Would a SBR verison of the Czech VZ61 need a certain number of USA made parts to be Sec 922 compliant?  

I assume these are made in Europe and imported in as pistols, and thus to become a rifle they'd need a certain number of USA parts, even if they're Form 1'ed into a SBR, is tha correct?

I know there are a lot of SBR VZ61 out there -  is Sec 922 being overlooked, or not applicable?  I've not seen any USA made parts for this system.

Sadly, yes.  BATFE has ruled 922r applies to SBRs, but not to pistols.

Several years ago, Czechpoint was offering a factory made SBR, so it's possible that there are US made parts for them, but that may have also been before the ATF clarification letter came out that said SBRs fell under 922R.

922 is bullshit. File your Form 1 and be done with it.

This is my take on it

People seem to think 922r applies to "all" pistols being made into SBR's and "all" imported weapons being assembled from parts or kits.  This is NOT true.  BATFE has to rule or make an opinion on this specific weapon.  In the case of the Scorpion Evo3 they opined on that specific weapon forcing CZ to put out 922r compliant SBR kits.  Part of the gray area is that the statute reads that if you are assembling from parts a weapon that resembles an SBR, or Full Auto, or Select Fire weapon that is currently available to specific entities in the US like law enforcement or the military then you are making a copy of that weapon and therefore have to be 922r compliant to turn it into a sporting rifle.  CZ does offer a select fire version to law enforcement in the US.

At the same time VZ does NOT offer the type of VZ61 that fits in the above category and BATFE has NOT opined on this specific weapon so at this time 922r does not apply.  The bottom line is DO NOT WRITE BATFE and stir the pot.  Leave well enough alone.

This is how I read the regulations..............on the other hand I could be full of shit.

Good to know.  Would explain why there aren't parts kits out for the VZ61.