[carguychris]

At least one sticking point is the wording that the transfer must occur "as if" it's being transferred from the FFL holders stock, which it is NOT.

+1, and I'd argue that this is the main sticking point, for three reasons.

• The dealer has to log the firearm into and out of his/her bound book, which is a time-consuming process compared to making a simple phone call, and may be hard to justify for a fee of only $10.
• Since the law says that the dealer can only charge $10 per transaction, deals involving multiple firearms potentially have to be broken down into separate transactions with individual and discrete NICS phone calls if the dealer wants to make more than $10 on the entire lot. This actually makes a multiple-gun non-FFL sale a good deal more complex and time-consuming than a standard multiple-gun retail dealer sale, which can usually be done with a single collective NICS check. (This was discussed in another recent thread.)
• Since the law requires the dealer to take the firearm into inventory, the dealer may wind up having to keep the firearm if the buyer fails the NICS check and the seller subsequently fails as well. This is not uncharted territory for many dealers- consignments and pawned firearms can be non-returnable- but it's a hassle, particularly for so-called "kitchen table" home-based FFL's who rely primarily on transfer fees, and don't have a good venue to resell non-returnable firearms at retail like a brick-and-mortar store. (Discussed earlier in the thread.)