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Adding a verticle grip to a pistol over 26 inches does not make it a "firearm."
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That's exactly what it does.
Read the letter in your link a little more carefully, mainly the last block of text on page 2. Also read the federal definition of a "pistol", notice it has no stated maximum OAL. A pistol with a 16" barrel is still a pistol. However, pistols are "designed to be held by a single hand", so adding a VFG changes that and takes it out of the realm of a "pistol". If you add the VFG and the pistol in under 26" OAL, the ATF contends it is then "concealable", and would be an AOW. If the pistol is 26" or greater in OAL and you add a VFG, it now fits none of the other federal sub-definitions of a firearm, so it is simply regulated as a "firearm".