NPRM - Definition of Frame / Receiver

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  • Kharn

    Ultimate Member
    Mar 9, 2008
    3,581
    Hazzard County
    I've heard that using a disposable painters coverall/zip up suit really helps keep them from getting attached to you. Then just vacuum up the floor and table every few passes with a shop vac helps keep them from getting everywhere...again...so I've heard. ;)

    A chintzy glove box made from some plastic tubing, fittings, and a clear tarp would help contain the carnage. Also can change from the tarp to white cloth to make a great miniature photo booth for selling stuff online.
     

    lazarus

    Ultimate Member
    Jun 23, 2015
    13,741
    I’m confused, since this is “technically” law, what happens if we just say **** it and don’t do it? They’re unmarked for a reason. What are they going to do? Come to every single persons house and search for weapons like it’s Iraq?


    Sent from my iPhone using Tapatalk

    Nothing at all.

    It isn't super clear, but the summary only talks about FFLs are required to mark a privately manufactured firearm if it comes in to their possession (personally or their business). Reading the entire friggen 100+ page NPRM it is CLEAR the marking requirements ONLY apply to FFLs (and exempt C&R holders unless the PMF is 50+ years old, exempting pre-1968 firearms PMF or otherwise).

    So as a private person, the NPRM doesn't touch on you at all, unless you are a prohibited person and are in possession of an unfinished 80%. In that case, ATF is likely going to be treating 80%s as firearms...so if you DO get caught with one, well they are going after you (not just a completed one).

    Where it WILL impact you is that likely all 80% being sold are going to have to be serialized and go through an FFL. But anything you already own or up until the NPRM goes in to affect has no impact on you whatsoever.
     

    lazarus

    Ultimate Member
    Jun 23, 2015
    13,741
    IF it looks like a firearm receiver, it has to have a serial number applied by an FFL...

    No grandfather clause...

    it's Gun Control by Exective Fiat... Biden demanded it and the ATF delivered...

    It's a good thing Trump did not set the precedent for Gun Control by Executive Fiat by demanding & getting a bump stock ban from the ATF that's still in the courts, without a temporary stay on enforcement or a grandfather clause turning millions of law abiding u.s. citizens into instant felons overnight...
    Sarchasm.


    BumpstockCase.com

    Only if an FFL touches it. If an FFL doesn't touch it, that isn't the case.

    To be clear, the NPRM is applying serialization requirements to FFLs.

    That being said, based on what they are saying in the NPRM, all 80% moving forward are likely to be treated as firearms. So manufacturers of 80% would be in the business of manufacturing firearms and will need a manufacturers license, even if they don't make completed firearms today. And thus also the serialization rule is going to apply.

    If you look at the ATF's language in the NPRM on readily convertible, 80%s are almost certainly going to be considered readily convertible, it won't matter if a jig or other parts ship with it. They cite case law where readily convertible included included a person with basic machine shop skills, access to a machine shop and its tools and several hours of work as being considered READILY convertible.

    Slightly above average person on the street who can use hand tools can transform an 80% in to a working firearm in a few hours. One with a router or dremel faster. One with a mill or x-y vise and a drill press even faster.

    You can bet the ATF is going to tell every 80% manufacture to comply, get an FFL and serialize every 80% or face prosecution.

    But again, all the 80%s already privately owned, the ATF is being clear, you do not need to do anything. No requirement to serialize. The only thing you WILL run in to, is you will not be able to sell an 80% over state lines as they are going to be considered firearms. Any of those gun show dealer's selling 80%s are also going to have to stop as they are going to be in the business of selling firearms at that point.

    Any PMF or 80% that an FFL touches, will need to be serialized and entered on their books. That includes if you needed a gunsmith to help fix something (the NPRM is clear, the gunsmith does NOT need to have it overnight to be required to enter it in to their books and serialize it. They touch, they need to be putting a serial number on it and have it on their books).

    now a non-FFL gunsmith would not need to, but if you hold an FFL other than an -03, if you do any work on the firearm, are transferring it, offering it for sale, take possession, etc. you must put a serial number on it within X time or before it leaves your possession unless it is to another FFL to have the serial number put on the PMF.

    The NPRM is effectively ending 80%s as we know it. But it is not banning existing ones in private hands nor is it requiring you to go out and put a serial number on your 80% or PMF unless an FFL is going to touch it.

    I can still see there being a market for 80%s moving forward, especially because of state laws. Some guys are still going to want to build their own guns. Plus some states (Maryland!) are stricter on a full up firearm. So once the NPRM is in affect, you'd need to have your FFL transfer an 80% to you and do a 4470. But if you wanted to build a PF940 for example, that's over the counter rather than needing to wait on a 77r, $10 fee and HQL.

    One thing I do see, and I don't think I'd consider it a perk necessarily, is more manufacturers getting in to making stripped frames and selling them. A lot of guys went the 80% route because they DID want to build a gun from scratch. They didn't necessarily care too much about drilling a few holes and milling a bit.

    Now in the AR world, lowers are everywhere. In the pistol world, not so much. Especially not right now. If wanted to build a Glock from scratch, it was way easier on many levels to get a P80 and build it than try to track down a stripped frame. And now, there are NO stripped frames (that I can find). So some of those guys who wanted to build a Glock from scratch probably will still be in the market for stripped frames (whether it was a P80 completed frame, or a Glock factory stripped, or someone else's completed frame). Or a 1911 frame, etc.

    Hell that is the reason I have a couple P80s is I wanted to build some Glocks and I haven't been able to find a stripped frame at any price, let alone a sane one, in well over a year. Oh sure, saving me time and a pain in the butt was a feature of a P80. But I would have been willing to do it.

    So I don't think the NPRM, if it goes in to affect as is and if it holds up through lawsuits, is going to stop the DIY market that has grown up. There are a lot of guys who just want to build their custom pistol themselves from scratch. Just like guys had been doing with ARs for a few years before 80s really came on the scene. It is likely to stop or massively curtain 80%s themselves and probably boost manufacturers of completed frames that are Glock Gen 3 (or whatever gen) compatible, 1911 compatible, etc. Hell, Glock may even get in to making frames and selling them rather than just complete guns (I doubt it).
     

    Overwatch326

    Active Member
    Aug 13, 2016
    370
    I would, if you could actually find it on regulations.gov! When you follow the link from the ATF page, it takes you to regulations.gov, but not the actual comment section. A search for the 2021R-05 brings up nothing.

    [UPDATE]: Atlantic Firearms (Bless you, boys) posted a video on this latest idiocy, and in the comments apparently someone e-mail ATF and got the following response:

    "The rule will publish this week (most likely Friday) in the Federal Register. Once it publishes, the comment period will begin and you will be able to comment at regulations.gov by searching for 2021R-05.
    Thank you."

    So... Comment period better be 90 days from 5/14, then; they're probably hoping everyone'll forget about it over the weekend if they slip it in on a Friday.

    Still no sign of it being up for comments...
     

    John from MD

    American Patriot
    MDS Supporter
    May 12, 2005
    22,965
    Socialist State of Maryland
    IF it looks like a firearm receiver, it has to have a serial number applied by an FFL...

    No grandfather clause...

    it's Gun Control by Exective Fiat... Biden demanded it and the ATF delivered...

    It's a good thing Trump did not set the precedent for Gun Control by Executive Fiat by demanding & getting a bump stock ban from the ATF that's still in the courts, without a temporary stay on enforcement or a grandfather clause turning millions of law abiding u.s. citizens into instant felons overnight...
    Sarchasm.


    BumpstockCase.com

    We must be reading different NPRM's because I don't see this anywhere.
     

    jcutonilli

    Ultimate Member
    Mar 28, 2013
    2,474
    Still no sign of it being up for comments...

    Did you read the notice in the federal register?

    They still have not completed the last step which is to publish notice in the federal register. The comment period does not start until the notice is published.
     

    wabbit

    Ultimate Member
    Apr 29, 2010
    5,274
    Not necessarily. If they do it right, it will. But the FCC under Pai/Trump effectively ignored all public commentary on net neutrality proposed rule and put it in to effect toot sweet.

    thanks, but I'm not planning to make a comment to the FCC while Trump is in office.
     

    Kharn

    Ultimate Member
    Mar 9, 2008
    3,581
    Hazzard County
    Only if an FFL touches it. If an FFL doesn't touch it, that isn't the case.

    To be clear, the NPRM is applying serialization requirements to FFLs.

    That being said, based on what they are saying in the NPRM, all 80% moving forward are likely to be treated as firearms. So manufacturers of 80% would be in the business of manufacturing firearms and will need a manufacturers license, even if they don't make completed firearms today. And thus also the serialization rule is going to apply.

    If you look at the ATF's language in the NPRM on readily convertible, 80%s are almost certainly going to be considered readily convertible, it won't matter if a jig or other parts ship with it. They cite case law where readily convertible included included a person with basic machine shop skills, access to a machine shop and its tools and several hours of work as being considered READILY convertible.

    Slightly above average person on the street who can use hand tools can transform an 80% in to a working firearm in a few hours. One with a router or dremel faster. One with a mill or x-y vise and a drill press even faster.

    You can bet the ATF is going to tell every 80% manufacture to comply, get an FFL and serialize every 80% or face prosecution.

    But again, all the 80%s already privately owned, the ATF is being clear, you do not need to do anything. No requirement to serialize. The only thing you WILL run in to, is you will not be able to sell an 80% over state lines as they are going to be considered firearms. Any of those gun show dealer's selling 80%s are also going to have to stop as they are going to be in the business of selling firearms at that point.

    Any PMF or 80% that an FFL touches, will need to be serialized and entered on their books. That includes if you needed a gunsmith to help fix something (the NPRM is clear, the gunsmith does NOT need to have it overnight to be required to enter it in to their books and serialize it. They touch, they need to be putting a serial number on it and have it on their books).

    now a non-FFL gunsmith would not need to, but if you hold an FFL other than an -03, if you do any work on the firearm, are transferring it, offering it for sale, take possession, etc. you must put a serial number on it within X time or before it leaves your possession unless it is to another FFL to have the serial number put on the PMF.

    The NPRM is effectively ending 80%s as we know it. But it is not banning existing ones in private hands nor is it requiring you to go out and put a serial number on your 80% or PMF unless an FFL is going to touch it.

    I can still see there being a market for 80%s moving forward, especially because of state laws. Some guys are still going to want to build their own guns. Plus some states (Maryland!) are stricter on a full up firearm. So once the NPRM is in affect, you'd need to have your FFL transfer an 80% to you and do a 4470. But if you wanted to build a PF940 for example, that's over the counter rather than needing to wait on a 77r, $10 fee and HQL.

    One thing I do see, and I don't think I'd consider it a perk necessarily, is more manufacturers getting in to making stripped frames and selling them. A lot of guys went the 80% route because they DID want to build a gun from scratch. They didn't necessarily care too much about drilling a few holes and milling a bit.

    Now in the AR world, lowers are everywhere. In the pistol world, not so much. Especially not right now. If wanted to build a Glock from scratch, it was way easier on many levels to get a P80 and build it than try to track down a stripped frame. And now, there are NO stripped frames (that I can find). So some of those guys who wanted to build a Glock from scratch probably will still be in the market for stripped frames (whether it was a P80 completed frame, or a Glock factory stripped, or someone else's completed frame). Or a 1911 frame, etc.

    Hell that is the reason I have a couple P80s is I wanted to build some Glocks and I haven't been able to find a stripped frame at any price, let alone a sane one, in well over a year. Oh sure, saving me time and a pain in the butt was a feature of a P80. But I would have been willing to do it.

    So I don't think the NPRM, if it goes in to affect as is and if it holds up through lawsuits, is going to stop the DIY market that has grown up. There are a lot of guys who just want to build their custom pistol themselves from scratch. Just like guys had been doing with ARs for a few years before 80s really came on the scene. It is likely to stop or massively curtain 80%s themselves and probably boost manufacturers of completed frames that are Glock Gen 3 (or whatever gen) compatible, 1911 compatible, etc. Hell, Glock may even get in to making frames and selling them rather than just complete guns (I doubt it).

    Stripped, serialized P80 frames are available.

    PSA today linked a YouTube review of their Glock 19 clone, which was also supposed to be avaliable as an 80% and separate parts kit.
     

    JMangle

    Handsome Engineer
    May 11, 2008
    816
    Mississippi
    Stripped, serialized P80 frames are available.

    PSA today linked a YouTube review of their Glock 19 clone, which was also supposed to be avaliable as an 80% and separate parts kit.

    Reminder that Botach has P80 lowers for $100.

    .... which I would never buy, of course....
     

    Overwatch326

    Active Member
    Aug 13, 2016
    370
    Did you read the notice in the federal register?

    They still have not completed the last step which is to publish notice in the federal register. The comment period does not start until the notice is published.

    Ah, must've missed that part. Just checked, and yeah, it's finally open for comment today. Keyboards at the ready, boys. Everyone remember to keep it polite; these snowflakes' feelings are easily hurt, like paper mache, or Raditz (props if you get it :P).
     

    85MikeTPI

    Ultimate Member
    Jul 19, 2014
    2,737
    Ceciltucky

    lazarus

    Ultimate Member
    Jun 23, 2015
    13,741
    Stripped, serialized P80 frames are available.

    PSA today linked a YouTube review of their Glock 19 clone, which was also supposed to be avaliable as an 80% and separate parts kit.

    Oh, okay thanks. At this point though I am just going to run with my 80s. Back when I was looking last spring, nada.

    That said, I haven't tried my PF940C or PF940V2 (I have a V1.5), but I really liked the grip on the good ole' Glock Gen 3's. At least the full size and the large receiver frames (G17 and G21). I've shot a Glock 19 a while back, but I can't recall now (it was my Glock cherry). I feel like I remember it working okay in my hand.

    I am one of the few where Glock's molding for the finger bumps actually seems to fit their hand well. So if I were to track down more stripped frames, I'd prefer a factory glock Gen 3 frame. Unrelatedly, I wish someone would make a Glock G34 gen THREE compatible slide.

    I do think some of the 80 manufacturers will switch to serialized partially completed frames if the regulations stand up in court and really do end up meaning that 80s are a thing of the past (at least with no serial number and skipping an FFL). Some guys just want to really build stuff from scratch.
     

    Allen65

    Ultimate Member
    MDS Supporter
    Jun 29, 2013
    7,186
    Anne Arundel County
    I do think some of the 80 manufacturers will switch to serialized partially completed frames if the regulations stand up in court and really do end up meaning that 80s are a thing of the past (at least with no serial number and skipping an FFL). Some guys just want to really build stuff from scratch.

    Or they'll just switch to lowers or frames that are less "complete", and sell them in transactions separate from firearm parts and jigs. Even under the proposed new rules, the line between "gun" and "inert piece of metal" will still need to be defined by ATF on a per-platform basis, much as is it now. Maybe AR lowers will need to have no buffer threads cut, or the magwell still solid. We just don't know where those lines will be until actual rulings are published based on the regs.
     

    85MikeTPI

    Ultimate Member
    Jul 19, 2014
    2,737
    Ceciltucky
    Don’t forget to post your opposition to the proposal. Just buying 80% to hide them is not a plan.

    The trolls are there, you should be too..

    “ Ghost guns must be regulated. The shadowy world of illegal firearms is dangerous to everyone, in a country where at least 100 people die each day from gun violence. Please, do the right thing and implement this rule to regulate these lethal weapons.”
     

    lazarus

    Ultimate Member
    Jun 23, 2015
    13,741
    Don’t forget to post your opposition to the proposal. Just buying 80% to hide them is not a plan.

    The trolls are there, you should be too..

    “ Ghost guns must be regulated. The shadowy world of illegal firearms is dangerous to everyone, in a country where at least 100 people die each day from gun violence. Please, do the right thing and implement this rule to regulate these lethal weapons.”

    I mean, it could be to hide them. The NPRM doesn’t come right out and say it in the summary, but it is fairly clear. The government is not coming for your 80%s. Unless you are an FFL. In which case you have to serialize any 80% in your possession or get rid of it within 30 days. Any future 80% that you end up possessing you have to serialize, I think it is, within 72hrs.

    Anyone in the business of manufacturing something complete enough to be considered a firearm receiver needs an FFL and said firearm receiver needs a serial number.

    And their new definition is almost certainly going to classify all those 80%s out there as firearms.

    Of course something even less complete might not be a firearm receiver yet.

    But you can be pretty certain anything sold as an 80% today will be reclassified as a firearm receiver as it is “readily converted”. The NPRM cites case law where a couple of hours of work by a skilled machinist in a regular machine shop was considered “readily converting”.

    Something tells me anything short of a blank forging that has to have everything killed and drilled on it as well as threaded is probably going to be considered a firearm receiver under their new interpretation.

    But again, if you are an FFL and if you don’t plan to sell an existing 80% over state lines. Well in that case the ATF doesn’t care about you. Go buy 80%s until the NPRM goes in to affect to your hearts content. You don’t even have to hide it.
     

    Kharn

    Ultimate Member
    Mar 9, 2008
    3,581
    Hazzard County
    I mean, it could be to hide them. The NPRM doesn’t come right out and say it in the summary, but it is fairly clear. The government is not coming for your 80%s. Unless you are an FFL. In which case you have to serialize any 80% in your possession or get rid of it within 30 days. Any future 80% that you end up possessing you have to serialize, I think it is, within 72hrs.

    Anyone in the business of manufacturing something complete enough to be considered a firearm receiver needs an FFL and said firearm receiver needs a serial number.

    And their new definition is almost certainly going to classify all those 80%s out there as firearms.

    Of course something even less complete might not be a firearm receiver yet.

    But you can be pretty certain anything sold as an 80% today will be reclassified as a firearm receiver as it is “readily converted”. The NPRM cites case law where a couple of hours of work by a skilled machinist in a regular machine shop was considered “readily converting”.

    Something tells me anything short of a blank forging that has to have everything killed and drilled on it as well as threaded is probably going to be considered a firearm receiver under their new interpretation.

    But again, if you are an FFL and if you don’t plan to sell an existing 80% over state lines. Well in that case the ATF doesn’t care about you. Go buy 80%s until the NPRM goes in to affect to your hearts content. You don’t even have to hide it.

    They're putting pretty much anything besides 3d printing a receiver beyond the reach of average people. And how many normal people have the skills and knowledge to assemble, calibrate, dial in a filament lot's temperature profile, diameter, etc, and print a receiver?

    Metal inserts for pistol rails and the like will be of questionable availability, since if they're visible when assembled they constitute the receiver.
     

    JMangle

    Handsome Engineer
    May 11, 2008
    816
    Mississippi
    They're putting pretty much anything besides 3d printing a receiver beyond the reach of average people. And how many normal people have the skills and knowledge to assemble, calibrate, dial in a filament lot's temperature profile, diameter, etc, and print a receiver?

    Metal inserts for pistol rails and the like will be of questionable availability, since if they're visible when assembled they constitute the receiver.

    I 3D print - take a look at the complex items many people are already printing. Give them an STL or STEP file and they can certainly print a reciever. IvanTheTroll made a great U-bolt reinforced reciever and it's good for thousands of rounds.
     

    lazarus

    Ultimate Member
    Jun 23, 2015
    13,741
    I 3D print - take a look at the complex items many people are already printing. Give them an STL or STEP file and they can certainly print a reciever. IvanTheTroll made a great U-bolt reinforced reciever and it's good for thousands of rounds.

    This. 3D printing continues to improve and in general, yeah you could make a serviceable enough receiver with a $400 3D printer and not a ton of knowledge. Maybe a slight cut above
    The average “man on the street”, but a lower level of knowledge needed than directions, basic hand tools and pipe sections to make a sten gun which I could probably make in a weekend. If not faster.

    A basic gun doesn’t take a whole lot.

    Yes, this will put a lot of guns out of the reach of what the average person is willing to do. Which sucks. It’ll also likely put easy to complete receivers out of the reach of the average criminal.

    It’ll drive more break-ins for guns and straw purchases. Not sure how much it’ll actually drive down criminal access to firearms.

    To that point, criminals who have been finishing 80s for criminals will probably just switch to 3D printing them. Oh no, the gun might only hold up to a couple of hundred rounds. So. How many does the average criminal end up firing in their career? 0-2 or 3 magazines?
     

    Mikeyworks

    Active Member
    Sep 20, 2007
    205
    Bel Air, MD
    Since the link is finally posted and the comment period has officially started; Should we perchance assemble a set of useful comments, points, elements of analysis, details, and references that our friends here on the site can use to help develop their own comments?

    I'm generally thinking that a compendium of information, collected from the educated masses will help a schmuck like me better frame his comments.

    Thanks!
     

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