B&T USW-320 NFA Engraving

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Mar 18, 2009
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B&T produced a USW320 grip module and stock, which enables a SIG P320 to be a SBR.

The question I have concerns the NFA engraving requirement, which requires makers of SBRs to “conspicuously” engrave information (Maker Name, City, State, Caliber, SN) on the “frame, receiver, or barrel.”

The issue is that in the case of the SIG P320, the Fire Control Group (FCG) is considered to be the frame. This is why the FCG is serialized and it was also confirmed in the ATF’s draconian frame and receiver rule. Fortunately, the B&T grip module has a window, which allows the SN on the FCG to show in a conspicuous manner. The B&T grip module has a plate on the dust cover rail intended for users to engrave their information. However, I am concerned that engraving the plate of the grip module would not satisfy the requirements of the law since the grip module (correct me if I am wrong) is not considered to be a frame, receiver, or barrel. Therefore, if one wanted to engrave their name/trust and city/state (considering that the caliber will be on the barrel and the FCG SN is visible through the grip module window), the only options that exist are to either 1) modify the grip module to allow the FCG to be engraved and for that information to be visible and/or 2) to engrave the barrel with the required info.

Please let me know if I am missing something or if there are alternative solutions.

I ask that folks please refrain from non-constructive comments such as “talk with a lawyer” or complaining about how dumb these rules/laws are.

Thanks!
 
B&T produced a USW320 grip module and stock, which enables a SIG P320 to be a SBR.

The question I have concerns the NFA engraving requirement, which requires makers of SBRs to “conspicuously” engrave information (Maker Name, City, State, Caliber, SN) on the “frame, receiver, or barrel.”
Wherever you are getting your info...it's outdated. Marking requirements changed a year ago.
§ 479.102 Identification of firearms.
Manufacturer, importer, or maker name, serial# and location must be on frame or receiver only.
Model, caliber or gauge, foreign manufacturer, country of manufacture may be on frame, receiver, barrel or slide



Please let me know if I am missing something or if there are alternative solutions.
You may need to write a letter asking for ATF's direction. There may not be sufficient room on the FCG to engrave your makers markings.
See the exceptions (3) Adoption of identifying markings
 
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