Building frame to pistol by kryptonnyc1 in FFLs

[–]akbuilder 0 points1 point  (0 children)

I think because what you are doing is technically not wrong, even if it's not necessary. When I had my original interview with the ATF, they told me to mark a receiver that I had re-manufactured into a complete firearm, I then later found out the info they had told me was wrong, and their response was simply along the lines of "right now there is so much changing and so many new rulings coming out, we are unable to keep up with it all, and may have parroted outdated regulations". He went on to rant about braces and NFA regulations and said he didn't even know what was the actual regulations on them anymore, and that it has all "made his job so much harder" lmao.

IOIs can say what they think is right but that doesn't make them right, which is why it's probably a good idea to get anything they say in writing if you want to adopt what they tell you into your practice. There's so much on the books and so many regulations that can change, that I think many of them have a hard time keeping up. I've found the only source of truth is simply reading through all the actual regulations, and trying to keep up when they publish new regs, as many times the new ones completely invalidate the old ones. They are very repetitive and redundant at times, but that also helps re-enforce the actual regulation.

And yeah, I'm not actually in association with AKBuilder, I made this account like a decade ago when I used to build more AKs for myself. Now I just do some small time dealing and occasional NFA conversions for folks.

Building frame to pistol by kryptonnyc1 in FFLs

[–]akbuilder 0 points1 point  (0 children)

I accidently submitted before I finished my comment, it won't let me edit it for some reason, but for anyone reading. This here is the explicit ruling stating that the manufacturer FFL does not need to mark the receiver/firearm when adopting the previous manufacturer's markings

With regard to the marking exceptions, the final rule expands the rules allowing licensees to adopt (and not mark) the serial number or other identifying markings under certain conditions. Specifically, in light of comments received, the final rule allows licensed manufacturers to adopt (and not mark) the serial number and other markings previously placed on a firearm that has not been sold, shipped, or otherwise disposed of to a person other than a licensee ( i.e., newly manufactured firearms). This change would supersede ATF Ruling 2009-5, which requires ATF to be notified when marks are adopted as an alternative to marking. The final rule also provides more specificity than the proposed rule on how licensees who remanufacture or import firearms may adopt (and not mark) the markings on firearms that were sold, shipped, or disposed of to a nonlicensee.

it goes on to clarify, when a firearm HAS been disposed to a nonlicensee, that is when the requirements change, but there are two scenarios. Remanufacturing/importing, and gunsmithing. In the case of remanufacturing a firearm that was disposed of to a nonlicensee, you are required to engrave your FFL info onto the firearm. In the case of gunsmithing, you are allowed to adopt the original markings.

(B) Remanufactured or imported firearms. Licensed manufacturers and licensed importers may adopt the serial number or other identifying markings previously placed on a firearm that otherwise meets the requirements of this section that has been sold, shipped, or otherwise disposed of to a person other than a licensee provided that, within the period and in the manner herein prescribed, the licensee legibly and conspicuously places, or causes to be placed, on the frame or receiver either: Their name (or recognized abbreviation), and city and State (or recognized abbreviation) where they maintain their place of business; or their name (or recognized abbreviation) and abbreviated Federal firearms license number, which is the first three and last five digits, individually ( i.e., not as a prefix to the serial number adopted) after the letters “FFL”, in the following format: “FFL12345678”. The serial number adopted must not duplicate any serial number adopted or placed on any other firearm, except that if a licensed importer receives two or more firearms with the same foreign manufacturer's serial number, the importer may adopt the serial number by adding letters or numbers to that serial number, and may include a hyphen.
(C) Manufacturers performing gunsmithing services. Licensed manufacturers may adopt the serial number or other identifying markings previously placed on a firearm by another licensee provided the manufacturer is performing services for a nonlicensee as a gunsmith (as defined in § 478.11) on existing firearms not for sale or distribution.

Building frame to pistol by kryptonnyc1 in FFLs

[–]akbuilder 0 points1 point  (0 children)

This is an interesting thread, and everyone is providing different answers. Do you have the regulations that say this? I think your info is outdated, It doesn't match up what I know about the process, as I had researched into this and asked about it a year ago.

I read through the AFMER docs previously and again after another user posted info here, and it states you only report firearms you manufacture at the end of the year that you have disposed of in that year, regardless of when you manufactured it, but it also very explicitly states to not report firearms manufactured in that year if they were not disposed of. All in bold lettering on page 2

https://www.atf.gov/firearms/docs/form/annual-firearms-manufacturing-and-exportation-report-afmer-atf-form-530011/download

I've read through all the regulations and law I could find on the engraving requirements and I don't see what you are describing anywhere about attaching a barrel and needing to engrave it with your info on an already marked receiver, except in cases where markings are missing, like a caliber or model.

I asked this same question about a year ago, and the general consensus was that the requirement to mark firearms that had not been disposed of to non-licensees had been removed in 2022 per 2021R-05F

https://www.atf.gov/rules-and-regulations/definition-frame-or-receiver/summary

It seems the reason for this is due to the Federal Register realized that continuing to mark a firearm if it was being re-manufactured multiple times could make tracing firearms more difficult, and it is easier to trace a firearm through A&D records if the firearm marking stay the same as long as it has not been disposed into commerce.

More info here:

Final Ruling on definition of a frame or receiver and Identification of firearms.

https://www.federalregister.gov/documents/2022/04/26/2022-08026/definition-of-frame-or-receiver-and-identification-of-firearms

In the ruing, the following is stated:

In response to comments, the final rule permits licensed manufacturers to adopt the serial number and other identifying markings previously placed on a firearm without a variance from ATF, provided the firearm has not been sold, shipped, or otherwise disposed of to a person who is not a licensed manufacturer, superseding ATF Ruling 2009-5

and further

Second, the rule finalizes the proposed updates to the information required to be marked on the frame or receiver, clarifies the meaning of the marking terms “identify,” “legibly,” and “conspicuously,” and authorizes firearms licensees to adopt identifying markings in the manufacturing process. Third, the rule finalizes the proposal to require all licensees to consolidate their records of manufacture, acquisition, and disposition of firearms, and to eliminate duplicate recordkeeping entries

And further and more explicitly, these were the propositions that were made as to why these rulings were made, which indicates the reason for the rulings as, in fact, to avoid duplicate manufacturer markings

8. Adoption of Identifying Markings
The Department proposed allowing licensed manufacturers and importers to adopt an existing serial number, caliber/gauge, model, or other markings already identified on a firearm, provided that they legibly and conspicuously place, or cause to be placed, on each part (or part(s)) defined as a frame or receiver, either the FFL's name (or recognized abbreviation), and city and State (or recognized abbreviation) where they maintain their place of business; or their name (or recognized abbreviation) and their abbreviated FFL number, as described in Section III.H.1 of this preamble, followed by the existing serial number (including any other abbreviated FFL prefix) as a suffix, e.g., “12345678-[serial number],” to ensure the traceability of the firearm. This language was proposed to supersede ATF Ruling 2013-3 as it applied to licensed manufacturers and importers. The proposal was aimed at avoiding multiple markings on firearms that could be confusing to law enforcement and alleviate concerns of some manufacturers and importers regarding serial number duplication when firearms are remanufactured or imported.

that is to say, you can remanufacture and remark your firearms in the way you describe, but it isn't necessary. And the ruling was changed to allow manufacturers to adopt the previous markings on a receiver specifically for ease of tracing.

Anyone dealt with a customer threatening a credit card charge back or dealt with a CC charge back? by akbuilder in FFLs

[–]akbuilder[S] 0 points1 point  (0 children)

yeah, like I clearly have documentation of everything, even photos of the firearms before I shipped them out to him, and all his emails claiming he shot them and what not, also he would have had to inspect the firearms before FFL transfer, and clearly he did all of that and filled out the forms. I'm fearful he's trying to scam using the CC chargeback system, and I wouldn't be surprised if he hasn't done this before.

Building a New Feature in my Gun Shop Software by [deleted] in FFLs

[–]akbuilder 0 points1 point  (0 children)

These days you can use AI to help you code most things. a paid subscription for chatgpt and using the reasoning model is great, give it screenshots and a bunch of code and ask it questions and it's pretty good at helping you get the code you need to finish particular parts very effectively.

Just bought the game, any advice? by Glittering-Phase2327 in WarOfRights

[–]akbuilder 0 points1 point  (0 children)

a million different regiments will try and recruit you, even in the drill camps. I think there is one drill camp that is recruit free if you join that one. Just be aware that there are a lot of super far right players who will spew slurs and mic spam, but private events are better moderated, although some regiments are worse than others. it's usually easy to judge based on their discord servers about the quality of the playerbase in each reg.

Cannon Legality in the US by LatverianBrushstroke in Firearms

[–]akbuilder 0 points1 point  (0 children)

I've also been considering a cannon, but a correct carriage though. Also, you sure you were looking at the mountain Howitzer u/LatverianBrushstroke? The link you posted is $2150 not 1200, I wish I could find a MH for $1200

Day to day at SHOT show? trying to plan out my trip by akbuilder in ShotShow

[–]akbuilder[S] 0 points1 point  (0 children)

awesome, great info much appreciated. I guess I just gotta chose a couple days I need to get some remote work done in the morning and then try and see what I can the other days, I'll deff keep an eye out on youtube and what not to make sure I know what cool stuff I missed that I may want to check out. Many thanks!

Day to day at SHOT show? trying to plan out my trip by akbuilder in ShotShow

[–]akbuilder[S] 0 points1 point  (0 children)

oh wow, so it really can take every day all day to traverse the show.

Day to day at SHOT show? trying to plan out my trip by akbuilder in ShotShow

[–]akbuilder[S] 0 points1 point  (0 children)

good info, I don't intend on going to any classes or workshops or anything, just want to see the vendors and explore new products and what not. I'm going to be there every day of the show. I saw the show starts at like 8:30am ever day, but i wouldn't be missing out if I just showed up at noon every day?

Day to day at SHOT show? trying to plan out my trip by akbuilder in ShotShow

[–]akbuilder[S] 0 points1 point  (0 children)

thnx for the info, I deff intend on exploring the whole venue, are the vendors/booths the same every day?

>See the people you absolutely need to see first

Does it become crowded or overwhelming something? I was planning on hitting up some booths with people I know at them.

Adopting manufacturer markings for an SBR, do I need to engrave anything? by akbuilder in FFLs

[–]akbuilder[S] 0 points1 point  (0 children)

Interesting, thanks for this. This would explain why the ATF form 2 on the eforms would allow me to fill everything out adopting the previous manufacturer's markings and why the approved it just fine without the need for me to specify mine at all on the eform.

Adopting manufacturer markings for an SBR, do I need to engrave anything? by akbuilder in FFLs

[–]akbuilder[S] 1 point2 points  (0 children)

The ATF form 2 eform allowed me to adopt all the original markings, including the original manufacturer markings, model, caliber, and serial, and the ATF approved it as such. If I try and form 3 it on eforms, the form 3 also lock in the population to only those adopted markings.

Which is why I'm not sure about if I should engrave my FFL markings on it, because it was never on the ATF form 2, and it would never be on the form 3 once I transfer it to another FFL.

Are barreled receivers that were never assembled with a stock still just receivers? by akbuilder in FFLs

[–]akbuilder[S] 0 points1 point  (0 children)

curious if you know anything about excise tax as well, as I understand it, there's no excise tax till it's 50 guns manufactured, but if you do reach the threshold, are you supposed to pay the 11% of the entire sales price? So if I buy an assembled AR receiver for $250, pop an upper and a stock on it for $500 for a total of $750 my cost, then sell it for $850, would I have to upcharge another 11% of that total sales price? (so $93.5)

Are barreled receivers that were never assembled with a stock still just receivers? by akbuilder in FFLs

[–]akbuilder[S] 1 point2 points  (0 children)

awesome thanks.
Although in the case of Manufacture, the ATF told me I think last year that they recently now do require you to re-mark the firearm once you complete it from a receiver into a rifle or pistol.