What FFL is Required to Build Custom Guns...


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CmdrSlander
April 19, 2013, 01:33 AM
I'm getting very interested in building custom M1911s for people, as a side job/hobby and a way to pay for a few pistol smithing courses I plan to take sometime in the future. I'd be using fitted frames and slides from a third party (most likely Caspian) so I won't actually be making guns in the legal sense, but I get the feeling I'd need some kind of FFL to do this as a business.

Enlighten me.

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Comrade Mike
April 19, 2013, 02:02 AM
What ever the standard dealer FFL is would probably have you covered. I think it's the 01

TheSaint
April 19, 2013, 02:36 AM
I'm no lawyer, but if I were considering doing what you're doing, I'd consult one and have it on paper just to be sure, or at the very least contact the ATF and ask them what they would think would be applicable.

natman
April 19, 2013, 02:44 AM
Take a look here:

http://www.atf.gov/firearms/faq/gunsmiths.html

Yes, you will need a standard 01 FFL.

Frank Ettin
April 19, 2013, 03:22 AM
But have a look here (http://www.atf.gov/firearms/faq/manufacturers.html) and take special note of examples 8, 9, 10, 11 and 12 in the answer to the last question.

The OP wrote:I'm getting very interested in building custom M1911s for people, as a side job/hobby and a way to pay for a few pistol smithing courses I plan to take sometime in the future. I'd be using fitted frames and slides from a third party (most likely Caspian)... I see a strong possibility that what he's planning to do would require a manufacturer license. It looks like taking a customer's gun and modifying it or repairing it is one thing; but making a gun from components for sale, whether to order or for speculation, might well be another.

Bubbles
April 19, 2013, 09:00 AM
If you are buying frames and parts, fitting them, and selling this finished product you will need a Type 07 (manufacturer) FFL.

The ATF has an excellent writeup of the difference between manufacturing and gunsmithing in Chapter 7.2 of the NFA Handbook. Even if you're not getting your SOT, you should be very aware of the info in 7.1 and 7.2.
http://www.atf.gov/files/publications/download/p/atf-p-5320-8/atf-p-5320-8-chapter-7.pdf

natman
April 19, 2013, 10:54 AM
Excellent point. If you modify the customer's gun, you're a gunsmith. If you buy guns (or frames) and modify them you're a manufacturer. In addition to the manufacturer's license, you'll need to pay excise tax.

Time to talk to a real lawyer / ATF.

jimmyraythomason
April 19, 2013, 07:43 PM
If you modify the customer's gun, you're a gunsmith. If you buy guns (or frames) and modify them you're a manufacturer. In addition to the manufacturer's license, you'll need to pay excise tax.
^This is the right answer^Time to talk to a real lawyer / ATF. This is your next move.

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