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  #5001  
Old 03-18-2021, 12:43 PM
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Thanks for the more precise details of the settlement. It's definitely worth paying attention to this part:

Quote:
The Department shall clearly notify any individuals registering firearms during the new Registration Period of the following: (a) that the Department may attempt to verify whether any particular registrant attempted to register their weapon(s) before July 1, 2018; (b) the potential consequences of providing false statements in connection with such registrations; and (c) that if they submit a weapon that was not attempted to be registered before July 1, 2018, they could be subject to consequences as prescribed by law.
So it sounds like they're pretty serious about only taking registrations from people who really tried (but failed) to register before the 2017 deadline (although I have no idea how they could prove otherwise, especially in instances where people couldn't even get the website to load at all), and most importantly, everyone needs to know that this absolutely cannot be used for registering a weapon that was acquired after 12/31/2016 or was otherwise ineligible for registration before then. And attempting to register a home-build that hasn't already gotten a DOJ-issued serial before 7/1/2018 is also not recommended.
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Last edited by CandG; 03-18-2021 at 12:50 PM..
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  #5002  
Old 03-18-2021, 12:44 PM
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Yeah, not sure this a win.
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  #5003  
Old 03-18-2021, 12:52 PM
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For anyone that this new registration period might apply to, I'll try to update the OP accordingly once all the facts are in. We've got a few months to sort it all out before anything happens.
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  #5004  
Old 03-18-2021, 12:53 PM
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Originally Posted by vino68 View Post
Yeah, not sure this a win.
I'm not sure it's really a win for us, either, but it's for sure a loss for DOJ, which makes me happy regardless
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  #5005  
Old 03-18-2021, 12:58 PM
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It will be interesting to see if any charges come out of this.

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Originally Posted by CandG View Post
So it sounds like they're pretty serious about only taking registrations from people who really tried (but failed) to register before the 2017 deadline (although I have no idea how they could prove otherwise, especially in instances where people couldn't even get the website to load at all), and most importantly, everyone needs to know that this absolutely cannot be used for registering a weapon that was acquired after 12/31/2016 or was otherwise ineligible for registration before then. And attempting to register a home-build that hasn't already gotten a DOJ-issued serial before 7/1/2018 is also not recommended.
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  #5006  
Old 03-18-2021, 1:09 PM
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Originally Posted by bigbully View Post
It will be interesting to see if any charges come out of this.
Sadly I can almost guarantee that someone in this huge state of ours is going to try to register something they just bought.

I'm going to do my part, by trying to spread the word here as much as I can, that nobody should try any funny business with this new registration period.
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  #5007  
Old 03-18-2021, 1:11 PM
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(redacted)
I'll definitely look into this scenario, and ones like it, and try to answer as best as I can. But right now I'm just not sure.

The thing that's weird is, home-builds (FMBUS) that were being registered as AW had a specific process for getting a serial number, which was different than the process used today for home-builds. But would a serial number obtained using the non-AW SN process still work for a AW registration in this next period? That might be something FPC's lawyers need to answer, because it's really not clear.

Since it was eligible to be registered before the 2018 registration ended, it *seems* like you might be ok. But where things get really murky, legally speaking, is that it was modified to no longer be an AW when the registration period ended, so now you're faced with 3 possibilities:

1. You claim that it has been an AW ever since registration ended, which is.... an unpleasant thought, because even though it retroactively isn't illegal anyymore, it was illegal at the time. Even if they say they won't prosecute anyone for that, it's not fun to tell DOJ you were a felon for a few years.
2. You try to register it during this upcoming period, in its current non-AW configuration, which theoretically they're *supposed* to deny because, according to their own regulations, they will not register anything that isn't currently in an AW configuration.
3. You convert it back into AW configuration and then register it, but then you're making an AW long after the 2016 prohibition started, which might not be good.

I have no idea which of those options is best. They all sound terrible. It's possible that the best option will be:

4. Do nothing. Keep your non-RAW pistol as a non-RAW pistol.
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  #5008  
Old 03-18-2021, 7:53 PM
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The only people that should register now are those facing charges. Don't give them the chance to up their compliance numbers.
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  #5009  
Old 03-18-2021, 7:59 PM
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Quote:
Originally Posted by CandG View Post
I'll definitely look into this scenario, and ones like it, and try to answer as best as I can. But right now I'm just not sure.

The thing that's weird is, home-builds (FMBUS) that were being registered as AW had a specific process for getting a serial number, which was different than the process used today for home-builds. But would a serial number obtained using the non-AW SN process still work for a AW registration in this next period? That might be something FPC's lawyers need to answer, because it's really not clear.

Since it was eligible to be registered before the 2018 registration ended, it *seems* like you might be ok. But where things get really murky, legally speaking, is that it was modified to no longer be an AW when the registration period ended, so now you're faced with 3 possibilities:

1. You claim that it has been an AW ever since registration ended, which is.... an unpleasant thought, because even though it retroactively isn't illegal anyymore, it was illegal at the time. Even if they say they won't prosecute anyone for that, it's not fun to tell DOJ you were a felon for a few years.
2. You try to register it during this upcoming period, in its current non-AW configuration, which theoretically they're *supposed* to deny because, according to their own regulations, they will not register anything that isn't currently in an AW configuration.
3. You convert it back into AW configuration and then register it, but then you're making an AW long after the 2016 prohibition started, which might not be good.

I have no idea which of those options is best. They all sound terrible. It's possible that the best option will be:

4. Do nothing. Keep your non-RAW pistol as a non-RAW pistol.
Option 5. You had kept your AW-configured guns out of state between the registration deadline and now. I have a few still sitting in NV that failed to register in 2017.

What do you think CandG?
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  #5010  
Old 03-19-2021, 8:18 AM
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Originally Posted by beanz2 View Post
Option 5. You had kept your AW-configured guns out of state between the registration deadline and now. I have a few still sitting in NV that failed to register in 2017.

What do you think CandG?
Good point!
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  #5011  
Old 03-20-2021, 4:07 AM
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Does this mean I can buy another complete lower w BB and add it to my RAWs and register it with CA DOJ before this period ends again?

Dch
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  #5012  
Old 03-20-2021, 8:57 AM
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Originally Posted by DCH View Post
Does this mean I can buy another complete lower w BB and add it to my RAWs and register it with CA DOJ before this period ends again?

Dch
Absolutely no. Registration will not be available for anything acquired after 12/31/2016. Attempting to register a lower acquired after 2016 would almost certainly result in a visit from your friendly neighborhood DOJ agents.

The fact that this question has been asked at least once now, makes me very concerned... I've updated my signature to try to hopefully keep people out of jail.
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  #5013  
Old 03-20-2021, 9:14 AM
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I applied for six the first time. Four are in.

EDIT: Two of the four are FMBUS with DOJ assigned SNs.

Other two I never heard back. Do I re-start the original submission?

.

Last edited by Maltese Falcon; 03-20-2021 at 9:20 AM..
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  #5014  
Old 03-20-2021, 9:24 AM
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I applied for six the first time. Four are in.

EDIT: Two of the four are FMBUS with DOJ assigned SNs.

Other two I never heard back. Do I re-start the original submission?

.
If the registrations were submitted successfully (which it sounds like they were), then no, I don't think you should re-submit them. I would try to request a registration letter from DOJ (instructions are in the Guide on page 1 of this thread) to see if maybe they did successfully get registered, and you just didn't get the confirmation for whatever reason. It's also possible they just haven't gotten to them yet, I know there are still a few people waiting for theirs.

Edit: Actually I just checked, and it doesn't look like I included instructions for requesting a duplicate registration letter in the Guide. All I know is that they charge a fee of $5 for it, per the regulations. But I'm unsure of the process. Might be worth a phone call to ask.
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  #5015  
Old 03-20-2021, 11:20 AM
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What about bullet button ar's that are legally owned by a minor??? Legal transfer and notarized prior to 2014? Are their going to be any exemption this time?
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  #5016  
Old 03-20-2021, 12:41 PM
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Originally Posted by slicksetter View Post
What about bullet button ar's that are legally owned by a minor??? Legal transfer and notarized prior to 2014? Are their going to be any exemption this time?
This is only for people who actually started the registration process and were unable to complete the process before the deadline. That means currently incomplete registrations only. No new registrations period. Any attempt to try new registrations could result in charges.
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  #5017  
Old 03-20-2021, 3:52 PM
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Understand, everything was disassembled to create non scarry rifles, The issue is if I hadn't, My children would have became felons overnight for their legally owned rifles.
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  #5018  
Old 03-21-2021, 12:23 PM
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Originally Posted by slicksetter View Post
What about bullet button ar's that are legally owned by a minor??? Legal transfer and notarized prior to 2014? Are their going to be any exemption this time?
If the minor didn't turn 18 before 7/1/2018, then they were not eligible to register during the 2017-2018 registration window, thus they will not be eligible to register during this upcoming window.
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  #5019  
Old 03-21-2021, 12:30 PM
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The attorney's got a large fee award. But was the mere re-opening of the registration a huge victory? I mean, unless you weren't paying attention you would have made the decision back then one way or the other. So unless you weren't paying attention or if you had a change of heart, I'm not excited.
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  #5020  
Old 03-25-2021, 7:23 PM
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OK, does this give me the opportunity to de-register my RBBAWs given that I have removed their BBs?
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  #5021  
Old 03-25-2021, 7:34 PM
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OK, does this give me the opportunity to de-register my RBBAWs given that I have removed their BBs?
De-registration has always been available, see excerpt from the OP of this thread below. This news doesn't change de-registration availability, nor the process for doing so. (My opinion is, unless you are selling the weapon, it isn't worthwhile to de-register in most cases. It's a hassle and it's unlikely that it would take you off DOJ's naughty list anyways. It would, however, remove the AW storage, transfer, and transport restrictions, which is particularly important with weapons for which you can't easily just swap out the receiver; but for AR's, it's usually better to just leave the registration alone, swap the receiver for one that isn't RAW, and store the RAW receiver somewhere for a rainy day.)

Voluntary De-Registration

Before you consider formal de-registration, consider that you can instead choose to modify or reconfigure the firearm to no longer meet the definition of an Assault Weapon, and then replace the serialized RAW receiver with a different (not RAW) receiver, effectively making the weapon no longer a RAW. Then you may retain the RAW receiver in case you ever decide to build it into a functional RAW again in the future.

If you still decide to formally de-register a RAW, the procedure is outlined below. Note that there is no such thing as mandatory de-registration. Under no circumstances are you required to contact DOJ about your RAW once it's registered. Even if you sell it, move, etc. However, in certain scenarios (like if you sold it), you may want to de-register it to disassociate your name from that weapon.
  1. Registered Assault Weapons may be de-registered under the following circumstances:
    • Weapons that are no longer possessed, after completing a BOF Form 4546 ("Notice of No Longer in Possession")
    • Weapons that have been modified or reconfigured to no longer meet the definition of an Assault Weapon
  2. Send a letter to DOJ that includes the following:
    • Full name, phone number, and current address; make, model, and serial number; and the DOJ Assault Weapon Registration Number (if known - if not known, then the letter must also be notarized).
    • If no longer in possession, must include a proof of sale or transfer.
    • If still in possession, must include 1 or more photos showing the weapon in a non-AW configuration.
    • Signature and date
  3. Mail the letter to: Bureau of Firearms, P.O. Box 820200, Sacramento, CA 94203-0200
  4. If still in possession, DOJ may request additional photos, information, or even an inspection (where or by whom, we don't know)
  5. After determining eligibility for de-registration, DOJ will delete the Assault Weapon Registration, and if you are still in possession they will convert the record to a standard "Firearm Ownership Report", or if you are no longer in possession they will convert it to a "No Longer in Possession" entry in AFS.
  6. Confirmation of de-registration and updated firearm ownership information will be mailed to your address.
  7. You may never re-register the weapon as an Assault Weapon, even if the registration period is still open! Attempting to do so would be admitting that you took a non-AW and made it back into an AW after it became illegal to do so on 1/1/2017.
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  #5022  
Old 07-15-2021, 4:43 PM
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I know I am posting this to an old thread, but there are a lot of loose ends here that are not tied up that I believe need further discussion. I am interested particularly in how this will impact the voluntary registration of self-built and self-serial numbered guns. A key component of the failed registration scheme was to allow people to declare guns that were self-build and self-serial numbered. These guns were not AWs but rather were pistols and featureless rifles. The stated goal of the DOJ was to get all self-built weapons registered and they offered voluntary registration as a means of legalizing home built guns.

What about about people that attempted voluntary registration on non-AW home builts only to have the CFARS system fail on them? Shouldn't this re-opening include a re-opening of the voluntary registration side of things since the system failed to deliver on this aspect of implementing the law?

Why is there no mention of this vital aspect of the failed registration scheme in the settlement and in our discussions? Did our lawyers not understand the full scope of the system failure here and settle for half a lunch?
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  #5023  
Old 07-15-2021, 4:51 PM
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Originally Posted by Caleb1911 View Post
I know I am posting this to an old thread, but there are a lot of loose ends here that are not tied up that I believe need further discussion. I am interested particularly in how this will impact the voluntary registration of self-built and self-serial numbered guns. A key component of the failed registration scheme was to allow people to declare guns that were self-build and self-serial numbered. These guns were not AWs but rather were pistols and featureless rifles. The stated goal of the DOJ was to get all self-built weapons registered and they offered voluntary registration as a means of legalizing home built guns.

What about about people that attempted voluntary registration on non-AW home builts only to have the CFARS system fail on them? Shouldn't this re-opening include a re-opening of the voluntary registration side of things since the system failed to deliver on this aspect of implementing the law?

Why is there no mention of this vital aspect of the failed registration scheme in the settlement and in our discussions? Did our lawyers not understand the full scope of the system failure here and settle for half a lunch?
The paper option was available for voluntary registration (still is) so I'm not sure how the website not working would have impacted your ability to volreg any firearm before the deadline.

Link here: https://oag.ca.gov/sites/all/files/a...rms/volreg.pdf
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  #5024  
Old 07-21-2021, 6:45 PM
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Thank you for your response, UG.
My recollection is that you had until the deadline to VolReg any self-built with your own serial number. If you missed this, you had to apply for one of the DOJ serial numbers and the gun would be treated as current self-builts which are basically like assault weapons with no chance to sell it at any point or transfer it upon your death. My understanding is that we had to use the CFARS system to do this particular VolReg. I do not recall a paper option being allowed for this aspect of the scheme.

Are you saying that a self-built non-assault weapon featureless rifle can be simply declared at this point? I think that horse has left the barn according to the DOJ.

I read a lot of the posts here on CalGuns and read the DOJ stuff. A lot of people were of the opinion that the VolReg had to be done on CFARS. Maybe I should chalk up my ignorance to the arcane and highly confusing way in which all of these regs were promulgated and foisted upon us.
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Old 07-22-2021, 6:22 AM
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80% rifles can stil be built in CA compliant featureless configuration. You have to applly for serial # ahead of time and then send photos of the completed receiver or rifle. The only sane reason to do this if you are build a clone of something and want custom receiver markings, otherwise it is a PITA waste of time. I did it to use a H&R marked receiver for an M16A1 clone build.
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Old 07-22-2021, 8:05 AM
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Originally Posted by Caleb1911 View Post
Thank you for your response, UG.
My recollection is that you had until the deadline to VolReg any self-built with your own serial number. If you missed this, you had to apply for one of the DOJ serial numbers and the gun would be treated as current self-builts which are basically like assault weapons with no chance to sell it at any point or transfer it upon your death. My understanding is that we had to use the CFARS system to do this particular VolReg. I do not recall a paper option being allowed for this aspect of the scheme.
You had previously said:
Quote:
I am interested particularly in how this will impact the voluntary registration of self-built and self-serial numbered guns
This led me to infer that before the deadline you self-serial numbered an 80% lower. Prior to the "deadline" you refer to above you could have VolReg that via papermail and that would have been that. That would have been done and then you could have attempted to do the AW reg (which may have not worked). However, this would have put the firearm with your SN "registered" in your name before the AW deadline and would not have required any online option.

Just to be clear when did you serialize the the 80%? (you may or may not want to answer depending how much you believe in self-incrimination)

Quote:
Are you saying that a self-built non-assault weapon featureless rifle can be simply declared at this point? I think that horse has left the barn according to the DOJ.
I don't know.

Quote:
I read a lot of the posts here on CalGuns and read the DOJ stuff. A lot of people were of the opinion that the VolReg had to be done on CFARS. Maybe I should chalk up my ignorance to the arcane and highly confusing way in which all of these regs were promulgated and foisted upon us.
This may have been the root of the issue. Not you being ignorant, but the complete confusion around any DOJ updates/laws/regs and their blatant disregard for any educational requirements to any bills. They really don't care that it is confusing and make 0 effort to educate the law abiding public.
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  #5027  
Old 07-30-2021, 4:57 PM
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Thanks again for the response, UG. Sorry for the slow-motion nature of this dialogue. I have been out of town and busy so I have been slow to respond.

The situation is that I have a friend who had a self-serial numbered featureless AK built on a plate receiver. The SN was put on before the deadline. He tried to log into CFARS to declare it before the deadline and he could not get into the website. We both were under the impression that this was the only way to VolReg the gun under the scheme they put in place. Since he played by the rules, he believes that he should be given another chance to VolReg the gun without having to apply for DOJ serial and all the restrictions that come with that sort of build. After all, it is their fault that the online VolReg system did not work.

I guess I was wrong on this (so were many others). If we have to go the DOJ serial number way, he loses the advantage of his rifle being treated like any other featureless rifle and they place assault weapon like restrictions on it.
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  #5028  
Old 07-30-2021, 5:12 PM
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P.S. This seems to be an unfair outcome because the lack of registration came from their incompetent boobery and lack of proper explanation, not from a lack of diligence to obey the law on his part. I believe that he is right. Since it was so poorly implemented and explained they owe everyone the chance to do what they supposedly offered in the online system: 1. VolReg; and 2. BBRAW reg. I know several people who believed that through not being able to log on to CFARS the DOJ effectively shut the door on VolReg. It was a Lucy pulling the football away from Charlie Brown type of thing. Who it is going to hurt to turn the clock back on the entire process and start over? These people are enraging and they get away with it over and over again.

The lawyers and the Judge in this case blew chunks if the VolReg is not re-opened at the same time. They let the DOJ shaft us again.

If I were the judge I would go so far as to even reset the purchase dates to the date that the new registration purchase period ends. This would be a fair settlement given what the DOJ did to the public. Who would it hurt? The goal is to get the guns registered. They failed. They should bear the consequences of that failure.
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  #5029  
Old 07-30-2021, 5:21 PM
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Originally Posted by Caleb1911 View Post
I guess I was wrong on this (so were many others). If we have to go the DOJ serial number way, he loses the advantage of his rifle being treated like any other featureless rifle and they place assault weapon like restrictions on it.
What? Don't confuse DOJ issued serial numbers and self built guns with assault weapons. They are mutually exclusive.

A person today, right now, can apply for a serial number from DOJ and self build a featureless rifle from raw materials. It will be treated just like every other featureless rifle from any other maker.

The only thing your friend would lose, would be his serial number.
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Old 07-31-2021, 7:28 PM
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Originally Posted by SkyHawk View Post
What? Don't confuse DOJ issued serial numbers and self built guns with assault weapons. They are mutually exclusive.

A person today, right now, can apply for a serial number from DOJ and self build a featureless rifle from raw materials. It will be treated just like every other featureless rifle from any other maker.

The only thing your friend would lose, would be his serial number.
He potentially loses the ability to register in a new AW window if DOJ treats it as "manufactured" via the time of his CA DOJ SN application though. Their records would show the volreg > July 2021 assuming it was done tomorrow.
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Old 07-31-2021, 7:33 PM
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He potentially loses the ability to register in a new AW window if DOJ treats it as "manufactured" via the time of his CA DOJ SN application though. Their records would show the volreg > July 2021 assuming it was done tomorrow.
True. And maybe I missed the part where he wanted to register it as AW? It sounds like it is featureless now and he does not want AW restrictions

Quote:
he loses the advantage of his rifle being treated like any other featureless rifle and they place assault weapon like restrictions on it.
I may be reading it wrong or maybe I skipped over some posts, but it sounds like the last thing he wants is AW.


In either case, it seems like his understanding is still incorrect based on what I quoted above.
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  #5032  
Old 08-01-2021, 1:24 AM
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If you buy a lower or a complete rifle in CA this last 6 months to a year is it automatically registered?
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Old 08-01-2021, 9:06 AM
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Thanks again for the help here, gentlemen.
The CA DOJ guidance on self-made guns makes for some
Here is the link:
https://oag.ca.gov/system/files/atta...umer-alert.pdf
Regarding self-made pistols, they want you to build in microstamp capabilities:
I quote directly from the document:

"Additionally, California law generally prohibits the manufacture of unsafe handguns. A self-
manufactured handgun must meet certain design features under state law. A self-manufactured
semiautomatic handgun, even if temporarily alt ered f or single-shot firing, must include safety and
security features, including:
 The firearm must incorporate a manually-operated safety device.
 The firearm must meet California’s drop safety requirements.
 The firearm must be able to imprint certain identifying information on two locations on each
cartridge case when fired.
Some exceptions apply to these rules. For full details and definitions of unsafe handguns and
required f eatures under California law, see Penal Code Sections 31900-3210"

Regarding self-built rifles (and not AWs!) they say this:

"4. Selling self-made firearms is illegal:
With limited exceptions, the sale or transfer of ownership of self-manufactured or self-assembled
firearms is prohibited under California law."

It seems to me from reading the above quote that they are treating self-made guns like assault weapons by banning future transfer and sale of the weapon. This is why my friend was concerned to get his gun registered under the older VolReg offering that was made in conjunction with the BBRAW regs.

This stuff is all messed up and confusing, but it seems clear to me that they have tried to make the self-build regs as difficult and unattractive as possible for someone who might consider going that route.
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Old 08-01-2021, 9:18 AM
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One more comment regarding pistol builds:
I saw a guy on YouTube build a P80 Glock using the CA DOJ serial number scheme and they did not challenge him on microstamping. Perhaps if you are building a Glock gen 3 clone they will let it go since the Glock gen 3s are still on the pistol roster. The odd thing is that he didn't seem to identify the gun as a Glock. Maybe they just don't know their own regs.

Again, nothing makes sense in how they promulgated the regs or how they apply them. It seems to me that they went way beyond what was authorized under the law.
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  #5035  
Old 08-01-2021, 9:26 AM
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Originally Posted by GregW948 View Post
If you buy a lower or a complete rifle in CA this last 6 months to a year is it automatically registered?
Yes, if it was purchased legally through an FFL.

It is NOT registered as an assault weapon, however. Only as a firearm that you own.
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Old 08-01-2021, 9:28 AM
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Quote:
Originally Posted by Caleb1911 View Post
One more comment regarding pistol builds:
I saw a guy on YouTube build a P80 Glock using the CA DOJ serial number scheme and they did not challenge him on microstamping. Perhaps if you are building a Glock gen 3 clone they will let it go since the Glock gen 3s are still on the pistol roster. The odd thing is that he didn't seem to identify the gun as a Glock. Maybe they just don't know their own regs.

Again, nothing makes sense in how they promulgated the regs or how they apply them. It seems to me that they went way beyond what was authorized under the law.
Bolded is the correct answer.

I would not attempt to build and/or self register a semi auto handgun in CA that was not roster complaint. Too risky, in my opinion.
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  #5037  
Old 08-01-2021, 9:28 AM
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Quote:
Originally Posted by GregW948 View Post
If you buy a lower or a complete rifle in CA this last 6 months to a year is it automatically registered?
Hi Greg
If you went through the DROS procedure when you purchased the lower or rifle then it will be automatically registered by the state. Your paperwork should be done. Regarding the rifle, if it is an AR or AK style, the manufacturer should have made sure that it meets the requirements to be a featureless rifle. Regarding the lower, you need to make sure that you build it in a featureless configuration to make sure that it remains a legal weapon.
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  #5038  
Old 09-16-2021, 2:28 PM
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More details in this announcement by the DOJ:

https://oag.ca.gov/news/press-releas...opening-bullet
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  #5039  
Old 09-16-2021, 4:05 PM
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More details in this announcement by the DOJ:

https://oag.ca.gov/news/press-releas...opening-bullet
I'm curious to see if the "paper" registration process will require photos.
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  #5040  
Old 09-17-2021, 12:50 PM
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I'm curious to see if the "paper" registration process will require photos.
I'm not sure, but here's what the original court settlement said:

Quote:
Originally Posted by ΜΟΛΩΝ ΛΑΒΕ View Post
5. The Department shall also and alternatively accept paper submissions from persons otherwise meeting the Registration Requirements, on a form that shall incorporate substantially all of the information that is required to be submitted electronically pursuant to California Penal Code section 30900(b)(2). Paper forms submitted in this manner shall be accepted by mail or overnight carrier delivery if accompanied by a postmark or other evidence of submission on or before the last day of the Registration Period.
So the stuff required on the paper form has to match the online form. That could mean that the electronic form won't require photos anymore, but I think more likely it means that you'll have to include physical photos with the paper form.

The settlement says, "pursuant to California Penal Code section 30900(b)(2)," which by itself does not require photos, but the DOJ Regulation 5474(c) which applies to that PC section, does specify a photo requirement.
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