Mac90 922r compliance

[Circuits]

class III firearms are not subject to 922 regulations.

No such thing as a class III firearm.

"NFA Firearms" or "Title 2 Firearms" are still subject to 922(r) if they're semi-auto. ATF changed their mind on it in the past couple years.

[micah360]

No such thing as a class III firearm.

"NFA Firearms" or "Title 2 Firearms" are still subject to 922(r) if they're semi-auto. ATF changed their mind on it in the past couple years.

sorry... I meant NFA... not class III (that is a dealer status right?)

This is news to me... I've read a couple different letters from the ATF on this matter and it seems to me that when a firearm is changed to NFA status through a Form 1, then 922 is not applicable to it anymore.

[Circuits]

This is news to me... I've read a couple different letters from the ATF on this matter and it seems to me that when a firearm is changed to NFA status through a Form 1, then 922 is not applicable to it anymore.

Yep, they changed their minds in several letters dated 2008 or later which have been posted to ar15.com... if it's semi auto, 922(r) still applies.

Yes this directly contradicts their opinion letters from the 2005/2006 timeframe.

The real bitch about ATF letters is that they're only ever directly applicable to the person they're addressed to, and the specific situation therein covered, and that means the next letter supercedes all that has gone before, except for the one person the previous letter applied to.

The only rulings the ATF issues which have general and widespread applicability are their occasional official "rulings", which are published on their website and in the ATF FFL newsletters. Those have never addressed 922(r) and NFA that I recall.

[BPTactical]

922 (r)
The Imported Parts Law (1990)
178.39 otherwise known as 922(r) 10 Foreign parts law on semi auto Rifles & Shotguns
http://www.atf.treas.gov/regulations/27cfr178.html
Sec. 178.39 Assembly of semiautomatic rifles or shotguns.
(a) No person shall assemble a semiautomatic rifle or any shotgun using more than 10 of the imported parts listed in paragraph (c) of this section if the assembled firearm is prohibited from importation under section 925(d)(3) as not being particularly suitable for or readily adaptable to sporting purposes.
(b) The provisions of this section shall not apply to:
(1) The assembly of such rifle or shotgun for sale or distribution
by a licensed manufacturer to the United States or any department or agency thereof or to any State or any department, agency, or political subdivision thereof; or
(2) The assembly of such rifle or shotgun for the purposes of
testing or experimentation authorized by the Director under the
provisions of Sec. 178.151; or
(3) The repair of any rifle or shotgun which had been imported into or assembled in the United States prior to November 30, 1990, or the replacement of any part of such firearm.
(c) For purposes of this section, the term imported parts are:

(1) Frames, receivers, receiver castings, forgings or stampings
(2) Barrels
(3) Barrel extensions
(4) Mounting blocks (trunnion)
(5) Muzzle attachments
(6) Bolts
(7) Bolt carriers
(8) Operating rods
(9) Gas pistons
(10) Trigger housings
(11) Triggers
(12) Hammers
(13) Sears
(14) Disconnectors
(15) Buttstock
(16) Pistol grips
(17) Forearms, hand guards
(18) Magazine bodies
(19) Followers
(20) Floor plates
The 16 countable parts of an AK rifle. No more than 10 of these parts may be imported.
On a typical stamped receiver rifle you need to replace 5 parts with no muzzle attachment and 6 parts with a muzzle attachment.
On a typical milled receiver rifle you need to replace 4 parts with no muzzle attachment and 5 parts with a muzzle attachment, because there isn't a barrel trunnion, it is part of the receiver.