Seriously?

Okay.... The Manufacturer and the ATF, that's who says.
They have to control one of the components as the firearm. If not, the a venfor like MidwayUSA could sell the lowers for a MKII w/o an FFL required. Then, lets say that Brownells or Tactical Solutions sold uppers w/o an FFL required. Two stop shopping to get a non-paper tracked handgun with no background check. Sounds great, but what about the whole issue of no guns for Felons, Terrorists, kids under 12 with mom's credit card?
Get it? There is a controlled part for all firearms. Most handguns it is the Frame, even if all the other components are serialized, it's only for the manufacturer/owner's records.
On AR-15's it's the lower receiver, but on FALs, and the HK USC for example, it's the upper receiver.

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