Sent this via email to ORF earlier today. Thought I'd share here:
Hi. My name is Michael Branson, I'm an attorney in Kansas City, Missouri. I'm very excited about some of the things ORF is planning to do now that some of our gun rights have been restored. You may have seen me posting on the AR15.com message boards under the moniker "Duke Nukem". I had an idea yesterday that I'd like to share with you.
I'm very impressed with the craftsmanship and attention to detail at ORF. I'm also impressed with the can-do attitude. I know that when ORF begins to build Mp5/HK94 type rifles on their own receivers that they will be the best of their kind on the market (ok, considering the competition, maybe that isn't saying much, but I'm trying to butter you up here!). I plan to be one of the first in line, with cash in hand, when your plans come to fruition.
I intend to buy an ORF Mp5 type and submit the paperwork to register it as a short-barreled-rifle soon thereafter. As you know (and actually describe on your website!) there are two ways to SBR an Mp5 clone: 1. cut the existing barrel and re-crown it, or 2. pull the barrel, put an honest-to-gosh Mp5 barrel in the trunion, reweld the receiver and refinish the entire firearm. Obviously the second method is more "correct", more time-consuming, and more expensive. In effect, you are building the gun not once, but twice.
Thus the first part of my idea. You've seen the Special Weapons SP89 type pistols, sold without a forend to avoid AOW status. Abominations! However, if ORF were to build an SP89 type, classify it as a pistol, and sell it with the short barrel already installed, I could do the paperwork for SBR and when the paperwork came back, I could then simply add on the necessary folding stock and forward pistol grip and presto change-o, a semi-auto Mp5k PDW, no expensive gunsmithing required!
The second part of my idea followed quickly. If we could do this with an SP89 type, why not sell a special "SBR package" full size Mp5 with a buttplate and no forend, and the correct Mp5-length barrel, and classify the firearm as a pistol? The 50oz rule preventing such a gun from being classed as a pistol is no longer in effect as of, well, today! The user can then keep the firearm as a big-ass oversized pistol for as long as he wants to. Then, when BATFE paperwork arrives, the user just faxes a copy of his paperwork to ORF, who sends the user the necessary stock and forearm to complete the package.
There are only two problems with my idea that come to mind:
1. U.S. parts count under 18 U.S.C. 922(v), otherwise known as the '89 import ban. If you are selling guns without furniture in order to avoid AOW status, you can't use that furniture as US parts for the purposes of the import ban. So you'd be looking at 2 extra U.S. made parts necessary to build an Mp5 "pistol", assuming all the furniture on the guns is usually U.S. made.
2. ORF could simply build SBR type rifles from the get-go, and avoid this complicated arrangement altogether. The disadvantage being that customers would have to wait for the serial-number-specific paperwork to return from BATFE before the SBR could ever be shipped to them, so a gun-hungry fella would be seperated from his cash months before ever seeing his product. Hmm... how long does the SBR paperwork usually take to get back?
I understand that this SBR idea may be unecessarily complicated and there might be some kind of block to it that I'm missing entirely. I can't help it, I think like a lawyer! Please let me know what you think of my crazy idea. --Michael Branson / "Duke Nukem"