You need to check with the FFL since some don't know the actual issues and think that it does actually need the bullet button.
A lower is not semi-auto, nor center-fire, so the restrictions don't apply until an upper is put on it. The same with the ban by name since that also requires it to be a semi-auto firearm.
You could make it into a bolt action, pump action, single shot, etc., as well as making it into a rimfire.
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