During this amnesty period, I would like to register an imported pistol as an SBR since it had an arm brace.  For this example, an HK SP89 imported from Germany as a pistol must be 922r compliant.  

Questions :

1.  I know in the past, these pistols have been registered as an SBR for many years, but under this New temporary arm brace amnesty Rule does The Rule say imported pistols can be registered ?  

2.  Will any of the 922r compliance regulations affect amnesty SBR registration approval ?

3.  Has anyone got an Amnesty SBR approval back yet on an imported pistol ?  

Thanks in advance for any helpful information and advice.  

I filed and it got approved.

February 24th to April 14th.

It was 3 imported pistols.

This is all answered in the FAQ

https://www.atf.gov/qa-category/final-rule-2021r-08f

I possess a pistol, which was imported and then subsequently equipped with a stabilizing brace. Does 18 U.S.C. § 922(r) apply to my firearm?

No. Section 922(r), in relevant part, makes it unlawful to assemble from imported parts a semiautomatic rifle that is otherwise not importable. The implementing regulations of the GCA at 27 CFR 478.39 provides that a person may not assemble a semiautomatic rifle using more than 10 of the imported parts listed in the relevant paragraphs of the regulation. As discussed in section IV.B.8.e of the final rule, the criminal violation under section 922(r) is for the “assembly” of the semiautomatic rifle; therefore, no modification of such firearm would cure the 922(r) violation because the “assembly” has already occurred. Accordingly, a person with an imported pistol that was subsequently equipped with a “stabilizing brace” will have the same options as anyone else under the final rule. Should that person choose to register the firearm, no further modification of the firearm with domestic parts is required.

So I guess same is true. If someone built an AK pistol years ago from a parts kit and then added a brace.  Don’t need to worry about parts count?

The pistol didn’t need 922r parts.  If you had a braced pistol without 922r parts they are allowing it to be Registered as an sbr without the parts.  It’s an “Amnesty”

So imported MKE pistols that were stabilized braced are no longer required 922r compliance?

What if you choose to file a tax paid form 1? Does 922r compliance apply? Thanks

922r (and engraving) only applies to the "builder". Prior to the ruling, adding a brace to an imported pistol didn't constitute building/making anything ....... thus no 922 compliance (or engraving) is necessary due to the reclassification.

A normal tax-paid registration will require both 922r compliance, as well as engraving

Ironically, I suspect that it does.  If you are going to do it, you have to do it now under the forbarance, if you want to avoid all that.

Of course.  Aside from standing next to your crate of commercial imports at customs, or internet chat forums, nobody actually gives a shit about 922r, but if it is a concern, now is you chance.

The ATF office was shut down until further notice.
The FBI is an operating criminal organization who's power has been suspended also. This info came from a very reliable source, yep you guessed it my dog
Most constitution obeying citizens are waiting for congress to repair these agencies. Could take quite a while with FBI putting up a last desperate fight.

So do what you know is right and constitutional, take care of you and yours.
Treat others as you would like to be treated & respect property.
I'm the acting authority at my house and the world I live in.

They are approving them and don't seem to care about 922r compliance. I have multiples approved.

Thanks for the info all. Is it too late to file the forbearance form 1?
I know, I'm usually not this late to anything.
@jaqufrost

@Bishop3
Wednesday is the last day. Once you submit the form you have ten days to mail your fingerprints.

I highly recommend filing today if you want to file. I don't expect the efile website to stay online Wednesday. ATF's efile system isn't known for reliability.

@jaqufrost
I have a dealer who can convert my prints to EFT tomorrow Tuesday. Do you recommend this over mailing them? Also is there a CLEO notification like a normal F1?

Thank you sir.

Given the current time constraints, I would file today and paper mail the forms in. That's better than scanning a set to ETF's tomorrow and not being able to file because the website is down.

ETA: Yes, cleo notification like normal. You print the cleo copy and mail it to them.

Thanks for the help. I got 2 forms submitted processing today, prints and CLEO notifications will go out in mail tomorrow morning.

Will the turnaround be close to the usual 30-60 days?

With this forbearance/amnesty F1 tax exempt submission, there is no concern with 922r and engraving. That is what I currently understand it to be.

I had some forms come back in 30 days and some are close to 90 days and not back yet. I did 27 forms and 25 have been approved without problems. One was returned for not having my middle name (none of my others listed my middle name).

No engraving required and they aren't going after people for 922r compliance.

Going to be fun to see how many months 5/30 and 5/31 forms take!

In the interim, what to do with any pistol stabilizing brace?

There are a couple lawsuits and an injunction court order that holds on the rule.

Well that's the thing... FBATF "approved" pistol braces too at one point now they say they are illegal SBR's. Who's to say 5 years from now they won't be at your door to collect your non 922 complaint SBR? Their "approvals" mean nothing.

They’ve never cared about 922r compliance on submissions.  It’s not a question or even mentioned on the Form.  They’ve been approving imported guns for years, including many that don’t seem to have much in the way of known US made 922r compliance parts.

Do what you want with them.  If you’ve gotten SBR approval, or a pending submission, it doesn’t matter.