03 FFL and C.O.E. Will it allow more sales transactions/year?

[c good]

I'm aware as a PPT, I'm allowed approximately 5 sales "transactions" per year.

Will an 03 FFL and C.O.E. Allow more sales transactions than five?

[9Cal_OC]

No.

[Quiet]

The infrequent transfer limits [PC 16730] still apply to a person with a valid C&R 03-FFL and valid COE, because they are not a CA FFL dealer. [PC 26520]

However...

All C&R firearms transferred from a person with a valid C&R 03-FFL and valid COE to a CA FFL dealer are exempt from the infrequent limits. [PC 26585]




Penal Code 26500
(a) No person shall sell, lease, or transfer firearms unless the person has been issued a license pursuant to Article 1 (commencing with Section 26700) and Article 2 (commencing with Section 26800) of Chapter 2.

Penal Code 26520
(a) Section 26500 does not apply to the infrequent sale, lease, or transfer of firearms.
(b) As used in this section, "infrequent" has the meaning provided in Section 16730.

Penal Code 16730
(a) As used in Section 31815 and in Division 6 (commencing with Section 26500) of Title 4, "infrequent" means both of the following are true:
(1) The person conducts less than six transactions per calendar year.
(2) The person sells, leases, or transfers no more than 50 total firearms per calendar year.
(b) As used in this section, "transaction" means a single sale, lease, or transfer of any number of firearms.

Penal Code 26585
Section 26500 does not apply to the delivery of an unloaded firearm that is a curio or relic, as defined in Section 478.11 of Title 27 of the Code of Federal Regulations, if the delivery satisfies all of the following conditions:
(a) It is made by a person licensed as a collector pursuant to Chapter 44 (commencing with Section 921) of Title 18 of the United States Code and the regulations issued pursuant thereto.
(b) It is made by a person with a current certificate of eligibility issued pursuant to Section 26710.
(c) It is made to a dealer.

[sbo80]

So the way I read that, is then someone with an 03/COE has a 5 limit, if those transfers are directly to another 03, or for non-C&Rs. But C&Rs transferred via PPT (meaning, through an 01), or sent to an 01 in another state*, have no limit. Kind of a weird result there. I can only sell 5 C&Rs directly to other 03s, but more than 5 if an 01 does the paperwork.
*(c) there doesn't say "CA dealer" or "license pursuant to Article 1...", it just says "dealer", so unless there's another definition that excludes other-state FFLs, I think it means you can transfer to them and it counts under (c).