Need advice on trusts and converting pistol ARs to SBRs

The new CFR that came out in August doesn't allow for barrel marking of makers marks any more. Some interesting stuff here. The barrel as an option for name, city and state is gone. ..

§ 479.102 Identification of firearms.
(a) Identification required. Except as otherwise provided in this section, you, as a manufacturer, importer, or maker of a firearm, must legibly identify the firearm as follows:

(1) Serial number, name, place of business. By engraving, casting, stamping (impressing), or otherwise conspicuously placing or causing to be engraved, cast, stamped (impressed) or otherwise placed on the frame or receiver thereof, an individual serial number, in a manner not susceptible of being readily obliterated, altered, or removed. The serial number must not duplicate any serial number placed by you on any other firearm. The frame or receiver must also be marked with either: Your name (or recognized abbreviation), and city and State (or recognized abbreviation) where you as a manufacturer or importer maintain your place of business, or in the case of a maker, where you made the firearm; or if a manufacturer or importer, your name (or recognized abbreviation) and the serial number that begins with your abbreviated Federal firearms license number, which is the first three and last five digits, as a prefix to a unique identification number, followed by a hyphen, e.g., “12345678-[unique identification number]”; and

(2) Model, caliber or gauge, foreign manufacturer, country of manufacture. By engraving, casting, stamping (impressing), or otherwise conspicuously placing or causing to be engraved, cast, stamped (impressed) or placed on the frame or receiver, or barrel or pistol slide (if applicable) thereof certain additional information. This information must be placed in a manner not susceptible of being readily obliterated, altered, or removed. The additional information shall include:

(i) The model, if such designation has been made;

(ii) The caliber or gauge;

(iii) When applicable, the name of the foreign manufacturer or maker; and

(iv) In the case of an imported firearm, the name of the country in which it was manufactured. For additional requirements relating to imported firearms, see Customs regulations at 19 CFR part 134.

(3) Multi-piece frame or receiver. In the case of a multi-piece frame or receiver, the modular subpart that is the outermost housing or structure designed to house, hold, or contain either the primary energized component of a handgun, breech blocking or sealing component of a projectile weapon other than a handgun, or internal sound reduction component of a firearm muffler or firearm silencer, as the case may be, shall be the subpart of a multi-piece frame or receiver identified in accordance with this section. If more than one subpart is similarly designed to house, hold, or contain such primary component (e.g., left and right halves), each of those subparts must be identified with the same serial number and associated licensee information not duplicated on any other frame or receiver. The identified subpart(s) of a complete (assembled or unassembled) multi-piece frame or receiver shall not be removed and replaced (see § 478.34 of this subchapter, 18 U.S.C. 922(k), and 26 U.S.C. 5861(g) and (h)), unless -

(i) The subpart replacement is not a firearm under 26 U.S.C. 5845;

(ii) The subpart replacement is identified by the qualified manufacturer of the original subpart with the same serial number and associated licensee information in the manner prescribed by this section; and

(iii) The original subpart is destroyed under the manufacturer's control or direct supervision prior to such placement.

(4) Frame or receiver, machine gun conversion part, or silencer part disposed of separately. Each part defined as a frame or receiver or modular subpart thereof described in paragraph (a)(3) of this section, machinegun, or firearm muffler or firearm silencer that is not a component part of a complete weapon or complete muffler or silencer device at the time it is sold, shipped, or otherwise disposed of by you must be identified as required by this section with an individual serial number not duplicated on any other firearm and all additional identifying information, except that the model designation and caliber or gauge may be omitted if that information is unknown at the time the part is identified.

(5) Size and depth of markings. The engraving, casting, or stamping (impressing) of the serial number and additional information must be to a minimum depth of .003 inch, and the serial number and any associated license number in a print size no smaller than 1/16 inch. The size of the serial and license number is measured as the distance between the latitudinal ends of the character impression bottoms (bases). The depth of all markings required by this section is measured from the flat surface of the metal and not the peaks or ridges.

(6) Period of time to identify firearms. You, as a manufacturer, shall identify a complete weapon or complete muffler or silencer device no later than close of the next business day following the date the entire manufacturing process has ended for the weapon or device, or prior to disposition, whichever is sooner. You must identify each part or modular subpart defined as a machine gun (frame or receiver, or conversion part) or muffler or silencer that is not a component part of a complete weapon or complete muffler or silencer device at the time it is sold, shipped, or otherwise disposed of no later than close of the next business day following the date the entire manufacturing process has ended for the part, or prior to disposition, whichever is sooner. For purposes of this paragraph, firearms awaiting materials, parts, or equipment repair to be completed are presumed, absent reliable evidence to the contrary, to be in the manufacturing process. Importers must identify imported firearms within the period prescribed in § 478.112 of this subchapter.

(7) Meaning of marking terms. For purposes of this section, the term “identify” means placing marks of identification, the terms “legible” and “legibly” mean that the identification markings (including any unique identification number) use exclusively Roman letters (e.g., A, a, B, b, C, c) and Arabic numerals (e.g., 1, 2, 3), or solely Arabic numerals, and may include a hyphen, and the terms “conspicuous” and “conspicuously” mean that the identification markings are capable of being easily seen with the naked eye during normal handling of the firearm and are unobstructed by other markings when the complete weapon or device is assembled.

(b) Exceptions -

(1) Alternate means of identification. The Director may authorize other means of identification to identify firearms upon receipt of a letter application or prescribed form from you showing that such other identification is reasonable and will not hinder the effective administration of this part.

(2) Destructive devices. In the case of a destructive device, the Director may authorize other means of identification to identify that weapon upon receipt of a letter application or prescribed form from you. The application shall show that engraving, casting, or stamping (impressing) such a weapon as required by this section would be dangerous or impracticable and that the alternate means of identification proposed will not hinder the effective administration of this part.
Interesting. The source I look at has also been updated.
 
Looking at the eFile form 1, the trickiest part is that there are places where you browse to add files (e.g, your form 23 and passport-like photo) and other places where you browse to add files but then have to click a separate button to actually add the file (e.g. photo of engravings, copy of trust). On my first pass through I didn't catch this but the form showed that it was verified and ready to file. From the draft pdf there's no way (that I could find) to see that files were missing. I caught this on final review and hopefully got everything right.
 
Looking at the eFile form 1, the trickiest part is that there are places where you browse to add files (e.g, your form 23 and passport-like photo) and other places where you browse to add files but then have to click a separate button to actually add the file (e.g. photo of engravings, copy of trust). On my first pass through I didn't catch this but the form showed that it was verified and ready to file. From the draft pdf there's no way (that I could find) to see that files were missing. I caught this on final review and hopefully got everything right.
If you dont have everything included it wont let you submit.
 
If you dont have everything included it wont let you submit.
Good to know. I included both the trust and the assignment of property. I imagine a lot of folks forget to include the assignment of property since it's not mentioned in the instructions.

It would be good if the ATF instructions had a checklist of documents to prepare before starting the form 1, e.g. required documents, forms, photos, etc. I used the form generator at thetrustshop.net to get familiar with form 1 and its requirements, and also to generate form 23.

Since I've bought silencers from silencershop.com, I bought fingerprint cards from them rather than rolling my own. IFAICT, one advantage of paper filing is that you can submit multiple form 1's with a single pair of fingerprint cards. Is there any way to eFile additional form 1s w/o having to provide new fingerprint cards each time?
 
Good to know. I included both the trust and the assignment of property. I imagine a lot of folks forget to include the assignment of property since it's not mentioned in the instructions.

It would be good if the ATF instructions had a checklist of documents to prepare before starting the form 1, e.g. required documents, forms, photos, etc. I used the form generator at thetrustshop.net to get familiar with form 1 and its requirements, and also to generate form 23.

Since I've bought silencers from silencershop.com, I bought fingerprint cards from them rather than rolling my own. IFAICT, one advantage of paper filing is that you can submit multiple form 1's with a single pair of fingerprint cards. Is there any way to eFile additional form 1s w/o having to provide new fingerprint cards each time?
That would go against the whole designed in 1987 windows 2.0 prodigy webpage vibe they got going on.

FWIW you only need one set of prints per envelope full of form 1 cover letters. Every time you get a confirmation on eforms you get a cover letter.
 
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Good to know. I included both the trust and the assignment of property. I imagine a lot of folks forget to include the assignment of property since it's not mentioned in the instructions.
Some trusts don’t use assignment of property forms. I have one that does and one that doesn’t. Sometimes I include it, sometimes I don’t. Always approved.

The one I have that doesn’t uses a Schedule A instead. 30+ times I submitted the exact same Schedula A…that has nothing for $200 cash list. Approved every time.
 
Do I need a copy of the trust, or a scanned version of the signed trust? Is a scanned version of the signed trust legally a copy of the trust?
FWIW, I submitted a scanned copy of the signed and notarized trust, based on these instructions from thetrustshop.net:

Gun Trust - Every time you submit a Form 1 Application, you are required to include a
complete copy of your signed and notarized gun trust. If you have created any Amendments
to your gun trust, they will also need to be included.

ps. I use the GeniusScan app on iPhone to scan documents, then email the pdf to myself (ETA: so that I can download the pdf to my desktop and upload to the ATF).
 
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I don't have anything of value to say besides why do we as law abiding citizens have to go through this legal cornmaze, but Chicago gangbangers are exempt???

😮‍💨
 
Ok, so serial number is covered.

You need to add Maker’s name, plus the City & State where the firearm is made. That can be on the receiver or barrel.

The caliber also has to be marked. That’s usually on the barrel. So even if the lower says “multi” you’re covered.

I did have one build where the lower said multi, and I was chopping down a longer barrel and lost the markings, so that on that one I had to engrave caliber as well.
It says Spike's on the receiver and the barrel is stamped with the caliber. The "maker" being me, my name, city, and state have to go on it as well, if I understand the above. All to simply put a collapsible buttstock on a gun that has a collapsible pistol brace of the same shape, and same make. So many other things the ATF could be focused on other than this.
 
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It says Spike's on the receiver and the barrel is stamped with the caliber. The "maker" being me, my name, city, and state have to go on it as well, if I understand the above. All to simply put a collapsible buttstock on a gun that has a collapsible pistol brace of the same shape, and same make. So many other things the ATF could be focused on other than this.
Yes. Name city and state on the receiver. IF you happen to live in the state and or city the original manufacturer is in you dont have to put it on there again. Just to muddle things up .
 
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Yes. Name city and state on the receiver. IF you happen to live in the state and or city the original manufacturer is in you dont have to put it on there again. Just to muddle things up .
Thanks. I wish I had waited a couple weeks. Ended up with a neat Black Rain billet that I’d now prefer to pay the tax for, but the Spike’s is already 35 days in the works.
 
Makes sense, although this one will stay in the family, and make its way to the family trust.

Yeah but its like buying a diamond ring and putting in a trust so it can never leave the family. Might as well be a Cubit Zirconia. I mean I have cheap ass receivers that are SBR'd and expensive Colts and to be honest I kinda wish I hadn't SBR'd the Colts.
 
Yeah but its like buying a diamond ring and putting in a trust so it can never leave the family. Might as well be a Cubit Zirconia. I mean I have cheap ass receivers that are SBR'd and expensive Colts and to be honest I kinda wish I hadn't SBR'd the Colts.
Interesting to see another point of view. I'm going down a similar path as @NiceOldDouble, building a new billet lower before filing the Form 1. TBH, I don't think I'll ever sell anything that has a tax stamp. Also, my build is mostly a fancy range toy, so I'll be happier having the stamp on the billet receiver. I don't really want to spend time and $200 to get a stamp on the cheap lower that I had to violate with a Dremel tool to get the high-end, two-stage drop-in trigger to actually drop in to. :)

ETA: But, yes, I totally get @wired 's position if your goal is function over form.
 
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Interesting to see another point of view. I'm going down a similar path as @NiceOldDouble, building a new billet lower before filing the Form 1. TBH, I don't think I'll ever sell anything that has a tax stamp. Also, my build is mostly a fancy range toy, so I'll be happier having the stamp on the billet receiver. I don't really want to spend time and $200 to get a stamp on the cheap lower that I had to violate with a Dremel tool to get the high-end, two-stage drop-in trigger to actually drop in to. :)

ETA: But, yes, I totally get @wired 's position if your goal is function over form.
I think you're buying into the cheap receivers aren't good receivers line if thinking. Modern CNC machines have pretty much destroyed that old fudds take
 
My "good" lowers fit on every upper I own. Not so much Barnes and PSA lowers.
I have one receiver that is out of spec. Its an Anderson and with it I have to knock the rear pin out with a punch. Ironically that arguably makes it a tighter fit and I get zero wobble out the upper. Bonus. The rest of the 30 or so of them regardless of price fit fine.
 
If you can knock out the rear pin relatively easily, with a few taps to start it, I wouldn't consider it out of spec at all. Sometimes they're a little tight.
If it was in spec it would need just finger pressure. I have no problem with it and otherwise its a fine receiver but that hole is a bit too low.
 
My "good" brand lowers fit on every upper I own that I've tested. Not so much Barnes and PSA lowers, some require tools and lots of force and hammering to get on or off lowers. Only in spec lowers should be SBRed.
but be careful you're not testing short barreled uppers on lowers that were first built as rifles, because that would be a felony for each one.
 
But once the lower is an SBR it doesn't matter...
yes, but if you're testing lowers with uppers to see which ones would be best to sbr, you run the risk of accidentally using a rifle lower with a short upper and making an illegal SBR. Doesn't matter if you're GOING to register it, you already broke the law.

But only you and the ghost of j edgar hoover will know. So if you wake up with your magazines stuffed full of ladies underwear dripping ectoplasm, you know why.
 
yes, but if you're testing lowers with uppers to see which ones would be best to sbr, you run the risk of accidentally using a rifle lower with a short upper and making an illegal SBR. Doesn't matter if you're GOING to register it, you already broke the law.

But only you and the ghost of j edgar hoover will know. So if you wake up with your magazines stuffed full of ladies underwear dripping ectoplasm, you know why.
What’s a rifle lower?

🤔😉
 
What’s a rifle lower?

🤔😉
you know you know!
I have 2 ARs I bought pre-assembled, in rifle configuration. a century and an M&P15
all others came as "other firearm", but a couple are registered as rifles of the short-barreled variety.
this is why i would laugh if the entire ATF burned to the ground.
 
People are more than welcome to do with their guns what they wish. But it’s sad that at the mere mention of the ATF making a rule (not a law, and totally subverting the AG’s guidance memo) people are rushing to register their privately held firearms. Turning this into a self fulfilling prophecy. They’re getting their registration without having to make one
 
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