HKPRO Forums banner

1 - 12 of 12 Posts

·
H&K Certified Armorer
Joined
·
8,216 Posts
Discussion Starter · #1 · (Edited)
Let me preface this by saying to Moderators that if this post is inappropriate, that I appologise in advance as I am not 100% sure... just found this tid-bit to be very interesting and thought I would share and get input.

I spent WEEKS talking to various ATF officials trying to get a straight answer on the question... "Is it prohibited to MOVE the manufacturer's serial number on a rife?". NO ONE there could give me straight answer.

The GCA states that it is unlawful to remove, obliterate or alter the mfg serial number yet nobody at the ATF could define "remove, obliterate or alter" to the extent that the statement is inclusive of "moving" or "relocating" the serial number.

I spoke to someone at the NFA branch and was told that if the final assembly was longer than 26" with a barrel length of longer than 16" (non-SBR) then the rifle would not have to be Form-1'd. Makes sense since Form-1's are for the manufacture of SBR's. They further stated that is was indeed prohibited to "move" or "relocate" the mfg serial number on any firearm that has already been registered with a Form-1.

Well this led to my next question... what about Title-1 rifles (ie. the SL8)? After a few more days of being transferred I FINALLY got a hold of someone at the FTB. I was told that a U.S. citizen (meeting the criteria for firearm ownership, etc...) CAN indeed mfg a Title-1 firearm for PERSONAL use without the need of registration/paperwork (catch words being "Title-1" and "personal use"). I was further told that a serial number was not required although strongly recommended (as confirmed by my extensive reading of the GCA). I was also informed that assmebly of this firearm could be done with various existing parts including parts as the result of the alteration of existing Title-1 firearms. Of course other GCA regulations still apply such as 922(r) in which if the rifle can not be classified of the "sporting" type as defined in the GCA, it can not contain more than 10 imported parts, etc...

So my final question point blank to the FTB was... "So I can legally cut-off the part of the receiver containing the mfg serial number as to use the remaining part as a component in my assembly?". Response was to the affect of "We do not regulate/trace Title-1 firearms, so yes. If you plan on mfg an SBR then you need to submit a Form-1 prior to assembly but as long as the firearm you want to make will qualify as a Title-1, we don't care what you do."

Well, needless to say it DOES all make sense but I went ahead and submitted a written request to the ATF FTB for written confirmation.

Thoughts anyone?
 

·
Merchant of Death (Admin)
Joined
·
11,953 Posts
Just a thought, but I think that you may be talking to the wrong folks at ATF regarding the weapon. The NFA Branch (and the FTB connected to it) are focused on Title II weapons and may not be able to adequately address your inquiry. You might want to speak with/write to the folks on the "other side" of the fence.

If it were my weapon, I would not want to get anywhere near an issue that involves "moving" an original serial number!
 

·
H&K Certified Armorer
Joined
·
8,216 Posts
Discussion Starter · #3 ·
Just a thought, but I think that you may be talking to the wrong folks at ATF regarding the weapon. The NFA Branch (and the FTB connected to it) are focused on Title II weapons and may not be able to adequately address your inquiry. You might want to speak with/write to the folks on the "other side" of the fence.

If it were my weapon, I would not want to get anywhere near an issue that involves "moving" an original serial number!
I do understand that the two br anches are "connected"... they ven share the same floor in the same building, lol. I spoke to Imports, Trace, and a few others... including department heads at each. Everyone said I needed to speak to FTB. So if the FTB confirms all this in writting... gospel?
 

·
Merchant of Death (Admin)
Joined
·
11,953 Posts
I would think that if you got a signed document from FTB stating in no uncertain terms that moving a serial number was acceptable, then you should be golden. That does not mean that they would not/will not reverse the opinion without notification to you. And that does not mean that there will be a "memo" sent out to every LEO saying that the action was blessed.

Again, if it was my weapon, I wouldn't try to do it even with a letter!
 

·
H&K Certified Armorer
Joined
·
8,216 Posts
Discussion Starter · #5 ·
I hear ya! I'm learning that the ATF changes its mind about at the same frequency my fiance does :D

I appreciate the input.
 

·
Registered
Joined
·
93 Posts
I think chopping off the part of the reciever with the serial and then using the rest violates the GCA. If you made your own reciever and built your "ONE" gun that everyone gets, then it would be ok but the way the FTB guy you talked to said about it sounds illegal. What exactly are you trying to accomplish with the weapon and perhaps I can be of more assitance.
 

·
H&K Certified Armorer
Joined
·
8,216 Posts
Discussion Starter · #8 ·
I think chopping off the part of the reciever with the serial and then using the rest violates the GCA. If you made your own reciever and built your "ONE" gun that everyone gets, then it would be ok but the way the FTB guy you talked to said about it sounds illegal. What exactly are you trying to accomplish with the weapon and perhaps I can be of more assitance.
I'm doing an SL8/G36 conversion. I want to cut-off the rear 2-3" to replace it with a conversion kit. The FTB officer pretty much said since the orignal receiver is Title-1 and not registered/regulated, no problem cutting it up and using it for parts.

Tom Form-1'd his because he made an SBR as did everyone else who used his Gen-3. Occording to te NFA people, they wouldn't accept my Form-1 because I'm not SBR-ing the rifle (can't own SBR's in MI). So my conversion will remain a Title-1.

I want to do this legally. Legally, I CAN do this if I Form-1 the thing which goes back to my Form-1 issue... no SBR = no Form-1.
 

·
Registered
Joined
·
93 Posts
I think the TB gen 2 conv. block just covers the ser. # and it def. legal. You just have to modify the rear of your rec. to accept it. Seems to solve most of your issues unless I am missing something....
 

·
H&K Certified Armorer
Joined
·
8,216 Posts
Discussion Starter · #11 · (Edited)
Beyond the federal tripwires, most states have laws against removing/obliterating the serial number, FWIW.
I appreciate the heads-up Boomfab... I'm good to go at the state level.

I think people are loosing focus on the main interest here...

1) ATF FTB said I was good to go because the receiver is Title-1. Just wondering if this makes sense to anyone as it did me.

2) "removing/obliterating"... I'm not doing either, I'm "moving/relocating". The GCA simply states "mfg serial number" NOT the "original application/location of the mfg serial number". I know this sounds trivial, but isn't most legal jargon?

I spoke to a dealer tonight at a Christmas party... he seems to agree with my line of logic but of course, as I plan to do, he suggested a written letter of verification.


Confucious say... "Man who lengthen gun with Gen-2 always have p**is envy of man who shorten with Gen-3" :D
 

·
Registered
Joined
·
131 Posts
My .02 is whatever you do "CYA", the time it takes trying to defend your actions and loss of a nice weapon until you prove your right is just not worth it in my opinion.
 
1 - 12 of 12 Posts
Top