SSE and FFL issues

[kemasa]

For those of you that are doing SSE modifications, you might want to check into the requirements with regards to your FFL and the firearm. I was talking to a person that I know at the BATF and this topic came up. Depending on how it is done, the person doing the conversion most likely would need to be an 07 FFL and also mark the firearm (there are means in which this can be done in an easy manner, but a variance would be needed).

I don't want to try to recall all the specifics as I might get it wrong, but the summary was that if the FFL is making the modification and selling the firearm, then they need to be an 07 FFL and also mark the firearm. There are three aspects, the modification, normal course of business and sale or distribution, which if all three are met, then the requirements apply.

If you do this, I would suggest that you look into this aspect.

[bandook]

(message deleted)

[kemasa]

(message deleted)

I am glad that you deleted your message since I got the notification of what you said and what you said was wrong.

Anyone can check with the BATF regarding what I am saying, which is what I am saying to do. The reason for my mentioning this I don't want anyone to get into trouble, so FFLs doing the SSE needs to do it right.

[Table Rock Arms]

This has been discussed a few times and you might be right. It depends on your interpretation of the ruling on drop in parts that I have attached. One thing I am not sure of is why you would need a marking variance however.

Ryan

[ke6guj]

i have mentioned this as a concern of mine for a while.

even making an offlist rifle CA-complaint with a maglock could be an issue.

But the word from "the right people" has been that if you take a complete firearm and just swap "drop-in" parts, that it isn't manufacturing and you don't have to be an 07, nor do you have to mark it.

[ke6guj]

This has been discussed a few times and you might be right. It depends on your interpretation of the ruling on drop in parts that I have attached. One thing I am not sure of is why you would need a marking variance however.

Ryan

because if you need to have an 07 so that you can re-manufacture that firearm into a SSE-firearm, based on previous ATF opinions, you would need to mark it with your info on it. ATF says that you can get a variance so that you don't have to mark something that you would normally need to, so long as they have a variance document that they have on file so they know which 07FFLs are actually involved in that firearm.

[jloffermann]

sse and markings like a stamp or engraving?

[ElvenSoul]

So what about revolvers going from DA to SA to get into CA?

[Table Rock Arms]

because if you need to have an 07 so that you can re-manufacture that firearm into a SSE-firearm, based on previous ATF opinions, you would need to mark it with your info on it. ATF says that you can get a variance so that you don't have to mark something that you would normally need to, so long as they have a variance document that they have on file so they know which 07FFLs are actually involved in that firearm.

A marking variance if for an FFL who performs work in the gun but does not intend to sell it.

[ElvenSoul]

Try this argument

When the US Army was using these

http://en.m.wikipedia.org/wiki/Pedersen_device

did they put new serial numbers on the rifles?

[kemasa]

This has been discussed a few times and you might be right. It depends on your interpretation of the ruling on drop in parts that I have attached. One thing I am not sure of is why you would need a marking variance however.

I am more or less just passing on what I have heard. You need to mark the firearm and you can make it anywhere, but generally manufacturing you have a new serial number, which you don't want to change, therefore the variance to be allowed to use the existing serial number. The markings can be anywhere and need not be on the frame, like on the barrel.

i have mentioned this as a concern of mine for a while.

even making an offlist rifle CA-complaint with a maglock could be an issue.

But the word from "the right people" has been that if you take a complete firearm and just swap "drop-in" parts, that it isn't manufacturing and you don't have to be an 07, nor do you have to mark it.

The key issue with a SSE, as I was told, is:

substantially the same dimensions

The barrel is not the same dimension at all, it is much longer.

The second issue is the magazine block, but personally I am not sure that it qualifies, but I have been told that it does:

does not result in any alteration to the original firearms so long as they are replacement parts. A replacement part, whether factory original or otherwise, has the same design, function, substantially the same dimensions, and does not otherwise affect the manner in which the weapon expels a projectile by the action of an explosive.

The magazine block could be viewed as an alteration and affects the functioning. I won't give my personal opinion on that :-).

One of the key factors is whether you are selling the firearm after the modification or if you are just doing work on it.

[kemasa]

So what about revolvers going from DA to SA to get into CA?

I don't know, that subject did not come up. The part is a factory part and about the same dimensions, so it might not qualify as manufacturing. I will try to remember to ask about that.

[kemasa]

A marking variance if for an FFL who performs work in the gun but does not intend to sell it.

There can also be other variances, such as being allowed to use the existing serial number on the firearm. As I understand it, it is a one time thing for the FFL, which would allow you to use the existing serial numbers, but you have to ask.

[Table Rock Arms]

I am more or less just passing on what I have heard. You need to mark the firearm and you can make it anywhere, but generally manufacturing you have a new serial number, which you don't want to change, therefore the variance to be allowed to use the existing serial number. The markings can be anywhere and need not be on the frame, like on the barrel.

I'm not saying your wrong as I understand you are just passing it along. I tought that you would not need a variance to use the serial number that is already on the gun. As for where engraving must go, I was under the impression that the serial number must be on the frame and the rest can be on either the frame or the barrel.

[kemasa]

I'm not saying your wrong as I understand you are just passing it along. I tought that you would not need a variance to use the serial number that is already on the gun.

I was told that you need a variance to use the serial number already on it. That is something to check on, but as I said, it is not a big deal and a one time thing to get permission, then you can do it on multiple firearms.

As for where engraving must go, I was under the impression that the serial number must be on the frame and the rest can be on either the frame or the barrel.

That is what I was told. If you stamp it on the barrel, it is easy.