BigWaylon
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Figured I’d share this just to track the situation I’m going through right now. If you’ve never really dealt with the ATF, this is one of those things that just happens every once in awhile. Overall, I’ve had very good experiences in dealing with them. My current situation is a little frustrating, and their next response will determine if that goes from a little to a lot.
I file 5320.20 forms each year (usually sometime in July-Sep) for the the entire following year. I file 11 firearms on a custom form I made and submit them for 10 states each time. That way if I get a random invite anywhere in the southeast I already have permission to cross state lines. I’ve never had them question my modified form. I have several firearms that I’ve submitted a different caliber and/or length (from what’s listed on the Form 1) for 5+ years and never had an issue, and I’ve never notified them of any changes. There’s no requirement to notify them, they just recommend you do it if it’s a permanent change.
So I created my 10-page PDF on 7/31/20 and emailed it in. They were approved on 8/6/20, and on 8/14/20 I got three envelopes like this:
This is a process they started a couple years ago. Every form gets its own cover sheet and envelope.
Getting them on different days has happened before. But in this case nothing else has shown up Saturday, Monday or Tuesday. I know all 10 were approved based on a phone call. Maybe the other 7 show up this week.
The issue I’m having deals with one particular SBR. It’s registered as a 5.56, but I ran a 5.7 upper on in for years, and have at least 5 approved 5320.20 forms with that caliber. Last year I moved my AR57 upper to a braced lower, and put a 7.5” 5.56 upper on the registered lower. Then earlier this year I bought a 10.5” Beowulf upper. I didn’t want to pay another $200, but didn’t want to run a .50 with a brace. So I built a new SBA3 lower, moved the 7.5” 5.56 to it, and used the registered lower for the Beowulf.
I submitted the forms showing what I planned to travel with, which is the 50. The three forms all came back with the 50 highlighted:
and an Approved (with the following conditions, if any) like this:
(The SN for the one in question is USA2####)
I’m assuming the other seven are approved with the same condition. So I call the ATF on Friday as soon as I opened the mail, and explained what my issue was. I wanted to travel with the firearm in a different configuration. The person that answered confirmed my info and transferred me to the examiner whose name is on the cover sheet. No answer, so I left a fairly detailed message.
No callback on Monday, so I called again this morning and got transferred again, and the guy answered...much to my surprise. He recognized my name and said he had me down for a callback today. We went over my issue again, and he was apparently quite new. Not the first time I’ve had to “train” the ATF on something
. I told him what I needed was a set of signed forms without the conditional approval. He said he was just doing as he was trained, which was to make a note of the caliber. So I explained about the temporary configuration rules and that most of his fellow examiners have told us never to send in a letter for a change on the AR platform because nothing is permanent and it’s just a waste of their time.
He said he’d research it further and get back with me. I was surprised again when he actually called back this afternoon. He’d gotten with his trainer/supervisor and what he tried to explain to me was that they were allowed to Approve forms with changes like .308/7.62/30-30/300BLK because they’re “close enough”, but going from 5.56 to .50 was “too much of a difference”. I politely told him that his supervisor was just making things up at this point. There’s nothing in the regulations to back that up.
He said he’d discuss it with them again, but would be off the next couple days. He said he’d follow back up with me but wanted to make sure I understood it wouldn’t be tomorrow.
I’ll update it again once I hear back. I’d rather them be trained to not do stuff like this. His solution was for me to write a letter to add additional possible configurations for the SN and they’d update the registry. I’ll do that if I have to, but I’d rather them follow the laws as they exist and not create the extra work for anybody that submits with different info. I’m going to assume if Terry (who has approved most of mine in the past) had gotten these, it wouldn’t have been an issue.
This is just an example as to why I don’t wait until the last minute to file interstate transport forms.
I file 5320.20 forms each year (usually sometime in July-Sep) for the the entire following year. I file 11 firearms on a custom form I made and submit them for 10 states each time. That way if I get a random invite anywhere in the southeast I already have permission to cross state lines. I’ve never had them question my modified form. I have several firearms that I’ve submitted a different caliber and/or length (from what’s listed on the Form 1) for 5+ years and never had an issue, and I’ve never notified them of any changes. There’s no requirement to notify them, they just recommend you do it if it’s a permanent change.
So I created my 10-page PDF on 7/31/20 and emailed it in. They were approved on 8/6/20, and on 8/14/20 I got three envelopes like this:
This is a process they started a couple years ago. Every form gets its own cover sheet and envelope.
Getting them on different days has happened before. But in this case nothing else has shown up Saturday, Monday or Tuesday. I know all 10 were approved based on a phone call. Maybe the other 7 show up this week.
The issue I’m having deals with one particular SBR. It’s registered as a 5.56, but I ran a 5.7 upper on in for years, and have at least 5 approved 5320.20 forms with that caliber. Last year I moved my AR57 upper to a braced lower, and put a 7.5” 5.56 upper on the registered lower. Then earlier this year I bought a 10.5” Beowulf upper. I didn’t want to pay another $200, but didn’t want to run a .50 with a brace. So I built a new SBA3 lower, moved the 7.5” 5.56 to it, and used the registered lower for the Beowulf.
I submitted the forms showing what I planned to travel with, which is the 50. The three forms all came back with the 50 highlighted:
and an Approved (with the following conditions, if any) like this:
(The SN for the one in question is USA2####)
I’m assuming the other seven are approved with the same condition. So I call the ATF on Friday as soon as I opened the mail, and explained what my issue was. I wanted to travel with the firearm in a different configuration. The person that answered confirmed my info and transferred me to the examiner whose name is on the cover sheet. No answer, so I left a fairly detailed message.
No callback on Monday, so I called again this morning and got transferred again, and the guy answered...much to my surprise. He recognized my name and said he had me down for a callback today. We went over my issue again, and he was apparently quite new. Not the first time I’ve had to “train” the ATF on something
. I told him what I needed was a set of signed forms without the conditional approval. He said he was just doing as he was trained, which was to make a note of the caliber. So I explained about the temporary configuration rules and that most of his fellow examiners have told us never to send in a letter for a change on the AR platform because nothing is permanent and it’s just a waste of their time. He said he’d research it further and get back with me. I was surprised again when he actually called back this afternoon. He’d gotten with his trainer/supervisor and what he tried to explain to me was that they were allowed to Approve forms with changes like .308/7.62/30-30/300BLK because they’re “close enough”, but going from 5.56 to .50 was “too much of a difference”. I politely told him that his supervisor was just making things up at this point. There’s nothing in the regulations to back that up.
He said he’d discuss it with them again, but would be off the next couple days. He said he’d follow back up with me but wanted to make sure I understood it wouldn’t be tomorrow.
I’ll update it again once I hear back. I’d rather them be trained to not do stuff like this. His solution was for me to write a letter to add additional possible configurations for the SN and they’d update the registry. I’ll do that if I have to, but I’d rather them follow the laws as they exist and not create the extra work for anybody that submits with different info. I’m going to assume if Terry (who has approved most of mine in the past) had gotten these, it wouldn’t have been an issue.
This is just an example as to why I don’t wait until the last minute to file interstate transport forms.
