This is just silly. What is the formal charge for owning a RR gun? The ATF are the people that said stop drilling front take down pin holes. Now you think they are going to say a gun without it is somehow not legal. Far from it.
Well I am a manufacturing FFL and SOT and I can tell you that you are wrong here.
If you own a RR mg it is good to go
Into the murky depths... "The Mechanics of the Heckler & Koch NFA Conversions"
ATF Technology Branch has quite emphatically ruled that a registered receiver gun, that as a registered conversion using a clip-on style trigger group housing, cannot be later converted to a different method of trigger housing attachment. In other words, a registered receiver conversion originally mechanically converted with a clip-on style trigger pack attachment method cannot later undergo a further alteration to a push-pin, swing down lower attachment provision. Plainly stated, ATF has ruled that the removal of the clip-on ledge piece of metal and subsequent drilling of the two pivot pin holes is, in and of itself, the act of manufacturing a NEW MACHINE GUN, regardless of whether or not the actual receiver is already registered as a machine gun!! While this may seem to make no logical sense at first glance, one must understand why ATF has taken this position and that is because they know that a registered receiver converted gun employing a ‘clip-on’ style trigger housing will have had to have been mechanically converted using a semi-auto fire control pack that has been modified to function in the selective fire mode, or in very rare cases a factory original machine gun pack and trigger frame altered to fit the clip-on attachment of the semi-auto receiver. They know that if you remove the clip-on ledge from the receiver, post initial conversion date, that you can then use a normal factory original machine gun-style fire control pack…all of which leaves the very interesting question of what happened to the original converted semi-auto fire control pack which had been modified to fire in the selective fire mode (or a modified machine gun pack and housing) and could, in and of itself, be used to convert another semi-auto gun!! Because the legal definition of what constitutes a ‘machine gun’ also defines conversion parts, or assemblies, to be ‘machine guns’ in and of themselves this leaves an “extra” unregistered machine gun out there. This is why the subsequent removal of the clip-on ledge, post initial conversion date, is creation of a NEW machine gun because presumably it frees up an unregistered conversion part (or assembly)! With a clip-on style trigger housing attachment method the actual NFA registered “machine gun”, as it was originally registered, is legally defined to be the combination of the semi-auto receiver and the original unregistered conversion part...not just the receiver alone!
The genesis of this ATF philosophy is derived from the enactment of the Hughes machine gun freeze amendment which was slyly inserted into the otherwise good natured McClure-Volkmer Firearms Owners Protection Act, enacted on that now famous date May 19, 1986. The Hughes amendment forever capped the number of fully transferable machine guns available to civilians, and this fact is what drives the ATF position on further modification of already registered receivers. Even more interesting in this case was the position ATF Technology Branch took on the status of literally thousands of lawfully NFA registered machine gun conversion parts or kits, most of which were hastily registered shortly before the enactment date of the McClure-Volkmer Act. ATF Technology Branch had initially taken the official position that any lawfully registered machine gun conversion part or kit could be installed in the host firearm at a date later than the initial registration date. This meant that a manufacturer or lawful registrant could hold onto that registered conversion part or kit indefinitely until it was desired to affect the actual installation into a host firearm. Problems soon arose however when ATF Field Agents tasked with checking on the compliance of Class II manufacturers soon discovered that certain of these manufacturers, in a greedy rush to register as many fully transferable conversion items as possible prior to the cut-off date, had been less than forthright in their descriptions of the conversion parts or kits…
So...just what ARE you looking at? The many possible scenarios.
First, you had those Registered Receiver conversions that had been originally mechanically converted to a legally defined machine gun receiver employing a factory MG style push-pin, swing-down style trigger housing. These guns occupy the pinnacle position of NFA conversions desirability status due to their unquestionable registration legality, duplication of factory mechanical features and cosmetic appearance, and ability to allow owner changes in factory style trigger groups along with enhanced spare parts availability.
Next up, those “Registered Receiver” guns that had the unmodified Semi-auto Title I configured receiver NFA registered as the “machine gun”, but had been originally converted with an unregistered conversion part or device. These guns have several handicaps and vices. First, because of the above mentioned legal rulings their receivers could never be further altered to a push-pin, swing-down trigger group mounting style, which committed them to forever using the same trigger group and fire control pack as had originally been installed on the date of initial conversion and NFA registration, with one minor possible exception. Because of the usage of that unregistered conversion part in the modified semi-automatic fire control pack, that conversion part itself could never be replaced, only repaired! This is legally prevented because to replace it with a new one, if damaged or lost, would constitute new manufacture of an unregistered machine gun which was made illegal by the new 1986 Laws. Also, this prevented easy replacement of trigger group spare parts, as to convert the semi-automatic fire control pack to replicate selective fire, many of the fire control parts had to be heavily modified themselves. This was due to an altered mechanical geometry required by the need to have the same mechanical functioning as a factory selective fire pack, but in a geometry necessitated by the requirement of having the lower front edge of the fire control pack adapted to mount on the “clip-on ledge” of the semi-auto receiver. So, to get suitable replacement or spare fire control parts, one has to have standard parts that were specifically altered for usage in such a conversion, which are not typically available as easily as factory MG parts are now. The key is that with these types of “Registered Receiver” conversions, the NFA registered “machine gun” is the original combination of the unaltered clip-on style receiver, and the originally installed unregistered conversion part...those two entities can never legally separate, they are “married” for the life of the weapon!! All of these reasons are why this type of “Registered Receiver” conversion occupies the lowest level of desirability amongst registered receiver conversions, and are priced accordingly.
Even more disheartening in present times is the fact that since conversions of this type use an unregistered conversion part of most likely a proprietary design, unless you can re-install that exact conversion part in a different pack, you cannot replace the original style fire control pack with a perhaps more desirable version such a “Navy Group”, or 2-or-3-shot “Burst” style ambidextrous lower group!!
[LEGAL WARNING! While it may be physically possible to adapt a factory select-fire ambidextrous style “Navy Group”, or “Burst” type trigger pack and plastic housing to fit a clip-on semi-auto receiver, it is patently ILLEGAL to simply adapt such a trigger group to fit, and then just clip it onto a “Registered Receiver” gun using a clip-on style housing attachment as you have just made a new, unregistered machine gun by doing so¼you’ve just created a complete conversion device to convert a semi-auto receiver!! The legal issue here, again, is that you are left with the original, unregistered conversion part being freed up when you swapped them out on your Registered Receiver conversion. There are currently available many of these adapted “Navy”/”burst”/Ambidextrous trigger groups offered for sale, but they are ALL illegal, unregistered conversion devices!! The ONLY way they are BATF legal is if they have been NFA registered as a Conversion device! This had to be either before the May 19, 1986 cut-off (which is HIGHLY unlikely due to very limited availability of these styles of factory parts then), or as a “post-86 Dealer Sample Conversion device”, or made at the request of Law Enforcement Agencies. ]
Lastly, somewhere in between the above two more common versions of registered receiver conversions are a very select group of Title I guns that were converted to select fire by a more questionable method...at least according to ATF Technology Branch after their early 1988 determinations and rulings. As alluded to previously, a select few semi-auto guns are known to have been converted by having their unmodified clip-on style receivers NFA registered as a “machine gun”, and then proceeding to attach a normal factory original MG select-fire, fire control pack and housing that had both been suitably modified together to clip-on attachment, as described above. These guns most likely were never visually inspected by ATF Technology Branch for suitability and conformance to approved methods prior to registration, and therefore “sneaked by” and into the NFRTR. In any era, these style conversions would be suspect as they contain an unmodified Title I receiver with its clip-on trigger group attachment point, and an unregistered drop-on conversion assembly. These guns are ripe for ATF making a determination that they were improperly registered, and may be subject to reclassification. Why the original registrant did not originally just register the converted trigger group assembly alone, instead of the receiver of the Title I gun, is a mystery...and a lingering problem for the current owner. These guns are just too much in a legal grey area to attach a reasonable sense of value to, and they are the perfect example of why a prospective purchaser of a “registered receiver” H&K conversion gun needs to extremely vigilant and aware of just exactly what particular gun he is looking at.
Within this understanding lies the major financial difference in perceived value of “registered receiver” conversion guns. A ‘fully converted’ gun able to use factory push-pin style, swing-down trigger groups is always deemed to be more inherently ‘valuable’ then a gun using a ‘clip-on’ trigger group, though the mechanical functioning is identical between the two guns. The perception is two-fold. First, on receivers able to use swing-down groups the ability to choose between the various factory offered styles of fire-control set-ups is greater, and they are simpler to exchange. Secondly, on registered receiver guns that employ a clip-on style group, at least one of the fire-control parts will be an unregistered conversion part, which means in practical terms that should this part break or be damaged it can only be repaired and never replaced, which limits to some small extent its serviceability.
