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1/22/2017 11:20:43 AM EDT
Pardon me if this is a stupid question but I don't fully understand 922r. Say you have a German HK that you want to have a paddle mag release installed or you just want the existing barrel sbr'd. Not both but just one or the other. Does the smith then have to install the allotment of 922r parts on your German HK?
1/22/2017 11:52:24 AM EDT
[#1]
Quoted:
Pardon me if this is a stupid question but I don't fully understand 922r. Say you have a German HK that you want to have a paddle mag release installed or you just want the existing barrel sbr'd. Not both but just one or the other. Does the smith then have to install the allotment of 922r parts on your German HK?
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What specifically is the German HK you're referring to and what is its current configuration?
1/22/2017 12:11:47 PM EDT
[#2]
If you are just having a paddle mag release installed then no, as you are not "creating" a new firearm.

But if you are filing a form 1 to make an SBR then you are "creating" a new firearm that must comply with 922r.
1/22/2017 12:40:16 PM EDT
[#3]
922r applies to whomever is assembling the weapon, not merely the current possessor.
1/22/2017 1:33:14 PM EDT
[#4]
Quoted:
Pardon me if this is a stupid question but I don't fully understand 922r. Say you have a German HK that you want to have a paddle mag release installed or you just want the existing barrel sbr'd. Not both but just one or the other. Does the smith then have to install the allotment of 922r parts on your German HK?
View Quote


These questions have never made it to an Appeals Court for a clear ruling. On top of that, 922r is so poorly worded it is moots itself with literal reading. So you are likely to get a lot of opinions. And then there is enforceabililty, how exactly do you know where the parts you are using were made.
1/22/2017 6:08:22 PM EDT
[#5]
It depends on which HK, If you are talking a pre import ban 91/93/94 then no it doesnt apply at all. 922r is concerned with imports... and applies to things built or imported after the 1989 Import ban.
1/25/2017 6:06:21 PM EDT
[#6]
922r for SBR's wasn't a thing until the umpteenth millionth jackass had to write yet another letter to ATF at which point the law of averages kicked in and someone there finally said yes.  I wish ATF charged $200 to answer letters.
1/25/2017 6:33:53 PM EDT
[#7]
Quote History
Quoted:

What specifically is the German HK you're referring to and what is its current configuration?
View Quote

Hello......?

So what is it? Care to participate in your own thread OP?
1/25/2017 7:41:31 PM EDT
[#8]
Quote History
Quoted:

Hello......?

So what is it? Care to participate in your own thread OP?
View Quote


Based on his other thread here, my guess is an HK94.
1/25/2017 8:14:33 PM EDT
[#9]
Quote History
Quoted:
It depends on which HK, If you are talking a pre import ban 91/93/94 then no it doesnt apply at all. 922r is concerned with imports... and applies to things built or imported after the 1989 Import ban.
View Quote
922r actually applies to anything assembled after it was enacted. There is no "grandfather" clause. A firearm could've been imported in 1966, but if "assembly" of said firearm occurs today using its imported parts, it would trigger 922r. Personally, I care so little about 922r that I almost didn't post this. 

I agree with everything RenegadeX posted. Enforcement is almost non-existent, because 922r is almost completely unenforceable. The critical thing to remember when considering 922r is that possession is not the violation; assembly is.

There is an ATF opinion letter floating around which states that if shortening the barrel (after SBR Form 1 approval) is the only modification to an imported "sporting" firearm, then 922r does not apply, because they do not consider merely shortening the barrel to be "assembling". So that answers one of the OP's questions at least.
1/25/2017 10:08:15 PM EDT
[#10]
As far as I know, no one has ever been charged let alone prosecuted solely for a 922 violation.  The few cases have been add-on charges during prosecution of other more serious crimes.
1/25/2017 10:21:27 PM EDT
[#11]
Quote History
Quoted:

Hello......?

So what is it? Care to participate in your own thread OP?
View Quote


Sorry, been busy...it's an HK 94, actually 2 but I'm thinking it wouldn't be wise to convert 2. One of them is definitely going to IGF to become an MP5 N. The way I understand it now is if IGF does the entire conversation and you opt for a pinned fake suppressor instead of having them SBR it and file  
a form 1 for you. It's legally not a "new" weapon. You get it home file your form 1 with your restamped MP 5 N model and get your stamp and have pin removed on fake suppressor and you've got a German HK (except for paddle release) ...I could be totally wrong so feel free to correct me.
1/25/2017 11:06:42 PM EDT
[#12]
It isn't about it being a "new" weapon. 922r is about "assembly" (from imported parts). The other production-related legal terms frequently encountered in ATF land are "making" and "manufacturing".

The latest wisdom from ATF is that SBR status doesn't change anything regarding 922r. Neither does shortening the original barrel.

What will be done in the conversion? If they shorten the original barrel, thread it, add a 3-lug, add a fake can, pin and weld same, install a paddle mag release, re-mark the model, and refinish, then did they "assemble from imported parts..."? That's the 922r question.

What about building-up the sear trip, and adding tungsten granules inside the bolt carrier?

These are all questions I don't believe ATF has answered, and I wouldn't be one to ask them either.

It really doesn't matter what the answers are, as far as you're concerned, since you won't be doing the assembly. When you get it home, Form 1, engrave, and remove the fake can, then you'll just be removing a part. There's no precedent I'm aware of that omission of a part could constitute "assembly", so you're in the clear. You're just a happy owner doing the possessing. 922r doesn't outlaw possession of anything.

The paddle mag release might as well be German, if all the other parts still are. I'm not aware of a German thread-on 3-lug, unless they turn one from an existing 3-lug MP5 barrel, which would make it one very expensive part! 
1/25/2017 11:44:19 PM EDT
[#13]
Well that clears up the fog some. I'm late very late to the HK roller lock & clone etc game. The guns have all always intrigued me since I was a kid. Just glad to finally be in possession of a few. thanks for the clarification
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