Was thinking that if an SBR is only an NFA firearm when configured as such, then can the NFA engraving be placed on a buttstock for example? Remove the buttstock and install a pistol brace, now it's no longer a NFA firearm and doesn't need the NFA engraving. RIGHT?!

Put the engraved buttstock back on, and now it's an NFA firearm and has the needed NFA info.

Buttstock is not the receiver Wont fly unfortunately.

No.

The stock is not the "frame, reciever, or barrel" as required by law.

https://www.law.cornell.edu/cfr/text/27/479.102

You can engrave the barrel, but then you need to engrave every short barrel of every upper you use on the SBR, which seems silly.

I SBR’d a semi UZI model A and engraved the short barrel. That way it is simple to restore the gun to Title 1 status and preserve the re-sale value by simply swapping the short barrel back to the original 16” barrel and notifying ATF if I want the gun removed from the NFA registry.  

In OP’s case, can he engrave the receiver of the gun and still toggle back & forth from being an SBR to a braced-pistol if he crosses State lines? The engraving itself does not make it an NFA firearm.

Please correct me if I am wrong.

What's the opinion on "frame" and "receiver"?

Engraving the SN'ed lower receiver is correct but what about AR upper receivers or grip frames on non ARs like HKs and FNs that are not the SN'ed part?

My Norrell 10/22 was engraved on the trigger group.

Yet they ruled a plastic stock is a machine gun.

Does any of this even remotely make sense or logical?  

Elsewhere, "frame or receiver" is used to mean the serialized part of a firearm that is the legal firearm for purposes of 4437 and such. While the part may use the words frame or receiver in the name, I don't think they are legally a frame or receiver.

By this logic you could engrave a magnet and stick it on the gun you wanted to SBR that day.
Unless you like prison rape, I wouldn't.

As long as you have a stamp I don't think you are going to get prison rape for name or address in the wrong spot.

Thanks guys. I went back and read the Form 1 instructions and it clearly states the engraving must conform with 27 CFR 478.92 and 479.102. I don’t remember if that verbiage was always in there or if it was added in the past few years.

Anyways, 27 CFR says you can write to them to request an exception to the normal engraving requirements but needs an approval by the director. Shrugs, requests will probably go unanswered and adds to the wait time I guess.

This is the legal definition (CFR478.11):

Firearm frame or receiver. That part of a firearm which provides housing for the hammer, bolt or breechblock, and firing mechanism, and which is usually threaded at its forward portion to receive the barrel.

So an upper or non serialized lower, by definition, could be engraved with maker and address.

I've been thinking about that since a previous discussion here. I have an approved stamp for a relatively uncommon (and as yet unassembled) lower and similarly uncommon barrel, but the complete package would use an easily found upper receiver. Keeping resale value in mind, I'd much rather have the markings on the upper receiver. Maybe I'll just do it, and print out a copy of the referenced CFR to keep with my stamp.

This pretty much describes an AR upper better than a lower. Is the water muddy enough yet ?

I've never seen a decisive authoritative answer, but many people don't add engraving (which certainly breaks rules) and nothing happens to them.

The thing is... idk what the US government can actually charge you with for failing to engrave (or having the required engraving in the wrong place) since I've been advised (and researched it myself) there isn't a separate USC chargeable offense... It's the same as possessing an unregistered NFA firearm. The way they prosecute that is by having ATF query the NFRTR and return a sealed form advising if the firearm in question is registered to you (or not). Since it would be, I don't really see how the US Attorney's office could proceed.

I don't think the ATF (or any AUSA) knows what to do about it either.

I theorize the copy of that CFR would satisfy most field agents (in the unlikely event your engraving ever came under scrutiny in the first place).
Even if they go back to their field office with it, who'd know what to charge you with?

I've never heard of anyone having their NFA firearm seized due to bad/missing NFA engraving (other than the 1 story about the guy at KCR whose firearm was taken by an ATF SA temporarily and electro-penciled nearby).

If ATF did seize it, but failed to successfully prosecute/proceed with a court case, the owner would have excellent standing to petition for return of their property (which is an optional part of their asset forfeiture process).

Obviously this is more risky than following industry-standard engraving practices, so YMMV.

There's not much re-sale valve on an AR lower to begin with - what, couple hundred bucks for a new one, depending on trigger, stock, etc?  And if you've gone to the trouble and expense of SBRing an AR lower, why take it out of the SBR registry and sell it off?  A different story for a say a HK94, Action Arms Uzi, etc.  

The nice thing about having the lower engraved is that you can then put any upper on it you want, and have a good to go NFA set up.  With only the upper engraved, if you wanted to put a different upper on your SBR lower, if it was inspected (not likely), then there's no engraving on it, unless you lug your other upper around too.