Confirmed, multiple stripped/complete receivers don't need to be reported

[EBR Works]

Well, I have some disturbing information. I just spoke with an ATF representative at (202) 648-7190 and specifically asked her about stripped and complete lower receivers with no upper receiver attached. She put me on hold for a minute and came back and told me that stripped or complete AR style lower receivers without an attached upper receiver MUST be reported. I asked her if there was something in writing specifically outlining this requirement. She asked me to email them, which I did as follows:

'fipb@atf.gov'

To: ATF

RE: Reporting of multiple sale or disposition of certain rifles - receivers

In regard to lower receivers for AR style firearms. Does the multiple reporting requirement pertain to stripped or complete lower receivers that have no upper receiver attached at the time of transfer? These lower receivers are obviously not caliber specific and could be used with any AR style upper receiver.

Michael

EBR Works - Type 07 FFL/Class 2 SOT
877-905-2673 Voice
805-435-8009 Fax
info@ebrworks.com

https://www.ebrworks.com

I will post their response when I receive it...

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[BannedinBritain]

Not to be a negative Nelly...but sometimes not asking the question is the best action.

[EBR Works]

I had a client start transfer of two receivers, one stripped and one complete with a stock a few days ago, so this needs to be clarified from my perspective. If you were in the same situation, would you not want to know the requirements? Being violated by ATF and putting your business at risk because you want to avert your eyes seems a bit illogical.

That being said, this is an awful situation.

[tenpercentfirearms]

I had a client start transfer of two receivers, one stripped and one complete with a stock a few days ago, so this needs to be clarified from my perspective. If you were in the same situation, would you not want to know the requirements? Being violated by ATF and putting your business at risk because you want to avert your eyes seems a bit illogical.

That being said, this is an awful situation.

You simply follow what has already been published and don't worry about it.

http://www.atf.gov/forms/download/atf-f-3310-12.pdf

This form is to be used by licensees to report all transactions in which an unlicensed person acquired, at one time or during five consecutive business days, two or more
semi-automatic rifles larger than .22 caliber (including .223/5.56 caliber) with the ability to accept a detachable magazine. This form is not required when the rifles are
returned to the same person from whom they are received.

Receivers are not semi-automatic rifles. Odds are the woman you spoke to is issuing FUD as there is no way they are going to be able to justify that a receiver is a semi-automatic rifle based on their own definitions of rifles and how you are supposed to mark other on the 4473.

[EBR Works]

Just received an email back from them:

Thank you for your recent inquiry to the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF). This is in response to your email dated August 24, 2011, in which you inquired about the reporting requirements for the ATF Form 3310.12, specifically if lower receivers need to be reported.


Q2. What types of rifles are required to be reported?
A2. The rifle transactions that must be reported are dispositions of semiautomatic rifles capable of accepting a detachable magazine and with a caliber greater than .22 (including .223/5.56 caliber) to an unlicensed person. However, the reporting requirement does not apply to receivers for such rifles. You may contact the Firearms Technology Branch at (304) 616-4300 if you are unable to determine if the rifles are subject to the reporting requirements.

Please see the Questions and Answers on the ATF website to answer any questions you may have pertaining to the reporting requirements of certain rifles. A link to the Q&As is attached for your convenience: http://www.atf.gov/firearms/industry...ple-rifles.pdf.
We trust the foregoing has been responsive to your inquiry. Should you have additional questions, please contact your local ATF office. A listing of ATF office phone numbers can be found at: http://www.atf.gov/field.

Regards,
Firearms Industry Programs Branch, ATF

So, my verbal contact was wrong as Wes surmized. Call me Elmer FUD. Sorry to waste your time guys.
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[RazzB7]

Thanks for the speedy follow-up, EBR.

[tenpercentfirearms]

Just received an email back from them:

So, my verbal contact was wrong as Wes surmized. Call me Elmer FUD. Sorry to waste your time guys.
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It wasn't a waste of time. You confirmed what we already knew. I appreciate it.

Now had you caused them to stick to this line of reasoning and we had to start doing multiple sales on receivers, we would have tarred and feathered you!

[EBR Works]

It wasn't a waste of time. You confirmed what we already knew. I appreciate it.

Now had you caused them to stick to this line of reasoning and we had to start doing multiple sales on receivers, we would have tarred and feathered you!

Happy to be of service.

As to the tar/feather thing, I would have taken it like a man.
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[darkest2000]

Yeah when you poke the bear...

Might wanna update the thread title so you don't give off the wrong info to passerby s who didn't bother to read the entire thread.

[tenpercentfirearms]

Thanks for the confirmation! What a helpful thread!

[EBR Works]

Yeah when you poke the bear...

Might wanna update the thread title so you don't give off the wrong info to passerby s who didn't bother to read the entire thread.

Done.

Thanks for the confirmation! What a helpful thread!

I'm a giver..
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[bohoki]

what caliber do you put on the 4473?

seems to me if it doesn't have one its not a rifle its an "other"

[tenpercentfirearms]

what caliber do you put on the 4473?

seems to me if it doesn't have one its not a rifle its an "other"

Whatever caliber is stamped on the receiver or firearm. If there is nothing stamped on it, then I put "none".

I would highly recommend you not put receiver if you transfer a S&W M&P 15 rifle that doesn't have the caliber marked on the receiver. Lying and neglecting to fill out the form would really be a bad risk to take over an issue that really isn't hard for dealers to comply with.

I am not saying I enjoy the President abusing his authority, but he will be held accountable in due time. It just would be stupid for any of us to risk our freedom over this small issue when relief is probably on the way.

[kemasa]

I put "multi" for the caliber, which is what it can be.

BTW, when I talked to my BATF contact he had said what the answer was. Also, the interesting aspect to this is that if you take an AR type firearm and take the upper off of it, then it does not qualify for reporting. So, if you sold the upper separately, you would not need to report it, but it is playing games. If you had both on the same receipt, you could be asking for trouble. They might not get you on that, but they can look for anything else.

One funny comment was made that Nevada does not have to report multiple purchases, but Las Vegas is much closer to Mexico than many locations in CA. It should be by distance (if at all), not just by state, but it is easier to do it by state.