Someone posted this in response to my questions about the requirement to mark your name/location on your SBR/SBS.

hkpro.websolv.com/ubbthreads/showflat.php?Cat=&Number=330999&page=0&view=collapsed&sb=5&o=&fpart=1

This is how I'd been interpreting things, and it seems that the NFA Chief agrees.

Good news, good to have a letter!

Wow, very good news as I've been giving a lot of consideration to SBRing my AR.  Did you cross-post this in the NFA sections of arfcom?

What still isn't clear is if you have to get a stripped receiver engraved if you use it to build a SBR.
The letter from Ken Houchens addresses existing, complete rifles.

Now, logic would dictate the following:

 * The receiver is the rifle for BATFE purposes -- it carries the makers name and serial number.
 * Build a rifle with that lower and it is then an exisiting rifle (matching what Houchens letter addresses).
 * So, no need to engrave when converting this EXISTING rifle to SBR form.

But I know how dangerous it is to apply logic to the law, and even more so to the unwritten rules of the BATFE.

hmmm

Quoted: Wow, very good news as I've been giving a lot of consideration to SBRing my AR.  Did you cross-post this in the NFA sections of arfcom?

Here's the thread I started in the "American Class 3 Association" forum here, which is where I received that link as a response:

www.ar15.com/forums/topic.html?b=6&f=17&t=194772

Quoted: What still isn't clear is if you have to get a stripped receiver engraved if you use it to build a SBR. The letter from Ken Houchens addresses existing, complete rifles. Now, logic would dictate the following:  * The receiver is the rifle for BATFE purposes -- it carries the makers name and serial number.  * Build a rifle with that lower and it is then an exisiting rifle (matching what Houchens letter addresses).  * So, no need to engrave when converting this EXISTING rifle to SBR form. But I know how dangerous it is to apply logic to the law, and even more so to the unwritten rules of the BATFE.

It is quite confusing.

There's a few different ways to look at things.

Technically, as I understand things, since a receiver isn't a complete rifle, i.e., no excise tax has been paid on it, it's not "really" a gun, if you build an AR from a stripped receiver, you'd technically be required to engrave your name and location on it, since you're "making" a rifle.

But, then again, if converting an existing rifle to SBR, you're "making" another rifle, so engraving is required.

Or, since the engraving is already done on these receivers, you don't have to do anything.

I'm not going to worry about any engraving requirements on Title I firearms.  Do you know of anybody that engraves their information on a rifle they build up from a stripped receiver and kit form?  Neither do I.  Regardless of how I read the law above, I don't believe that we're required to do such a thing (hence, the keyword "technically").

Along with that, now there's no requirement to do so with an existing rifle/pistol/shotgun that you wish to convert to SBR/SBS form.

Schweeeeet.

Kythri, I think you're reading into it a bit much.  It's pretty clear cut in the letter unless it's read Tuesday night by a candle.   If so then you might need to look at it in a mirror and see if it's different.  

Now are you as confused by my post as I was with yours?  



Just pickin on ya

I doubt you'll have any issue with a factory marked lower if you have paperwork in hand.   In any case it would be a minor technical violation and damned hard to get a conviction even if you were in the wrong.   A "reasonable person" would believe that letter to say you dont have to mark it.  
I'm planning to SBR a spare bushmaster lower I have lying around.   It was purchased as a "stripped receiver" on the 4473.

Quoted: Kythri, I think you're reading into it a bit much.  It's pretty clear cut in the letter unless it's read Tuesday night by a candle.   If so then you might need to look at it in a mirror and see if it's different.   Now are you as confused by my post as I was with yours?   Just pickin on ya I doubt you'll have any issue with a factory marked lower if you have paperwork in hand.   In any case it would be a minor technical violation and damned hard to get a conviction even if you were in the wrong.   A "reasonable person" would believe that letter to say you dont have to mark it.   I'm planning to SBR a spare bushmaster lower I have lying around.   It was purchased as a "stripped receiver" on the 4473.

I guess its  good thing i always list my stripped lowers as "pistol" when I do the 4473.

We will see. I hae a form one ready to go in this week.
CH