After a few weeks of contemplation and discussion with (who I thought was a freindly FFL) I am now getting a bit of a run-araound.
It is based on the markings on a lower, specifically the word PISTOL to signify that this was transfered in and sold as a PISTOL for later un-knowledgable persons to not have a problem with it in PISTOL configuration during a roadside stop or just a check if and when some other ass-ault weapons ban type law comes into play.
I have yet to find a manufacturer that will mark a lower with the words PISTOL (except for Bushmaster on the Carbon 15 Lowers of their PISTOL and I believe Oly on their OA-93's). One (CMMGINC.com) will transfer the lower (un-marked) to me thru my FFL and ship it just as if it was a pistol. And I did find one source that would have the word PISTOL "Laser Engraved".
The problem that has arrised is that the FFL that I have discussed this with says that since he is also a gun-smith (and he works on a plethora of federal and local law enforcement weaponry) and was informed by the BATF(E) that under no circumstances can anyone other than the manufacturer or BATF(E) themselves authorize ( Form 1 for SBR is such authorization) any marking (IE: Laser Engraved word of PISTOL) addition to the lower.
Does anyone have any information and links to rebut his statement ? Or do I need to go to the BATF(E) Tech Branch for this clarification?
This also plays along with marking AUTO on a lower for a RDIAS.