Just printed out two sets of the key letters outlining the registering and assembly of an AR/AK pistol , and will keep a set with each of my 'pistols' in their cases .

I carry these often in the cab of my trucks , cocked-locked and ready to rock .
Maine doesnt allow you to have a rifle's loaded-mag inserted , nor a loaded rifle chamber , while inside/on a motor vehicle . . . . but a loaded pistol is good to go with a CCW.

Thanks again ARFcom

To Clear up any questions concerning OAL measurement(especially in regards to muzzle devices) 3rd page:

SB15 ATF Approval letters plus photos taken at the ATF FTB

SWEEEETT!!

ETA - Do you make one for rifle length buffer tubes? I have really long arms.

I like the airsoft angle too. Keeps you out of hot water just in case they rule it an NFA firearm.

And?

I wanted to buy a stripped never built receiver for a pistol build.  Dealer wouldn't sell me one, said it was illegal unless engraved from manufacturer as a pistol receiver.  Contacted the manufacturer who is local.  He said the same thing.  No over priced pistol receiver for me




 

That may be a Mi. law but it is NOT a federal law.

Thinking out loud here...could the change of adding the "Frame or Receiver only" check box to Form 4473 a few years ago, be the rationale for the letest determination?

If receiver was transfered as a receiver, per ATF guidance, rather than pistol or long gun then as long as it was never a complete rifle their rationale holds, regardless of the presence of a buttstock along the way.

Of course this is the agency that shall never be trusted, too...

I would LOVE to see a BATF letter regarding this item.  I've searched and not found any letters that differentiate a stripped AR-15 lower based on it's markings.  

I do agree that in MICHIGAN, you have to get the sales pistol form from the FFL at time of purchase, then turn 2 copies into the state.
So, my understanding is:
1) FFL transfers stripped lower as "other" on form 4473
2) FFL prints pistol sales form for use to register lower as a pistol with state of Michigan "If you intend to build the lower into a pistol."

Anyone???

Thanks,
AJ

Someone mentioned in MI you build the receiver into a pistol then register it as such.

Might be tough, as you only have 10 days from the time you purchase until you have to turn in the pistol sales form.
Also, you get the pistol sales form from the ffl at the time you acquire the lower.
I'd like to know where I can order everything to complete a pistol in 10 days in our current environment ;-)

AJ

Army_of_One, how long did it take for the FTB to answer your letter?

At most a month.  I was surprised by how fast it was answered.

I sent mine on Jan-14th and still have not received a response. Granted, I think my letter required a bit more work for them to answer.

I'm unaware of any such Michigan law (if anyone is, please stop me from making a mistake, as I'm about to take delivery of a virgin receiver and intend a pistol build with it). AFAIK, the only requirements WRT the lower are the Federal requirements that it has not been assembled as a rifle in the past (mine is factory fresh, going from them to my FFL- I intend to suggest he fill the 4473 as "other" or "receiver", and will not accept the form if marked "rifle").

Sounds to me like the above is a manufacturer and FFL holder both being overly cautious (can't blame them really) to avoid any potential accusation of impropriety. WRT the ATF people telling them that's what is required, they didn't send off to FTB it seems, but just issued their own "opinion" as an "official" one (which it is not, field agents, presuming that is who they are dealing with, are charged with enforcing the law, not interpreting it).

You're correct about the 10 day thing. And I've been careful not to obtain a pistol barrel before I have the lower (coming this week). But a few questions, food for thought... When does it become a pistol? And would it be illegal to register the receiver as soon as it is obtained as a pistol regardless of completion status?

WRT the Sales Record form, it does not have to come from the FFL (What would you do in a private purchase?). And if you don't have a MI CPL, you still need to obtain a license to purchase from your local Law Enforcement Agency. And the Sales Record that you mail in (remember, there is no longer an inspection required) can be obtained from sources other than your FFL (a 10 second Google found this for me).

I will discuss with my FFL about the registration (whether to send it right away, as I'd like to do, to preclude any presumption the receiver was built into a rifle first- though I already have the pistol buffer, and can use that and it's paperwork as well as posts here as evidence of my intentions should it come to that). Or to register it when I am finished building (again, there is no more inspection required, it is merely a paper trail). I see no harm* in simply registering the receiver right after I obtain it. Since I am the builder, I will then be obtaining it from myself.

*Yes, I know registration sucks, and I am aware of the potential harm in such a system, but it is State law here, and I was only referring to no harm from a legal standpoint.

Picked up my lower a few days ago. Discussed registration with my FFL, he cautioned me against registering it before it's completed (or at least substantially completed). while I need to list  the caliber (a no brainer), also required are barrel length (wasn't 100% sure until I found and ordered a barrel) and the length overall. For the loa, I'll probably get by with an assembled lower and a mock up of the assembled upper (temp/test fit barrel to upper and mate to lower, take measurement).

If the barrel gets here soon enough (I have doubts the way parts have been shipping), I still may make the 10 days. But I'm not concerned, because as the FFL pointed out, it's not a pistol yet.

Your state has pistol registration? All we have to do here is list the receiver as Multi or something like that on the 4473, and it can be built into a rifle or a pistol. There's no registration.



 

So it's been 119 days and the ATF still hasn't replied to my submission. After leaving 3 messages, they finally called back on day 91. The guy in charge of my submission told me that he hadn't had a chance to look at it yet. Needless to say, I was pretty disappointed. Now a month later, and still no response to my submission. I left another message today. Hope the news is better this time.

Yeah, has nothing to do with it being an AR. It's just a stupid and very old State law that all (modern) pistols be registered. The up side is that we're a "shall issue" state, and if it's registered as a pistol, it can be carried as one. A new law says 26 inches and over is not a pistol in Michigan, but I have a folding AK and an 8 shot pistol gripped riot gun that are both registered as pistols because they are between 26 and 30 inches (an old standard being replaced by this new one). Those will be grandfathered (still can carry them).

And my AR Pistol will be under 26 inches with it's 7.5 in. barrel (should be completed next week or the week after, depending on shipment of a few last parts, barrel forward is all that is lacking, rest I completed yesterday). That will be a new motoring companion

Does Anyone have any experience building a AR Pistol from an 80% lower? Maybe Im being over concerned, but wasnt sure if the "pistol" rules applied to a 80% build (Ie: marked pistol?and for Michigan registration?). Or maybe it all lies under the project being a 80%er so as long as you do it all your self your OK?

Just putting this out here. I work for a local shop and had a few customers ask about the Stark Equipment SE-5 grip being ok to use on a pistol. I am sending off an official request for review but here is what Fire Tech sent me back as a prelim regarding it:

Mr. Josh1982

The Stark SE-5 grip is designed with an angle gripping surface the same as the Magpul AFG and would be classified as such. If you would like an official opinion from ATF, please submit a request to the below address:

Chief, Firearms Technology Branch

244 Needy Road

Martinsburg, WV 25405

We currently have a 90 day turn around.

Firearms Technology Branch

cid:[email protected]

From: Josh1982
Sent: Thursday, November 14, 2013 8:24 PM
To: FIPB Regulatory Email inquiries
Subject: Submit a Firearms Regulatory or Firearms General Question or Concern



Good Evening,

I work for a local gun shop in WA and have a customer here asking if the Stark Equipment SE-5 model angled fore grip is still considered an angled fore grip like the Magpul AFG 1 and 2 models or is this to be considered a true vertical fore grip and not legally able to be used on an AR type pistol. I have attached a link to the manufactures webpage as well. We have had several other people asking for proof of an official ruling to keep with them to suffice questions by local law enforcement. Thank you for your time.

V/R

Josh1982
Gun shop
FFL# X-XX-XXX-XX-XX-XXXXX

Stark Equipment web link:

http://starkequipment.com/

Just bought a Sig PM400 pistol with the SB15 brace.  I saw ATF letters saying that the Magpul AFG is ok, but only one other reference to "magpul-type" grips.  I sent this to ATF (with pictures of both angled grips) specifically asking:

1 - is the Magpul ruling still in effect?
2 - Is a similar grip, the Strike Force Industries Cobra Tactical Foregrip  legal without changing pistol classification.

In short, both are ok.  Here is their response to me:

From: [email protected] [mailto:[email protected]]
Sent: Monday, December 23, 2013 10:15 AM
To: [email protected]
Subject: Angled foregrip question

This refers to your recent e-mail to the Firearms Technology Branch (FTB), Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF), regarding the lawfulness of the addition of a Magpul Angled Fore-Grip or “Magpul-type” angled fore grip to an AR-type pistol.

As background, the amended Gun Control Act of 1968 (GCA), 18 U.S.C. § 921(a)(3), defines the term “firearm” to include …any weapon (including a starter gun) which will or is designed to or may be readily converted to expel a projectile by the action of an explosive…[and]…the frame or receiver of any such weapon….

With respect to the definitions of “handgun” and “pistol” under Federal statutes and regulations, you may be aware that the GCA, 18 U.S.C. § 921(a)(29), defines “handgun” to mean, in part, …a firearm which has a short stock and is designed to be held and fired by the use of a single hand….  Additionally, 27 CFR § 478.11, a regulation implementing the GCA, defines “pistol” as …a weapon originally designed, made, and intended to fire a projectile (bullet) from one or more barrels when held in one hand, and having (a) a chamber(s) as an integral part(s) of, or permanently aligned with, the bore(s); and (b) a short stock designed to be gripped by one hand and at an angle to and extending below the line of the bore(s).

Please note also that the GCA, 18 U.S.C. § 921(a)(7), defines “rifle” to mean, in part, …a weapon designed or redesigned, made or remade, and intended to be fired from the shoulder….

Finally, the National Firearms Act (NFA), defines the term “firearm” to include …a rifle having a barrel or barrels of less than 16 inches in length…[and]…a weapon made from a rifle if such weapon as modified has an overall length of less than 26 inches or a barrel or barrels of less than 16 inches in length…. (See 26 U.S.C. §§ 5845(a)(3) and (4)).

Individuals desiring to manufacture a firearm subject to NFA provisions (machineguns excepted) must first submit and secure approval of an ATF Form 1, Application to Make and Register a Firearm, and pay the applicable $200 making tax.

For your information, FTB has determined that the addition of a forward vertical grip to a handgun would result in the making of a NFA-category firearm.  


However, we have also found that the Magpul AFG is not a vertical forward grip.  

Consequently, the addition of a “Magpul AFG”, or the “Magpull-type” angled fore grip (Cobra Tactical fore grip, as pictured below) to a handgun does not result in the making of a firearm subject to NFA controls, and may lawfully be added to your pistol without changing its GCA classification.

We thank you for your inquiry and trust the foregoing is helpful.  

Firearms Technology Branch

Someone should ask them to define "angle" and "vertical".  BCM makes some nice gangster grips that aren't quite vertical (and are fantastic)...

Thought I'd post what I received back in regards to using the Magpul UBR's receiver extension / buffer tube on a pistol.  The areas highlighted in red are the actual questions asked and answered.

I'm tempted to write the ATF and ask if a "wire support brace" for an M-231 PFW attached to an AR pistol would make it an SBR.  I'd roll for 50/50 that I'd get approval.

MAybe I should develop and market an adjustable arm brace, like those that have been found legal by the ATF.  For people with longer forearms.

Excellent idea.

Wow this is confusing!! Here is my scenario:

I have several stripped lowers that have "NEVER BEEN ASSEMBLED AS A RIFLE" or any other configuration. They have remained in the stripped, unassembled state since purchased, a few of them were bought years ago. I've been building ar15's for 20 years but never really cared for the "pistol" config. Until now...

I know all of these lowers are noted on their respective 4473 as "rifle". My confusion is, since they have never been assembled as a barreled rifle action, does the 4473 disqualify them from being built as an ar15 pistol, without a stamp?


Disregard, I found what I needed to know.

What did you come up with?

Like anything else regulated by .gov, there is once again blurred lines deviding the gray area.

Gotcha.

I have thought about this as well, I mean if my kids want to shoot my pistols, the brace will not fit them the same way it would fit on my arm, this is definitely an issue which needs addressed. On another note, I just wrote to ATF to inquire about another issue I was having which I have solved by creating a device which takes care of it. Stay tuned...

I emailed the ATF, could I request a written letter upon response? or should I physically mail a letter and what is the correct mailing address and who to make it out to?

You should mail a paper letter . I am not sure why but in the ATF bureaucracy they seem to work better . You will get a written response . Mail to the ATF FTB , firearms technology branch . Good luck

The link to this is dead and the only other copy of the "standard buffer tube" letter is a pretty poor scan.  Anyone have a link to the actual pdf that can be posted?

Download link: Here

OUTSTANDING!!

Thank you Sergeant Bradley.

Those Sig braces looks funny on my pistol, but I like it.

Thank you ATF, sorta.

http://www.gunsandammo.com/files/2014/04/S72-LEGAL-B1404030900021.jpg

does anyone have a letter or know right off: if I have an ar pistol, and a concealed weapons permit, could I actually carry my 8.5" cmmg 300blk as my carry pistol. I know I wouldn't do it as it weighs entirely too much and im partial to my springfield xds, but it makes me curious...

This isn't something that the ATF would issue a letter on, because it doesn't deal with federal law.  Your state may have its own definition or restriction on the type of firearm that may be carried with a license, or they may not, in which case it would be treated like any other pistol under the law.

In TX, I could carry my AR pistol with my CHL if I wanted to, but I would have to follow all of the same restrictions as when carrying a glock or XD, and somehow devise a way to carry it without obviously printing.  Seems kind of silly when I could legally open carry a 16" rifle instead, but there you have it.

Yep, State laws. Let's not bother them with things far outside their jurisdiction (we must first educate ourselves and know what law we are looking to clarify before we seek an opinion (as stated in another thread, the BATF is not "Dear Abbey").

Does anyone have the atf letter on vertical grips on ar pistols with overall length greater than 26 inches?

Start at the top of page 3.

Okay, after doing pretty extensive research in many different areas, I just wanted to be sure I am properly interpreting federal law in regards to VFG's on an AR 'pistol' or similar. If the 'pistol' exceeds 26" as measured from the rear of the buffer tube to the muzzle of the barrel, it is no longer classified as a pistol, but rather a firearm. It therefore would also not be considered an AOW, again due to it's overall length. It would then be legal to add a Vertical Forward Grip to the rail of said 'firearm' and still be in compliance with BATFE regulations?

Pretty much correct...

 

Agree.

Check your local regulations too.

I live in MD, not even going down that road LOL, but VFG are not an issue with state law here, only federal laws. Good to know.. my 'firearms' will become a bit more usable now...

has anyone seen any letters that apply to a more "generic" AFG instead of specifically the Magpul AFG? For instance the Strike Industries Cobra.