07 FFL question(s)

[Manpants]

Trying to understand the process of mfg an AR pistol as an 07 FFL.

If a shop holds an 07 and has custom mfg lower receivers stamped as such (AR pattern) and are logged into the A&D as "receiver" and an AR pistol is mfg from said rcvr with the build happening in the order of:

BB install > lpk > 0 rd sled > upper install then be DROS'd as pistol with cal. listed as multi as stamped on said rcvr or would the barrel then dictate the cal?

Also once DROS is complete logging out of the A&D not require any additional steps?

Am I missing something with the initial A&D logging and or order?

[scoutpup99]

According to my ATF inspector he said if you build a gun from a receiver that is manufactured by someone else, even if marked with your info, you have to log the receiver out to your 07ff and then log it back in as a pistol or rifle.

for example:
I get a receiver from JD Machine and have them file a marking variance with ATF. Once they ship me the receiver I have to log it in as a receiver from JD Machine with the make and model as listed on the receiver. Once I take that receiver and build it into a rifle or pistol I have to log it out first to my 07ffl. once it is logged out you have to log it back in under the manufactured entry.

Also per my ATF inspector as on 07 ffl you have to have a three entry bound book not a 2 like 01 dealers. By three entry I mean you have a section for received from, manufactured and disposition.

[lugnutwrench]

According to my ATF inspector he said if you build a gun from a receiver that is manufactured by someone else, even if marked with your info, you have to log the receiver out to your 07ff and then log it back in as a pistol or rifle.

for example:
I get a receiver from JD Machine and have them file a marking variance with ATF. Once they ship me the receiver I have to log it in as a receiver from JD Machine with the make and model as listed on the receiver. Once I take that receiver and build it into a rifle or pistol I have to log it out first to my 07ffl. once it is logged out you have to log it back in under the manufactured entry.

Also per my ATF inspector as on 07 ffl you have to have a three entry bound book not a 2 like 01 dealers. By three entry I mean you have a section for received from, manufactured and disposition.

scoutpup99, I'm a n00b when it comes to this stuff, but can I trouble you to walk through what you described? I'm familiar (in theory) with marking variances. Assuming the simplest case of buying a manufactured lower (e.g., a multi-caliber lower from Stag Arms), and then "manufacturing" a SSE AR pistol, an 07 has two options:

1. Mark the now-pistol lower with the 07's information (probably also marking the lower with the word "pistol" in the process, although I don't think this is required)
2. Seek approval for a marking variance from the ATF

In the first case, I'm assuming the 07 is ultimately responsible for maintaining all markings. Do you know if the 07 contracts out to Company X solely for the purpose of marking the firearm, does Company X have to be listed/require a variance?

In either case, what would the subsequent log entries look like, say, for the following lower received on 2012-01-01 by the 07 FFL # 9-77-XXX-XX-XX-99999 and manufactured into an AR pistol on 2014-01-01?

Aquisition
Manufacturer: Stag Arms
Model: SALWR
Serial #: 123456
Type of Action: receiver
Caliber: 5.56 NATO (as marked)
Date Acquired: 2012-01-01
Acquired From: Stag Arms LLC; FFL # 6-06-XXX-XX-XX-99999

[lugnutwrench]

Also, I'm assuming that before manufacturing anything, the 07 is also required to register with the DDTC (renewed annually). Do you know if that's right?

Sorry for all the questions. I really appreciate any guidance.

[Manpants]

According to my ATF inspector he said if you build a gun from a receiver that is manufactured by someone else, even if marked with your info, you have to log the receiver out to your 07ff and then log it back in as a pistol or rifle.

for example:
I get a receiver from JD Machine and have them file a marking variance with ATF. Once they ship me the receiver I have to log it in as a receiver from JD Machine with the make and model as listed on the receiver. Once I take that receiver and build it into a rifle or pistol I have to log it out first to my 07ffl. once it is logged out you have to log it back in under the manufactured entry.

Also per my ATF inspector as on 07 ffl you have to have a three entry bound book not a 2 like 01 dealers. By three entry I mean you have a section for received from, manufactured and disposition.

What we did was use the 2 entry book and logged in the rcvr. Then logged it out to ourselves. We then have a separate book marked as a Manufacturing book. We then logged it back in there as a pistol and will log it out as such upon DROS completion on the depo line.

All the things I bring up online have a different method with each having a different discussion with the ATF. I would think a different book for mfg would be easier for a no-notice. I would assume our company for private label already took care of the marking variance. They are marked only with our info.

[scoutpup99]

Aquisition
Manufacturer: Stag Arms
Model: SALWR
Serial #: 123456
Type of Action: receiver
Caliber: 5.56 NATO (as marked)
Date Acquired: 2012-01-01
Acquired From: Stag Arms LLC; FFL # 6-06-XXX-XX-XX-00729[/QUOTE]

Manufacturer: Stag Arms
Model: SALWR
Serial #: 123456
Type of Action: receiver
Caliber: 5.56 NATO (as marked)
Acquired From: Stag Arms LLC; FFL # 6-06-XXX-XX-XX-00729
Date Acquired: 2012-01-01
Disposition: Your 07 ffl info
Date Disposed: 1-1-14

Manufacturer: Your FFl Name (firearm must be remarked with your 07 info.)
Model: SALWR
Serial #: 123456
Type of Action: Pistol
Caliber: 5.56 NATO (as marked)
Acquired From: Your ffl info
Date Acquired: 2014-01-01

Any Firearm manufactured with a receiver that has not been sold via retail (01ffl) channels must have the manufacturer marks of the manufacturer who released it to retail channels, unless a marking variance has been issued by ATF. If you build a firearm from a receiver that has been released to retail channels you only have to put marks on the barrel like importers do. I.e. you bought it from another dealer.

That is my understanding of the marking issue based on my last atf inspector visit.



As for the department of state registration you are supposed to file with them each year. Supposedly there was going to be a change made to the ITAR registration requirements for items not for export. Not sure if the changes happened.

[scoutpup99]

All firearms an 07ffl manufactures(assembles) must have their markings unless a marking variance has been approved by the ATF.

[lugnutwrench]

Manpants and scoutpup99, thanks for entertaining the basic questions. That makes it much clearer now. If I find out anything more on the DDTC front, I'll post it here.

[lugnutwrench]

So far, my research says that an 07 FFL either needs to register with the DDTC ($2,250 annually), or receive a Common Jurisdiction exemption for each model manufactured. Some reading:

http://www.silencertalk.com/forum/viewtopic.php?f=4&t=45696

http://www.ar15.com/forums/t_6_44/352526_Do_07_FFL_s_need_to_pay_the_ITAR_fees_.html%26page=5

http://www.pmddtc.state.gov/commodity_jurisdiction/index.html

http://www.atf.gov/files/publications/newsletters/ffl/ffl-newsletter-2012-11.pdf

(See p. 3.)