SSE2 using STI 100% frame?

[BAJ475]

I have read various post but did not find any consensus. I understand that if I started with an 80% STI style frame, such as manufactured by Limited-10, that as a non FFL I could put together a handgun in California, so long as it was first an exempt single shot break top pistol. My question is could an 07FFL start with a bare STI frame (100%) and build it into a break top single shot pistol and then DROS it to me in that configuration or would the FFL also have to start with something like an 80% frame?

Thanks for any input that any of you can provide.

[EBR Works]

If the frame is virgin and never built as a semi-auto, the 07 could build it as SSE2 "break top" or "bolt action". He would have to engrave it with his information and pay 10% Federal Excise tax on the build. He could then transfer the firearm to you as roster exempt.

[BAJ475]

If the frame is virgin and never built as a semi-auto, the 07 could build it as SSE2 "break top" or "bolt action". He would have to engrave it with his information and pay 10% Federal Excise tax on the build. He could then transfer the firearm to you as roster exempt.

That would be my take but then there is the Franklin Armory AR Pistol issue. I understand FA's stated purpose, but I'm not trying to get anything on the roster so simply exempt is good enough for me.

[EBR Works]

AFAIK the FA debacle is only applicable to their specific make/model that they attempted to roster.