AR Stripped Lowers on 4473 forms

[novalondon]

I am a 07FFL in Arizona and need info on your state laws on Stripped AR Lowers when 4473 forms are completed in California.

Can a buyer in Ca. have the lower listed as a "RECEIVER" on the 4473 when first purchased as a new never built on part?
If so, can they, the buyer then build it into a AR pistol and be within the laws of California.
Here in Arizona I list all new Stripped lowers as receivers when they are sold on the 4473 and then they are built into whatever the buyer wants, rifle or pistol. I provide a copy of the 4473 to the buyer so if contacted by LEOs they can show proof the pistol build was done on a legal lower and not a converted rifle lower.
I have not had a problem doing this here in a quote- Free State !
I see several questions on this site asking this and looking to have 07ffls build single shots with bullit buttons installed for intial purchase and then making them a max 10 shot once it is in private ownership.
Any FFL care to answer who has knowledge in this?

[Mssr. Eleganté]

Ever since they changed the Form 4473 in 2008, ATF has required all FFLs to list stripped lowers as "Other Firearm (Frame, Receiver, etc.)", even if the buyer is planning to build a rifle out of it. So yes, California FFLs list them the same way you do on the Form 4473.

The problem is that California has an additional layer of paperwork because of our DROS (dealer's record of sale) system. The DROS system only has two choices for listing firearms that are sold, "handgun" and "long gun". FFLs here have to transfer stripped lowers as "long guns" if they want to avoid the California safe handgun roster. The legal eagles here on Calguns feel that DROSing a receiver as a "long gun" might taint that receiver forever as a long gun. At this time they recommend that we don't build handguns on a receiver DROSed as "long gun".

The reason people want 07 FFLs to build a virgin lower into a single shot handgun is because that is one way to get around our safe handgun roster. Single shot handguns that meet certain dimensional requirements are exempt from the safe handgun roster. That means a California FFL can DROS a single shot AR pistol as a "handgun". Once you own a single shot handgun in California there is no law against altering it into a configuration that would not be exempt from the roster. So after the buyer takes it home from the FFL they are free to replace the fixed single shot "SLED" with a fixed 10 round magazine.

[novalondon]

Thanks for the quick reply and the explanation of your DROS system. I did not understand even what it meant, let alone on how it operated. I really feel for you guys over there. Sorry you have to do all the hoop jumping to do what we here take for granted right now.