AW Registration Guide **3/18/2021 update: Registration may re-open soon**

[simonp]

Forgive me if this has been covered in the past, but has anyone's registration been denied on the grounds that they are registering multiple AW's by mating the same upper with more than one lower?

Not seen that happen


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[CandG]

Forgive me if this has been covered in the past, but has anyone's registration been denied on the grounds that they are registering multiple AW's by mating the same upper with more than one lower?

There was one 3rd party report (a guy at a gun store who said someone came in and said it happened to their friend) of a DOJ visit to someone's home to verify that isn't what they did, but the story hasn't been verified. Nothing legally says that you can't do that, but in any case I'd recommend avoiding using the same upper for more than 1 firearm.

There is no doubt that DOJ doesn't want us doing that. The only question is, can we do it anyways? And there's no solid answer on that. But be aware that it might result in a knock on your door.

[Crazy4Guns]

I have a couple question about the additional firearm characteristics in the registration form. I have a stock Colt Le 6920 I got from Riflegear a few years back. Do I check that it has a flash suppressor, telescoping stock, and pistol grip that protrudes beneath the action of the weapon? Thanks in advance.

[CandG]

I have a couple question about the additional firearm characteristics in the registration form. I have a stock Colt Le 6920 I got from Riflegear a few years back. Do I check that it has a flash suppressor, telescoping stock, and pistol grip that protrudes beneath the action of the weapon? Thanks in advance.

Yep, you got it

[DoctorLove]

According to whoever told the story, what came of the visit?

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[CandG]

Which visit? There have been at least 6 I know of. One of them has a major thread going on in the General Guns forum right now.

[DoctorLove]

The unverified one where the guy registered multiple lowers with the same upper

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[simonp]

Which visit? There have been at least 6 I know of. One of them has a major thread going on in the General Guns forum right now.

6 for using the same upper mated to different lowers?


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[CandG]

The unverified one where the guy registered multiple lowers with the same upper

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Oh... No idea. The whole story was only one sentence long. That's the problem with 3rd party reports, they often lack critical information

[DoctorLove]

Got it. Thank you

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[Discogodfather]

My take on the whole same upper on multiple lowers:

DOJ originally allowed lowers to be registered in all of the previous reg periods including 89, 00, and 01. Then it didn't matter if what you had functioned.

The DOJ's plan (reinforced when Holder took over the regs) was to minimize registration. They knew many people had multiple lowers. What real gun guy didn't have at least a few in the safe, we live in a day when you can buy a high quality fully GTG lower for $60. They also knew if they allowed people to register those the numbers would have been much much higher.

That, combined with other tactics including mandating BB stays on, insanely complicated registration process, and delaying the process by 6 months (as well as other ridiculous shenanigans) has yielded a largely failed reg period that didn't even come close to the 1.5 million they budgeted for.

So is it illegal to register multiple lowers with the same upper? I think it is legally problematic. The logic problem is this:

1) DOJ mandated through the regs that only functional rifles at the time of registration would be allowed in
2) You had to have built the firearm and had a fully functioning weapon before December 31st 2016.

So if I swap the same upper on to multiple lowers and I all do it at the same time, meaning let's say 6 open applications for registration are open at the same time, then didn't I just violate point #1? How can I have 6 independently functioning rifles at the time of my registration? Obviously only 1 was functional and the rest were non functional. Even if I complied with #2 and literally sat there and rotated the upper onto different complete lower assemblies within the legal time frame of 2001-2016 I still violated #1.

I should have said this much sooner, but the real way to get around this would have been to register 1 at a time, thus preserving the concept that the rifle was fully functioning at the time of registration. After they are registered we can disassemble them and keep them like that, right? There is no rule or concept I can see anywhere that says that an BBAW has to be functional at all times AFTER registration. It's just applies for registration.

[CandG]

Great post Disco. I agree with all that. The main points are:

"Was fully assembled and fully functional before 2017"

And

"Was fully assembled and fully functional when you completed the registration form".

What happens before, between, and after all those timeframes, is not addressed by the law nor regulations.

So as long as all rifles were functional at some point before 2017, then you could complete one (again) and register it, disassemble and use the upper to register another, disassemble and use the upper to reassemble another and register, and so on. As long as they aren't registered simultaneously, then I see no laws broken.

Of course, ianal, ymmv, caveat emptor.

I'll add:

If you register all simultaneously, it could still potentially be argued in the same way, that they were fully functional when you photographed the guns and submitted the forms into your "shopping cart" and received the CFARS confirmation... Regardless of their conditions when you paid for the bulk of them with one credit card transaction.

You only check the boxes certifying that "all of the above is true" when you add it to your cart, not when you pay for them.

[lordmorgul]

[DoctorLove]

The question is has anyone successfully registered multiple lowers using the same upper? And for those who have submitted their regs in such a way, what should be done? Sit and wait?

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[DoctorLove]

You can call your ffl and get that info

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