Q: FFL manufactured 40 SBRs back in 2011 and 2012 by attaching short barreled uppers to existing completed rifles. They took off the original uppers and replaced them with Shorty Uppers. They are now in the process of having their FFL Name at the time of the manufacture and City, State engraved on the receivers. This will then match up to the approved Form 2s. How are these to be recorded in the A&D Records? Should they now list the original manufacturer and their FFL name both under manufacturer in the A&D Records as that is what will now be engraved on the firearms? Also at this point how do they correct the A&D Records? Under our current understanding of 2013-5 they can make corrections to the original A&D entry and explain in a “Notes” column. Correct? I think this was supposed to be addressed by Scot B but I have nothing completed back on it and there is no case open. So here goes on a second item for these same 40 SBRs: As stated they are engraving their FFL Name at time of manufacture, city, state on the 40 SBRs. There are also using the original manufacturers markings on the firearms. Do they need a variance from 27 CFR 478.92 to utilize the original manufacturers markings to include serial number, caliber and model? If so since these were actually manufactured in 2011 and 2012 how would this be done after the fact? This issue was not noted or questioned by ATF during their recent inspection..
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