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  #201  
Old 02-19-2017, 3:59 PM
ifilef ifilef is offline
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Quote:
Originally Posted by kemasa View Post
$45 for a PPT is illegal, so it is bad. A PPT is limited to $25 for the DROS and $10 for the FFL.
IIRC, the statute(s) are quite clear that overcharging for a PPT will subject the violator to license forfeiture.

Last edited by ifilef; 02-19-2017 at 4:07 PM..
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  #202  
Old 02-19-2017, 4:50 PM
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Originally Posted by ifilef View Post
IIRC, the statute(s) are quite clear that overcharging for a PPT will subject the violator to license forfeiture.
And how often have you seen that happen?
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  #203  
Old 02-19-2017, 4:54 PM
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Quote:
Originally Posted by kemasa View Post
And how often have you seen that happen?
I can't competently answer that question but would encourage a call to the DOJ whenever someone encounters such PPT overcharging.

I believe there's an additional statute that requires FFL to post signage indicating lawful charges for PPT.

Later: Found this statute re signage:

"26875.
A licensee shall post conspicuously within the licensed premises a detailed list of each of the following:
(a) All charges required by governmental agencies for processing firearm transfers required by Section 12806, Chapter 5 (commencing with Section 28050), and Article 3 (commencing with Section 28200) of Chapter 6.
(b) All fees that the licensee charges pursuant to Section 12806 and Chapter 5 (commencing with Section 28050).
(Added by Stats. 2010, Ch. 711, Sec. 6. Effective January 1, 2011. Operative January 1, 2012, by Sec. 10 of Ch. 711.)"

See, also, FAQ #20 here: https://oag.ca.gov/firearms/dlrfaqs#20G

Controlling statute re over-charging:

"28055.
(a) For a sale, loan, or transfer conducted pursuant to this chapter, the purchaser or transferee or person being loaned the firearm may be required by the dealer to pay a fee not to exceed ten dollars ($10) per firearm.

(b) No other fee may be charged by the dealer for a sale, loan, or transfer of a firearm conducted pursuant to this chapter, except for the applicable fees that may be charged pursuant to Sections 23690 and 28300 and Article 3 (commencing with Section 28200) of Chapter 6 and forwarded to the Department of Justice, and the fees set forth in Section 31650.

(c) The dealer may not charge any additional fees.

(d) Nothing in these provisions shall prevent a dealer from charging a smaller fee.
(Added by Stats. 2010, Ch. 711, Sec. 6. Effective January 1, 2011. Operative January 1, 2012, by Sec. 10 of Ch. 711.)"

Last edited by ifilef; 02-19-2017 at 11:18 PM..
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  #204  
Old 02-19-2017, 5:11 PM
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Quote:
Originally Posted by kemasa View Post
And how often have you seen that happen?


I can't name one.
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  #205  
Old 02-19-2017, 5:28 PM
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Originally Posted by kemasa View Post
And how often have you seen that happen?
Never heard of any dealer getting into trouble over this either.
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  #206  
Old 02-19-2017, 5:36 PM
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Never heard of any dealer getting into trouble over this either.
Which is probably why there's folks that charge more.. they pretty much know the DOJ isn't going to enforce anything...
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  #207  
Old 02-19-2017, 6:27 PM
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Originally Posted by ugimports View Post
Which is probably why there's folks that charge more.. they pretty much know the DOJ isn't going to enforce anything...
Yeah, while the rest of us dealers are trying to eek out an honest living, and doing everything in our power to understand & abide by the different laws and regulations..
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  #208  
Old 02-19-2017, 11:05 PM
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Originally Posted by Addax View Post
Yeah, while the rest of us dealers are trying to eek out an honest living, and doing everything in our power to understand & abide by the different laws and regulations..
Yeah, because if I were to ignore the law then I would be the one that the DOJ decides to make an example of.

I have no problem witn people reporting violations, but they should not expect much.

I did once get a nasty phone call from the DOJ because a TX FFL complained that I would not deliver some firearms to his customer, which surprised me since it was none of their business. When I explained the sales tax evasion issue, things changed quite a bit.
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  #209  
Old 02-20-2017, 12:44 PM
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Originally Posted by ifilef View Post
I can't competently answer that question but would encourage a call to the DOJ whenever someone encounters such PPT overcharging.
I am not saying not to do that, but I suspect that the most that will happen is that the FFL will get a phone call. I would not even bet on a phone call though.

Quote:
I believe there's an additional statute that requires FFL to post signage indicating lawful charges for PPT.
Quite true, but there is also a sign on the freeway with the speed limit, but that does not mean everyone or even a majority of people who violate it get a ticket. I have never heard of a FFL getting in serious trouble for violating the law with respect to PPT fees. Perhaps it has happened, but I would have thought that it would get mentioned. Now, I am not going to violate the law just because others get away with it, for several reasons.
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  #210  
Old 02-23-2017, 8:08 AM
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I'm located in La Mesa/San Diego (91942) and can drive 25ish miles to an FFL. Looking for someone who will receive and DROS a CZ-SP01 to me from a out of state FFL.

The odd ball is that the CZ-SP01 comes with the high-cap magazines. I've heard of gun stores keeping the mags and DROSing the gun which is what i prefer. If not, i could ask the seller FFL to remove the mags and send the gun. The CA Roster calls out the SP01 by SKU (01152) which is the low capacity version. The standard capacity version is (91152). I do not know if that would cause issue. I know of San Diego Guns selling a (91152) without mags so i'm assuming its acceptable but i would like to try out Calguns first before calling.

Many Thanks!
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  #211  
Old 02-23-2017, 8:12 AM
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Ask the receiving FFL to block the mags for you. We do that for a fee ($15/mag) -- cheaper than losing the mags altogether.
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  #212  
Old 02-23-2017, 8:18 AM
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Originally Posted by ugimports View Post
Ask the receiving FFL to block the mags for you. We do that for a fee ($15/mag) -- cheaper than losing the mags altogether.
Good tip. Before i ask them, may you explain how you guys block the mags?

Also you didn't seem concerned about the guns having different SKUs, am i worrying about nothing?
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  #213  
Old 02-23-2017, 8:27 AM
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Originally Posted by rauldelga View Post
Good tip. Before i ask them, may you explain how you guys block the mags?

Also you didn't seem concerned about the guns having different SKUs, am i worrying about nothing?
Depends on the pistol. For the SP01 the 91152 is the same gun as 01152 (just mag difference). Springfield Armory 1911s, different story..

As far as how to block the mags? I use mag blocks that I rivet to the floor plate. Everyone does it differently currently. Ask your preferred FFL how they would do it. They might use a block + epoxy or block + epoxy + rivet.
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  #214  
Old 02-23-2017, 8:31 AM
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Quote:
Originally Posted by ugimports View Post
Depends on the pistol. For the SP01 the 91152 is the same gun as 01152 (just mag difference). Springfield Armory 1911s, different story..

As far as how to block the mags? I use mag blocks that I rivet to the floor plate. Everyone does it differently currently. Ask your preferred FFL how they would do it. They might use a block + epoxy or block + epoxy + rivet.
Duly noted. Thanks for the info. I'm trying my best to not scare off FFLs when i ask if they can receive an SKU "not" on the roster.

UPDATE:
I called several gun stores around and I was pleasantly surprised at how easy it is. They can still DROS the gun but will keep/toss the mags (except for honey badger firearms).
As of 20170223 FFL transfer fees (add tax to all)
Socal Gun = 75 + 28.50 DORS
San Diego Guns = 40 +25 DROS
Honey Badger Firearms = 50 (this is the only one that can guarantee block mags 5 bucks each) + 25 DROS
Chula Vista Gun Store = 30 + 30 DROS
Royal Loan = 90 + 25 DROS
American Shooting = 100 + 25 DROS
Gusslers = 45 + 25 DROS

I'm choosing between San Diego Guns / Honey Badger Firearms / Chula Vista Gun Store / Gusslers.
Note, all of the above offered excellent customer service over the phone and answered all my stupid questions.

UPDATED 2:
I've decided to go with Honey Badger. They mag block the 18 rounders to 10 rounders for 5$ each which brings the overall price of the CZ to the lowest of the bunch. No other dealer offered that service. MagCar mags are going for $22.50 on ebay right now so I added $45 to the final price for other dealers. San Diego Guns and Chula Vista Gun Store total was $803 and $799 respectively. Honey Badger would be $779. Note, SDguns and CVgunstore were cheapest at $755 each but the additional cost of me buying mags bounced them above Honey Badger.
Now, I could just wait till the CZ's are in stock in san diego, however most gunstores price them above $690 retail so after taxes and fees im looking at $770 at best. I'm just too impatient and would spent a few bucks to get it now.
Special thanks to the users who helped me. I did not know magblocking was a thing and specific requirements to ship into CA.

UPDATE 3:
I called Honey Badger asking about the process of ordering a gun online. They said to have the FFL contact them and thats about it. All my contact info will be given to them by the seller and they'll call me when the gun arrives to start the DROS. I called the gunbroker seller and they were also very helpful. Gave them Honey Badgers contact info and they said they would take care of it. At first he was concerned they can't ship the gun with the mags and said they could remove the mags. He also tried looking to see if they had a 01152 model to save me some money. After explaining honey badger will pin the mags the gunbroker seller was happy to accept payment and ship the gun with mags. Overall great experience. Note: I'm only logging this info here because i think it may help someone else down the road, especially in San Diego area. Of the dealers i called only Honey Badger offered to pin mags to 10 rounds. This may help others obtain SP01s

Last edited by rauldelga; 02-23-2017 at 12:31 PM..
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  #215  
Old 03-01-2017, 11:31 PM
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Looking for a reasonably priced ffl close to Venice 90291. Appreciate any help.
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  #216  
Old 03-19-2017, 11:36 AM
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Any FFL in/near Williams, CA?
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  #217  
Old 04-29-2017, 5:04 PM
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Putting the word out for ffl dealer near 91352, I am in the market for a lc9s. Pm me here on my message board. Thank you
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  #218  
Old 05-20-2017, 7:04 AM
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Looking for an FFL in Stanislaus County with a decent transfer fee for my online purchases (handguns/long guns) please, thanks.
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  #219  
Old 06-09-2017, 3:40 AM
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Anybody know of any FFL's that release on a Possible Undetermined status in Socal? thanx.
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  #220  
Old 06-14-2017, 5:16 PM
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nearest ffl to cerritos/downey area?? i want to have a ca-legal pistol shipped
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  #221  
Old 06-14-2017, 8:28 PM
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Are there any 07 FFLs or others who can receive a non-compliant Kel-Tec Sub-2000 and pin the stock/add muzzle break/grip wrap for transfer to me as a compliant weapon? I'm in Orange County, so if it is possible and you are in So Cal please let me know.
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  #222  
Old 06-14-2017, 9:28 PM
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Are there any 07 FFLs or others who can receive a non-compliant Kel-Tec Sub-2000 and pin the stock/add muzzle break/grip wrap for transfer to me as a compliant weapon? I'm in Orange County, so if it is possible and you are in So Cal please let me know.
None. No FFL can do that conversion legally in California. The firearm must be compliant before entering the state.

CA AW FFL holders could in theory receive it, but have been told if they do CA compliant conversions their AW permit will be revoked.

ETA: What Baboosh mentioned below will work. Shipping disassembled has no issues because it's not an AW at that point. Any FFL can install compliance parts before it is re-assembled.
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  #223  
Old 06-15-2017, 8:54 AM
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Originally Posted by hamgun View Post
Are there any 07 FFLs or others who can receive a non-compliant Kel-Tec Sub-2000 and pin the stock/add muzzle break/grip wrap for transfer to me as a compliant weapon? I'm in Orange County, so if it is possible and you are in So Cal please let me know.
If it is shipped disassembled then yes. Also the DOJ new AW laws list specifically that if certain items are removed it is no longer a semi automatic rifle and AW laws do not apply.

If the seller is willing to help and the FFL understands the law then it can be easier to get it in without a middle man
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  #224  
Old 06-15-2017, 10:31 AM
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None. No FFL can do that conversion legally in California. The firearm must be compliant before entering the state.

CA AW FFL holders could in theory receive it, but have been told if they do CA compliant conversions their AW permit will be revoked.

ETA: What Baboosh mentioned below will work. Shipping disassembled has no issues because it's not an AW at that point. Any FFL can install compliance parts before it is re-assembled.
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Originally Posted by Baboosh View Post
If it is shipped disassembled then yes. Also the DOJ new AW laws list specifically that if certain items are removed it is no longer a semi automatic rifle and AW laws do not apply.

If the seller is willing to help and the FFL understands the law then it can be easier to get it in without a middle man
What changed in 2017 that allows CA FFLs to convert AWs into non AW's? I have been asked a lot lately to just split AR15s in half and forward to CA lately. Prior to 2017 that was almost always rejected by CA FFLs because they considered them as AW's in a state of disassembly/repair and not "un"-AW's. If I could have shipped them like that last year it would have been a much easier and faster process. I would like to get more CA FFLs on board with accepting disassembled guns but I do not know what PC to show that makes it legal to just disassemble rifles to make them legal.

If sending a disassembled AR15 is legal how is the buyer able to take possession if assembling for the safety demo turns it back into an AW if it is not converted at the FFLs premise?
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  #225  
Old 06-15-2017, 10:41 AM
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What changed in 2017 that allows CA FFLs to convert AWs into non AW's? I have been asked a lot lately to just split AR15s in half and forward to CA lately. Prior to 2017 that was almost always rejected by CA FFLs because they considered them as AW's in a state of disassembly/repair and not "un"-AW's. If I could have shipped them like that last year it would have been a much easier and faster process. I would like to get more CA FFLs on board with accepting disassembled guns but I do not know what PC to show that makes it legal to just disassemble rifles to make them legal.

If sending a disassembled AR15 is legal how is the buyer able to take possession if assembling for the safety demo turns it back into an AW if it is not converted at the FFLs premise?
The way CA DOJ has published new regulations is why this is confirmed legal now. They basically stated disassembled firearms cannot be AWs.

In regards to assembly for demo, the firearm would need to be compliant to complete that piece. However, many customers are exempt form the demo if they have a hunting license, CCW, LEO, or a few other exemptions.

We don't have an issue with split up for shipping.
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  #226  
Old 06-15-2017, 10:43 AM
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Originally Posted by audiophil2 View Post
What changed in 2017 that allows CA FFLs to convert AWs into non AW's? I have been asked a lot lately to just split AR15s in half and forward to CA lately. Prior to 2017 that was almost always rejected by CA FFLs because they considered them as AW's in a state of disassembly/repair and not "un"-AW's. If I could have shipped them like that last year it would have been a much easier and faster process. I would like to get more CA FFLs on board with accepting disassembled guns but I do not know what PC to show that makes it legal to just disassemble rifles to make them legal.

If sending a disassembled AR15 is legal how is the buyer able to take possession if assembling for the safety demo turns it back into an AW if it is not converted at the FFLs premise?
If it is disassembled then it is not an AW. What exactly would the FFL be converting? Putting a grip wrap on? That isn't even manufacturing per the ATF. Or the buyer can take all the parts home, FFL keeps the receiver and it is DROSed as a receiver only because that is exactly what they received. Buyer then has the responsibility to make sure it is CA compliant.

Receivers do not need a safety demo to be performed.

Quote:
11 CFR 5471 (hh) "Semiautomatic" means a firearm functionally able to fire a single cartridge eject the empty case and reload the chamber each time the trigger is dulled and released. Further, certain necessary mechanical parts that will allow a firearm to function in a semiautomatic nature must be present for a weapon to be deemed semiautomatic. A weapon clearly designed to be semiautomatic but lacking a firing pin, bolt, carrier, gas tube or some other crucial part of the firearm is not semiautomatic for purposes of Penal Code section 30515, 30600 and 30605(a) and 30900.
Even before the new regulations disassembled was never an issue. We had DOJ audits when shipments came in and asked Bob during an audit. The new regulations just made it crystal clear and in writing.
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  #227  
Old 06-15-2017, 10:59 AM
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IOr the buyer can take all the parts home, FFL keeps the receiver and it is DROSed as a receiver only because that is exactly what they received. Buyer then has the responsibility to make sure it is CA compliant.
You have a problem there. Under Federal law that would be considered in a take down condition since all the parts are in the box and it is just taken apart. While CA does not considered it a so-called a-salt weapon, it is a complete firearm.
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  #228  
Old 06-15-2017, 11:03 AM
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Originally Posted by kemasa View Post
You have a problem there. Under Federal law that would be considered in a take down condition since all the parts are in the box and it is just taken apart. While CA does not considered it a so-called a-salt weapon, it is a complete firearm.
We have always logged them into our book as a receivers, 2 ATF audits and inventory check and they have never mentioned anything. Even while seeing parts in the box or attached to the box.

If logged into book as a rifle and the DOJ inspects your book, I know legally you can fight this, and they see it logged in as a rifle how do you explain that?

Our ATF auditors have always been helpful, I will send a quick email.
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Old 06-15-2017, 11:16 AM
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Originally Posted by Baboosh View Post
We have always logged them into our book as a receivers, 2 ATF audits and inventory check and they have never mentioned anything. Even while seeing parts in the box or attached to the box.

If logged into book as a rifle and the DOJ inspects your book, I know legally you can fight this, and they see it logged in as a rifle how do you explain that?

Our ATF auditors have always been helpful, I will send a quick email.
I wondered about this in the past. How do you log in Ruger Takedowns? Or shotguns like Benelli's that don't come assembled?

I used to log them in as receivers as you mentioned, but our atf auditor said to log them in as complete firearm if that's what was received (even if disassembled).
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Old 06-15-2017, 11:19 AM
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Originally Posted by ugimports View Post
I wondered about this in the past. How do you log in Ruger Takedowns? Or shotguns like Benelli's that don't come assembled?

I used to log them in as receivers as you mentioned, but our atf auditor said to log them in as complete firearm if that's what was received (even if disassembled).
Well if we ordered a rifle or a shotgun then its logged in as we ordered as I log in based off our invoice.

However if we are shipped items from another FFL or individual a firearm, and then parts, we log them in as a receiver. Since I could not accept that rifle legally in CA it cannot be a rifle.

We have had people order a complete lower and a complete upper from Primary Arms and other online retailers and the entire order gets shipped to us. It sure wasn't a rifle on their books, why would we log them in as a rifle? The only firearm I received was a receiver.
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Old 06-15-2017, 11:23 AM
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My worry is the CA DOJ and them auditing our book. I sure don't want a entry in my book saying I certify something was a rifle when it is not CA compliant.

Not sure if the DOJ can do anything if the firearm is not even in your possession anymore but I sure as heck don't want to open myself those accusations and litigation.
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Old 06-15-2017, 11:31 AM
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Originally Posted by Baboosh View Post
We have always logged them into our book as a receivers, 2 ATF audits and inventory check and they have never mentioned anything. Even while seeing parts in the box or attached to the box.
What an IOI notices and says does not indicate what the requirements actually are.

Quote:
If logged into book as a rifle and the DOJ inspects your book, I know legally you can fight this, and they see it logged in as a rifle how do you explain that?
Simple, it did not meet the definition of a so-called a-salt weapon. You received rifles all the time and you don't have to prove that it was not a so-called a-salt weapon, do you?

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Our ATF auditors have always been helpful, I will send a quick email.
That is a good idea.
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Old 06-15-2017, 11:41 AM
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Originally Posted by Baboosh View Post
Well if we ordered a rifle or a shotgun then its logged in as we ordered as I log in based off our invoice.

However if we are shipped items from another FFL or individual a firearm, and then parts, we log them in as a receiver. Since I could not accept that rifle legally in CA it cannot be a rifle.

We have had people order a complete lower and a complete upper from Primary Arms and other online retailers and the entire order gets shipped to us. It sure wasn't a rifle on their books, why would we log them in as a rifle? The only firearm I received was a receiver.
If you receive the firearm from a gunbroker seller and it says "Smith & Wesson M&P Sport II Rifle" on the invoice, but shipped separated, how would you log it in?

Most of our invoices state the type of firearm (typically from gunbroker, or possibly Buds, Grab A Gun, etc..).

I understand your PSA example and the invoice for that would actually say Receiver on it.

I've received many Side-by-side shotguns disassembled and the invoice said Shotgun on it.
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  #234  
Old 06-15-2017, 11:42 AM
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Originally Posted by ugimports View Post
I wondered about this in the past. How do you log in Ruger Takedowns? Or shotguns like Benelli's that don't come assembled?
That is a good example. It is a complete firearm in the box.

Quote:
I used to log them in as receivers as you mentioned, but our atf auditor said to log them in as complete firearm if that's what was received (even if disassembled).
[/quote]

That sounds like the proper thing based on what I have seen from the BATF.

[quote]
Quote:
Originally Posted by Baboosh View Post
Well if we ordered a rifle or a shotgun then its logged in as we ordered as I log in based off our invoice.
If you ordered all of the parts, it is a complete firearm, based on what I recall from the BATF. That is why it is said that if you are selling all the parts, the lower should be sold separately. As well, if you assemble it for the customer, you can't sell them all the parts at once, the lower should be transferred before you put it together.

Quote:
However if we are shipped items from another FFL or individual a firearm, and then parts, we log them in as a receiver. Since I could not accept that rifle legally in CA it cannot be a rifle.
That is not correct. If all the parts are there, then it is a complete firearm. The CA DOJ has said that if the upper is not on an AR type firearm, then it is not a so-called a-salt weapon. That means you can receive it, but you can not put it together unless and until it is in a legal configuration.

Quote:
We have had people order a complete lower and a complete upper from Primary Arms and other online retailers and the entire order gets shipped to us. It sure wasn't a rifle on their books, why would we log them in as a rifle? The only firearm I received was a receiver.
Because it is a complete firearm, just like if you sold all the parts together. The problem with what they are doing is not your problem and you should not cause problems for yourself in order to protect them.

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Originally Posted by Baboosh View Post
My worry is the CA DOJ and them auditing our book. I sure don't want a entry in my book saying I certify something was a rifle when it is not CA compliant.
Ignoring Federal issues is not a good idea. There is not enough information in your bound book or other records to prove or even indicate that what you received was not legal. If you received a firearm in take down condition and you don't record it as you should under Federal law, that is easier to prove.

Quote:
Not sure if the DOJ can do anything if the firearm is not even in your possession anymore but I sure as heck don't want to open myself those accusations and litigation.
I get that, but do you want to subject yourself to Federal issues out of fear of CA issues?

To me, it is what is legal, not what you can get away with. If the firearm is a complete firearm in take down condition, then I am going to record it as required.
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Old 06-15-2017, 11:43 AM
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Originally Posted by kemasa View Post
What an IOI notices and says does not indicate what the requirements actually are.

Simple, it did not meet the definition of a so-called a-salt weapon. You received rifles all the time and you don't have to prove that it was not a so-called a-salt weapon, do you?

That is a good idea.
True, however it does set precedence. I've enjoyed ATF audits, they are helpful, nice and are there to help to make sure we are doing our job. I ask tons of questions and they will put it in writing if I want.

I've been lucky, haven't had to battle the DOJ on anything really. Both times I had Bob, I know he wasn't the most liked but he was fair to us. We got through both with basically no marks besides little paperwork fixes. I believe Bullet Barn got rolled up in something like this, not sure how it panned out I may need to reach out.

I am emailing them now, I'll be happy to post the response.
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  #236  
Old 06-15-2017, 11:47 AM
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Originally Posted by ugimports View Post
If you receive the firearm from a gunbroker seller and it says "Smith & Wesson M&P Sport II Rifle" on the invoice, but shipped separated, how would you log it in?

Most of our invoices state the type of firearm (typically from gunbroker, or possibly Buds, Grab A Gun, etc..).

I understand your PSA example and the invoice for that would actually say Receiver on it.

I've received many Side-by-side shotguns disassembled and the invoice said Shotgun on it.
Good questions, this is why I like this forum. With regards to the Sport II I'd log it in as S&W, M&P (believe that is what it says on the receiver) type: Receiver. To me that is the only firearm I received.

Maybe we have been doing it wrong. But with almost 10k guns on the books do I change it now or wait to be told to change it?
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Old 06-15-2017, 11:48 AM
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Originally Posted by Baboosh View Post
True, however it does set precedence. I've enjoyed ATF audits, they are helpful, nice and are there to help to make sure we are doing our job. I ask tons of questions and they will put it in writing if I want.
Unless it is in writing, it means nothing. Yes, most IOI seem to be good and helpful, but some are wrong and you have to prove them wrong, which can cause problems.

Quote:
I've been lucky, haven't had to battle the DOJ on anything really. Both times I had Bob, I know he wasn't the most liked but he was fair to us. We got through both with basically no marks besides little paperwork fixes. I believe Bullet Barn got rolled up in something like this, not sure how it panned out I may need to reach out.

I am emailing them now, I'll be happy to post the response.
It will be interesting to see what the response is.
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  #238  
Old 06-15-2017, 11:53 AM
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Originally Posted by Baboosh View Post
Maybe we have been doing it wrong. But with almost 10k guns on the books do I change it now or wait to be told to change it?
When you realize that you are doing something wrong, you change it right away, do not wait until you are called on it.

As mentioned, how would you log in a Ruger 10/22 takedown? It is in two pieces.
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Old 06-15-2017, 11:54 AM
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If you ordered all of the parts, it is a complete firearm, based on what I recall from the BATF. That is why it is said that if you are selling all the parts, the lower should be sold separately. As well, if you assemble it for the customer, you can't sell them all the parts at once, the lower should be transferred before you put it together.
So you are saying if I order a complete lower from RSR and on the same invoice from RSR I order a complete upper I ordered a complete firearm and it needs to be logged into my books as a complete rifle even though the parts were never attached? How does that make sense?

Quote:
Because it is a complete firearm, just like if you sold all the parts together. The problem with what they are doing is not your problem and you should not cause problems for yourself in order to protect them.
So you are saying every time someone buys parts to complete a gun at the same time the selling FFL is the manufacturer even though he never assembled the parts? That is against everything I have ever read, asked or been told.

Quote:
Ignoring Federal issues is not a good idea. There is not enough information in your bound book or other records to prove or even indicate that what you received was not legal. If you received a firearm in take down condition and you don't record it as you should under Federal law, that is easier to prove.
I am not ignoring federal laws. I am simply logging in what firearm I received.
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Old 06-15-2017, 11:57 AM
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Originally Posted by kemasa View Post
When you realize that you are doing something wrong, you change it right away, do not wait until you are called on it.

As mentioned, how would you log in a Ruger 10/22 takedown? It is in two pieces.
I will wait to see what the ATF has to say.

But I ordered a rifle, this is a different scenario in my eyes.
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