18 January 2023

Speculation

There's precedent, so you might be OK: but...

ATF might not have the power to waive the fee to register the SBR-you-thought-was-a-pistol.

The power to do an amnesty is part of the law, and their regulation reversing their previous regulation doesn't appear to conform to that.

Never mind that there's a lawyer's bonanza in the semantics of the situation as well.

Registration is allowed for two situations.

If you're making an NFA item and if you're receiving an NFA item.

If YOU added a pistol brace to your pistol, then you made it, fill out Form 1 and you should be good.  Oh, and don't forget to get it engraved with your information.

But what if you bought it already made?

That should have been on a Form 4.

The lawyers will be debating this.

It appears that ATF is going to allow Form 1 registration of guns shipped in that configuration from the factory.

DON'T FORGET TO HAVE IT ENGRAVED WITH YOUR INFORMATION!

The potential trap here is ATF might not have the power to offer what they're offering and that an NFA amnesty is required to let you off the hook.

They sure as shit don't want to do one of those because there will be a flurry of people "finding" a drop-in auto-sear, lightning link or "I just noticed that extra hole in my receiver, isn't that odd?"

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