SSE: "Manufacturing" and Complete off roster Frames

[JaeOne3345]

Hi,

I have spent quite some reading information regarding the SSE process. I already own an STI that I use for competition that was done through the SSE as a single shot conversion.

I have acquired a Pachmayr Dominator single shot conversion kit for use on a complete 1911/2011 STI frame.

I have a local 01 FFL who is willing to help me through the process so I do not have to use who I used before (3 hour drive).

What exactly constitutes "manufacturing," and the necessity of a 07 FFL to do the conversion first? The Dominator kits attaches onto any frame and no smithing is needed. Nothing is cut/modified. (Yes I have searched and am still confused on the meaning).

If the assembled frame is shipped to my 01 FFL , and I give him the Dominator kit/slide to install on the frame before he starts my DROS, are we in the clear? Or are we "manufacturing?"

This is the type of kit in question. It blocks the magazine well also.



According to the following thread and advice from bweise, I think we are clear:

http://www.calguns.net/calgunforum/showthread.php?t=524638

What's the 49 per year rule all about? I know for a fact my FFL probably does more than 49 transfers per year, but they are all typical roster type transfers. He has done zero transfers of this type (SSE).

[kemasa]

There is no real answer to the question since it really depends on what exactly is done, by whom and who is making the determination.

Based on some of the BATF FAQ, it is be considered manufacturing, but doing it once is not. If the person doing the conversion is the FFL who doing the transfer, they could be considered doing it for sale, which means it could be manufacturing.

In other words it is best if someone else does the conversion :-).

[JaeOne3345]

What if we kept a paper trail of receipts for the frames I am ordering from the out of state seller, that prove he (my FFL) is not the one selling me the frames?

[kemasa]

The problem is that who pays is not the issue. The FFL having it, making the changes and then doing the transfer is, as well as even selling it to another FFL.

Look at the FAQs for manufacturing, it just does not make sense really.

[JaeOne3345]

Thanks for the advice. He told me he only wants to do it for me 1 or two times to help me out and that's it. I am not looking to push the issue any further.

[kemasa]

I was told that 1 time was fine, 2 times perhaps not, 3 times you are manufacturing. It is a gray area, to say the least.

[echoarms]

My local ATF tech guy said no. Altering a frame into a functioning gun is manufacturing.

[kemasa]

I have been told otherwise, but all the parts have to be the property of the owner of the firearm.