Q: I feel I have some very good and creative questions… just saying. A FFL Variance takes about 3 months to be approved by the ATF, however a name change or addition to a FFL takes a matter of minutes. I have a customer that needs us to do their actions/lowers. I would normally mark the lowers Specialized Tactical Systems, or STS as those are the two names on my FFL. If i was to add “CTG” to my FFL names I would then be able to mark the lowers with a CTG, STS or the full Specialized Tactical Systems. If this CTG happens to be the initials of another company, well they would just reap the benefits of customers thinking they were the primary manufacture. These lowers/receivers would just be transferred to “CTG” as if they were any other weapon. Perhaps I would have to file a DBA with the state, but that is still a matter of hours vs. months. Is it just my weird thinking or is this a small “Variance” loop hole?
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