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I didn't realize that. Kind of makes getting a FFL/SOT dealer license pointless unless you have a contact in LE who will give you the letters.
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I would agree that if your hypothetical goal/aspirations is to collect a stable of post-sample machineguns than the 01/03 route is certainly the much tougher row to hoe, especially if you don't have LE contacts for love letters.
That said, manufacturer licenses come with additional zoning and compliance hurdles to jump over and there is the ever present ~$2000 annual "ITAR" registration fee hanging over your head that you may or may not be forced to pay.
If you look at a site like fflgeolocator and you can see how many dealers vs manufacturers vs importers vs DD manufacturers there are out there. I presume most of this FFl type distribution is zoning, compliance, and license cost based.
If FFL types were all the same cost and effort than everybody might as well get the gold standard license which is the 10/02 (manufacturer of destructive devices) which pretty much lets you buy and build whatever you want. The big downside is that the type 10 license is the FFL fee is $3K, plus SOT, plus ITAR so it gets up there in cost in a hurry. Some folks do it though even if they have no real DD business. Around the corner from me is JJFU who is a Type-10/02 and to the best of my knowledge has no real legitimate Type-10, DD business. However, I suspect the owner has plenty of disposable income.....so why not.
Many folks can easily get an 01 FFL out of their house if zoning permits it and for many 01 holders its worth the $500 SOT fee to be able to do higher margin NFA transfers along with the side benefit of being able to get pre-sample machineguns at reduced costs as well as other NFA firearms like silencers, SBRs, etc. on a tax free and much faster transfer time Form 3 transfer.
In my mind if you have any interest in NFA firearms and already have an 01 FFL, paying the $500 fee for the SOT seems like a no brainer to me. It takes less than 1 NFA transfer a month at current market NFA transfer fee rates to break even on the SOT fee.
If the BATFE offered individuals a $500 annual "Expedite Fee" where my F4s/F1s were processed on the same sub 30 day timeline as a Form 3 (and I still paid the $200 taxes) I would highly consider it.