Legal: Here's a recent (and nasty) ATF letter- pre-Ban receiver status

[EMDII]

********************************************
DEPARTMENT OF THE TREASURY
BUREAU OF ALCOHOL, TOBACCO AND FIREARMS
WASHINGTON, DC 20226

NOV 1 6 2001

Dear Mr. XXXXXXXXXX:

This refers to your letter of March 19, 2001, in which you ask about the status of certain semiautomatic assault weapons which have been altered to another configuration.

As defined in section 921(a)(30), of Title 18, United States Code (U.S.C, the term "semiautomatic assault weapon" includes certain named weapons and certain semiautomatic rifles, pistols, and shotguns that have a combination of enumerated features. Title 18 U.S.C. section 922(v)(1) prohibits manufacture, transfer, and possession of semiautomatic assault weapons; however, section 922(v)(2) provides that any semiautomatic assault weapon that was lawfully possessed under Federal law on September 13, 1994, is excluded from the prohibition.

A frame or receiver of a semiautomatic assault weapon, meets the definition of a "firearm" in 18 U.S.C. section 921(a)(3); however, a firearm frame or receiver alone, without the additional qualifying features, does not meet the definition of a "semiautomatic assault weapon" in section 921(a)(30). Therefore, a firearm frame or receiver does not meet the exemption in section 922(v)(2).

We have also determined that a semiautomatic assault weapon in knockdown (unassembled) condition consisting of a receiver and all parts needed to assemble a complete semiautomatic assault weapon are subject to regulation if the parts are segregated or packaged together and held by a person as the parts for the assembly of a particular firearm.

You describe an AR15 type rifle that met the definition of a semiautomatic assault weapon and was lawfully possessed on September 13, 1994. At some subsequent time the rifle was temporarily reassembled in a configuration such that it no longer had the qualifying features of a semiautomatic assault weapon. You asked if the original components could then be lawfully reinstalled on the rifle.

Provided that the original components were held by the owner and reinstalled on the rifle, it is our opinion that the rifle would still qualify as an exempted semiautomatic assault weapon even though it had been temporarily assembled in a different configuration. We note, that mere disassembly of a semiautomatic weapon by an owner would not remove the firearm from the definition of a semiautomatic assault weapon nor would the reassembly constitute manufacture of a prohibited semiautomatic assault weapon.

Your second question concerns a semiautomatic assault weapon that also meets the exemption in section 922(v)(2). However, this firearm was disassembled and the receiver, without other components, was sold. Since the receiver is no longer possessed with all parts necessary to assemble a complete semiautomatic assault weapon, it no longer meets the definition of a semiautomatic assault weapon. The receiver does not meet the exemption in section 922(v)(2) and assembly of this firearm in the configuration of a semiautomatic assault weapon would be prohibited under section 922(v)(1).

If you are interested in determining the status of a particular receiver or semiautomatic assault weapon, you should contact the manufacturer or importer and ask about the date that it was manufactured and the configuration at the time of sale. It may also be necessary to contact subsequent dealers and owners who possessed the firearm.

We regret the delay in responding to your inquiry. If you have further questions concerning this matter, please contact us.


Sincerely yours,

Curtis H.A. Bartlett
Chief, Firearms Technology Branch

Ergo: ATF says a pre-Ban receiver sold 'solo' is NO LONGER pre-Ban! WTH!

[Sand Pirate]

Wow, that's a neat trick. If I possess a Colt Sporter and full-auto fire control parts, ATF says I have "constructive possession of a machine gun", even though I don't possess a machine gun.

How convenient that possession of a pre-ban receiver and all the parts to build it into a functioning rifle don't qualify as "constructive possession of a grandfathered assault weapon".

I wouldn't mind so much about the change of rules in the middle of the game, if it didn't involve 10 years in prison....

[TheOtherChris]

So I'm guessing that if I have a preban rifle and sell the stripped receiver, the new owner can not assemble it into an AW...
But, if I sell my complete preban rifle which the new owner then reconfigures with parts he owns and then sells the original parts back to me it is OK.

Interesting interpretation.

Now, using the same logic, one could infer that an NFA registered M16 when stripped and sold is no longer an NFA receiver and could then be assembled into a postban semi AR15. Also, a registered DIAS won't go brrrp without a rifle so once it is removed and sold it is no longer an MG
Of course BATF ain't gonna buy that interpretation.

I wonder how they'll counter that argument?

Not that it really matters to me.
I have had my prebans since before the original California ban of '89.

The Other Chris

[gunnut1]

We have also determined that a semiautomatic assault weapon in knockdown (unassembled) condition consisting of a receiver and all parts needed to assemble a complete semiautomatic assault weapon are subject to regulation if the parts are segregated or packaged together and held by a person as the parts for the assembly of a particular firearm.

So does this mean we can't have receivers and kits in the same house? What a pisser! A kit contains all of the said parts to assemble a complete semi automatic assault weapon. What a pisser!

[buzzbomb]

Where is DABTL? This is where he usualy reminds us that it is our duty to obey all laws no matter how odious, no matter what.

[Brian in MN]

Their logic seems kinda thin to me. Let's say I have a SAR-48 receiver and Ted wants to buy it. We agree on a price of $1000 shipped. If Ted already owns a parts kit he is never in posession of a receiver without all the parts to build his rifle. Even if they want to get nit picky about the time the receiver is in transit all one has to do is ship the receiver with a parts kit. Either Ted can ship me his parts kit along with the $1000 for the receiver or he can pay me an extra fifty bucks, or whatever, to round up a POS kit to include for shipping purposes.

In any case, it seems like they would have to turn over a lot of rocks to prove that the rifle Ted built on the SAR-48 receiver was ever without a parts kit. I think those folks probably have better things to do with their time.

[Derby FALs]

Originally posted by Brian in MN
Their logic seems kinda thin to me.

What does "logic" have to do with it?

[Ekie]

Bartlett is dead wrong on this one, just cuz he is a cop don't mean he can't make a mistake, or that he has a clue what he is talking about.

He says this first:

"You describe an AR15 type rifle that met the definition of a semiautomatic assault weapon and was lawfully possessed on September 13, 1994."

That describes a AR that is grandfathered under 18 USC section 922(v), it meets all requirements. I say all, but there is only one, that it have been legally owned on 09-13-94. That is it, done deal, should have been the end of the letter.

Here is where he goes into fantasy:

"The receiver does not meet the exemption in section 922(v)(2)"

So what? The rifle was legally owned on 09-13-94, and thus grandfathered, so why bring this receiver business up later?

"and assembly of this firearm in the configuration of a semiautomatic assault weapon would be prohibited under section 922(v)(1)."

Nope, sorry Charlie, assembly is not covered under 18 USC section 922(v), only the acts of manufacture, transfer, and possession are covered.

I don't know why people write cops stuiped letters like that any who. Junk in, junk out.

[Brizz]

Ekie, unless I misunderstood the original post, Bartlett works for the ATF. For all purposses that matter, his (The ATFs)interpretation IS THE LAW.

It's not right, but the only way to fight it is in court (AFTER you've been arrested in most cases). I'm sure I'm not alone in wishing it was different, but just dismising his interpretation in favor of your own could get you thrown in jail. It is much harder to prove your innocence than you may think (and regaurdless of how it's supposed to work, it is guilty until proven innocent)

[Ekie]

Hardly, Bartlett is a pin head in D.C. It is the DOJ that would take the case, and that one they will not take, cuz they will enforce the law, not some letter writtn by a cop.

[xcpd69]

Originally posted by gunnut1


So does this mean we can't have receivers and kits in the same house? What a pisser! A kit contains all of the said parts to assemble a complete semi automatic assault weapon. What a pisser!

gunnut1,

I have been a voice crying in the wilderness for years on this issue.

I have always believed, and still believe, that you COULD be prosecuted for having a kit with all the evil features, plus a receiver, for possession of an assault weapon in "knockdown" condition.

The solution is very simple. Order your kit, make the necessary modifications, THEN purchase a receiver. Then in no possible way could you have been in possession of an illegally configured rifle.

If I'm wrong, what is the possible harm of doing it my way?

BUT if I'm right, the consequences could be significant.

[dmk]

The solution is very simple. Order your kit, make the necessary modifications, THEN purchase a receiver. Then in no possible way could you have been in possession of an illegally configured rifle.

Wouldn't you have to still dispose of the removed parts? ("...if the parts are segregated or packaged together and held by a person...")

According to the logic of the letter, even if you had a fully assembled rifle, posessing the removed parts would still make you a felon. As they could argue that your rifle "was temporarily reassembled in a configuration" that was legal and that your could put the "illegal" parts back at a later date. Of course, there would be no logical benefit to you in doing so, but this IS the ATF and the word logic is apparently not in their vocabulary.

[Gavin]

I have to agree with Ekie 100% here. Why do people write ATF about this bullsh*t.

Also - this ruling is garbage, totally unenforceable and a waste of paper.

Gavin

[dmk]

What about vendors like FAC and DSA?

They have entire warehouses of parts kits, recievers and various imported parts. They might be licenced to build rifles, perhaps even FA ones, but they still need to abide by the import regs. They need to count U.S. parts just like we do.

They would be illegal (many times over!) according to the following "opinion":

"We have also determined that a semiautomatic assault weapon in knockdown (unassembled) condition consisting of a receiver and all parts needed to assemble a complete semiautomatic assault weapon are subject to regulation if the parts are segregated or packaged together and held by a person as the parts for the assembly of a particular firearm. "

[Ekie]

Gavin, hmm, we agree on something?

Actually it is this simple:

Which is correct, one or two?:

1) Paragraph (1) shall not apply to the possession or transfer of any semiautomatic assault weapon otherwise lawfully possessed under Federal law on the date of the enactment of this subsection

2) Paragraph (1) shall not apply to the possession or transfer of any semiautomatic assault weapon otherwise lawfully possessed under Federal law on the date of the enactment of this subsection. This exception will be rendered irreversibly void in the case of any particular semiautomatic assault weapon if at any one point in time after the enactment of this subsection if said semiautomatic assault weapon is in such configuration that it is no longer a semiautomatic assault weapon.

One is law, and two is something we read in a letter from the ATF tech branch. So the choice is law or a letter. I am going with the law, how bout you guys?

[Ekie]

BTW, I called the Tech Branch about this, cuz I thought it might be a fraud being as goofy as it is. Was given confirmation that really is what they think over there. So I asked a question, what would happen if you had a "grandfathered" semiautomatic assault weapon, a AR, and you sent your only upper to TANKS to have a ramp job done, and UPS lost it. Can you buy another upper and truck on? He said no, you "would be up a creek with out a paddle".

Same sort of thing with a FNC, say your firing pin broke and you had no spare, you just lost your grandfathered status. pure nonsence.

[Ekie]

As far as having all the parts to build a semiautomatic assault weapon being the same as a semiautomatic assault weapon, sure that is the ATF take. This allowed many more rifles to be grandfathered. At the same time the ATF is not out looking for guys with brand new receivers and parts kits so they can lock them up for a 18 USC section 922(v) violation. Just ain't happening, so don't worry about it, if you can't help but worry I recomend some medication of some sort.

[Brizz]

Gavin and Ekie,
If it's not the ATF, then who do we find out from? This isn't a flame, I really do want to know. How do we find out about the grey areas of the law?

In court the ATF agents would be the "Expert Witness" and as honest of a person as I am, my side of the story would sound weak in comparison.

I'd rather not have to take the risk if I can avoid it by knowing the laws that would actually be applied to me.

[Ekie]

James Bardwell is the best known expert on Fed firearms law around, he is the one to ask. Really though, this is a no brainer, just read the law and follow it. I just posted it a few posts up, you know the ditty about being legally owned on a certain date, no more or no less, that is the law.

In order for the ATF to be such a witness, there needs to be a trial, and why would the DOJ prosecute a case involving the violation of the intent of a letter written by some dude named Bartlett?

[sobrbiker883]

Call me paranoid or crazy, but I figure there's a much better chance of meeting an ATF agent at my house if I write the ATF and ask them if what I'm doing or thinking of doing is OK.

Kinda along the lines of calling the police to see if there are any warrants for your arrest-"come in to the station and we'll check."

-Happy to learn from you all though.

[drjarhead]

What about a lower receiver with PG and telestock? How could that be anything but an AW given its number of "evil features"?

[TerrySC]

Had a friend who was stuck with two pre ban recievers that he didn't sell or build before the dates rolled over on him. Now he can't build the guns as pre bans. My question is how anyone who gives a hoot is going to know when they were built? (meaning he doesn't spill the beans on himself)

[drjarhead]

Originally posted by TerrySC
Had a friend who was stuck with two pre ban recievers that he didn't sell or build before the dates rolled over on him. Now he can't build the guns as pre bans. My question is how anyone who gives a hoot is going to know when they were built? (meaning he doesn't spill the beans on himself)

they won't

[hkshooter]

Maybe. Maybe not.
All one has to do is call the manufacturer of the receiver, give them the serial number and they will tell you when the item was built and what configuration it was built in be it bare receiver or complete weapon.
With the proper credentials they will even tell you who it was sold/transfered to and on what date.

[redneck whitesox PBR]

From the BATFE Website FAQ

(O7) Are replacement parts for grandfathered semiautomatic assault weapons and large capacity ammunition feeding devices subject to regulation under the law?

No. Parts may be replaced in grandfathered semiautomatic assault weapons and grandfathered feeding devices without violating the law. However, if the frame or a receiver for a semiautomatic assault weapon is defective, the replacement must be made by the weapon's manufacturer or importer. The replacement receiver must be parked with the same serial number as the original receiver, and the original receiver must be destroyed. However, a manufacturer or importer who is unable to mark the replacement receiver with the same serial number as the original receiver may seek a marking variance in accordance with 27 CFR 178.92. In addition, the permanent records of the manufacturer or importer should indicate that the receiver for the weapon has been replaced.

[Rivaltm]

before they can prosecute you they have to prove that you sold it dis-assembled.

it would be hard if it was friend to friend, easy if you advertised "stripped preban reciever for sale".

[Kulaman308]

what a mess,I think I'll take you up on the MEDS..

[HATCH]

Well, well.

So, from what the ATF stated.
If I bought a Polish AK47 kit and a Hesse Receiver.
Boxed them both up in the same box and tossed them in my closet, then I am committing a felony. Since

We have also determined that a semiautomatic assault weapon in knockdown (unassembled) condition consisting of a receiver and all parts needed to assemble a complete semiautomatic assault weapon are subject to regulation if the parts are segregated or packaged together and held by a person as the parts for the assembly of a particular firearm.

Boy that is gonna be a shocker.

Think of all the people out there that build kits.
With the above quote, I think that everyone is committing a felony.
For example, I buy a polish AK kit from Global trades.
I then buy a HESSE or OOW receiver.
I box them both up to ship to my builder(any FFL licensed builder)
I just committed a felony.
The atf just determined that I have just built an assault weapon.
Heck I bet they could even get me on NFA violations since at one point in time I might have all the full auto parts, the kit itself, and a reciever all in the same place.

Man this sucks.
I guess this really drives down the price of "preban" ar 15 receivers.
Not really.... IF you buy a "preban" receiver, just make sure the your FFL transfer agent writes it in the book as a "ar15 rifle" leave off the receiver part.
Since the ATF has already determined that the receiver is a firearm anyway.
Also even if the ATF were to investigate the matter, I am sure my dealer can not remember the configuation of a ar15 that he transfered 6 months ago, much less 30 days ago.

CHARLES

[HATCH]

Originally posted by redneck whitesox PBR
From the BATFE Website FAQ

(O7) Are replacement parts for grandfathered semiautomatic assault weapons and large capacity ammunition feeding devices subject to regulation under the law?

No. Parts may be replaced in grandfathered semiautomatic assault weapons and grandfathered feeding devices without violating the law. However, if the frame or a receiver for a semiautomatic assault weapon is defective, the replacement must be made by the weapon's manufacturer or importer. The replacement receiver must be parked with the same serial number as the original receiver, and the original receiver must be destroyed. However, a manufacturer or importer who is unable to mark the replacement receiver with the same serial number as the original receiver may seek a marking variance in accordance with 27 CFR 178.92. In addition, the permanent records of the manufacturer or importer should indicate that the receiver for the weapon has been replaced.

where did you find this info at.
If this is the ATF saying that then they just screwed everybody.
NO PARTS MAY BE REPLACED.
That means you CAN NOT replace the followers or floorplates on your preban mags in order to meet the 10 parts rule.
Hey does this mean I can't change the stockset on my preban FAL?

[redneck whitesox PBR]

Re read it. It is an answer to the above question "Are replacement parts for grandfathered semiautomatic assault weapons and large capacity ammunition feeding devices subject to regulation under the law? "

The answer is " No. Parts may be replaced in grandfathered semiautomatic assault weapons and grandfathered feeding devices without violating the law."

There is a period after the "NO". It says that parts MAY be replaced and are NOT subject to regulation. It seems BATFE needs to get their story straight.

[Kulaman308]

I have read ALL of these Can and Cannot's. If the Powers to Be are correct,(and if you read the REGS) their Not..ALL of the manufactures,07 Builders,01 Dealers,which for years did nothing but buy every Preban Rec.,and Build it into an M4,or some other Collapsable Stock,Flash Hider equipped w/Pistol grip,are ALL going to Jail.This includes DSA,Enterprise,Armalite,DPMS,etc,etc.(you get the idea)..I was a Dealer 01 Before the 94 ban,and for a few years after.Many Thousands of Recievers,bought,and confirmed Preban(Left as complete rifle),have been Bought (mostly by Builders w/Money),how many remember trying to buy a Preban Rec.,that had been confirmed a complete unit when they left the Factory,just to get Beat Out by these Company's with doing a rebuild on their mind,and selling for BIG Bucks??!!! Well I got beat out of Many,I even emailed this 1 Gunshop that was buying every Preban Rec.,and asked,(ARE YOU GOING TO LEAVE ANY RECIEVERS FOR THE REGULAR GUY)?? NO,we will Buy every reciever that we can get our hands on,(This was investigated by them at the Time,and Found to be LEGAL)!!! Otherwise they wouldn't have sunk Hundreds of Thousands of dollars into doing this (now,all of a sudden banned practice).I for 1 don't buy it..(BATF said the RECIEVER IS THE GUN),except in the case of it leaving the Factory as a Reciever,Not a Complete rifle.. This will have to go thru Congress,they cannot change the Regs.in Mid Stream.Just as the Regs.will NOT be changed back to (drop the AWB).Sorry to say,but the Ban stays,most likely as is..I have spent many hours reading Regs.,and this new report doesn't stick.. I can't remember the Handles of some of our members,that have Posted the Regs.,but THEY are in BLACK & WHITE..Also,what about the High Dollar sales of Preban Barrels,and parts,is this Now Illegal?? Read the Regs.,don't send Letters. My 02..

[jzdziarski]

I would like to see the original letter that this was in response to. I suspect that the ATF is responding to a question about selling a stripped lower (e.g. without the internals or collapsible stock), because if you have a lower receiver with a collapsible stock and pistol grip, you have an assault weapon by definition.

Otherwise, like some have suggested, you can always ship the rifle with the upper, and then buy it back if you want to be 100% safe. I've heard rumors that the ATF would make you "prove" that you had a complete rifle before '94, so a letter from the original owner couldn't hurt either.

With all the sales of stripped lowers going on, I'm wondering if this letter may be complete BS anyhow...I don't see it except on a couple different forums, and it seems to be slightly different between each forum. I would also think something like this would be on the FAQ on the ATF website.

I'm in the process of trading lowers with some guy; we both have complete pre-bans. If Mr. ATF Letter Writer were right, this would cause both our rifles to lose their pre-ban status.

[jzdziarski]

Another interesting letter I found from http://www-2.cs.cmu.edu/afs/cs/user/...alist/law.html that defies all logic. If the weapon _is_ the receiver, then this letter makes absolutely no sense. It also doesn't differentiate between upper and lower receivers.

DEPARTMENT OF THE TREASURY
BUREAU OF ALCOHOL, TOBACCO AND FIREARMS
WASHINGTON, DC 20226

AUG 27 1998 F:FPD:FTB:CHB
3311


Dear Mr. :

This refers to your letter in which you ask about replacing
receivers on semiautomatic assault weapons made by various
manufacturers.

It is unlawful for any person to manufacture, transfer, or
possess a semiautomatic assault weapon except as provided in
section 922(v) of Title 18, United States Code. A semiautomatic
assault weapon which was lawfully possessed on the date of
enactment of this section [September 13, 1994] may still be
lawfully possessed and transferred.

This exemption would not apply to a "pre-ban" semiautomatic
assault weapon having a receiver which has been replaced by a
different manufacturer after September 13, 1994. If the frame or
a receiver for a semiautomatic assault weapon is defective, the
replacement must be made by the weapon's manufacturer or
importer. The replacement receiver must be marked with the same
serial number as the original receiver, and the original receiver
must be destroyed.

We trust that the foregoing has been responsive to your inquiry.
If you have further questions concerning this matter, please
contact us.

Sincerely, yours,

[signed]
Edward M. Owen, Jr.
Chief, Firearms Technology Branch

[Kulaman308]

RIGHT ON (jz).....





EDITED TO SAY jz),You most already know this,but for instance,I had a Cast OlyArms Preban,it litterly Fell apart,so I sent it back to OLY,and they sent me a Replacement,at the cost of $79.,that was for going from Cast to Forged..Then they MUST DESTROY the reciever I had sent to them,which I felt was alittle late,since it was destroying itself. TOO Many fingers in the Pie..Too many differances of opinions. IM coming to you.

OK,WHO STUCK IN THAT FACE???

[xcpd69]

Originally posted by Kulaman308
RIGHT ON (jz).....





EDITED TO SAY jz),You most already know this,but for instance,I had a Cast OlyArms Preban,it litterly Fell apart,so I sent it back to OLY,and they sent me a Replacement,at the cost of $79.,that was for going from Cast to Forged..Then they MUST DESTROY the reciever I had sent to them,which I felt was alittle late,since it was destroying itself. TOO Many fingers in the Pie..Too many differances of opinions. IM coming to you.

OK,WHO STUCK IN THAT FACE???

Uhh...YOU stuck in that face.

When you typed "EDITED TO SAY:" then followed it by "(jz)", placing the ":" next to the first bracket "(" , it generated the frown face ":" plus "(" =

[Kulaman308]

I didn't know that. Thanks..Frankly,I think (falfiles) is the BEST site on the net..!!!

[perdurabo]

I buy a pre-ban stripped receiver. It cannot fire, therefore it is defective. To replace the defective parts I will need a "pre-ban" kit. I assemble the pre-ban kit onto the receiver and it is no longer defective.

Seems logical to me.

Even if you are prosecuted (and you wont), you could probably find a way to drag the trial out until September, 1994 in which case the violation will be Ex Post Facto and the charges will have to be dropped. If a new AW Ban is passed before then (and I hope to god it isnt), you're screwed anyway as we wont have any rights to own anything vaguely resembling a military style semiauto.

[Beryl]

I think Sand Pirate's original post about the F/A parts comparison would make an effective defense in court.

Personally, I don't think there is a problem because:

1) They have to prove that the gun was not in that condition already
2) They have to convince a US Attorney to prosecute
3) They have to convince a Grand Jury to Indict
4) They have to convice a trial jury that you are guilty of something and it serves the purposes of justice to convict you.

[mojo_matic]

O.K., there are a great number of loop-holes, and many interpretations by the ATF. My overall thought/question is just how many people have been arrested (let alone indited/convicted) for ANYTHING mentioned in this thread? If you have a pre-ban reciever, just assemble the damb thing! When in the world do think that an ATF officer is going to look at your rifle, and question whether or not the parts belong to it? Maybe if a person gunned down some people, or robbed a bank, but if someone committed these crimes, whether or not their rifle is compliant is the least of their worries.

It costs money to prosecute. It takes evidence beyond a doubt to convict. I would guess that easily 99% of these concerns wouldn't hold up in court. I also believe that 99.9% of the agents out there wouldn't approach you at a range if you are shooting responsably.

I'm not saying too ignore the regs. I just bought a STG build, which had compliance issues, that were quickly squared away. But come on, what is the chance that if I didn't, I would be apprehended by the ATF because of it?

My opinion considering these laws: Be responsable with your rifle (on and off the range). Make a concerted effort to obey the laws set forth by ATF. If there is a grey area, document it. If for some wild reason you are actually confronted by an ATF agent, supply a compy of the regs, highlighted by the areas in question in regards to you weapon, and your interpretation. You have proved that you have put thought and attention to the matter, and that you in fact respect the laws set forth. If the ATF agent was stupid enough to the next step, the same talk with the supervisor will diffuse the situation ASAP. I believe that if an ATF agent really wanted to be a prick, you and your rifle will be taken into question, even if it was obviously legal, because of the "grey" areas. But an ATF agent wouldn't do this, because they have a job in which mistakes are frowned upon. They are people, and they have supervisors. An agent is going to put their ass on the line for something much more viable than a U.S. parts number count.

I have spent a great deal of time around people of stature in law-enforcement disciplines. I don't feel that I'm talking out my ass. Enjoy the sport, try to obey the guidelines set forth by the ATF, if there is a grey area, do your best to comply, and document any areas that may be questonable in reference to your rifle. The ATF is interested in people who want to commit crimes and the public's safety. That is why they get really hot over class 3 weapons---public safety (gun control makes me livid, but I personally do not see a viable purpose for ANY common citizen to own a full-auto weapon, when taking possible safety issues into consideration). Overall, for the rest of us, basic knowledge and respect for the laws are all we need to worry about. The ATF has more important things to worry about than whether or not your rifle's parts kit actually belongs too your pre-ban reciever.

[55bird]

The BATF has no intention of being plain spoken on these matters.It allows them the power of intimidation to steer as many folks clear of these types of firearms as possible until they get the statues written as they want.Which it may already be.Scary thought.Obscure laws applied selectively.

[NHBandit]

Wouldn't it be something if we all could send our "defective" torch cut Imbel recievers from our kits back to Imbel and get them replaced with new replacements (same serial number of course) and the BATF had to consider them to be grandfathered assault rifles that had simply been repaired..... Anybody got a phone number for the sales department at Imbel ?

[P806]

Wouldn't that be the cats meow!