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I stamped my info on one of my home builts years ago along with a serial number and would like to sell it. From what I'm reading as of 2022 the dealer needs to add ANOTHER serial number to the gun including parts of his FFL # - this from the ATF web site:

  1. D.Privately made firearms marked by nonlicensees. Unless previously identified by another licensee in accordance with this section, licensees may adopt a unique identification number previously placed on a privately made firearm by an unlicensed person, but not duplicated on any other firearm of the licensee, that otherwise meets the identification requirements of this section provided that, within the period and in the manner herein prescribed, the licensee legibly and conspicuously places, or causes to be placed, on the frame or receiver thereof a serial number beginning with their abbreviated Federal firearms license number, which is the first three and last five digits, followed by a hyphen, before the existing unique identification number, e.g., “12345678-[unique identification number]”.
So now it would have 2 serial numbers? We don't have room to add the FFLs abbreviated number to the existing number. Technically - even though I built it - overstamping or welding it up and reserializing it would be illegal - right? What about all the 1919A4s with mfr correct serial numbers and markings? Will they all need a second serial number? I'm working with a great dealer - just want to be sure we're doing it by the books. TIA.
 

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Who knows about all this crap from the ATF. They suck. Why not just allow them to adopt the serial just like when making a SBR from a pistol, you just use the existing serial. Its all tracking BS which they are not allowed to do anyway.

My thoughts are that if there is not room for:
“12345678-[unique identification number]”.
then one could do two lines and this:
“12345678-
[unique identification number]”.
That way the serial on a 1919a4 plate could be added above the existing serial. Like this:
Font Grey Chalk Circle Writing



Or. you just include the letters before the existing serial into the serial:
Grey Font Commemorative plaque Concrete Number


So now the serial is 123456-NO8670506. Who said that the NO can't be considered part of the serial? Or maybe just skip the NO and act like its not there.

The ATF is so stupid that on my Chauchat, they considered the "CSRG" as part of the serial on my gun and made us add it to the form 4! So this has been done before. (Not my actual gun pictured below but just as an example of how it looks).
Rectangle Font Line Signage Metal


Here is a picture of my actual form 4:

Rectangle Font Material property Parallel Pattern


So I think in general we over think this issues as far as the ATF sees things. I also don't think there is any rule that is all has to the same text height, so you could make it the ATF minimum so it will not show as much.

I hope that helps. As in anything, who knows what the ATF would say but this is my guess how we can do it and stay legal.
 

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Edit: had to re-read that excerpt from the new rules. Sounds like even if you marked it with a serial number that meets the basic serial number marking requirements, they still want the FFL to add to the serial number now. I guess FFLs will have to be experts in determining if a firearm is home made or not.
 

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Do it the way Craig Jordan did it. He stamped his info, including the serial number, on the lower edge of the RSP.

 

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It says “May” not “must” so what is the requirement that an FFL mark it at all?
That statement allows the licensee to adopt a method of marking or not. I think it is the last part that stipulates the requirement:
“…provided that, within the period and in the manner herein prescribed, the licensee legibly and conspicuously places, or causes to be placed, on the frame or receiverthereof a serial number beginning with their abbreviated Federal firearms license number, which is the first three and last five digits, followed by a hyphen, before the existing unique identification number, e.g., “12345678-[unique identification number]”.”
 

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The question I have is slightly off topic, but it is FFL related, so hoping the experts here may chime in on this one. I am trying to buy a M37 type striped lockframe, and this particular one has no visible numbers anywhere on it, and I looked closely from all sides of it, under a magnifier. The seller thinks that: it is an FFL transfer part, even though this lock frame has no numbers whatsoever stamped on it, not even a drawing number or a part number. In AZ, this is not a FFL type of a part, and as far as I know, as per ATF, currently there is no specific requirement for a 1919 type lock frame to be transferred through an FFL. If anyone knows anything about such a requirement, please point to it, or if there are any suggestions as to how best to proceed, and let the seller know the facts, that would help. Thanks for the input as always, Jim.
 

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The question I have is slightly off topic, but it is FFL related, so hoping the experts here may chime in on this one. I am trying to buy a M37 type striped lockframe, and this particular one has no visible numbers anywhere on it, and I looked closely from all sides of it, under a magnifier. The seller thinks that: it is an FFL transfer part, even though this lock frame has no numbers whatsoever stamped on it, not even a drawing number or a part number. In AZ, this is not a FFL type of a part, and as far as I know, as per ATF, currently there is no specific requirement for a 1919 type lock frame to be transferred through an FFL. If anyone knows anything about such a requirement, please point to it, or if there are any suggestions as to how best to proceed, and let the seller know the facts, that would help. Thanks for the input as always, Jim.
It might be called a lock frame but it is not a FRAME / RECEIVER so is not a FFL transfer part.
 

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IMBLITZVT, GBYENKO, thanks for posting, it does appear this issue to be a "system caused misunderstanding" generated by gunbroker site, on it's own ideas. Have contacted the seller directly, and he said that he does not want or need an FFL for this particular part, but that the gunbroker had added this requirement on their own to that transaction. So, he had contacted them, and they also agreed that this was not the case with a lock frame, so they also took "their Req"., of this sale. All together, this transaction had successfully completed, and I am now waiting for that special lock frame on it's way here. Thanks again to all who helped. Jim.
 

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Where is it that an FFL "MUST" mark a home build? NKY, what you posted doesn't include "must" anywhere, it appears more a method.
I agree that it does not say "must" anywhere. I was only pointing out that I respectfully disagree with your earlier post suggesting that the use of "may" was related to the entire section. What I was trying to say was that the "may" appears to only be relevant to the first part of the section, which suggest that the FFL can adopt a previous identifying number, and that the second part of the section clearly states the required action. Interpret it as you like, I was only putting forth my own opinion as to its meaning. As with all new "rules" that the alphabet people construct, it makes no sense and will have no impact on criminal activity.
 

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If a FFL takes a homebuild ("PMF" in ATF lingo) into inventory, it must be marked as per the latest ruling.

The FFL can mark it with the FFL digits in front or if there's no room or wouldn't be unique to that FFL, stick their own unique serial number & info on somewhere else. Yes. multiple serial numbers on the same gun. ATF told me that directly here in an except from longer email asking how I'm as a FFL supposed to know if an AR engraved "Joes Gunwerkz, Akron OH SN#1001" is a PMF or not--

...
The final rule amends the regulations to require all FFLs to identify (mark) any PMF they take into their inventory. This requirement will allow licensees to comply with GCA recordkeeping requirements when accepting PMFs and allow ATF to trace those firearms through licensees’ records if involved in a crime.

Where the PMF is already marked by a nonlicensee with a unique identification number that otherwise meets the marking standards in 478.92, FFLs may establish a PMF serial number by placing their abbreviated license number (first three and last five digits) as a prefix to the number, followed by a hyphen, e.g., “12345678-[unique identification number].”

The final rule amends 27 CFR 478.92(a)(4)(iii)(D) to allow for such adoption of a PMF serial number.

The resulting serial number must be unique and therefore may not duplicate any number that the FFL has previously placed on a firearm.

FFLs must be aware of the serial numbers they have used/marked.

Any commercially manufactured firearm will have all of the require markings as required in 478.92. PMFs are not likely to have all the same markings because private individuals have no requirements. If you still have trouble determining the manufacturer you may contact ATF Firearms and Ammunition Technology Division for an official identification.

There is nothing in the regulations that prohibits you from putting additional markings on a firearm. Although additional unnecessary markings may cause confusion if the firearm should ever be traced.

Thank you,

Axxxxx Pxxxx | Firearms Enforcement Specialist
U.S. Department of Justice | Bureau of Alcohol, Tobacco, Firearms and Explosives
Firearms Industry Programs Branch
99 New York Avenue NE
Washington, DC 20226
 

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It says “May” not “must” so what is the requirement that an FFL mark it at all?
Continue reading to the part where it says "provided that..............." It says that the license (FFL) must add the abbreviated License # a hyphen then a unique (to the FFLs records)serial number. This is only if you are going to sell your self-made gun. Be it a 1919A4 or an 80%AR, or whatever.
 

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Continue reading to the part where it says "provided that..............." It says that the license (FFL) must add the abbreviated License # a hyphen then a unique (to the FFLs records)serial number. This is only if you are going to sell your self-made gun. Be it a 1919A4 or an 80%AR, or whatever.
English as a second language? I read
It again and didn’t see “must”. Even if it did, it would be the same as “FFL may paint the Ferrari pink but it must be bright pink”. There is nothing in the quoted section that FFL must paint the Ferrari pink, only that they may.

1. Must private sales now go thru an FFL?
2. Must FFLs mark home made guns that go on their books?

those are the questions
 
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