# ATF To Expand Definition Of A Regulated Firearm Receiver



## RedLion (Sep 23, 2015)

The coming illegal BS.

An internal Department of Justice document explaining how the Biden Administration plans to restrict so-called ghost guns was leaked on Tuesday. The 107-page document, obtained by The Reload, outlines changes the Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF) wants to make to outlaw the sale of homemade gun kits by unlicensed manufactures. At the direction of President Joe Biden, the agency plans to propose federal rule changes, which would require anyone selling unfinished firearms receivers to obtain a federal license and mark the parts with a serial number. Anyone who continues to sell unfinished receivers without a license could face federal felony charges.

It then says any unfinished part that “may readily be converted” into a receiver must be treated as a receiver and requires sellers to obtain federal licenses, mark the unfinished parts with serial numbers, and perform background checks on buyers. The proposal provides only subjective standards for what makes an unfinished part “readily” convertible into a finished firearm but provides footnotes to court cases where the term has been applied. One court example included in the document said a part completed in “around an eight-hour working day in a properly equipped machine shop” was considered “readily” convertible. The only example of a ruling defining when a part is not “readily” convertible involved a process that “required [a] master gunsmith in a gun shop and $65,000 worth of equipment and tools.”


----------



## Kauboy (May 12, 2014)

I tried to read the beginning of the document, and I'm still working my way through it, but it looks to me as if they will only be able to target people who are selling the "readily convertible" kits and parts.
Did anyone see any mention of personally built guns meant for self ownership?
I've not seen anything yet that would prevent me from manufacturing my own guns, as long as I am not looking to transfer them to anyone else.
I just won't be able to buy a "readily convertible" frame/receiver without a 4473.
But I think I can still make my own from scratch.

If I'm wrong, and this is taking aim at that too, please point me to the page/section.

Yeah, it's an unholy infringement any way you look at it, but I'm just curious how far it really goes.


----------



## Back Pack Hack (Sep 15, 2016)

I think they're trying to target the sale of entire buy/build/shoot kits. A single SKU with everything needed.... the 80% receiver, the jig, the mill bits, and all the other parts necessary to complete a functional firearm.

They apparently don't have the wherewithall to figure out that buying the parts individually accomplished the same thing.


----------



## RedLion (Sep 23, 2015)

The big piece is trying to ma.ke it so that you will not be able to buy any 80% receivers without a back ground check or without that receiver being serialized. Other parts being serialized is another crazy part


----------



## Kauboy (May 12, 2014)

RedLion said:


> The big piece is trying to ma.ke it so that you will not be able to buy any 80% receivers without a back ground check or without that receiver being serialized. Other parts being serialized is another crazy part


I tend to agree with @Back Pack Hack on that. The wording suggests they are only trying to impact 80% receivers when they are part of a full build kit.
Without the rest of the parts, an 80% receiver isn't able to "readily be assembled, completed, converted, or restored to expel a projectile by the action of an explosive".
Yes, it can be made into a "firearm", but that doesn't meet the full definition of the regulation. It needs to be able to expel a projective via an explosive.

It looks like 80% lowers sold by themselves are not being explicitly targeted by this. Though I'm sure the ATF will still try to group them in.


----------



## RedLion (Sep 23, 2015)

Kauboy said:


> I tend to agree with @Back Pack Hack on that. The wording suggests they are only trying to impact 80% receivers when they are part of a full build kit.
> Without the rest of the parts, an 80% receiver isn't able to "readily be assembled, completed, converted, or restored to expel a projectile by the action of an explosive".
> Yes, it can be made into a "firearm", but that doesn't meet the full definition of the regulation. It needs to be able to expel a projective via an explosive.
> 
> It looks like 80% lowers sold by themselves are not being explicitly targeted by this. Though I'm sure the ATF will still try to group them in.


Nope. They want all receivers serialized.

The new proposal would require the individual who builds a firearm to engrave a serial number within 7 days of completion


----------



## Kauboy (May 12, 2014)

RedLion said:


> Nope.
> 
> The new proposal would require the individual who builds a firearm to engrave a serial number within 7 days of completion


That applies to FFLs who receive a "privately made firearm", since they are a licensee that must only deal in serialized firearms.



> Page 40
> 4. Marking of privately made firearms
> Because privately made firearms do not have the identifying markings required of
> commercially manufactured firearms, this rule proposes to amend 27 CFR 478.92 to
> ...


It also applies to any non-FFLs who sell kits which include partially completed frames or receivers.
But they specifically point out that these non-FFLs would likely not incur a significant cost, as they would either simply become FFLs (allowing them to sell firearms, or readily convertible parts kits) or stop selling the kits with the frames/receivers, or just sell the frames/receivers by themselves.



> Page 56
> 2. Partially Complete Firearm Kits
> This section addresses non-FFL manufacturers who manufacture partially
> complete, disassembled, or inoperable frame or receiver kits, to include both firearm
> ...


I have not found anything to suggest that a PMF must have a serial number when made and owned by a private citizen.


----------



## RedLion (Sep 23, 2015)

Kauboy said:


> That applies to FFLs who receive a "privately made firearm", since they are a licensee that must only deal in serialized firearms.
> 
> 
> 
> ...


You must have missed the part that I quoted? Would require "the individual who builds the firearm" to engrave a serial number within 7 days of completion. Not FFL, but anyone building a receiver and firearm, that includes an individual not selling.
The powers that be want as much control and restriction as they can steal.


----------



## Kauboy (May 12, 2014)

RedLion said:


> You must have missed the part that I quoted? Would require "the individual who builds the firearm" to engrave a serial number within 7 days of completion. Not FFL, but anyone building a receiver and firearm, that includes an individual not selling.
> The powers that be want as much control and restriction as they can steal.


You quoted a statement from an article. (an article I can't get to through my work's internet filter at the moment)
Please quote the actual document, and I will gladly take a look.
The phrase "the individual who builds the firearm" is not found within the document itself.


----------



## RedLion (Sep 23, 2015)

Kauboy said:


> You quoted a statement from an article. (an article I can't get to through my work's internet filter at the moment)
> Please quote the actual document, and I will gladly take a look.
> The phrase "the individual who builds the firearm" is not found within the document itself.


Sure it is you just have to dig more. I trust the source I quoted. You are welcome to dig through the entire doc.


----------



## Back Pack Hack (Sep 15, 2016)

I guess I should start serializing all my metal coat hangers and belt loops.

Plus: Given I've built fully-functional firearms in less than two hours using nothing more than some plumbing and hardware items from Home Depot, does that mean I'll have to fill out a 4473 when I buy brass nipples and ¼x20 machine bolts?


----------



## Kauboy (May 12, 2014)

RedLion said:


> Sure it is you just have to dig more. I trust the source I quoted. You are welcome to dig through the entire doc.


I did. I searched for your phrase, and a few variations of it using the built in search function. The phrase you quoted is not present.
Did your source reference the section or page of the document that they found this on?


----------



## RedLion (Sep 23, 2015)

Any completed receiver is a completed firearm per law. This passage backs up what the article I quoted said.

D. Definitions of “complete weapon” and “complete muffler or silencer device” This proposed rule would add definitions for “complete weapon” and “complete muffler or silencer device” to 27 CFR 478.11 and 479.11. A “complete weapon” would 51 See United States v. Dodson, 519 F. App’x 344, 352–53 (6th Cir. 2013) (gun that was restored with 90 minutes of work, using widely available parts and equipment and common welding techniques, fit comfortably within the readily restorable standard); United States v. TRW Rifle 7.62x51mm Caliber, 447 F.3d 686, 692 (9th Cir. 2006) (a two-hour restoration process using ordinary tools, including a stick weld, is within the ordinary meaning of “readily restored”); United States v. Mullins, 446 F.3d 750, 756 (8th Cir. 2006) (a starter gun that can be modified in less than one hour by a person without any specialized knowledge to fire may be considered “readily convertible” under the GCA); United States v. One TRW, Model M14, 7.62 Caliber Rifle, 441 F.3d 416, 422–24 (6th Cir. 2006) (“[T]he Defendant weapon here had all of the necessary parts for restoration and would take no more than six hours to restore.”); United States v. Woods, 560 F.2d 660, 664 (5th Cir. 1977) (holding that a weapon was a shotgun within the meaning of 26 U.S.C. 5845(d) and stating “[t]he fact that the weapon was in two pieces when found is immaterial considering that only a minimum of effort was required to make it operable.”); United States v. Smith, 477 F.2d 399, 400–01 (8th Cir. 1973) (machinegun that would take around an eight-hour working day in a properly equipped machine shop was readily restored to shoot); United States v. 16,179 Molso Italian .22 Caliber Winler Derringer Convertible Starter Guns, 443 F.2d 463 (2d Cir. 1971) (starter guns converted in no more than 12 minutes to fire live ammunition were readily convertible under the GCA); United States v. Morales, 280 F. Supp. 2d 262, 272–73 (S.D.N.Y. 2003) (partially disassembled Tec-9 pistol that could be assembled within a short period of time could readily be converted to expel a projectile); United States v. Catanzaro, 368 F. Supp. 450, 453 (D. Conn. 1973) (a sawed-off shotgun was “readily restorable to fire” where it could be reassembled in one hour and the necessary missing parts could be obtained at a Smith & Wesson plant); compare with United States v. Seven Miscellaneous Firearms, 503 F. Supp. 565, 574–75 (D.D.C. 1980) (weapons could not be “readily restored to fire” when restoration required master gunsmith in a gun shop and $65,000 worth of equipment and tools).Definition of Firearm “Frame or Receiver” and Identification of Firearms - NPRM Draft Predecisional/Deliberative- For Internal Review Only and Not for Public Distribution 34 be defined as “a firearm other than a firearm muffler or firearm silencer that contains all component parts necessary to function as designed whether or not assembled or operable.” Likewise, a “complete muffler or silencer device” would be defined as “a firearm muffler or firearm silencer that contains all of the component parts necessary to function as designed whether or not assembled or operable.” These definitions are needed to explain when a frame or receiver of a firearm, including a firearm muffler or silencer, as the case may be, must be marked.


----------



## Kauboy (May 12, 2014)

RedLion said:


> Any completed receiver is a completed firearm per law. This passage backs up what the article I quoted said.
> 
> D. Definitions of “complete weapon” and “complete muffler or silencer device” This proposed rule would add definitions for “complete weapon” and “complete muffler or silencer device” to 27 CFR 478.11 and 479.11. A “complete weapon” would 51 See United States v. Dodson, 519 F. App’x 344, 352–53 (6th Cir. 2013) (gun that was restored with 90 minutes of work, using widely available parts and equipment and common welding techniques, fit comfortably within the readily restorable standard); United States v. TRW Rifle 7.62x51mm Caliber, 447 F.3d 686, 692 (9th Cir. 2006) (a two-hour restoration process using ordinary tools, including a stick weld, is within the ordinary meaning of “readily restored”); United States v. Mullins, 446 F.3d 750, 756 (8th Cir. 2006) (a starter gun that can be modified in less than one hour by a person without any specialized knowledge to fire may be considered “readily convertible” under the GCA); United States v. One TRW, Model M14, 7.62 Caliber Rifle, 441 F.3d 416, 422–24 (6th Cir. 2006) (“[T]he Defendant weapon here had all of the necessary parts for restoration and would take no more than six hours to restore.”); United States v. Woods, 560 F.2d 660, 664 (5th Cir. 1977) (holding that a weapon was a shotgun within the meaning of 26 U.S.C. 5845(d) and stating “[t]he fact that the weapon was in two pieces when found is immaterial considering that only a minimum of effort was required to make it operable.”); United States v. Smith, 477 F.2d 399, 400–01 (8th Cir. 1973) (machinegun that would take around an eight-hour working day in a properly equipped machine shop was readily restored to shoot); United States v. 16,179 Molso Italian .22 Caliber Winler Derringer Convertible Starter Guns, 443 F.2d 463 (2d Cir. 1971) (starter guns converted in no more than 12 minutes to fire live ammunition were readily convertible under the GCA); United States v. Morales, 280 F. Supp. 2d 262, 272–73 (S.D.N.Y. 2003) (partially disassembled Tec-9 pistol that could be assembled within a short period of time could readily be converted to expel a projectile); United States v. Catanzaro, 368 F. Supp. 450, 453 (D. Conn. 1973) (a sawed-off shotgun was “readily restorable to fire” where it could be reassembled in one hour and the necessary missing parts could be obtained at a Smith & Wesson plant); compare with United States v. Seven Miscellaneous Firearms, 503 F. Supp. 565, 574–75 (D.D.C. 1980) (weapons could not be “readily restored to fire” when restoration required master gunsmith in a gun shop and $65,000 worth of equipment and tools).Definition of Firearm “Frame or Receiver” and Identification of Firearms - NPRM Draft Predecisional/Deliberative- For Internal Review Only and Not for Public Distribution 34 be defined as “a firearm other than a firearm muffler or firearm silencer that contains all component parts necessary to function as designed whether or not assembled or operable.” Likewise, a “complete muffler or silencer device” would be defined as “a firearm muffler or firearm silencer that contains all of the component parts necessary to function as designed whether or not assembled or operable.” These definitions are needed to explain when a frame or receiver of a firearm, including a firearm muffler or silencer, as the case may be, must be marked.


What you've quoted is a definition, but it does not state that individuals must mark privately made firearms.
It covers all scenarios where a firearm must be marked, as they are needed now, to cover things that can be readily convertible.
But it still only covers when licensees do it, or when non-licensees sell kits or partially completed receivers.

Did you read my quoted passages? They specifically denote that the marking of PMFs only need to be done by FFLs when they are received, or when non-FFLs sell kits that include partially complete receivers/frames.


----------



## RedLion (Sep 23, 2015)

Kauboy said:


> What you've quoted is a definition, but it does not state that individuals must mark privately made firearms.
> It covers all scenarios where a firearm must be marked, as they are needed now, to cover things that can be readily convertible.
> But it still only covers when licensees do it, or when non-licensees sell kits or partially completed receivers.
> 
> Did you read my quoted passages? They specifically denote that the marking of PMFs only need to be done by FFLs when they are received, or when non-FFLs sell kits that include partially complete receivers/frames.


No. It states a change that all completed firearms need to be marked whether assembled or not. It is currently not required to "mark" or serialize a receiver completed by an individual not intending to sell.


----------



## Kauboy (May 12, 2014)

RedLion said:


> No. It states a change that all completed firearms need to be marked whether assembled or not. It is currently not required to "mark" or serialize a receiver completed by an individual not intending to sell.


It is not stating a change in the manner you are presenting.
It is stating a change to identify when certain types of non-complete/non-functioning firearms, that can be readily converted to complete weapons, must be marked.
It does not address, in any terms, privately made firearms. The examples are all pre-existing, but non-functioning, firearms.


----------



## RedLion (Sep 23, 2015)

Kauboy said:


> It is not stating a change in the manner you are presenting.
> It is stating a change to identify when certain types of non-complete/non-functioning firearms, that can be readily converted to complete weapons, must be marked.
> It does not address, in any terms, privately made firearms. The examples are all pre-existing, but non-functioning, firearms.


Yes it does state what I say. You are not reading it correctly.


----------



## RedLion (Sep 23, 2015)

Without all of the footnotes.

D. Definitions of “complete weapon” and “complete muffler or silencer device” This proposed rule would add definitions for “complete weapon” and “complete muffler or silencer device” to 27 CFR 478.11 and 479.11. A “complete weapon” would….. be defined as “a firearm other than a firearm muffler or firearm silencer that contains all component parts necessary to function as designed whether or not assembled or operable.” Likewise, a “complete muffler or silencer device” would be defined as “a firearm muffler or firearm silencer that contains all of the component parts necessary to function as designed whether or not assembled or operable.” These definitions are needed to explain when a frame or receiver of a firearm, including a firearm muffler or silencer, as the case may be, must be marked.


----------



## Kauboy (May 12, 2014)

RedLion said:


> Without all of the footnotes.
> 
> D. Definitions of “complete weapon” and “complete muffler or silencer device” This proposed rule would add definitions for “complete weapon” and “complete muffler or silencer device” to 27 CFR 478.11 and 479.11. A “complete weapon” would….. be defined as “a firearm other than a firearm muffler or firearm silencer that contains all component parts necessary to function as designed whether or not assembled or operable.” Likewise, a “complete muffler or silencer device” would be defined as “a firearm muffler or firearm silencer that contains all of the component parts necessary to function as designed whether or not assembled or operable.” These definitions are needed to explain when a frame or receiver of a firearm, including a firearm muffler or silencer, as the case may be, must be marked.


Yes, they "must be marked" when converted to a "complete weapon" from a non-functioning/non-complete (but pre-existing) firearm.
It says nothing about the making of a new firearm by a private citizen. Their own examples only refer to pre-built, but non-functioning, firearms that were later determined to be "readily convertible" in court.
In every instance where the regulation intends to affect "privately made firearms" (PMFs), they are expressly stated as being the target of the section.
This section does not do so.
It is simply a definition for a "complete weapon" or "complete muffler or silencer device".
To find the appropriate sections discussing the markings, you have to keep reading, and I provided an expressly stated quote above that clearly provides for the "Marking of privately made firearms " found on page 40.
It explicitly details that, due to privately made firearms NOT requiring marking, that when an FFL receives such a firearm, they must mark it within 7 days, destroy it, or turn it over to law enforcement.


----------



## RedLion (Sep 23, 2015)

No. Any completed firearm, including receivers must be marked. You must be reading something different than I am or that the article quoted read.


----------



## Kauboy (May 12, 2014)

RedLion said:


> No. Any completed firearm, including receivers must be marked. You must be reading something different than I am or that the article quoted read.


I'll direct your attention to page 42:



> Page 42
> At the same time, consistent with the intent of the GCA,
> *nothing in this rule would impose any undue or*
> *unnecessary Federal restrictions or burdens on law-abiding citizens to make their own*
> ...


What say you?


----------



## RedLion (Sep 23, 2015)

Kauboy said:


> I'll direct your attention to page 42:
> 
> 
> 
> What say you?


It is misleading, as is always consistent with the ATF. The goal as stated is to have all receivers serialized. When all receivers, 80% lowers and maybe less finished products are required to be serialized just to sell how are you going to get an unfinished product to finish at home short of buying aluminum in long bar stock, cutting to size and then finishing. Of course this always has been possible.
Of course if you go through all the hassle of the difficult way, then of course you will not have to serialize it.

The examples in the proposed rule will outlaw ALL lower receivers and build kits period.

Read more: https://www.ammoland.com/2021/04/atfs-new-rules-take-on-ghost-guns-serializing-blocks-metal/#ixzz6siQK58PF Under Creative Commons License: Attribution Follow us: @Ammoland on Twitter | Ammoland on Facebook The document does highlight the need for a complete machine shop, and qualified workers to complete a firearm would not fall under the proposed rules. The document would mean new 80% AR-15 lower receivers #ad, chunks of metal, would need a serial number and require the buyer to obtain a background check before the seller could transfer it because it could be “easily” convertible with “readily available” tools.

The examples provided in the document show the proposed rule would likely outlaw the sale of any unfinished receiver, especially when included in a kit with other parts and instructions or tools needed to complete the part. That’s because most unfinished parts sold in America today, including so-called 80% AR-15 lowers, can be finished at home in a few hours with commonly available tools like drill presses and compact mills.

In fact, this would have a far reaching impact throughout the entire industry. Under this language, all forgings would be required to be serialized from the forge before being sold to manufacturers like BCM, Aero, Colt, or anyone else. Lots of smaller manufacturers actually purchase 80% lowers in bulk and machine from there, and this would directly impact their ability to manufacture their firearms as well.


----------



## Kauboy (May 12, 2014)

I'm leary of interpretations from websites that don't employ lawyers to describe the impact.
My own interpretation could be wrong, but I'm not finding anything to support the idea that all 80% lowers will now require serial numbers when sold by themselves.
I don't rely on internet articles when they won't bear the burden of my charges if I follow their bad advice.
I need to see it in writing in the regulatory language as finalized.
Looking at this document, I don't agree with the interpretation that these articles are concluding.

And my original point about homemade firearms still stands, that an individual can indeed still make a firearm without serialization.


----------



## rice paddy daddy (Jul 17, 2012)

So, what would this mean for the muzzle loading black powder rifle kits sold by Dixie gunworks?
They come all machined, but in parts for the customer to assemble himself.


----------



## Ranger710Tango (Feb 27, 2021)

This won’t affect me but I still oppose all gun legislation or actions/orders

Some do not care about gun legislation or executive actions taken on guns or accessories if it doesn’t affect them, bump stocks for example.

In my opinion that’s the wrong attitude toward the subject.


----------



## 2020 Convert (Dec 24, 2020)

Ranger710Tango said:


> This won’t affect me but I still oppose all gun legislation or actions/orders
> 
> Some do not care about gun legislation or executive actions taken on guns or accessories if it doesn’t affect them, bump stocks for example.
> 
> In my opinion that’s the wrong attitude toward the subject.


Wrong attitude. I have seen what they will do.

You can go to the local store, go to the shelf and pick up a box of ammo. The last box of ammo I bought in my state, someone had to pick it up out of the case and I couldn’t touch it until I paid for it.

Now if I choose to buy Ammo in my state, I have to wait and pay for a background check. They are tracking what you are buying And comparing to what guns they know you have.

By saying it doesn’t affect me, you are giving them the power to control you.

I will liken your attitude to the German people that weren’t Jewish. How did that work out?


----------



## Kauboy (May 12, 2014)

2020 Convert said:


> Wrong attitude. I have seen what they will do.
> 
> You can go to the local store, go to the shelf and pick up a box of ammo. The last box of ammo I bought in my state, someone had to pick it up out of the case and I couldn’t touch it until I paid for it.
> 
> ...


I think you misunderstood his point.
He will not personally be affected by this change because he won't engage in sale/purchase of the impacted items, but STILL opposes all gun control.
He knows that it WILL affect someone's rights, and it is another step down the slippery slope.


----------



## Kauboy (May 12, 2014)

rice paddy daddy said:


> So, what would this mean for the muzzle loading black powder rifle kits sold by Dixie gunworks?
> They come all machined, but in parts for the customer to assemble himself.


I'm not familiar with the current laws concerning muzzle loading kits, but it sounds like they would be affected by this change too.
They would fall under their new interpretation of the definition of a "firearm".



> Page 19:
> A. Definition of “Firearm”
> Under the GCA and implementing regulations, the term “firearm” includes:
> “(A) any weapon (including a starter gun) which *will or is designed to *or *may readily be
> ...


It looks like they are targeting all kits.
An 80% lower, by itself, cannot meet this interpretation, as it cannot be "readily converted to expel a projectile by the action of an explosive" without additional parts.
If it's not included in a kit, it doesn't look like it would apply.


----------



## Ranger710Tango (Feb 27, 2021)

I’m going to ask a lawyer in my group to break it down for me. If anything ever came up it’s who I’d call so it would probably be good for me to get his explanation of the new regulations coming. He works with federal and local prosecutors so he can get their interpretation as well.


----------



## Kauboy (May 12, 2014)

Ranger710Tango said:


> I’m going to ask a lawyer in my group to break it down for me. If anything ever came up it’s who I’d call so it would probably be good for me to get his explanation of the new regulations coming. He works with federal and local prosecutors so he can get their interpretation as well.


I'd appreciate hearing their interpretation.
Primarily how this appears to impact unfinished receivers currently considered to not be "firearms".
If you don't mind, can you let us know what you learn?


----------



## 2020 Convert (Dec 24, 2020)

Kauboy said:


> I think you misunderstood his point.
> He will not personally be affected by this change because he won't engage in sale/purchase of the impacted items, but STILL opposes all gun control.
> He knows that it WILL affect someone's rights, and it is another step down the slippery slope.


I don’t own an AR-14 as Alzheimer Joe calls it. Never saw a need. Been thinking about an AR-10.

Because of the Draconian laws in the Kommunist Republik, way too many hoops to jump through. I would be better off buying a cheap 308, to let them come confiscate. I could buy ammo locally and have what I want after getting a kit.

If we don’t stand together on this issue, the current administration (full of people from the Kommunist Republik) are going to chip away until he can’t go pick up a box of ammo off the shelf, has to get a background check and be like the people in the Kommunist Republik. NJ is already proposing a similar law.

I was ACTUTALLY looking looking out for his simplistic way of thinking.


----------



## Ranger710Tango (Feb 27, 2021)

Kauboy said:


> I'd appreciate hearing their interpretation.
> Primarily how this appears to impact unfinished receivers currently considered to not be "firearms".
> If you don't mind, can you let us know what you learn?


I sure will. I’m going to text him tomorrow but it may take a few days got him to read and get back to me. Trial cases have picked back up since Covid eased up so he’s busy.


----------



## Kauboy (May 12, 2014)

@RedLion, after getting on my personal computer, I read the articles you linked to.
They do not provide any references to sections of the document that would support the claim that an 80% lower sold as a single item would be changing in any way.
The section I quoted in post #7 addresses "partially complete frame or receiver parts kits", and that these "kits" will require a mark once they reach a certain stage.

Again, this is not describing an 80% lower sold as a single item, but as a kit that the buyer would use to complete the receiver. (including all/some necessary jigs, bits, etc...)
If the non-FFL manufacturer wishes to sell full kits for the at-home buyer to complete, they would now be required to mark the incomplete frame/receiver.
This will simply create a division in the selling community where one seller sells the 80% lower, and another seller sells the remainder of the kit. Nothing would need to be marked in this case.


----------



## Ranger710Tango (Feb 27, 2021)

I sent the text this morning and the Lawyer acknowledged he received it.

I’ll give him a few days to check into it then start bugging him.


----------

