The "ghost gun" advantage.

[Prof Young]

I have a shooting buddy who is very mechanically inclined. He has made a couple of those "kit" guns that some refer to as "ghost" guns because they, apparently aren't a gun when you buy them and so there is no paper trail of any kind.

I'd kind of like to have an AK so I asked him about making one. He said he'd be glad to help me. I could even use his shop. So I asked about price. He said about $600 bucks to which my response was that I could buy a whole AK for that. He told me you don't save $$$ on this kind of gun. The only advantage is that there is no paper trail. Seriously?

I live in IL and the state police are NOT supposed to keep records of the back ground checks and who bought what. Someone at a very high level of state gov. would breaking the law in a heavy duty way for the State Police to have record of gun ownership. (Not that it couldn't happen, but this would be very serious law violation!) Granted I have to have a FOID card, but that doesn't tell them what guns I own, or even if I own any guns at all. However; my buddy says that IL gun dealers have to keep records of who bought what. Really?

So two questions:

1. Do IL gun dealers have to keep records of every sale? A list of who owns guns bought from their shop?

2. Is no paper trail the only "advantage" of a "ghost" gun.

Life is good.
Prof Young

[JoeSixpack]

I think "ghost gun" was started by the gun grabbers out in Cali.
At one point I think they was actually attempting to seize any they came across, I could have that wrong though.

They are referring to any gun that didn't come from a manufacture.
So this applies to 80% complete receivers as well as anything made by hand, cnc, or 3d printer.

Your friend is right I don't think there is any monetary advantage to making one (in most situations) an ar15 lower can be had for as cheap as like 30 bucks, really hard to beat that doing it your self.

It is not against federal law to manufacture a gun for your own use, it still has to adhere to the law though.
I don't know what the state to state laws are on making your own. so YMMV in that regard.

The real advantage is the gun is not going to have any sort of paper trail.. this is true.
Again this might vary from state to state, But in general no requirement to inform anyone or register it.

Just don't go selling it.. that would make you a manufacture.

Honestly though? if you're really so keen on not having a paper trail.. and I really hate to say this because the gun grabbers make it sound like this is the primary function of gun shows.. but buying used privately, no receipts, paying cash would disassociate you from the guns original "paper trail".

Im really not so worried that I'd go out of my way to avoid paper.
But I can see the appeal if you lived in some states.

[Metal god]

1. Do IL gun dealers have to keep records of every sale? A list of who owns guns bought from their shop?

Not sure specifically about IL but most FFL ( "federal" firearms license/d ) dealer must keep records of every gun sold for .....hmm I want to say 20+ years and even some years after they close . I'm not completely sure of all the numbers . So yes the state can find out who bought most any gun originally . If they have the serial # . First they contact the manufacture to see which FFL they sold it to . They then go to that FFL and ask to see there DROS ( dealer record of sale ) That should give them who bought the gun NIB . After that who knows what happens to the gun unless sold through a FFL again which they then would keep a record .

Is no paper trail the only "advantage" of a "ghost" gun.

Yep pretty much and FWIW It's not against the law "federally" to build your own firearm which is what you are doing with 80% AR-15 lowers and those AK kits .

[JohnKSa]

There's a paper trail unless you buy all your parts face-to-face using cash. The paper trail may not be as easy to locate as when you buy from an FFL, but it's still there.

In a state where you have to have a permit to own guns, I would argue that there's little point in trying to hide the fact that you own guns from the state. I suppose that there are some people who go to the hassle of getting the card and then never buy a gun, but it's not likely.

The benefits of building a gun from an 80% receiver are as follows:

1. The sense of accomplishment.
2. The legal circumvention of federal laws regarding the recordkeeping normally associated with the purchase of new firearms.

All FFL holders in any state are required to keep records of all the guns they sell. Those records stay with them as long as they are in business and are transferred to the BATF when they go out of business. The BATF is prohibited by law from using those records to create a database or registry of gun owners but is allowed to use them to perform a "forward trace" when law enforcement asks them to do so. A forward trace follows the path a particular firearm took from manufacturer to wholesaler/distributor to FFL/retailer to the initial purchaser but generally ends there.

In a few states, gun owners are required to register firearm ownership of all or certain types of firearms with the state and I imagine that would hold true of firearms one makes for their own use. I don't know the specific laws of IL.

By the way, you need to be careful about how much help your friend gives you in finishing the 80% receiver. If he helps you too much, then he could be possibly construed to be an unlicensed firearms manufacturer which would put him at odds with federal law and possibly any state laws regarding the transfer of firearms between private parties.

Just don't go selling it.. that would make you a manufacture.

You can't build a firearm with the intent of selling it unless you are a manufacturer. But, as I understand it, you can build a firearm for yourself and then later decide you don't want it and sell it legally at that point. However, if you do that a lot, you should expect to eventually have a talk with the BATF at which point you would need to have a really convincing case for why your repeated manufacture and sale of firearms doesn't make you a manufacturer.

[Frank Ettin]

Note that while someone may build a gun for his own use, it's my recollection that ATF has taken the position that you must do it all by yourself with your own tools.

It's late and I'm off to bed. I'll do some research and see if I can find some documentation later.

[44caliberkid]

You don't save any money building an 80% receiver. It is just that there isn't a record of manufacture or who was the original purchaser. If banning or confiscation ever passes, they won't know you have it. Although, some AR parts manufacturers/ distributors have been raided and their computers seized, so BATF does have sales and customer records for some dealers. Which I think JohnKSa was referring to. Your online buying records could be easily hacked.
That said, building an AR is easy, they just pin and screw together. The AK is a whole nuther animal. You have to weld frame rails into the receiver and heat treat it, and rivet parts together. You also have to press (hydraulic press) the parts onto the barrel and they must be perfectly indexed. Putting together an AR is a fun couple of hours on a Saturday morning and you can be shooting by noon. Putting together an AK takes days and specialized tools to do it right.

[5whiskey]

IMO, John really hit on the one true advantage of manufacturing your own kit gun... the sense of accomplishment. There is no real monetary advantage to doing so in most cases. As to the lack of paper trail, I understand the fears of a one-day registry being created and used to round up and seize firearms. In this case, the "ghost" gun may be beneficial in preventing that said firearm from being in the database and being seized.

With those fears being understood, I believe them to be irrational at this point. Things can change in a hurry, I understand. Even 10 years ago, gay marriage didn't have a majority of public support and even President Obama initially said "I'm not there yet." 10 short years later and it's the law of the land (which I'm fine with, BTW, as it has zero affects on my day to day life). Firearms ownership is a little different, though. We have a constitutional amendment promising our freedom to possess firearms, and long-standing statutory federal law preventing any kind of searchable database. Yes, when you go buy a gun from a gun dealer there is a traceable paper trail but it must be manually searched. Even if you purchase from a private party, there is a good chance that the firearm can eventually be traced back to you by interviewing all previous owners (assuming they kept a record of who they sold it to, which is technically not required but very prudent). Because of the labor involved, no Fed is going to come looking for your gun unless it has been involved in a crime. At that point, if you are a responsible citizen and on the up and up, you would likely volunteer any information needed anyway in the interest of justice.

All this to basically say the benefits of the "ghost" gun lack of paper trail have about a 1% chance of ever being realized in our lifetime. Not until the constitution is amended and long-standing statutory law is changed. When I see those headwinds coming, then I would debate making a couple to keep around. Even then, are you going to risk committing a felony (even though we feel that our rights are being violated)? I don't know if I would or not.

[johnwilliamson062]

it's my recollection that ATF has taken the position that you must do it all by yourself with your own tools.

My understanding is you can't rent tools or have anyone else touch them during manufacturing. I don't think ATFE has gone as far as borrowing or using friends tools being illegal, but I also don't think they have said it is OK. Also, I believe the legal consequences are mostly on the for-profit owner of the tools. This has also been extended to not for profits such as makerspaces and coop, which is downright ridiculous. A for profit makerspace I understand, but a non-profit doesn't make sense in my mind as it is a long stretch to it being a business operation in my mind.

Just don't go selling it.. that would make you a manufacture.

This isn't true. You can't manufacture it with the intent to sell. You can manufacture it with the intent of personal use, then at a later date change your mind and sell it. You don't have to serialize it by federal law at any point, but ATFE requests you do so. Discussion of how to prove intent at time of MFG and what red flags ATFE, etc. has been covered and it is one of the issues ATFE will not closely define, so mostly conjecture.

A normally manufactured firearm can be traced from manufacturer to first purchaser somewhat easily.
The law enforcement agency sends the serial number to the manufacturer and asks them to find where it was sent. They tell the agency what distributor they shipped it to. The agency then contacts the distributor. The distributor looks at their records and finds out what retailer they sent it too. The agency then contacts the retailer. The retailer looks at their records and tells the agency what individual they sold it to. From there the agency must track the gun through records of the individuals that sold it after tha.
The base records are the 4473s the FFLs must retain on all transfers. These must be gone through manually at each physical location. Some may have additional records that are more easily searched. Easy, but it takes a lot of time.
It is done for high profile cases where political fodder can be gained, such as mass shootings, and my understanding is almost never else-wise as it is too time consuming and for guns more than a few years old the trail after the last ffl transfer is usually nearly impossible to follow.

In theory a database could be constructed using all the 4473s. It would not be accurate for guns that were then resold and there are currently laws to stop such actions. The time it would take would be ridiculous and they aren't even doing it for most individual guns used in crimes, so I doubt it would be done for all guns.

I've said it before and will again, depending on how extensive you believe NSA eavesdropping on US citizens to be, and I think listening to all gun shop phones would be less absurd than somethings we know have been done and just as justifiable from an anti-terrorism anti-organized crime perspective, NSA could have a complete set of data recorded from all recent 4473 calls that could be electronically parsed and assembled into a wildly inaccurate database overnight.

All that said, I've considered building a ghost gun many times and it isn't worth the investment to me. I would like to buy a mini-mill for myself sometime in the future and once I do I will probably make one, but the investment is not worth it for the project. There are some silicone mold plastic lower methods that look much cheaper and easier that might be worth a look. Someone posted how they made them on TFL a year or two ago.

[Frank Ettin]

Originally Posted by johnwilliamson062

....I don't think ATFE has gone as far as borrowing or using friends tools being illegal,....

It's certainly not clear. See ATF Ruling 2015-1 (pp 5-6, emphasis in bold added):

...Held, any person (including any corporation or other legal entity) engaged in the business of performing machining, molding, casting, forging, printing (additive manufacturing) or other manufacturing process to create a firearm frame or receiver, or to make a frame or receiver suitable for use as part of a “weapon … which will or is designed to or may readily be converted to expel a projectile by the action of an explosive,” i.e., a “firearm,” must be licensed as a manufacturer under the GCA; identify (mark) any such firearm; and maintain required manufacturer’s records.

Held further, a business (including an association or society) may not avoid the manufacturing license, marking, and recordkeeping requirements of the GCA by allowing persons to perform manufacturing processes on blanks or incomplete firearms (including frames or receivers) using machinery, tools, or equipment under its dominion and control where that business controls access to, and use of, such machinery, tools, or equipment...

So in broad terms it looks like:

• If someone takes money for it, he can't help you.
  
  
• If someone is in the business of using the tools, he can't let you use his tools.
  
  
• But, maybe, your buddy who is an accountant can loan you a screwdriver and drill press from his home workshop in his garage.

[zukiphile]

Originally Posted by JohnKSa

The benefits of building a gun from an 80% receiver are as follows:

1. The sense of accomplishment.

I am amazed by the technical skill of people who can run equipment and turn an 80% lower into a usable product. I know I couldn't do that.

On the other hand, those 80% lowers always seem more expensive than a good (just good, like an Anderson, not something special) lower for $35 or $40.

[carguychris]

Originally Posted by Frank Ettin

• If someone is in the business of using the tools, he can't let you use his tools.
  
• But, maybe, your buddy who is an accountant can loan you a screwdriver and drill press from his home workshop in his garage.

It sounds to me that people could do "group builds" as is done with kit-built aircraft, i.e. organize a gathering where everybody takes turns using one person's tools to perform a certain manufacturing step.

FWIW the 80% receiver manufacturing process seems conceptually similar to building kit-built aircraft, which likewise can only be completed to a certain stage by the kit maker, and the owner/manufacturer may only farm out a small number of manufacturing steps to a commercial provider. (The regs applying to building your own aircraft are quite complicated compared to a "ghost gun," which makes sense when you consider that an average airplane is a much more complex machine than a firearm.)

[PoiDog]

If the 80% lower is your only AR, your only gun, and you bought it without using a credit card or online, you have a chance of it being invisible. You can buy uppers just about anywhere without paperwork.

But if you're a normal gun owner, and own several guns, somebody knows about it. It doesn't take Sherlock Holmes to figure you might have more guns laying around.

I imagine it's pretty difficult to stay off the radar these days.

[johnwilliamson062]

If they aren't your buddy's tools, but are actually tools belonging to the business which your buddy owns then I agree ATFE has been pretty clear they can't be used.
Harbor freight sells a fair number of small manual "mill/drill" and mill+lathe machines. Very few are owned by incorporated entities as they have no place in a commercial shop.
If the friend personally owns the tools and did not have them in a separate legal entity like an LLC, I'd be willing to go as far as saying I'd send a small check to your legal defense fund if they brought charges

I'd love to see a case concerning a member used not for profit makerspace.

[4V50 Gary]

Frank Ettin is right. It must be with your tools/machinery.

[Metal god]

Frank Ettin is right. It must be with your tools/machinery

Not arguing but when do you think the anti's will stop . Well you rent the house you live in so you can build it there . I lease my car so that must mean I can't call it "my" car .

How about , you can"t buy the tools if you plan to sell them after the build kinda like buying a gun if you only bought it to resale sell it for a profit , that's a straw purchase ????

[johnwilliamson062]

From ATF Clarification January 2, 2015

Use of Manufacturing Machines, Tools, or Equipment
An FFL or unlicensed machine shop may also desire to make available its machinery (e.g., a computer numeric control or “CNC” machine), tools, or equipment to individuals who bring in raw materials, blanks, unfinished frames or receivers and/or other firearm parts for the purpose of creating operable firearms. Under the instruction or supervision of the FFL or unlicensed machine shop, the customers would initiate and/or manipulate the machinery, tools, or equipment to complete the frame or receiver, or entire weapon. The FFL or unlicensed machine shop would typically charge a fee for such activity, or receive some other form of compensation or benefit. This activity may occur either at a fixed premises, such as a machine shop, or a temporary location, such as a gun show or event.

A business (including an association or society) may not avoid the manufacturing license, marking, and recordkeeping requirements under the GCA simply by allowing individuals to initiate or manipulate a CNC machine, or to use machinery, tools, or equipment under its dominion or control to perform manufacturing processes on blanks, unfinished frames or receivers, or incomplete weapons. In these cases, the business controls access to, and use of, its machinery, tools, and equipment. Following manufacture, the business “distributes” a firearm when it returns or otherwise disposes a finished frame or receiver, or complete weapon to its customer. Such individuals or entities are, therefore, “engaged in the business” of manufacturing firearms even though unlicensed individuals may have assisted them in the manufacturing process.

Held, any person (including any corporation or other legal entity) engaged in the business of performing machining, molding, casting, forging, printing (additive manufacturing) or other manufacturing process to create a firearm frame or receiver, or to make a frame or receiver suitable for use as part of a “weapon … which will or is designed to or may readily be converted to expel a projectile by the action of an explosive,” i.e., a “firearm,” must be licensed as a manufacturer under the GCA; identify (mark) any such firearm; and maintain required manufacturer’s records.
- 6 -


Held further, a business (including an association or society) may not avoid the manufacturing license, marking, and recordkeeping requirements of the GCA by allowing persons to perform manufacturing processes on blanks or incomplete firearms (including frames or receivers) using machinery, tools, or equipment under its dominion and control where that business controls access to, and use of, such machinery, tools, or equipment.

Held further, this ruling is limited to an interpretation of the requirements imposed on persons under the GCA, and does not interpret the requirements of the National Firearms Act, 26 U.S.C. 5801 et. seq.

ATF Ruling 2010-10 is hereby clarified.

I don't see anything in that which would indicate privately owned tools lent at no cost would be included, although this clarification does not clearly exclude such activity. I don't see how such activity could fall under "...engaged in the business.." by the wildest of stretches. The inclusion of not for profit associations seems quite a stretch to me. If there are further clarifications or cases where ATFE has pressed charges, I would love to see the links.

I have discussed the issue with lawyers concerning associations and the ruling, but it was not long after that clarification was issued.

One could sell the tools to a friend if worried. Used tools don't change value much through the course of a project. If broken he gets to keep, if not you could buy them back.

[JohnKSa]

I don't see how such activity could fall under "...engaged in the business.." by the wildest of stretches. The inclusion of not for profit associations seems quite a stretch to me.

The language "business (including an association or society)" is pretty sweeping. Maybe you and your friend aren't an "association or society" but how would you go about proving something like that in court if it came to that?

Not arguing but when do you think the anti's will stop .

Realistically, this isn't so much an issue of the anti's trying to redefine the term "manufacture" to be more restrictive as it is an issue of people trying to expand the limits of what "manufacture" means.

Saying that a person who hits the button to start a computer controlled milling machine that someone else owns and programmed is manufacturing a gun is like saying that the person who turns on the assembly line switch at a automobile plant is manufacturing cars.

It's not at all unreasonable for the BATF to insist on a more reasonable definition of "manufacture". The real problem is that when people push the limits, it can result in pushback in the form of "clarification" of existing rules. And that, unfortunately, often means that things are far less clear then they were in the beginning.

It is pretty easy to understand what is meant when the law says that a person can manufacture a firearm for his/her own use. Once someone tries to claim that pushing a button to start a process that someone else defined on machinery that someone else owns is "manufacturing" then the additional verbiage required to clarify what "manufacturing" really just makes the water muddier.

The proper response is to step back and take a common sense approach. If you want to manufacture a firearm then there's no problem. The law specifically allows people to manufacture their own firearms if they wish to do so. Of course you will need to acquire the skills and tools to accomplish the process.

On the other hand, if you just want to end up with a "ghost gun", but actually have no interest manufacturing your own firearm then the rational/reasonable response is to acknowledge that you're not the person that law was written for and move on.

[Metal god]

John I understand your point but I'm of the school of thought that if your not breaking the law you are following it . I don't buy into the whole loop hole thought . You are either complying with the law or you are not .

Example is the bullet button in CA . The states says it's a loop hole . I say no , we that have them are in "full" compliance with the law ( to date ) . We as individuals of a "free" country should not be required to individually guess what the anti's want . If they are so ignorant on how to write laws , then maybe they should not be writing them .

As far as technology goes . I'm sure we are not far from a point where I can just go to a machine shop with a thumb drive and push one button and I'll be able to mill a receiver from a block of what ever I want to use . What will they do then . I find it unreasonable to put those types of regulations on a law abiding citizen .

I'll admit I'm not a lawyer , What other products are regulated to that point . To where you must own the tools used and can't make the product if renting , leasing or just using someone else's tools ?

.

[JohnKSa]

John I understand your point but I'm of the school of thought that if your not breaking the law you are following it . I don't buy into the whole loop hole thought . You are either complying with the law or you are not .

I certainly agree that if the law is being followed there is no crime. However that's not what I was responding to. I was responding to the implication that this clarification could reasonably be viewed as a dangerous precedent that should cause us to worry that the antis will run amok taking similar actions.

As far as loopholes go, there are loopholes and there are loopholes.

There are "loopholes" in the sense that a law allows things that some people feel it shouldn't even though that was actually within the original intent of the law. This kind of "loophole" isn't really a loophole at all--it's simply rhetoric. Bullet buttons, your example, aren't really a loophole. Same with private gun sales--they aren't a "gun show loophole" because the law was never intended to prevent private gun sales.

And then there are actual loopholes. It is a fact that because laws are created by humans that they are fallible and therefore sometimes contain unintended legal options (loopholes). Similarly they may be subject to interpretations not intended by the lawmakers (loopholes). It is also true that as technology progresses and times change, new opportunities (loopholes) are created that didn't exist when the laws were written.

It's certainly legal to take advantage of those loopholes (i.e. to comply with the letter but not necessarily the intent) while the loopholes exist. I'm not arguing that point at all. I'm also not arguing that this particular "clarification" constitutes a reasonable restriction.

I'm just saying that it doesn't make sense to pretend that some sort of dangerous precedent is being set when true loopholes are closed. It would be more reasonable, to complain about the people who (albeit legally) pushed the limits of the law until pushback was essentially inevitable.

[johnwilliamson062]

"association or society" but how would you go about proving something like that in court if it came to that?

I believe the state is still required to provide the proof. I'm not sure if such things have been defined in regard to ATFE rules as they have in regard to incorporation and taxation or if ATFE has adopted either definition. As I understand it one can have an association or society by IRS definition without legally incorporating or formally forming a trust, although last I heard IRS was trying to restrict it and going after things like high school baseball booster clubs with checking accounts(an actual real life example).

No one wants to go to court with a federal agency. Even if you win you lose, especially if you don't get support from advocate groups, but often even if you do get financial support. One has to find a balance on risk and there is nothing I have seen that lead me to be particularly concerned about borrowing a friends personally owned tools.

[JohnKSa]

I believe the state is still required to provide the proof.

I figured that the progression was obvious but I'll go step by step.

The term "association" is very general. A group of individuals who voluntarily enter into an agreement to accomplish a purpose is an association.

So if you and your friend enter into an agreement to accomplish a purpose (i.e. lend me your tools so I can finish my 80% receiver), you qualify as an "association" under the general definition. There is no need for money to change hands, there is no need for your friend to be a business. The only proof the state would have to provide is that your friend lent you tools with the general understanding of what you were going to do with them.

Now the ball is in your court to prove that you and your friend aren't an "association" and that gets me to the question I asked in the previous post. How would you go about proving that you weren't an association?

As far as I can see, the only way for this to work out in your favor is if you have some way to refute any evidence the state has that your friend knew what you were going to do with the tools he lent you.

[johnwilliamson062]

If you want to design association that broadly I guess I just have to give up the idea in general. I don't see how I can purchase tools without forming an association with someone using your definition.
I could start with chipping flint and work up to a drill press, but at some point I am probably going to need a book and use of a library card would almost certainly form an association as defined.

At the end of the day ATFE has to tie it into "...engaged in the business..."
No one wants the legal heat so they are getting away with how broad they are defining "...engaged in the business..." as pertains to associations right now.

ATFE is using these rulings to shut down the use of business equipment because they can bully the business owners. No shop owner making car parts wants to go bankrupt fighting a legal battle because (s)he allowed his/her toolmaker to finish an 80% receiver on their own time after hours. And (s)he goes bankrupt even if (s)he wins.
Shut down makerspaces with the same leverage.

[Frank Ettin]

Originally Posted by johnwilliamson062

If you want to design association that broadly....

The term "association" can indeed apply that broadly.

The thing is that there are a number of open questions left by the ATF ruling. Until those questions are answered definitively, if they ever are, anyone building a gun for his own use relying on borrowed tools is in largely uncharted territory and exposing himself to considerable legal risk. And I suspect that no one really sees enough potential upside to be anxious to have his day in court for the purpose of clarifying the rules.

[JohnKSa]

If you want to design association that broadly...

First of all, it's not my definition. Second, what I want has nothing to do with anything.

I don't see how I can purchase tools without forming an association with someone using your definition.

I realize that you're being sarcastic, but I'll go ahead and give you a straight answer anyway.

The issue of whether or not there is an association specifically relates to getting help or using someone else's tools or machinery.

If the tools are actually yours--if, for example you were to actually purchase them and then use them yourself without any appreciable amount of help from someone else--then the issue of whether or not there is an association is moot.

At the end of the day ATFE has to tie it into "...engaged in the business..."

All they have to do is show that you didn't actually make the gun yourself. If they can show that then they have evidence that someone is avoiding the manufacturing license, marking, and recordkeeping requirements of the GCA.

ATFE is using these rulings to shut down the use of business equipment because they can bully the business owners.

It's not bullying for the BATF to enforce a reasonable definition of "manufacture". And realistically, this isn't so much an issue of BATF trying to redefine the term "manufacture" to be more restrictive as it is an issue of people trying to dramatically expand the limits of what "manufacture" means.

This is really VERY simple in spite of efforts to make it otherwise. The law specifically allows people to manufacture firearms for their own personal use. Of course people who want to manufacture a firearm will need to acquire the skills and tools required to perform the manufacturing process.

People who aren't actually interested in manufacturing a firearm need to understand that this law does not apply to them. And they need to understand that if they attempt to use this law to avoid the manufacturing license, marking, and recordkeeping requirements of the GCA, that they, and/or anyone who helps them, are very likely violating federal law.

[5whiskey]

People who aren't actually interested in manufacturing a firearm need to understand that this law does not apply to them. And they need to understand that if they attempt to use this law to avoid the manufacturing license, marking, and recordkeeping requirements of the GCA, that they, and/or anyone who helps them, are very likely violating federal law.

This is the takeaway. The personal use manufacturing exemption wasn't created for the purpose of us having the ability to make a "ghost gun." I'm sure that exemption created much angst and gnashing of teeth when the law was authored, but we have it and should be thankful that some lawmakers stuck to their guns. Alas, the purpose was for the hobbyist to create something without violating the law. Not for a legion of non-hobbyists to skip the 4473 paper trail. We should be happy the exemption is there instead of complain that it is as restrictive as it is.