you say, it's the lower thats registered.
I just spoke with a friend from SCSC here in Md. He's got an FFL, and said something simular to what you say. It "could" be illegal depending on who's doing the checking, but, unless I'm in trouble for something, nobody will be looking.
This really sucks. I'm trying to do the right thing, and can't because nobody REALLY knows whats right. I hate Md.