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I also think if they issue you a firearm as a replacement it still goes directly to you, right?
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When Ruger replaced an LCR they couldn't fix I had to go through a FFL. The replacement LCR had issues, and I returned it, they couldn't fix that one either so they sent me another replacement, and I had to go through the FFL a second time.
I think the rule is: new serial number = FFL transfer