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Now, since you would be a manufacturer, if you decide, "Hey, today I'm going to make my semi auto M16 go full auto!", from what I understand you cant get in trouble but do you have to register the weapon and pay 10,000-20,000 for the sear because the M16 is running full auto now?
Class 2's don't have to buy transferable receivers or sears. They can manufacture brand new non-transferable dealer sample MGs from standard low cost parts. They do have to register their new MG with the ATF after they build it and it can never be sold again, except to a Class 3 or govt/mil/LE
Now, I am not a Class 2 manufacturer or FFL or anything like that, so take what I say as a straight opinion.
I have talked with every small time FFL that I have bought from recently about how to obtain and keep a license. Most of them have told me that you have to be able to show that you are using your FFL License to make a profit, it cannot be for personal use only. Otherwise the ATF will not let you keep it or renew it or whatever.
Following that logic, I would assume that the same is for manufacturers. If you cannot show that you are selling your products, it will be short lived.
Although here in the 9th circuit, there was a case where someone made a machinegun and it was deemed legal since it did not cross into the Federal domain. I do not have the case name offhand, but a quick search of this site could probally find it for you. It was a big deal awhile back.
If that is the reason you are seeking a manufacturers SOT, then forget it. First, the $1,000 fee is per year. You must then actually have a manufacturing facility with all federal, state and local licenses, insurance, utilities, storage and everything else required to actually manufacture firearms. If you give up the license, you will be required to transfer any machineguns you manufactured but haven't sold. You cannot keep them.
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