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Old February 29, 2016, 10:50 AM   #1
Gunny0345
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FFL question

Hi all I have a FFL 01 and if I got my sot 3 if I bought some lowers to assemble a post 86 Ar-15
would that be considered manufacturing? I am just putting parts together,
I know to purchase a post 86 I need a sot 3 and a law letter as a dealer sample. thanks
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Old February 29, 2016, 11:55 AM   #2
dogtown tom
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Quote:
Gunny0345 Hi all I have a FFL 01 and if I got my sot 3 if I bought some lowers to assemble a post 86 Ar-15
would that be considered manufacturing?
To assemble firearms from lowers YOU buy.... you must have an 07FFL. ATF considers this manufacturing. The State Dept does not consider assembly as manufacturing so no ITAR needs to be paid.

If you assemble a firearm from parts your customer brings you, that's considered gunsmithing and only requires an 01FFL.

To manufacture NFA firearms you would need an 07FFL (Manufacturer) and 02 SOT and pay ITAR every year.





Quote:
I am just putting parts together,
I know to purchase a post 86 I need a sot 3 and a law letter as a dealer sample. thanks
Correct.
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Old February 29, 2016, 01:34 PM   #3
Gunny0345
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FFL Question

thanks a lot I appreciate it yeah I would be buying complete lowers and uppers and putting them together. but I could not sell them though. since they are post 86 parts like if I bought a upper from one place and a lower from a class 3 dealer. would I need anything else to complete the gun? would I also need a chief of police letter to get them or just to buy a complete nfa ar-15?
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Old February 29, 2016, 02:06 PM   #4
Sharkbite
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Are you talking about "making" dealer samples? Or tax stamped guns?
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Old February 29, 2016, 06:22 PM   #5
dogtown tom
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Quote:
Gunny0345 thanks a lot I appreciate it yeah I would be buying complete lowers and uppers and putting them together.
You would need an 07FFL and 02SOT.





Quote:
but I could not sell them though. since they are post 86 parts like if I bought a upper from one place and a lower from a class 3 dealer.
Sure you could........but the FFL buyer would need to provide a LE demonstration letter for a post '86 machine gun.

You haven't been real clear on exactly what you plan to build. With an 07FFL you can build Title I AR15's all day long and sell them to anyone. If you build machine guns you can only transfer to other 07's with a LE demonstration letter.




Quote:
would I need anything else to complete the gun?
Complete lower + complete upper = complete gun. Insert magazine.

If you are buying a complete full auto lower you would need a law letter.



Quote:
would I also need a chief of police letter to get them or just to buy a complete nfa ar-15?
If you buy a machine gun that is post '86 you will need a LE demo letter. Both a complete machine gun and a machine gun frame or receiver is the same in the eyes of the law.
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