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I want to see the exact title number of the letter or the law, because we have swapping uppers on the registered lower for years now.

You don't register the upper, you register the lower and that is what they issue the stamp on.

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~snip.......

I know one thing for sure:  If the ATF tells you something you didn't know about an NFA regulation and if you ask about/share what they told you in this forum you will get nothing but grief over it.

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Where does it say anyone can change their approved SBR around?

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Let’s flip that.  Can you provide the title or letter of the law that says changing calibers or barrel lengths on an approved SBR is legal without updating the documentation?  The fact that people have been doing it for years carries no legal weight.  Fact is, someone submitted an application to make an SBR that included barrel length and caliber, and that specific configuration was approved.  Where does it say anyone can change their approved SBR around?

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SCOTUS and Revenue Rulings dating back to before most NFA owners were born. Always comedy gold when folks think NFA scenarios are new and have not been adjudicated decades ago.

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Can you provide the title or letter of the law that says I can shoot FMJ and JHP ammo through my .45 pistol? Or the one that says I can shoot 115gr and 147gr ammo through my 9mm? Or .223 and 5.56 ammo through my AR-15? Or that I can shoot it either left-handed or right-handed?

No...you can't. Because that's not how the law works. There is no flip-side to this situation.

Everything which is not forbidden is allowed.

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How is that?

So I should never ask them for instruction or clarification, even though they gave me correct guidance this time?

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This whole thread is a joke and a waste of our time. Bad info all around, and yes that includes what came from the ATF.

There is no requirement to notify when swapping uppers.
There is no requirement to have records updated for other calibers.
There is no requirement to be able to return to original specs.

I'm very tempted to just move it to GD...it's that ridiculous.

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It won’t help

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If there was any consistency, I might agree.

But I can show you approved 5320.20 forms from the last several years in a row, where the caliber and/or length doesn't match the Form 1...and they've always been approved without any notification sent in.

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Final word on this:  I spoke with a qualified attorney AND the station chief at the BATF main branch.  The record update procedure was added to SOP after instances of transfers being denied when records did not match the new configuration and due to confiscations of NFA items for the same reason.  When the regulations were written in the late 60's multiple configurations were not anticipated so there is NO requirement in the regulations to send an update notice.  It is recommended, not required.

Station chief gave me examples of why it should be done VOLUNTARILY:  Accident or pulled over by police may result in confiscation if the paperwork is not present or doesn't match the configuration.  Owner makes a configuration change and neglects to update the record then years later sells the NFA item, the Form to transfer WILL be denied until the record is corrected.

Another prime example of not required but strongly recommended is 5320 out of state travel.  This one was a surprise since I thought this WAS a requirement.  No regulation requirement to send in the form but same scenario applies if pulled over or in an accident etc. where the officer asks to see paperwork in the other state.  Don't HAVE to file the 5320 either, but stupid not to do so.  (Getting approval from ATF before moving an SBR, SBS, MG or Destructive Device to another State is required.  The law that requires it is 18 USC 922(a)(4) and the regulation is 27 CFR 478.28.  Yet you don’t have to use the Form, you can write ATF a letter asking for their approval to move an NFA weapon to another State.

I asked why three reps in his office told me the added configuration notice was a requirement.  He said over the years it has become SOP but the line between required and strongly suggested has become blurred.  You guys who said there is no requirement in the regulations were correct and you guys who mentioned the need for the update for transfers were right too.

Bottom line: No REQUIREMENT to update the record for added/changed configurations and they haven't changed the regulations to reflect a need to update the record.  Btw you WILL get a BATF APPROVED stamped copy of your letter back to put in your range bag in case of any questions.  I'm sending the update letter and see plenty of reason to do so and no reason not to.

Thanks to everyone who posted positive/helpful commentary.

Quoted:  Is 41F a Law?

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So If I drive around with my SBR lower with no upper attached, am I dividing by zero?

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This came up last year for me, as well.

I had a few SBRs that I originally filed Form 1s for a few years back detailing that they had 10.5 inch barrels. Since originally filing, I put 11.5 inch uppers on them and all was well.

Last year, I filled out some 5320.20s to take the SBRs into another state. On the Form 20, I put that the SBRs had 11.5 inch barrels.

The Form 20 came back disapproved and there was a note that I needed to update the NFRTR if I wanted to get a Form 20 approved for the SBRs.

I could have filled out and signed a new Form 20 stating that the rifles had 10.5 inch barrels when they really had 11.5 inch barrels, but would that be wise?

There might not be a regulation that requires you to notify them if you change barrel length, but if they’re disapproving requests based on info about barrel length not matching up with what they have on file from the original paperwork, then can you really do everything you want with the SBR?

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NO....

write and notify ATF.