Any one know the actual ATF location of what is "legal?"  Is there a searchable PDF on that topic?  Like what can be repaired and what can't   I know there are a lot of opinions, I just want to read it.

I know its all subjective to interpretation, but I would like to read it.

Edit:  I've been searching but can't find what I am looking for.

I don't even know that such a thing exists. From what I've always heard and been told is that as long as the original sn and makers information is left in tact you are good to go. And of course not taking a mac11, cutting away everything and welding the sn and makers info on a 249 or something. But for like an M16 which is what I'm guessing you mean by RR lots of things could be fixed on it if you had a kaboom and blew up the lower. To a point of course.

From what I've read on the internet, virtually every Olympic Arms made "M16 pattern" RR has been to one shop or another to be repaired into mil spec so that it could actually be used with mil spec parts.  The 100 or so Group Industries stainless steel M16 lowers were also notorious for needing tweaking - usually for overly tight magwells.  

MHO, YMMV, etc.

Clearly putting a MAC serial on a 249 has been done and has resulted in jail time.  The ATF made a ruling on that.

How much of the RR can be repaired before most of the metal is replaced?  I don't know, just what I've read from what someone else has told them.  

I only want to read the ATF guidelines.  The more I look the more I think the guidelines don't exist.  I believe they are completely ambiguous just to keep gun owners in a perpetual state of uncertainty.  The more I read and search the more I am disgusted.  There is a reason I am interested in this.

I have seen the de-milling pictures for various machine guns.  It was a dry read.  That language is very precise on cut placement.  Example, if the serial number is completely cut from the receiver it is still considered a registered receiver, because it is NOT demilled according to the guidelines.  From that it can be repaired.  All the material around that could technically be replaced.

Everything else is kinda non existent.  Example take a registered receiver and transfer the serial to a new receiver and destroy the old one.  I have read that is completely illegal, or is it?  Olympic Arms and Colt used to do it (or so I have read).  Then they stopped.  Was it illegal?  Or frowned upon?  Was it not profitable?  If it was illegal then the ATF would have gone after the owners of those receivers.  Never read they didn't.

Reason for my question.  I have always understood that once you have a suppressor, the caliber of the suppressor can NOT be changed.  Example a 9mm suppressor can NOT be converted to a 45 caliber suppressor.  Everyone thumps that bible.  Now a major suppressor manufacturer is doing just that.   I know suppressors fall under different legal verbiage than receivers.  Its just that I've read that so many times, that I took it for being true.

People say the "original" manufacturer can make those changes.  Is the word "original" actually in the ATF language?  Thats just something I have read.

I'm not advocating anything, just want to read it.  For the record I bought an Olympic PAWS receiver from Tony_K, it works fine.  I don't require any modification of it.

Thing about the ATF language is that the rules are open to interpretation and then the interpretation can be reviewed and changed.  

Edit:  To be clear, I'm asking for where I can read more on it.  I have found dozens of opinions, but I can't find what those opinions are actually based on.

I remember that there was a ruling by the BATFE during the assault weapons ban that a manufacturer could replace an entire receiver of an AR-15, using the same serial number as the destroyed serial number as part of a warranty replacement. I remember it because there were instances where someone had a weapon break and Bushmaster replaced the receiver with the old serial number. The Brady Bunch shit a brick over this because they were counting on guns breaking over time to help reduce the number of "assault weapons" in civilian hands, and the BATFE ruling shot that hope right in the ass.

I don't know that this applies to NFA weapons or not.

Apparently you can still do this with non NFA receivers.  I don't know if it is time or money efficient to do so.  Sometimes its not a matter of the antigun lobby, sometimes its just a matter of economics.  Clearly being able to replace a registered receiver is cost effective to ME, but probably not to Colt, Olympic Arms, etc.

Edit:  I thought I submitted this response, but I did not before Tony_K.

So, is the repair of NFA machine guns a gray area?  Clearly its not manufacturing, clearly the repairs are new.

I was afraid of that.  In the reading that I have done, nothing is really consistent.  In that, my questions along this line of thinking are mostly answered.  However, I come away from it even more upset.

Another thing that is quite upsetting in the gun culture (couture if you know what I mean) is the repetition of an opinion without reference to a credible source.  You know what I mean.  I am glad that I looked into this just for my edification.

Here's how I would handle it -

I would restrict my repairs to what a jury of 12 dingbats would reasonably consider a repair.


A lot of times you'll see people quibbling over the language of the gun laws, but at the end of the day what counts is getting ATF to agree with you, and if that fails getting a jury to agree with you.

People think that a gray area is their friend but it's actually not.  Gray areas are what make lawyers rich, not you.


Like for example, if your state says that guns must be transported in a locked case, then you buy a stout gun case and put a big fat padlock on it.

No policeman or jury member is going to look at your case with a padlock on it and be able to deny that it is a locked case.


I think the acid test would be the statement:

"The gun had XXXX damage, so I had YYYY done to fix it."

How could anyone argue with that?

While you are correct if the ATF disagrees and files criminal charges, they also have the option of seizing property under administrative charges where the burden of proof is different.  Under administrative law, the burden of proof will be for you to prove compliance with their regulations.  No jury involved.

Back in 2007-2008 time frame, AAC and GemTech got into an online pissing match over manufacturers making "repairs" to suppressors built by other manufacturers. IIRC, it resulted in some fairly strict guidelines coming down from BATFE. At the time, AAC was hosting a contest wherein owners of other manufacturers' cans would submit a photo and AAC would pick a monthly winner and then rebuild the winner's can so that it had the same baffle design of a similar AAC can. With almost alarming regularity, it seemed the winners were always GemTech owners. In affect, the contest winners were disposing of their old cans and getting a different one, with the same manufacturer, model, and serial number as the one they already owned. BATFE determined they were taking possession of a different can and AAC had to stop the contest.

I always enjoy your knowledge shared here Tony.  I hope this is not a hijack but what is your opinion on the origin of the NIB with post 86 manuals, Black anodized M16A2s that showed up at a well known dealers site last year. I was under the impression that they were "replacements".

Actually the AW Ban statute 922 (v) reads almost exactly like the Machine Gun Ban 922 (o).

I.E. it bans it, then says it is OK as long as it was lawfully possessed before the effective date of Enactment which was September 14, 1994.

922
(v)(1) It shall be unlawful for a person to manufacture, transfer,
or possess a semiautomatic assault weapon.
‘‘(2) Paragraph (1) shall not apply to the possession or transfer
of any semiautomatic assault weapon otherwise lawfully possessed
under Federal law on the date of the enactment of this subsection.

If I recall correctly, ATF has ruled it is OK for a licensed manufacturer to replace the receiver of a registered machinegun as long as it is actually the same company that registered it.  

Where Olympic Arms got into trouble was it was replacing receivers of machineguns that they themselves had manufactured in Semi-Auto configuration but PAWS a separate company, had drilled the auto sear hole and filed the actual Form 2. Or was replacing receivers registered by SGW their predecessor.

Now keep in mind just because a manufacturer uses the same trade name doesn't mean it is the same company in the eyes of the ATF.  For example, I believe Strum Ruger would qualify to replace the receivers on an AC 556 because they have continuously been in business and held an SOT since the time of the registration.  But a company like Colt who has gone through multiple reorganizations would NOT be eligible to replace a damaged receiver with the same serial number due to the fact the company has not been continuously in business since the receiver was manufactured.

To answer safetyoff's question about the NIB Colt M16A2's, I personally believe they are replacements, I wouldn't touch one with a 10 foot pole if it was my money.

I think they are one ATF ruling away from being confiscated as contraban and the current owner left holding the bag.

Of course I think the "New" rebuilt Oly Arms receivers are in the same boat.  So far ATF has let those slide, but they could change their mind at any time and declare them all Post 86 samples and confiscate them with no compensation to their current owners.

Mine has not been worked on.

There are still quite a few out there that have not been worked on, mine was not.

But is becoming more common. A decade or two ago when MGs were still "Cheap" it didnt make sense to pay someone $500-1000 to work on a oly arms lower that was out of spec, you just take than money and upgrade to a colt. But now with non-colt RR running close to $20k and Colt RR around $30k, buying a out of spec oly and having it worked on is a great way to save some cash especially if youre just looking for a shooter or trying to get into the M16 world on a budget.

I don't own any of those guns that came on the market last year, but I followed the auctions with interest and examined some of the guns in person.

The ones I saw had A2 receivers.

I would repair it, never post anything on net, and never tell anybody.

Funny concept, but I am old school.

I have two of them.  One has been worked on and one has not.

The older of the two pretty much takes normal uppers at this point as I think a decade of shooting it has slowly worn down any high spots on the receiver.  The mag well is a bit tight and doesn't drop p-mags free.  Regular USGI or E-Mags are no issue.  Never really concerned me since I have never really been a pmag fan.

The other one just had the top of the receiver shelf milled by a couple thousandths and the front take down lugs widen a smidge as well.  The mag well was fine out of the box.

I don't see how the traditional Oly "bring to spec" type "repair" could in any way be construed as remanufacturing a post sample when you are talking about removing a thousandth or two from a bearing surface.

OP what do you need to have repaired on your Oly?

I examined several of those guns in person and they looked absolutely legitimate.

If there was anything "replacement" about the guns or on the guns, it was not detectable.

It pays to be wary, but it doesn't pay to see a something wrong when it's not actually wrong.

where's the challenge in that?

Seriously, not everyone does their own repairs.  So unless you plan on killing the gunsmith after he does the repair, then there is a potential that the repair would become known to whoever.


I'm not sure exactly what the OP is referring to when he says "repairs".

Has ATF ever dropped the hammer of doom on anyone for repairing a crack or re-machining some out of spec holes?

I would bet you dollars to donuts that the only things ATF is worried about is people morphing MAC10s into M60s or similar hokus pokus.


Why would they care if you get your M11/9 refinished and rewelded?

It's not our fault that a lot of these guns were slapped together by people who couldn't weld or use a drill press accurately.

How about when you have an FNC machined to take a FA sear, they are literally converting the lower on the gun from SA to FA.  But ATF officially doesn't care.

No need to whack the gunsmith. Just no need to blab all over the internet and invite scrutiny. How did that work out for the GemTax?

Well of course.

Telling someone that you're doing something definitely increases the odds that they will find out.

On the other hand, when a bunch of gunsmiths are openly and even famously making a living repairing MGs, the cat's out of the bag already.


In the 1970s, Numrich had some reverse-engineered Thompsons made called "West Hurleys".  They have a number of dimensional problems, particularly the blish lock slots.

So there are several guys who actually install a big steel sleeve and machine new slots.   If that doesn't count as a major repair, then nothing does.

This repair has been discussed openly for decades.


I think this thread is kind of paranoid, just seeing a boogeyman under the bed.

Show me where it says anywhere that you cannot repair a gun.

You are one who started the paranoia - if it is so obviously legal, why are you worried about defending it in court?

CC me on that.

The most current rulings I have seen, which now apply to all firearms, is the serialized component cannot be replaced with same once the unit leaves the MFG area.

Tony.  After looking around I have to admit you were right.  After the Olympic Arms exchanges were shut down it appears the BATFE issued a ruling that machinegun receivers could not be replaced, only repaired.

I still maintain that before this ruling manufacturers were able to replace receivers on an exchange basis as with any other firearm, I think what attracted the ATF's attention was the fact that OLY was replacing ANY OLY registered receiver regardless of who had actually registered it.  This I understand would not be allowed as they were not the original manufacturer.

Aside from Colt and Ruger, whose procedures/policy for receiver replacement was well known, what other "manufacturers" are you talking about?

Olympic would replace any of their lowers that where converted by other companies. Most(if not all) Olympic M16's where actually registered as MG's by a third party SOT like PAWS or Weapon Specalities. So when Olympic started replacing old M16 lowers that where built on one of their receivers they were engraving someone else's info like PAWS on it, which as far as I'm concerned is breaking the law. Sure it was their lower that was a host, but they weren't the one on the F2. That's why I wouldn't suggest anyone touching a new billet oly M16 lower with a 10' pole. I'd be worried they are one ruling away from being contra ban.

I'm familiar with the Olympic thing.......it was never kosher to begin with......my question to Bighunt was can he name a domestic MG manufacturer (not "convertor") that had any type of receiver replacement/exchange program other than Colt or Ruger.......and if so.....what was their policy/procedure???? If he maintains this was was actually done, what is this based on?

I am simply stating that published federal rulings by ATF had long allowed any firearm receiver Title 1 or Title 2 to be replaced with the same serial number by the original manufacturer. This is what Oly claimed they were doing. When in fact they were not the NFA manufacturer of record on the registry. After the Oly incident the ATF clarified the ruling to not apply Title 2 machine guns.

No rule ever said this. In fact just the opposite, Serial Numbers must be unique and never re-used. Clarification came out a few years ago it could only be done before the receiver leaves the MFG area. Once it leaves that area, it is considered made and cannot be replaced.

I thought the whole subject of the thread was the legality of repairing receivers.  Which according to certain world class experts, we're supposed to keep secret.  Because of the scrutiny of Big Brother.

Oh well, wrong again.  Cue sad music.

I knew the premise of AAC rebuilding Gemtech cans using Gemtech SNs but I ever knew it was a photo contest type thing. Thanks for the education

Do you have an insight on where I can find that ruling?   I'd like to read the original ATF statement without interpretation.