Quoted:
You guys do what you want. I will listen to the person who approved my form 1. Also to answer posters question no there is no wait. Just send in the letter that the ATF requests. People are correct that this is not an absolute requirement but many ATF agents are not sure of the requirement. I choose to cover myself and put in a simple letter stating my intent to use additional uppers.
Also you don't even need to own the original upper configuration. You just have to put it back that way if you sell gun as complete rifle.
.02
Of course you can do whatever you like, just don't call it a requirement. That's my biggest issue here. And again, you don't need to be able to return to the original configuration. Nothing in law, regulation or even internal procedure conforms to this, so this should give you a moment of pause before accepting it as fact from an examiner, SOT or anyone else. While I agree examiners occasionally put applications into problem status for this, a phone call, with 100% efficacy, will resolve this and get your application back into processing.
You have to understand that examiners are not gun people nor do they know the law very well. They process paperwork, that's all. Most of them could not tell the difference between an M16 and an MP5. To rely on their advice, even for procedural or administrative issues, let alone legal, is silly. If something doesn't sound right, then push them to explain or talk to their supervisor.
ETA: I don't mean to suggest that this is some sort of illegal regulation coming out of NFA Branch, not at all. This is almost entirely a customer-side myth. 99% of transfers involving mismatched configurations are processed as-is without a hitch because that's the law. One in a hundred is flagged for some clerical error or misunderstanding, but again, this is cleared up with a simple phone call, not with letter writing and certainly not by following their erroneous instruction.