Getting LCM Permit w/o FFL?

[Th4tNinja]

I am looking to starting an e-com business selling firearm parts. I do not plan on selling any firearms anytime soon so I do not plan on getting a FFL01/07. I saw that I would need a LCM permit to import/sell LCMs. So does anyone know if it's possible to get a LCM permit without a FFL. Or has anyone without a FFL tried getting an LCM permit?

[mmaaka]

you can make it happen. you will need a sellers permit , business license and will not be able to purchase or resell any SERIALIZED parts. that will require a FFL. you can even sell compliant magazines and you can get your ammo vendor permit from the DOJ with proof of a business license as well if you wish

[Quiet]

Starting 01-01-2012, the large capacity magazine permit was limited to CA firearm dealers only. [PC 32315 and 11 CCR 5480(c) & 11 CCR 5482(b)]



Penal Code 26700
As used in this division, and in any other provision listed in Section 16580, “dealer,” “licensee,” or “person licensed pursuant to Sections 26700 to 26915, inclusive” means a person who satisfies all of the following requirements:
(a) Has a valid federal firearms license.
(b) Has any regulatory or business license, or licenses, required by local government.
(c) Has a valid seller’s permit issued by the State Board of Equalization.
(d) Has a certificate of eligibility issued by the Department of Justice pursuant to Section 26710.
(e) Has a license issued in the format prescribed by subdivision (c) of Section 26705.
(f) Is among those recorded in the centralized list specified in Section 26715.

Penal Code 32315
Upon a showing that good cause exists, the Department of Justice may issue permits for the possession, transportation, or sale between a person licensed pursuant to Sections 26700 to 26915, inclusive, and an out-of-state client, of large-capacity magazines.

Penal Code 32430
Section 32310 does not apply to the possession of, importation into this state of, or sale of, any large-capacity magazine by a person who has been issued a permit to engage in those activities pursuant to Section 32315, when those activities are in accordance with the terms and conditions of that permit.

California Code of Regulations Title 11 Divison 5 Chapter 39 Article 4 Section 5480
(a) This article applies to Penal Code section 32315 permits for the out-of-state importation and exportation of large-capacity magazines as defined in Penal Code section 16740. Importation and exportation includes the transportation of magazines as necessary to complete a transfer to or from an out-of-state source.
(b) No permit shall be issued to any person who fails to establish “good cause” for issuance of the permit and that the permit would not endanger public safety. “Good cause” shall be established by the following:
(1) A statement from the applicant that a large-capacity magazine marketplace exists for their dealership; and
(2) Compliance with The Dangerous Weapons Control Law comprised of the provisions listed in Penal Code section 16580 relative to large-capacity magazines and record keeping requirements specified in section 5483 of these regulations.
(c) Large-capacity magazine permit applications shall be filed on a DOJ form, BOF 050 (Rev. 01/2012) which requires the following information: California Firearms Dealership (CFD) number; dealership name; dealership mailing address; statement of good cause; signature of dealership licensees; and date.

California Code of Regulations Title 11 Divison 5 Chapter 39 Article 4 Section 5482
(a) The term of a large-capacity magazine permit shall be from January 1 through December 31. It is the responsibility of the permittee to submit a completed renewal application prior to December 31 of each year in order to maintain uninterrupted status as a large-capacity magazine permittee. Renewal applications shall be submitted on the form BOF 050 (Rev. 01/2012) prescribed in section 5480, subdivision (b) of these regulations.
(b) If at any time a permittee is not among the licensed firearms dealers on the DOJ Centralized List of Firearms Dealers, the large-capacity magazine permit is no longer valid and shall be canceled.

California Code of Regulations Title 11 Divison 5 Chapter 39 Article 4 Section 5483
Permittees shall maintain acquisition and disposition transaction records of the importation and exportation of large-capacity magazines. Records shall include transaction date, transaction volume; and the name, address, and Federal Firearms License number (if any) of the out of state transferee or transferor. Records must be maintained at the dealership for three years and be made available to representatives of the DOJ or any other law enforcement agency upon request.

California Code of Regulations Title 11 Divison 5 Chapter 39 Article 4 Section 5484
(a) Large-capacity magazine permits shall be subject to revocation for failure to comply with record keeping requirements specified in section 5483 of these regulations or for failure to comply with The Dangerous Weapons Control Law comprised of the provisions listed in Penal Code section 16580 relative to large-capacity magazines.
(b) All procedures and hearings related to the revocation of a large-capacity magazine permit shall be conducted in accordance with Government Code sections 11500 et seq.