Out of state C&R FFL holder need to do the CFLC if shipping to FFL for transfer?

[ptoguy2002]

I am not a C&R holder.
Out of state seller is a C&R FFL holder.
He needs to ship the rifle to a CA FFL for transfer.
Does the out of state guy need to do the CFLC thing?

I'm not so much into C&R's, so please excuse the noob question.

[Mssr. Eleganté]

No, he does not have to do the CFLC thing. Type 03 FFLs (C&R) and Type 06 FFLs (ammo manufacturer) are exempt from the CFLC requirement.

[emcon5]

Check with your FFL to make sure he will accept a shipment from a 03. Some are jackholes.

[eltee]

What if the seller is a class 1 Dealer by license but sends a C&R rifle? CFLC needed or no? Receiving (Calif) FFL is also Class 1.

THANKS

[microwaveguy]

FFL01 to FFL01 would need the CFLC #

[eltee]

Thanks.

[Mssr. Eleganté]

FFL01 to FFL01 would need the CFLC #

There is an exemption to the CFLC for C&R long guns in CPC 27820.

[charlieyankeesierra]

There is an exemption to the CFLC for C&R long guns in CPC 27820.

When I look at the CPC, I come to the same conclusion for FFL01. However, a popular interpretation is seemingly that the CPC 27820 exception only applies for FFL03, in part due to the way the FAQs read on the oag.ca.gov CFLC web page. CPC 27555 references all FFL types "licensed pursuant to Chapter 44 (commencing with Section 921) of Title 18 of the United States Code," and so when the exception in 27820 refers to 27555, it seemingly applies to all FFL types. Therefore, seemingly, to be eligible for the 27820 exception an FFL01 would have to make infrequent C&R type transfers (satisfying clauses a and c), in addition to the item not being a handgun (clause b).

I know this is an old thread, and perhaps it is a foregone conclusion that whatever is suggested or implied in the oag.ca.gov CFLC FAQs becomes de facto the law, but it would be nice if this aspect of the CFLC were clarified.