ATF Letter Clarifies Rules on Firearm Receiver Transfers

With the current high demand for AR15-style rifles, the sales of both bare (stripped) and semi-assembled lower AR receivers has increased dramatically. This has led to questions, from both buyers and Federal Firearms License holders, as to how these lower receivers should be handled during sales. The ATF has issued a letter which deals with these issues. Important points to note are:

1) An FFL may not sell a frame or receiver to anyone under 21 years of age [Title 18, U.S.C., section 922 (b)(1)]. Comment: This is because the receiver could, potentially, be made into a pistol.

2) An FFL may not transfer a frame or receiver to an unlicensed person from another State. [Title 18, U.S.C. section 922(b)(3)]. Comment: Again, this tracks the rules regarding transfers of pistols, because some frames/receivers can be built into pistols.

3) Multiple handgun sales forms (ATF forms 3320.4) are NOT required for sales of multiple frames or receivers of any firearm, as they are not pistols or revolvers. Comment: This may seem inconsistent with points 1 and 2 above, but this follows from the provisions of CFT 478.11 which states that bare frames or receivers are not handguns until so assembled.

Further information on these points is contained in the July 7, 2009 letter from the ATF, which is linked below. All FFLs are encouraged to download this letter and read it carefully.

CLICK HERE for 7/9/2009 Letter from ATF Re Firearm Frames and Receivers