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ATF Open Letter to FFLs – Determination of ‘Readily Completed’ Frames

Talyn

SAINT
Founding Member
The letter to FFLs has added significance – as technologies like 3D printing advance from hobbyist levels to professional-grade manufacturing, determining when a firearm is created will be increasingly difficult.

ATF Open Letter to FFLs – Determination of ‘Readily Completed’ Frames

A complete copy of the ATF open letter can be found at ATF.gov.

The Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) is issuing this open letter to assist the firearms industry and the public in understanding whether a “partially complete, disassembled, or nonfunctional” frame of a Polymer80, Lone Wolf, or similar semiautomatic, striker-fired pistol (sometimes generally referred to as “Glock-type” pistols) has reached a stage of manufacture such that it “may readily be completed, assembled, restored, or otherwise converted” to a functional frame, and is therefore classified as a “frame” or “firearm” in accordance with the final rule titled Definition of ‘Frame or Receiver’ and Identification of Firearms (Final Rule 2021R-05F), which became effective August 24, 2022. In particular, the following addresses partially complete, disassembled, or nonfunctional semiautomatic striker- fired pistol frames or parts kits manufactured, sold, or distributed by Polymer80 (known as ‘Poly80’ or ‘P80’ frames or blanks), Lone Wolf (known as ‘Freedom Wolf 80%’ frames), and others, with the characteristics described below.

Summary


Applying the regulatory text of Final Rule 2021-05F, partially complete Polymer80, Lone Wolf, and similar striker-fired semiautomatic pistol frames, including, but not limited to, those sold within parts kits, have reached a stage of manufacture where they “may readily be completed, assembled, restored, or otherwise converted” to a functional frame. This definition of “readily” applies to each and every classification of a partially complete frame or receiver under this Rule, whether sold alone or as part of a kit. Therefore, even without any associated templates, jigs, molds, equipment, tools, instructions, guides, or marketing materials, these partially complete pistol frames are “frames” and also “firearms” as defined in the GCA and its implementing regulations, 18 U.S.C. § 921(a)(3)(B) and 27 CFR 478.12(a)(1), (c).

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I'm not a lawyer, and in defense of the ATF they have to write these letters for lawyers, so I have read it three times.....

So if I read that right, it seems to be saying,

"Forget what the actual rule change says, we're now going to call Polymer80, LoneWolf and Similar partially completed frames, actually completed frames or actual firearms".....

Similar Semi-Automatic is pretty darn broad, even striker fired is way to broad, Glock Type Pistol does narrow it down some....

While I have been saying, that the Polymer80 kits do have a real complaint, they can be completed quickly, cheaply and very easily; the rest of 80% frames take to much work to be a practical alternative for getting a firearm illegally.

But, now it appears the ATF said it couldn't change the rule like the President directed in his Executive Order because it would be struck down in court as unconstitutional. But a few months later, now that all the attention has died down, we're going to do it anyway, just not by changing the rules, just threatening FFL's with a letter......

Which Party doesn't respect the Constitution?
 
More explanation.....
My 80% 1911 frames were milled out with forward and rearward cavities just like he described in the video. But, it still took me months to complete my pistol. Granted that is to do a finely finished pistol with fitted parts and coatings, etc....

If I just wanted it to fire as soon as possible, no coating, engraving or finish, well I'd still need hundreds of dollars worth of special tools and a couple of days using all drop in parts....

He also states, which is clear in the open letter, it also has to be a "Polymer Frame" and even more specific Polymer80/LoneWolf frame or similar, as in a Glock type frame. Cause these frames require 10's of dollar jig and typically home tools to finish within an hour....

Still it stick in my craw, they publish a rule that doesn't change anything, only to turn around a few months later and post an open letter that changes everything that doesn't follow the rule they published...
 
I don’t know, let’s ask George Santo’s who always tells the truth.
:unsure: A freshman Congressman following the Joe Biden model of self-promotion? I'm talking about right now, not in 45 years if George Santos becomes President to make national address to call his political opposition Semi-Fascist that do not respect or follow the constitution, while issuing unconstitutional executive orders.....
 
:unsure: A freshman Congressman following the Joe Biden model of self-promotion? I'm talking about right now, not in 45 years if George Santos becomes President to make national address to call his political opposition Semi-Fascist that do not respect or follow the constitution, while issuing unconstitutional executive orders.....
You missed the point.

Think about it.
 
Did I, can you explain?
Did you miss my point, think about it.
No I didn’t miss your point in your original post. The comment I made was made to spread what I will call an infection in defying the constitution.
To end this useless back and forth.

It’s not just one party.
 
No I didn’t miss your point in your original post. The comment I made was made to spread what I will call an infection in defying the constitution.
To end this useless back and forth.

It’s not just one party.
It's not just one party.... ....that is true...

But when its 90% one party and 10% the other party, you don't see the gross hypocrisy of the party doing it 90% of the time claiming the other party is Semi-Fascist and doing it all of the time?

A politician lying, is not violating the constitution....
Especially when you point to a politician lying exactly like the Politician that is President did his whole career...
 
I don’t know, let’s ask George Santo’s who always tells the truth.
While his excuse to Tulsi Gabbard was a strawman, it doesn't negate the fact that Joe Biden is easily as guilty of just as many ridiculous lies and has been caught lying multiple times and the people giddy with joy over this incident were deafeningly silent about Biden's lies. And Adam Schiff's lies, Kamala Harris' lies, Hillary Clinton's lies, etc.

Biden claimed to have been arrested in South Africa trying to get in to see Mandela in prison for christ sakes.

Anyway, we could stack up all the lies told by Biden's party against the ones told by Santos' party and it is very lopsided. Guess which way ?
 
While his excuse to Tulsi Gabbard was a strawman, it doesn't negate the fact that Joe Biden is easily as guilty of just as many ridiculous lies and has been caught lying multiple times and the people giddy with joy over this incident were deafeningly silent about Biden's lies. And Adam Schiff's lies, Kamala Harris' lies, Hillary Clinton's lies, etc.

Biden claimed to have been arrested in South Africa trying to get in to see Mandela in prison for christ sakes.

Anyway, we could stack up all the lies told by Biden's party against the ones told by Santos' party and it is very lopsided. Guess which way ?
I don’t dispute that at all.
 
Claimed he was arrested marching for Civil Rights in the South also, but never was...
Giving his seminal speech for President during the primaries, to find out it was plagiarized from a British Politician.
Claiming his wife was killed by a drunk driver, the trucker was sober and his wife was found at fault in the traffic accident, not the trucker.
Claimed he graduated top of his class, he was at the bottom.
Claimed he was appointed to the Naval Academy, he didn't even apply, but claimed he meant he applied when called on the ridiculous embellishment.
Claimed he attended the tree of life synagogue...
Claimed he was truck driver, driving 18 wheelers...
Corn Pop?

Anyway, back to the ATF, that was given an executive order by the President to change the rules on 80% frame/receivers to ban them from being treated any differently than finished firearms.

The ATF published their new rules, that failed to do what the executive order directed them to do. Best speculation was because during the public comment phase of the publishing the new rule, it became very clear to the ATF the rule change would be struck down immediately as unconstitutional. So they only changed what they could, that would pass constitutional muster....

And now that all the controversy has died down, during the middle of the holidays, when no one is paying attention, the ATF publishes an open letter to FFL's stating, forget what the rules says, we are telling you Polymer80 and LoneWolf 80% frames are finished frames/firearms.
 
Claimed he was arrested marching for Civil Rights in the South also, but never was...
Giving his seminal speech for President during the primaries, to find out it was plagiarized from a British Politician.
Claiming his wife was killed by a drunk driver, the trucker was sober and his wife was found at fault in the traffic accident, not the trucker.
Claimed he graduated top of his class, he was at the bottom.
Claimed he was appointed to the Naval Academy, he didn't even apply, but claimed he meant he applied when called on the ridiculous embellishment.
Claimed he attended the tree of life synagogue...
Claimed he was truck driver, driving 18 wheelers...
Corn Pop?

Anyway, back to the ATF, that was given an executive order by the President to change the rules on 80% frame/receivers to ban them from being treated any differently than finished firearms.

The ATF published their new rules, that failed to do what the executive order directed them to do. Best speculation was because during the public comment phase of the publishing the new rule, it became very clear to the ATF the rule change would be struck down immediately as unconstitutional. So they only changed what they could, that would pass constitutional muster....

And now that all the controversy has died down, during the middle of the holidays, when no one is paying attention, the ATF publishes an open letter to FFL's stating, forget what the rules says, we are telling you Polymer80 and LoneWolf 80% frames are finished frames/firearms.
SCOTUS needs to hear a lawsuit against the ATF for creating law, which is beyond the scope of their authority. I assumed the EPA case back east would play into that.
 
SCOTUS needs to hear a lawsuit against the ATF for creating law, which is beyond the scope of their authority. I assumed the EPA case back east would play into that.
And even worse, when the ATF published their new rule, that was short of banning 80% frames/receivers outright, because it would be the Beuruecracy Unconstitutionally creating new law; the Democrats of Congressed all signed a letter to Biden, DOJ and ATF protesting why they didn't ban the 80% frame/receiver by rule change and do their job for them.....

But hey, there this goofy freshman congressman doing the same as Biden in telling ridiculous lies to pad his resume, see Republicans violate the constitution just as bad as democrats :cautious:
 
Biden tells a lie every time he opens his mouth and strays away from the telepromter.
Its possible Santos is trolling the MSM? How long will the MSM and Dems go on about Santos before they realize he is doing exactly the same thing Biden does, that they have been utterly silent about?

How's that Presidential Lies chronicle going Washington Post? Oh, you ended it just as Biden became President, hmmm? Is the Washington Post slogan a "warning" or a "mission statement"?
 
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