ATF Rul. 2015-1 (AR builders beware)

[Windwalker]

Cross posted-

Just when I think of something fun to do they spoil it.

ATF Rul. 2015-1

http://www.atf.gov/sites/default/files/assets/Firearms/FirearmsIndustry/atf-ruling-2015-1-manufacturing-and-gunsmithing.pdf

January 2, 2015

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 Gun Control Act of 1968 (GCA); identify (mark) any such firearm; and
maintain required manufacturer’s records. 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 firearms (including frames or
receivers) using machinery or equipment under its dominion and control where that business
controls access to, and use of, such machinery or equipment. ATF Ruling 2010-10 is hereby clarified.

(summarized for brevity) 

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.

Date approved: January 2, 2015

B. Todd Jones
Director

[Jingles]

Not to be a total non conformists or question my government but I think I would have to check exactly what is in the Gun Control Act of 1968. Departments DO NOT MAKE federal laws the congress does then they are either signed or vetoed by the President.  That is why the constitution is so important and we need to get back to a Constitutionally run Government. Tired of all this change this or that to suit someone in charge saying I want to change this so I'll make it a regulation.. Regulations Are NOT LAWS........ fu-- THEIR REGULATIONS

[Fl0und3rz]

Seems like this applies only to those "in the business," who have been allowing their business assets to be used by hobyists "under instruction." I don't like it, but it's not surprising.

[addicted]

Anyone read unintended consequences?

[JimmyHoffa]

Must be enough 80% receivers out there that the gruberment is missing out on a significant amount of tax dollars.

[Bean Counter]

I suppose its a good idea to buy a few AR lowers so they're grandfathered in under the current laws and what not.

[jay.sharkbait]

EVERYONE PANIC!!!!!!!

This clarification only applies to people finishing 80% rec'rs at commercial machine shops......

[T Pearce]

Anyone read unintended consequences?

Recommended reading.
Between that book and the movie No country for old men, I rather not leave the BOL.
 

[Bigshooter]

I thought all this was, was a revision to include 3D printing.

[csaaphill]

Not to be a total non conformists or question my government but I think I would have to check exactly what is in the Gun Control Act of 1968. Departments DO NOT MAKE federal laws the congress does then they are either signed or vetoed by the President.  That is why the constitution is so important and we need to get back to a Constitutionally run Government. Tired of all this change this or that to suit someone in charge saying I want to change this so I'll make it a regulation.. Regulations Are NOT LAWS........ fu-- THEIR REGULATIONS

exaclty seems like just because they know tons of people might be doing this they make this crap up F that crap.
How many more usurpations and absolute despotisms do we put up with?

[Windwalker]

The way I read it- unlicensed individuals can convert 80% lowers, if they own all the equipment.

The spirit of this IMHO is focused on warning businesses intent on machining AR blanks for others.
Which...doesn't make sense financially so the other tact would be reining in unserialized build projects with decent CNC machines.

More of a risk if you take it to a buddy's shop or do it at work if they decide a "distribution" has taken place and require you to be licensed as a manufacturer..
"(includes making a frame or receiver, or taking any of the steps to make an existing frame or receiver functional)"

Hmm, so no more AR lower machining parties at the local machine shop.

"If the above mentioned activities were permitted, firearms could be legally manufactured without any markings or serialization by dealer-gunsmiths
who could avoid licensing as a manufacturer simply because his/her customer is unlicensed. For example, instead of purchasing marked and serialized
receivers or complete weapons from licensed dealers, individuals might purchase unregulated castings or machined/molded bodies from a supplier,
perform a minor machining or other operation sufficient to create a “firearm frame or receiver,” contract with a gunsmith to perform necessary and
substantial machining operations, and then assemble a complete weapon without marks of identification or records of production. 
Such activity runs contrary to a major purpose of the GCA in that it eliminates the ability of law enforcement to trace firearms used in crime, or stolen or lost firearms."

- defines a “person” to include “any individual, corporation, company, association, firm, partnership, society, or joint stock company.”

A business (including an association or society) may not avoid the manufacturing license, marking, and record keeping 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.

[csaaphill]

Not to be a total non conformists or question my government but I think I would have to check exactly what is in the Gun Control Act of 1968. Departments DO NOT MAKE federal laws the congress does then they are either signed or vetoed by the President.  That is why the constitution is so important and we need to get back to a Constitutionally run Government. Tired of all this change this or that to suit someone in charge saying I want to change this so I'll make it a regulation.. Regulations Are NOT LAWS........ fu-- THEIR REGULATIONS

but it doesn't mater anymore Jingles, a Constitutionaly Protected Republic died long ago, when people began circumventing our rights and no reprisel from us so...
But dunno from what I read anyone means anyone as in Me or anyone else who has thier own machine shop and can do all the steps their own has to comply or die basically.  me all you want, but this is just one more nail in the coffin of those wanting to stay away from GOv entity's knowing what you building etc.. AND ya they shutt down the web site that offered files for 3d prinitng thier own plastic reciever. People really need to shutt up and not advertise freedom to the feds or anyone really, because once the find out liberty dies.

[Windwalker]

 

 Sorry state of affairs..
The new trend seems to be public announcement via (well attached) 'leaks' pertaining to a memo or new direction via interpretation or vague ideal held by the supreme commander.
No law, just hearsay.
Leftists tow the line and surround it with published support & it becomes the new way things are done.
Any grief is followed up with IRS inquiries, tip offs to BATF etc.
If you support, coffers filled, special assignments made or favors filled.     


They come to be accepted by degrees, by precedent, by implication, by default, by dint of constant pressure on one side and constant retreat on the other –
until the day when they are suddenly declared to be the country’s official ideology.

Necessity is the plea for every infringement of human freedom.
 It is the argument of tyrants; it is the creed of slaves.

[timberfaller]

There used to be bumper stickers out there that said,

Don't lie,cheat or steal!! The Government Hates competition!!

Yes, the Republic has been under attack for decades mainly by the Democratic Party and lazy Republicans!  Aided by LIV'S!

[Special T]

The way I read it- unlicensed individuals can convert 80% lowers, if they own all the equipment.

The spirit of this IMHO is focused on warning businesses intent on machining AR blanks for others.Which...doesn't make sense financially so the other tact would be reining in unserialized build projects with decent CNC machines.

More of a risk if you take it to a buddy's shop or do it at work if they decide a "distribution" has taken place and require you to be licensed as a manufacturer..
"(includes making a frame or receiver, or taking any of the steps to make an existing frame or receiver functional)"

Hmm, so no more AR lower machining parties at the local machine shop.

"If the above mentioned activities were permitted, firearms could be legally manufactured without any markings or serialization by dealer-gunsmiths
who could avoid licensing as a manufacturer simply because his/her customer is unlicensed. For example, instead of purchasing marked and serialized
receivers or complete weapons from licensed dealers, individuals might purchase unregulated castings or machined/molded bodies from a supplier,
perform a minor machining or other operation sufficient to create a “firearm frame or receiver,” contract with a gunsmith to perform necessary and
substantial machining operations, and then assemble a complete weapon without marks of identification or records of production. 
Such activity runs contrary to a major purpose of the GCA in that it eliminates the ability of law enforcement to trace firearms used in crime, or stolen or lost firearms."

- defines a “person” to include “any individual, corporation, company, association, firm, partnership, society, or joint stock company.”

A business (including an association or society) may not avoid the manufacturing license, marking, and record keeping 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.

I agree with yourstatment. I know of several guys who have done the build your own party with an automated CNC machine... most actually bought 60% lowers and finished them.  Government is behind the times and since the manufacture of the jigs has been so sucessful the end product works too well. The ATF is going after those with the most to lose, and strong arming them into complience. Since the risk VS reward is low you wont find people bucking this ruling... you will however find Jigs to do this as a great investment.