Most readers of this column will have already reviewed many articles regarding the “move” of many firearms and firearms-related articles to the Commerce Department in terms of regulation and administration. This move was universally lauded for eliminating much of the cumbersome and expensive International Trafficking in Arms Regulations (ITAR), as administered by the U.S. Department of State (State Department / State). This migration was many years (decades) in the making and did, in fact, make life easier for many.

Unfortunately, the move did not make life easier for those who manufacture National Firearms Act (NFA) items such as suppressors and machine guns. Manufacturers of those items are still required to register with the State Department’s Directorate of Defense Trade Controls (DDTC), regardless of whether the manufactured items are destined for international commerce. Many manufacturers are aware of the onerous process of maintaining compliance under Department of State control. Fortunately, State has rolled out its new online system, the Defense Export Control and Compliance System (DECCS). DECCS will replace DTRA, DTrade, EFS, ELLIE and MARY, providing users access to a number of DDTC business applications through a single, cloud-based portal. Currently, the Registration, Licensing, Advisory Opinions and Commodity Jurisdictions applications are live in the DECCS Portal.

Many manufacturers of NFA items were grudgingly drawn into the regimented and confounding world of ITAR registration with the Department of State many years ago, and many NFA manufacturers chose to simply ignore the need for registration, despite the dire warnings regarding the consequences of such malfeasance. Frankly, State’s old system was cumbersome and overly complicated. One had to download approved electronic documents; electronically complete some portions of those documents; print out those documents; sign those documents; scan the now-signed documents; save and then submit those documents; and then head on down to your local bank to submit your onerous payment via ACH or wire (though State loved calling it “FedWire”), all the while, cross-referencing applications and payments with all sorts of arcane reference numbers. All that appears to be buried. Applying for a DECCS account is fairly straightforward at deccs.pmddtc.state.gov/deccs. It is also quite secure. Users will immediately notice that the system employs two-factor authentication for each login to the system. This can be done via a smart phone application or via an automated dialer service.

Once logged into the system, users can go directly to the registration programs via pull-down menus. The ITAR registration is significantly streamlined, and users are walked through each step of the process, including identification, documentation and certification. Of note is that documentation is more rigorous and includes items such as articles of incorporation. All of this can be done online and electronically. No printing and rescanning.

The best part? The base registration fee is currently, as of the time of the writing of this column, only $500 (as opposed to $2,250) and can be paid for with a credit card after the registration has been approved! No expensive trip to the bank to make the payment. The NFATCA has railed for ages against the onerous registration scheme employed by State for NFA manufacturers that do not export and have no intention of doing so. We have worked hand-in-hand with other organizations in the long process of reducing the impact of ITAR registration. The current process is a much appreciated first step in reducing the regulatory burden, but we still have a long way to go! We have been committed to assisting the NFA community for almost 15 years. Our goal is to help our community act responsibly and safely within the law. We work with legislators and regulators to expand NFA opportunities for everyone. We thank you for your continued support. Thank you and don’t forget to sign up or renew your membership today at nfatca.org/join.htm.

Don’t Fake Your Love Letters

One of the great challenges of writing a regular column for a magazine is embracing the lag between writing the column and having it published. There’s a lot that goes on in between those two events, and it takes effort and time to get things right. That lag also means that it can be difficult to maintain a firm connection with current events, but I don’t think that this column will have a problem with currency in this issue. As this column is being written, there is a small kerfuffle (always wanted to use that word in this column!) on social media regarding a small aspect of the National Firearms Act (NFA).

The latest topic that is fanning the flames is the current activity deployed by ATF’s NFA Division in regard to dealer sample machine guns. Back tracking a moment, the machine gun world in the United States is divided roughly among fully transferable firearms, so-called “pre-May” dealer samples and post-May dealer samples, also known as “posties.” FFL/SOT’s have been able to obtain these posties by way of submitting documentation, along with the Form 3 application for transfer, that establishes that the firearm is particularly suitable for use by a law enforcement agency (or military unit). Such information must show why a sales sample of a particular firearm is suitable for such use and the expected governmental customers who would require a demonstration of the firearm. Information as to the availability of the firearm to fill subsequent orders and letters from governmental entities expressing a need for a particular model or interest in seeing a demonstration of a particular firearm would establish suitability for governmental use. This documentation is often called a “love letter” and has been a long-standing component of the NFA landscape. Some dealers obtained these love letters with ease, and others encountered great difficulty. Apparently, ATF has now decided that some love letters are not quite what they seem and have begun verification of the letters.

Of course, there is a great deal of jumping to conclusions: “Love letters are dead!” “Prices will sky-rocket for the going-out-of-business posties!” “ATF is changing the rules again!” “I predicted the end of this!” A copy of a recent rejection of a love letter has surfaced, and it seems to be the focus of the consternation as shown above.

As is often the case, the ire of social media may, indeed, be slightly misplaced. Most, if not all, FFL/SOTs are still able to utilize bona fide love letters to justify the acquisition of a postie. There is no end to the process, as codified in Federal regulation. There is no change at the NFA Division in Martinsburg, West Virginia. NFA Division has always investigated transfer requests that may be viewed as suspicious. Yet seeing proof of NFA Division doing its job has become a cause celebre’ for the denizens of Facebook and gun forums. Nothing has changed. You can still use a love letter to obtain a postie. What you cannot do is abuse the system. And you absolutely must make certain that the love letter process is legitimate: The CLEO executing the validating statement understands what he or she is affirming and that NFA Division may actually verify the document. Further, the love letter states that a demonstration is requested for contemplation of a future purchase. Don’t submit the letter if you have no intention of doing the demonstration! In short, don’t fake the love letter.

The NFATCA reviews these types of issues on a very regular basis. Let us know if you run across something that catches your eye! We will be happy to check things out and provide some basis in fact for what appears to be happening. Send us an email at info@nfatca.org. Or visit us online at nfatca.org or facebook.com/NFATCA.

During the spring and early summer, NFA transfer questions came to the NFA-TCA by the hundreds. I am always amazed at the sheer number of individuals that are not only given, but gladly take, bad advice in their quest to find yet another shortcut to getting an NFA item. In many cases it is under the guise of trying to save a few dollars; knowing all the while that the process is risky. Let’s put a fine point on this: there are no shortcuts. The quickest and most efficient way to transfer an NFA item is to do it correctly, completely and legally – the first time.

An NFA Revocable Trust, plain and simple, is a legal instrument designed to protect specific assets, especially in the event of your untimely demise. It is also a sophisticated legal instrument that can have an enormous impact upon whether or not you stay on the right side of the law. Why on earth someone would want to entrust that protection to a process that has been intentionally short cut, is beyond me. I have seen examples of trusts that have been copied from someone else’s trust or have been downloaded from some web site where there are no checks and balances on making certain that what you are getting will comply with state laws and will properly serve your estate. The short story here is when it comes to a document that may very well have to stand up in court, never anoint yourself as a lawyer, especially if you don’t have the training.

The NFATCA has seen just about every conceivable shortcut attempt that you can imagine and almost every single one of those transfers’ attempts gets bumped back to the dealer for a variety of reasons. This year has seen a huge increase with this problem. Virtually four out of five trusts get bumped back because it was simply an improper trust. What amazes me even more is the fact that the transferee expects the dealer to decipher what the specific problem is and give them advice on how to solve it. Your dealer is most likely not an attorney and even if he or she is, is most likely not a trust attorney. If your dealer is not a lawyer and he is selling you or even giving you a blank trust form document for you to “cut and paste” then a crime is being committed: unauthorized practice of law (UPL). It’s the same crime if he or she is creating a trust for you on the shop computer connected to the Internet or running Quicken. Not using a reliable attorney that knows and understands the laws in your state is risky business and will guarantee you a recipe for problems.

Trust transfers represent such a large portion of current transfer requests that the NFA Branch has been forced to train all of the examiners on what to look for in a trust that is legitimate and will pass the initial muster. Since our examiners are not lawyers they must depend on a variety of solid guidelines as to what is acceptable and what is not according to ATF counsel. I remember the days when virtually every trust came through with flying colors… Those days are gone! With prohibited persons actually obtaining NFA items through trusts, thus avoiding the law, the NFA Branch has had to tighten up, take a closer look at each trust document, and make certain that the trust document is structured according to all legal requirements. Needless to say this is a tough assignment for our examiners and requires yet another level of checks and balance that have never been required by the system. And it goes without saying that this additional work load has an impact on turnaround times.

I want to make it clear at this point that the NFATCA believes in the trust process as a rock solid method of protecting your assets, let alone the fact that it provides a work-around for CLEO issues, such as the law enforcement agency that still thinks they are approving a Form Four. It is at this point that we would like to point out that the individuals that are shortcutting this process and adding yet another level of hardship to the NFA Branch must remember one thing and only one thing: The problems that are being created are jeopardizing this process for everyone else. The NFA Revocable Trust is an invaluable asset to any NFA owner and should be coveted as a privilege that provides many benefits. Why abuse such a wonderful privilege? Unfortunately we all know that given an opportunity to gain an edge, it is inevitable that someone will take advantage and spoil the opportunity for everyone else.

Earlier, I mentioned that ATF Counsel has given some fairly strict marching orders with regard to trust review. In fact, these marching orders are, essentially, a punch list that each examiner uses to establish the validity of the trust document before them. And if there is the slightest whiff of uncertainty, the trust gets bounced. Keep in mind that since the examiners are not lawyers, they do not have the authority to give you advice on what you did wrong! Folks, if the trust is not valid, and an NFA item has been or gets transferred into it, then an illegal transfer has occurred. That is a federal offense. Some folks who had trusts sail through before are now discovering that they no longer work. These people, in particular, should have even more concern than the rest of us because they might already be in possession of an illegally transferred item. This issue has stunningly huge implications.

As part of NFATCA member services, we try to guide our members through this ever-changing landscape. We give them information that has been validated against ATF opinion and practice. We help them to do it right the first time. For less than the price of a weekly coffee, you can help us help you. In the meantime, here is your very own NFATCA Trust Buster Checklist:

1. Our best advice is to hire a competent attorney that is familiar with your state’s trust laws.
2. Internet templates and services are frequently not as up-to-date as one would hope. Further, the nuances of NFA item ownership are not even present. Generic asset trusts may not be appropriate. The same holds true for many off-the-shelf software packages.
3. Beware of dealers practicing law, even those who are doing so without even knowing it. You tend to get what you pay for.
4. Avoid cutting and pasting of an already existing trust. You will likely not know the where, when and how of the original trust, which means it probably will not work for you.
5. Make sure that your trust:

• Is validly constituted in the state in which you reside.
• Is properly funded.
• Has the beneficiary(ies) properly designated.
• Has the successor(s) properly designated.

Look at it this way: You are building a vehicle that is supposed to keep you from paying hefty fines or going to jail. For most folks, that’s a big deal. Now is not the time to fill the tank of this vehicle with cheap gas.

Come join the NFATCA today by visiting us at www.nfatca.org.

The Auto-Ordnance Corporation spent nearly twenty years trying to market the first production run of 15,000 Thompson submachine guns. Unfortunately, no one customer wanted enough of this new type of weapon at any one time to deplete the inventory. In 1939, two very important events transpired: the rumblings of another world war began in Europe and a new management team took over an almost failed Auto-Ordnance Corporation. The new president, J. Russell Maguire, had a fresh vision for Auto-Ordnance and the foresight to place the Thompson back in production – even before the old inventory of Thompson guns manufactured years ago by Colt’s Patent Firearms Manufacturing Company were sold. A deal was struck in December 1939 wherein the Savage Arms Company, Utica, New York, became the second subcontractor to manufacture the Thompson. The first Savage manufactured Thompsons rolled off the assembly line four months later for delivery to many new Auto-Ordnance customers.

When long time Thompson enthusiast Mike Wank first examined Savage Thompson submachine gun S-15043, he knew immediately the serial number was almost too good to be true. Serial number S-15043 was recorded on the ATF registration Form 4 and the numbers on the upper receiver and lower frame matched. Mike recognized something was probably amiss with this serial number; however, he purchased S-15043 because he found exactly what he wanted – a Tommy Gun at a good price.

No documentation has been uncovered that tells exactly what serial number Savage Arms used when Thompson production began. It is believed by many Thompson experts the serial numbering started exactly where the Colt manufactured Thompson’s stopped: No. 15041. To support this belief are documented Savage Model of 1928 Thompsons in the 15,000, 16,000 and 17,000 serial number ranges. The earliest production Savage Thompson known to exist is S-15651. Actually, it is the only Savage Thompson found by this author to exist in the 15,000 serial number range. As were many of the early Savage Thompsons, S-15651 was apparently sold to the British Purchasing Commission as evidenced by the British Broad Arrow markings on the left side of the receiver by the magazine well. The extreme need for guns by the British in early World War II may well explain why there are so few surviving examples of early Savage Thompsons. It is very likely many of these early guns were probably used until they could be used no more and discarded or simply just lost in battle.

If Savage started production at serial number S-15041, then S-15043 would be the third Savage Thompson manufactured. Could Mike have purchased the third Savage Thompson? And as a shooter!

Early production Savage Thompsons have a few characteristics that are quite different from the later production Savage Thompsons. The most common known difference is the New York, N.Y. U.S.A. address on the right side of the receiver. The great majority of Savage Thompsons have a Bridgeport, Connecticut U.S.A. address. Many Thompson enthusiasts have never seen a Savage Thompson with a New York address. The exact point where the address markings changed is unknown. Frank Iannamico’s excellent Thompson reference book, American Thunder II, places the address change somewhere between the 75,000 and 84,000 serial number ranges.

The second characteristic of early Savage production Thompsons is not so well known; it involves the patent markings on the right side of the receiver. Early Savage Thompsons have patent date markings that are identical to the markings on the late serial numbered Colt Thompsons. These are the patent date markings with the 1922 dates (identical to Colt Thompsons from serial No. 14500 to the end of the Colt production at No. 15040). The patent markings commonly found on the great majority of all Thompsons, including Savage Thompsons with a New York address, are patent numbers. As with the different addresses, above, it is also unknown at what point the patent date markings changed to the patent number markings. Research by the author has documented Savage Thompsons in the 25,000 and lower serial number ranges with the patent date markings; and documented Savage Thompsons in the 26,000 and higher serial number ranges with the patent number markings. Somewhere in between this range of serial numbers appears to be the change-over point – approximately 10,000 guns into production. However, this research was somewhat limited in scope because there are not a lot of very early Savage Thompsons to examine. As with all war time manufactured firearms, exceptions undoubtedly exist and will surface as research continues.

It is important to re-emphasize Savage receivers were still being marked with a New York address when the patent date markings changed to patent number markings. There are three known variations of address and patent markings on the Savage Thompson receiver:

• The very early first type Savage receiver marked with a New York address and patent date markings (seldom encountered).
• The second type Savage receiver marked with a New York address and patent number markings is the most commonly found Savage receiver with a New York address. The patent numbers were positioned in the same location as the patent dates.
• The third type (and most commonly encored) Savage receiver is marked with a Bridgeport address and patent number markings.

A quick inspection of Mike’s Thompson revealed a Bridgeport, Connecticut address and patent number markings and is definitely a late production Savage receiver. Careful examination of the serial number area revealed some handy work by an enterprising person or company.

The matching serial number on the lower frame of S-15043 looks to be original. There is a very slight misalignment of the numbers, but this is common on Savage lower frames. Most important, all the numbers on the lower frame are machine stamped and appear unchanged and unaltered.

Mike filed a Freedom of Information Act (FOIA) request on S-15043 to learn more about the history of this Savage Thompson with the unusual serial number. From the redacted documents provided by ATF, it can be determined S-15043 began life on the National Firearms Act (NFA) Registry via an Internal Revenue Service (IRS) Form 2 (Return of Firearms Manufactured, Imported, or Received by Manufacturer, Importer, Dealer (Other Than Pawnbroker), and Pawnbroker, under Chapter 25, Subchapter B, Internal Revenue Code), dated December 1, 1951. This registration date explained the reason for the handy work on the receiver and also told the exact origin of this Thompson. December 1, 1951, is believed to be the date George Numrich of The Numrich Arms Company (NAC) registered approximately 95 class three weapons that were included in the Thompson assets purchased from Frederic A. Willis and three of his associates on October 23, 1951. The class three weapons involved in this sale included Thompson submachine guns, prototype Thompson guns, Birmingham Small Arms (BSA) submachine guns, a .30-06 machine gun and a sufficient quantity of parts to assemble complete Thompsons. The small number of Thompsons registered by Numrich Arms Company in 1951 has come to be known by many in the Thompson community as the “NAC” or the “crate” Thompsons – because the complete Thompson business was packed away in crates when purchased by George Numrich. Continuing research has revealed several other NAC Thompsons also began life on the NFA Registry on December 1, 1951, with a documented transfer from former Thompson owner Frederic A. Willis to Numrich Arms Company.

Fortunately, the buttstock of S-15043 retained a property tag of one of the previous owners, The Village of Liberty. Internet research revealed such a city in the State of New York, very close to Mamaroneck, New York, the location of the Numrich Arms Company in 1951. Review of the FOIA redacted IRS/ATF forms indicated S-15043 had not been owned by a governmental agency for many years. A call to the police department located a retired officer who was for many years in charge of the Village of Liberty Police Department Firearm Training Division: Lt. Doug Lindsley.

Doug Lindsley began his career at the Village of Liberty Police Department in early 1971; he retired with the rank of Lieutenant in June 1995. Three times a year he attended the Federal Bureau of Investigation (FBI) firearms training at Camp Smith, New York, and also assisted as a firearms instructor for the FBI special agents. In 1979, he was invited to attend the FBI’s annual qualification, barbecue, and competition shoot at Camp Smith. The shoot lasted three days and when the smoke cleared, Doug had finished first, ahead of the 186 FBI agents and 44 different state agency officers. Unfortunately, he could not accept the first place award because the competition was only for the agents… but he did manage a big smile for a long time afterward. The Thompson was used in many different phases of training at Camp Smith, but this only lasted for a couple of years. Doug recalled the Bureau began phasing out submachine gun training and started emphasizing the use of shotguns for the many small towns and rural areas in the State of New York. There are no known photographs of S-15043 while it was at the police department or any record of it ever being fired in the line of duty.

S-15043 was at the department when Doug became a police officer. A 50-round drum and two 20-round magazines accompanied the gun. Some excellent detective work by Doug produced a copy of the original IRS Form 5 (Firearms) tax exempt transfer document. This form shows August 15, 1952, as the date of transfer for S-15043 between the Village of Liberty Police Department and Numrich Arms Company. It is signed by “George R. Numrich, Jr., Individual Owner, 505 Halstead Avenue, Mamaroneck, New York.”

Doug believed S-15043 was sold back to Numrich Arms in the early 1980s and the money used to purchase shotguns. He was half-right; obtaining shotguns for the Liberty Police Department was the reason S-15043 was sold. But the purchasing dealer was Selective Fire Limited, a well known Class Three dealer now located in Marietta, Georgia.

The police patch shown in this story was the official department patch when S-15043 was in service with the Village of Liberty Police Department. Doug believed this patch should always be with S-15043 and proudly provided it to Mike.

Is Mike’s Thompson the third production Thompson submachine gun manufactured by Savage Arms Company in 1940? Yes and no. The receiver was definitely not produced in the early months of 1940. It is a late production Savage receiver that was probably surplus or rejected for some unknown reason and then never needed because production changed in 1942 from the Model of 1928 Thompson to the Model M1 Thompson. However, the lower frame appears to be original and at one time part of the original Savage S-15043 Thompson. Interviews of several former owners indicated S-15043 may have been parkerized after it was sold by the Village of Liberty Police Department. It is not hard to imagine how the original third Thompson manufactured by Savage could have been used in early quality control type testing that ultimately may have led to the receiver being destroyed or discarded. There is no doubt the lower frame of S-15043 was retained by Savage Arms (and later by Auto-Ordnance Bridgeport) and ultimately made its way to the Numrich Arms Company when George Numrich purchased the Thompson in 1951.

Review of other known “NAC” Thompsons with Savage receivers show the same serial numbering handy work as S-15043. The reversed numeral three in the serial number is just another example of the rudimentary Numrich Arms Company early markings. Careful examination of the receiver revealed what may have been a “NAC” or “NU” (for Numrich?) marking below the Numrich Arms Company stamped serial number; this marking was probably removed when this Thompson was refinished. Numrich Arms Company had to mark the serial numbers on the Thompson receivers in 1951 before registration with the Internal Revenue Service or the government would assign a serial number. The lower frame of S-15043 was obviously found in among the many Thompson parts and mated with a Savage receiver. A decision to mark this Thompson with the serial number of the lower frame was made and a new “NAC Thompson” was born. What happened to the “first” Savage S-15043 will probably never be known; however, the lower frame of this third Savage Thompson continues to live on as part of this “NAC” or “crate” Thompson.

Just when you thought things couldn’t get any worse it just seems that the news doesn’t get any better. Ammo prices are through the roof, if you can find any. The AR family of rifles has all but disappeared from the shelf and the backlog for many of the manufacturers has surpassed the 50,000 mark for waiting customers. A thousand rounds of 5.56 that used to cost $175 surpassed the $400 mark months ago. What used to be an $800 decked out AR is now passing the $2,000 mark. It seems there is no end to the news.

Although still in pretty good shape the NFA buyers are slow but sure. We know that short barreled shotguns, short barreled rifles, and suppressor purchases are at an all time high. If we keep on the current track of buying NFA merchandise in 2009, it will surpass a million, yes 1,000,000 transfers in the fiscal year ending October 1st. It is really a strange phenomenon if you look at the buying surge and keep in mind that last year we barely passed the 500,000 mark for transfers.

There are still a lot of machine guns that are transferable being sold this year but nothing to compare to what we have seen in the last five years. Some of the active dealers who are used to selling three and four guns at a show have now fallen back to selling accessories rather than depending on the revenue from NFA sales. They may be selling a lot of NFA stuff but the margins are lower on a suppressor and a short barreled rifle or shotgun. In a recent conversation with an NFATCA dealer we were told that last year they sold nearly sixty high end NFA items compared to a mere dozen this year. So although the buyers are still out there, the “cautiously optimistic” crowd is larger than ever. Because we still don’t have a grip on what is happening with our own economy most of us are holding on to what we have or dumping what we don’t need or want to make room for a better cash flow, just in case. It makes for some strange numbers showing that the older guns are not selling like they used to. The choice is to hold on and wait for better times or to sell the gun and perhaps even take a loss. This chemistry makes both buying and selling interesting, to say the least.

Keep in mind that the “transferable” number of machine guns that are available will never get any bigger, and unfortunately will only shrink as time passes on. I remember two years ago Ken Houchens announced to the Knob Creek crowd that a recent NFA study showed that there were only 182,619 transferable machine guns in the United States. If that one fact isn’t enough to make you a believer just watch pricing as time passes. Sure the economy will affect how and when people buy, but make no mistake, the buying crowd is much larger than the selling crowd by a wide margin. In short, that 182,619 number is and has been for over 20 years, a safe bet. Pricing may change a bit from year to year but the really good stuff has and will continue to be holding its own, as long as you are patient. Just remember, it hasn’t been that long ago since many of us paid $250 for an HK sear or $300 for a MAC 11. I wish I could say that this was the first time that we have seen this kind of lull in the economy. For those of us who have seen this before we know that patience is a virtue and that waiting is the name of the game. That’s the part that is hard to bear. For many of us we ask the simple question, “Wait for what?”

In all of the fury there is one thing that you can rest assured that is happening in the NFA community: the NFATCA is and has been watching out for your interests. We watch the numbers every day and keep track of virtually every activity in the NFA industry that may affect our future. We keep in daily contact with major industry representatives and the top management of ATF to make absolutely certain that both the industry and ATF are moving in lock step with one another. This year we have an agenda that focuses on nine separate objectives that have been jointly created by industry and ATF. At this writing, we have made three proposals to put four of our objectives behind us as major accomplishments this year. I know we keep talking about the secrecy of these issues but we promise, as results are available you will read them right here first. In the meantime, we the NFATCA say “stick to your guns” and support your NFA community in any manner that you feel suitable. We would like to have you become a part of what we are doing and encourage you to do so. However, if that is not on your agenda, join us every month here and read about what we are up to and think how you could make a difference for all of us. Every effort helps and every NFATCA member encourages you to get out to the shows and make a difference in whatever manner you can. Of the three hundred plus members, every individual is making a difference in some way. We challenge you, as an NFA supporter to do the same.

Pretty exciting times, as far as we are concerned! Don’t miss the boat any longer; come join the only organization in the country that is watching over every single NFA issue possible. All of this energy is just for you, the NFA owner. Join the NFATCA today by visiting us at www.nfatca.org.

There are many semiautomatic variants of newly manufactured NFA firearms available to the military firearms enthusiast. Most people can live with the fact that they are operationally different due to the 1986 ban on the manufacture of machine guns for civilian ownership. Other changes, much more noticeable, also take place to meet the other Title I requirements including barrel length and overall length.

While the semiautomatic mechanism is currently “written in stone” at the present time, there is no prohibition on the civilian manufacture of any other NFA category, including silencers, destructive devices (DD), Any Other Weapons (AOW), Short Barreled Shotguns (SBS), and the focus of this article, Short Barreled Rifles (SBR). While you can’t alter the function, you can certainly get it back to that look you would like, simply by registering it as a Title II firearm prior to making any modifications.

Some popular rifles that get “altered back” to their more original look by using the same barrel length as their fully automatic brethren include the AR-15 and all its variants, and the Uzi carbine. Both are quite simple by mechanical standards and only require a swap in parts with minimal tooling, if any, being necessary. The FN PS90, which seems to be growing in popularity by enormous proportions, looks great with a shorter barrel as well; just like the original P90. The physical swap, while not beyond the abilities of many serious enthusiasts, is much more entailed than those previously mentioned and is thus the subject of this article.

The Legal Stuff Must be Taken Care of First

Before altering any firearm from a Title I to a Title II firearm, it is most important that prior approval from the Bureau of Alcohol, Tobacco, Firearms & Explosives be obtained. It is even necessary to obtain their approval before purchasing the parts to complete the conversion and own them in conjunction with your host firearm.

The form an individual will be using to register and “manufacture” the SBR will be an ATF Form 1 (5320.1) Application to Make and Register a Firearm. It is extremely similar in appearance to the familiar Form 4 used to transfer a machine gun to an individual. The basic information is the same, except you determine the information to be filled in regarding the firearm. If you are starting with an existing firearm, as is the case of our PS90 example, the original manufacturer and serial number is used. Any changes you propose to make will be listed in the new description, including barrel length, caliber, overall length, etc.

You will need to affix a recent passport photograph to the completed form and obtain a Law Enforcement Certification, again, just like the Form 4. It must be submitted in duplicate and accompanied by a pair of BATFE NFA Fingerprint cards (available from most local Class III Dealers or can be obtained directly from BATFE) as well as the Certification of Compliance with 18U.S.C. 922(g)(5)(B) (BATFE Form 5330.20). This form is often referred to as the Citizenship Certification. With the exception of the Fingerprint cards, all these forms can be obtained from the BATFE Website www.atf.gov or from the extremely beneficial website www.TitleII.com, formerly known as Danbrew’s PDF Document Center.

Include a check in the amount of $200 for the manufacturing fee payable to “The Department of Justice” with your package, and you can start your planning. Your approved form can show up anytime from 6 weeks to 12 weeks from mailing, and at that point you can start procuring the parts needed to undertake your project and start assembling the new configuration.

Getting to know the PS90

The FN PS90 is a compact Bullpup design with a very short overall length. This makes it even more attractive to bring through the Registered SBR process. With the short barrel, it is extremely compact and packs a big punch compared to similar sized firearms, usually available in pistol calibers. Its slim aesthetics are only exemplified by the unique, horizontal magazine, which lies flat, snapped over the top of the action with absolutely no protrusion in any direction. Basic disassembly for normal maintenance is very simple and requires no tools.

The PS90 is divided into 4 major components; the barreled receiver, the bolt group, the stock and the hammer pack. To field strip the PS90 the first thing you do is remove the magazine, inspect and clear the action and make sure no ammo is present. The next step is to pull the cocking handle rearward to cock the hammer, and than let the handle return to its forward position. Depress the barrel support lock located forward of the chamber area and slide the barrel and receiver assembly completely out the front. Next, tip the receiver down towards the front and slide the bolt group out the same opening as the receiver. Then, slide the butt plate at the rear of the firearm up, and off. The last thing to remove is the hammer pack located under the butt plate you just removed. The hammer group release lever is lifted up and the entire self-contained hammer pack is removed by sliding rearward from the stock. At this point the FN PS90 is field stripped enough for general maintenance and is quickly and easily reassembled.

SBR’ing the FN PS90

The PS90 is a very different creature from most other systems on the market. With many firearms, when factory short barrels are not an option, most people just cut the original barrel to the desired length, re-crown and thread if desired. In the case of the PS90, this isn’t the only option. The barrel on this gun is actually hidden under a much larger barrel shroud, and is blind pinned behind the flash hider. This shroud, from the barrel locking nut area, all the way to the tip of the flash hider is a one-piece unit and must be completely removed before proceeding. The original barrel is only usable again for your project if you cut it to the right length, re-crown and re-thread it for the proper barrel nut. Your other option is to procure a correct length barrel and correct barrel nut to finish your project and save the other parts for future projects or trading materials. Either way, you will need a new barrel nut as the old shroud is no longer useful in any capacity. Everything necessary to complete this project came directly from CMMG (www.cmmginc.com) including excellent directions with all questions asked. A new barrel was installed and a special barrel nut was supplied and utilized, converting the threads to the popular 1/2×28 to allow use of common muzzle accessories. The original barrel nut with the original P90 Flash Hider is also available to complete that “factory look” if that is what you are going for.

If you do wish to try and salvage your original barrel for future use or other projects you can drill out the blind pin located directly behind the flash hider. After removing this pin, the sleeve, also acting as the barrel retaining nut, can be removed and the barrel is allowed to be slid out through the rear of the receiver. If you don’t care about salvaging the barrel and sleeve for future replacement as is, you can simply cut through the barrel and sleeve behind the flash hider, remove the barrel sleeve to the front and remove the barrel through the rear of the receiver. The barrel will still be usable for a short barrel project in the future.

Special Tools & Flying Springs

No one likes flying springs, especially when we don’t know where they came from in the first place, what they looked like, or how to replace them even if we did find them. The special tools refer to some minor modifications necessary to some common wrenches to allow them to fit in the confined spaces of the barrel and the barrel nut.

We will discuss the necessary modified tools first. The two wrenches that needed to be modified for this project include a metric 15mm and a 19mm. Since the spaces they need to fit are very thin, some material must be removed from the width of most standard wrenches. This can be accomplished with a bench mounted belt sander in short order. For a point of reference, the space the 15mm wrench needed to fit in measured only .235 inches wide while the unmodified wrench dialed in at .290 inches wide.

For the flying springs, it is important to know that the barrel, when in place, acts as a host for 3 captive springs. If the old barrel were to be quickly withdrawn from the rear of the receiver there would be nothing to hold the springs in their necessary position and have the potential to create a major problem. To address the spring placement concern, a range rod of a similar diameter can be used pushing the old barrel out (from front to back) with it, while capturing all the springs in their normal position. When the new barrel is inserted from the rear of the receiver, it slowly pushes the range rod out (to the front), recapturing the springs in their intended location again. With the new, short barrel in place the barrel nut was added at the front of the receiver and the barrel was tightened from the rear of the receiver while the front nut was held captive in the receiver and assisted with the 19mm wrench. With a tightening of the barrel nut, and reassembling the PS90, your SBR project is complete.

Do It Yourself or Hire a Pro?

Even though it is completely legal to manufacture your own SBR, some people choose to have a licensed Title II Manufacturer do the work for them. There are a few key reasons it may be advantageous to subcontract this work out. First, once you are approved by BATFE to complete your SBR, you must engrave your name on the receiver as the new manufacturer. Some people don’t want their own name engraved on a firearm as the manufacturer for reasons of liability or for concern about possible future sale. Others choose to have someone else do the work for them just because of time or mechanical constraints.

The process of hiring a licensed Title II Manufacturer to do this work for you is almost as easy as building it yourself on the Form 1 earlier described. In this case, the gun is sent to the manufacturer with a request to remanufacture it to an SBR, and a BAFTE Form 4 is completed to transfer the gun back to you once completed. It is the same federal tax ($200) and approximately the same time frame. The form is almost identical and the Title II Manufacturer is the one who engraves their business name on your firearm. Some manufacturers who do this work are CMMG, Inc. and TROSUSA, both well known in the FN arena.

Online Support

As the author was researching sources of information for this project, several businesses and helpful online communities were discovered. If you have any questions about the FN PS90, or are simply a new fan, you can visit either of the following websites that contain a lot of information: www.fnforum.com and www.fivesevenforum.com. Both were very helpful. For BATFE forms to complete the legal registration before engaging in the project, you will find everything you need at www.titleii.com. For general questions about NFA, the folks at “Tom Bowers Board” www.subguns.com are always happy to help out. For parts, accessories and heavy technical support we highly recommend CMMG at www.cmmginc.com.

PS90 Parts & Accessories
CMMG, Inc
Ph: (660) 248-2293
Fax: (660) 248-2290
www.cmmginc.com

SBR Conversions & Accessories
Mark McWillis
P.O. Box 680
Clackamas, OR 97015
Ph: (503) 358-3708
www.trosusa.com

• Czech, VZ82/CZ82 pistols (in original configuration), all calibers, all serial numbers.
• Gerat 06H, 7.92 X 33 caliber semiautomatic rifles made by Firepower International, Ltd., of England bearing the following serial numbers: 08, 10, 11, 12, 14, 15, and 16.

Section III – Firearms removed from the provisions of the National Firearms Act and classified as curios or relics, still subject to the provisions of 18 U.S.C. Chapter 44, the Gun Control Act of 1968:

• Beretta, Model 92SB pistols, caliber 9mm, S/N C31509Z through C31538Z; with factory-issued detachable folding shoulder stocks.
• Coston Supply Co., Coston Line Throwing Gun, caliber .45-70, S/N 447; determination applies only when included as an integral part of its accompanying accessory kit.

Section IV – NFA firearms classified as curios or relics, still subject to the provisions of 26 U.S.C. Chapter 53, the National Firearms Act, and 18 U.S.C. Chapter 44, the Gun Control Act of 1968:

• SS-1 Sidewinder machinegun, serial numbers Ex-001 through Ex-0015 and Ex-0017 through Ex-020.

ATF Announces Final ITAR Rule

ATF has announced a final rule that conforms the regulations in 27 CFR Part 447 to the revised International Traffic in Arms Regulations. The final rule amends the list of countries from which the importation of defense articles into the United States are prohibited by adding Afghanistan and removing South Africa and some of the states comprising the former Soviet Union (Armenia, Azerbaijan and Tajikistan). The rule also removes the arms embargo against the countries of Serbia and Montenegro. It also clarifies an outdated reference in the regulations to Zaire, currently known as the “Democratic Republic of the Congo.”

Importer Legal Issues

An overview and update on legal issues that licensed importers should be aware of was presented by David Wulf, an ATF acting associate chief counsel, during the annual ATF Importers Conference held last summer in Washington, D.C.

While 18 USC 922 (I) makes it generally unlawful to import firearms and ammunition there are certain exceptions.

Government exceptions are found in 18 USC 925(a)(1) which allows federal, state and local governments to import firearms and ammunition that otherwise would be prohibited from importation, such as nonsporting firearms/ammunition and surplus military firearms. This exception does not apply to government contractors.

The “Sporting Purposes” test is found in 18 USC 925(d)(3) which provides that firearms and ammunition are importable if they are of a type that is “generally recognized as particularly suitable for or readily adaptable to sporting purposes.” This does not apply to NFA or surplus military firearms.

If you bring a firearm out of the U.S., such as on a European hunting trip, no Form 6 is needed for its return. However, upon return, you must satisfy U.S. Customs that you took the firearm out of the U.S. Using Custom form 4457, as well as a sales slip, are good ways to do this.

Conditional importations are permitted under 18 USC 925(d) which allows the importation of a firearm for examination and testing to determine whether the firearm would be importable.

Curios and Relics are covered in 18 USC 925(e) and 27 CFR 478.11 defines Curios and Relics. Regardless of other Gun Control Act prohibitions, importers can import C&R long guns and C&R sporting handguns. To be a Curio & Relic, the firearm must be in its original configuration. Parts can be replaced as long as the configuration isn’t changed.

The Scientific or Research Purposes exception allows non-sporting firearms and ammunition to be imported for research and development purposes. An example would be importing ammunition to test a weapons system. Several years ago ATF expanded what was considered scientific or research purposes to include things beyond “laboratory research” such as research and development. In 2006, ATF advised that product liability testing is included in this exception.

It should be noted that ammunition imported for scientific or research purposes will only be approved in reasonable amounts. 28 USC 5844 allows the importation of NFA firearms for limited purposes including scientific or research purposes. However, 18 USC 922(o) has no exception for scientific or research purposes. Thus, post ’86 machine guns can not be imported for this purpose.

Smokeless powder designed for use in small arms ammunition by itself is classified as “ammunition.” Thus, importers of smokeless powder must be licensed as importers under the Gun Control Act, must also be licensed as an importer under the explosives laws, be AECA registered, and apply for an approved Form 6 to import.

Numerous airgun silencers tested by ATF’s Firearms Technology Branch have been determined to be, by nature of their design and function, firearm silencers.

A firearms silencer is defined in 18 USC 921(a)(24) as a device for silencing, muffling, or diminishing the report of a portable firearm, including any combination of parts, designed or redesigned, and intended for use in assembling or fabricating a firearm silencer or muffler, and any parts intended only for use in such assembly or fabrication.

Starter guns which will or are designed to or can be readily converted to expel projectiles are considered firearms. Starter guns built on the frame or receiver of a firearm are firearms.

37/38mm gas guns are destructive devices when possessed with bean bag ammunition. The bag cartridge, standing alone, constitutes ammunition for a destructive device. ATF Ruling 95-3 provides that 37/38mm gas/flare guns possessed with “anti-personnel” ammunition, consisting of cartridges containing wood pellets, rubber pellets or balls, or bean bags, are destructive devices as that term is used in 18 USC 921(a)(4) and 26 USC 5845(f)(2). Finally, Wulf noted that nail guns are not firearms. ATF Ruling 54-245 held that a tool powered by blank .22 and .38 cartridges that is used for setting studs or driving anchors into masonry or metal is not a firearm. Even when a nail gun expels a projectile by the action of an explosive it is not regulated as a “firearm.”

ATF Installs New Phone System

One of ATF’s busiest customer call centers, the Federal Firearms Licensing Center (FFLC) in Atlanta, Georgia, has implemented an Automated Call Distribution system (ACD) to improve customer service.

The FFLC mail call center phone line, (866) 662-2750 (toll-free), is the first number dialed by many licensees. A primary ACD enhancement gives callers the option of waiting in a queue to speak with a live customer service representative instead of being transferred into a voice mailbox, which is sometimes full and unable to accept new messages. The ACD system also efficiently redirects the more common types of calls not requiring a live response. For example, requests for application packets are some of the most frequent and repetitive calls received by the FFLC. The ACD system automatically refers these calls at the beginning of the call-flow process to the ATF Distribution Center in Virginia (703) 455-7801 for a response, freeing customer service representatives to devote their time to answering more complex licensing questions.

Another important ACD enhancement is the systematic measurement of call volumes by date, time, length, and type. The system generates statistical reports that inform management how to allocate customer service representatives resources to best meet workload demands. Thanks to ACD, the FFLC now knows that the customer service representatives facilitate more than 3,400 calls per month. ACD also counts the number and length of abandoned calls and tracks customer wait times in the queue to establish performance benchmarks by which to plan and measure continued improvement. The ACD system has been such a success that ATF plans to expand its use to other customer call centers in Enforcement Programs and Services, such as the Federal Explosives Licensing Center and the National Firearms Act and Imports Branches.

ATF Switching to Electronic Fund Processing

Licensees making payments to ATF should note that ATF is switching to electronic fund processing. Checks presented to ATF will be converted into an electronic funds transfer, meaning that ATF will copy the check and use the account information to electronically debit your account for the amount of the check. The debit will be shown on the payer’s regular account statement. The original check will not be sent back as it will be destroyed by ATF, but the agency will keep a digital image of it.

The author publishes two of the small arms industry’s most widely read trade newsletters. The International Firearms Trade covers the world firearms scene, and The New Firearms Business covers the domestic market. Visit www.FirearmsGroup.com. He may be reached at: FirearmsB@aol.com.

The OIG found, for example, that NFA Branch staff do not process applications or enter data into the NFRTR in a consistent manner, which leads to errors in records and inconsistent decisions on NFA weapons applications. In addition, the NFA Branch has a backlog of record discrepancies between the NFRTR and inventories of federal firearms licensees that were identified during ATF compliance inspections. Further, the NFRTR’s software programming is flawed (by ATF’s own admission) and causes technical problems for those working in the database.

“The lack of consistency in procedures and the backlog in reconciling discrepancies, combined with the technical issues, result in errors in the records, reports and queries produced from the NFRTR,” the OIG wrote. “These errors affect the NFRTR’s reliability as a regulatory tool when it is used during compliance inspections of federal firearms licensees.” However, the OIG said it did not find evidence that individual weapons owners or federal firearms licensees had been sanctioned or criminally prosecuted because of errors in the database.

The NFA Branch Chief (Ken Houchens) told the OIG that he has recently initiated several actions to reduce errors in the NFRTR, such as hiring additional staff, improving communications and training of staff members, and revising a procedures manual. Additionally, both the NFA Branch Chief and the Assistant Director of the Office of Enforcement Programs and Services both stated that lack of funding precluded other significant actions such as correcting and upgrading the programming for the NFRTR and implementing online submissions of applications.

Timeliness Improvements

The OIG found that the NFA Branch has decreased the amount of time it takes to process NFA weapons applications and improved responsiveness to customer inquiries. Between 2004 and 2006, the average processing time for all eight types of NFA weapons applications decreased collectively from 30 days to 8 days. (The eight types of NFA weapons applications are: Form 5320.20, Application to Transport Interstate or to Temporarily Export Certain NFA Firearms; Form 1, Application to Make and Register a Firearm; Form 2, Notice of Firearms Manufactured or Imported; Form 3, Application for Tax-Exempt Transfer of Firearm and Registration to Special Occupational Taxpayer; Form 4, Application for Tax-Paid Transfer and Registration of a Firearm; Form 5, Application for Tax-Exempt Transfer and Registration of a Firearm; Form 9, Application and Permit for Permanent Exportation of a Firearm; and Form 10, Application for Registration of Firearms Acquired by Certain Government entities.)

In the same time period, the average processing time for the four types of applications used by individual weapons owners (Forms 1 and 4) and NFA weapons dealers (Forms 3 and 5) for registering and transferring NFA weapons decreased collectively from 39 days to 10 days. Specifically, processing time for Form 1 decreased from 99 days to 28 days; for Form 4, from 81 days to 9 days; for Form 3, from 30 days to 4 days; and for Form 5, 30 days to 9 days. The NFA Branch Chief attributed the improved processing times to the hiring of more contractor Data Entry Clerks, who enter data from the paper forms into the NFRTR, thereby freeing other staff to focus on reviewing the content of the applications.

To further improve customer service, the NFA Branch established a working relationship with the National Firearms Act Trade and Collectors Association (NFATCA), which represents NFA weapons dealers, manufacturers, importers, and owners. To build that relationship, the NFA Branch hosted a meeting with members of the NFATCA executive board in 2006 to demonstrate Branch operations and discuss NFA and NFRTR issues. The NFA Branch and the NFATCA also collaborated to write a handbook on the NFA and the weapons registration process, which ATF has made available on its website. However, the OIG found that the ATF website’s generally poor structure makes it difficult to navigate or locate relevant information and is a potential barrier to the electronic handbook’s use. The NFATCA has since announced it will offer printed copies of the handbook for sale at cost. Contact them at their website address: www.NFATCA.org for details.

Background

On June 26, 1934, the U.S. Congress passed the National Firearms Act (NFA) to limit the availability of machine guns, short barreled shotguns and rifles, firearm sound suppressors and other similar arms often used by criminals during the Prohibition Era. The NFA imposed a tax on the manufacture, import, and distribution of NFA arms not under the control of the U.S. government. The Bureau of ATF collects the taxes and maintains NFA arm possession records in a central registry – an electronic database called the National Firearms Registration and Transfer Record (NFRTR), which contains records on almost 2 million arms. ATF’s NFA Branch (under the Firearms and Explosives Services Division, Office of Enforcement Programs and Services) maintains the NFRTR and processes all applications to make, manufacture, import, register, and transfer NFA arms.

Congress expanded the scope of the NFA through the Gun Control Act (GCA) of 1968 to include destructive devices (bombs, incendiary devices such as flash bang grenades, and arms with a bore of greater than one-half inch), frames and receivers that can convert a semiautomatic arm into an automatic arm, and other concealable arms. The GCA restricts registrations of NFA arms only to makers (unlicensed individuals who usually make one arm at a time for individual use), manufacturers and importers. Further, the GCA called for a 30-day amnesty period ending December 1, 1968, where anyone possessing an NFA arm could register it without consequence. Any NFA arm not registered during the amnesty is considered contraband and cannot be registered.

On May 19, 1986, Congress passed the Firearms Owners’ Protection Act to prohibit possession of machine guns that were not legally possessed prior to its enactment. Thus, newly made machine guns were to be available only to the U.S. government and law enforcement entities.

NFA arms and their possessors must be registered with the NFRTR, and whenever possession is transferred (through sale, rental, gift, or bequest) the registration must be updated. A possessor is required to retain the approved NFA weapons application form as proof of a weapon’s registration and make it available to ATF upon request (26 U.S.C. § 5841 [e]). Manufacturers, importers, and makers of NFA weapons also are required to register each newly made, manufactured or imported arm.

The (OIG) examined ATF’s effectiveness in maintaining the records of registrations and transfers of NFA arms in the NFRTR. The OIG conducted the review in response to requests from members of Congress who had received letters from citizens expressing concern about the accuracy and completeness of the NFRTR. These citizens asserted that errors in the NFRTR and errors in decisions by NFA Branch employees left NFA weapons possessors vulnerable to unjust convictions for violating the NFA.

Inconsistent Data Entry

Due to inadequate standard operating procedures, training and communications, NFA Branch staff members do not process applications or enter data uniformly into the NFRTR. The staff’s variations in completing these tasks results in errors in NFRTR records, reports and queries as well as inconsistent decisions on NFA weapons registration and transfer applications, the OIG found.

The NFA Branch does not provide staff with a comprehensive standard operating procedures manual. The NFA Branch Chief inherited an undated manual of standard operating procedures when he assumed his position in 2005. The manual was under revision at the time of the OIG’s review, but the NFA Branch Chief said he has not had enough staff to complete the revision.

Specifically, none of the staff members the OIG investigators interviewed had ever received a copy of this manual as a resource to help them perform their duties. Instead, the procedural memorandums and directives provided to NFA Branch staff as guidance were usually specific to one issue and did not cover the basic information needed to process applications and enter data into the NFRTR.

NFA Branch staff also stated that they did not have adequate written direction on how to enter data such as abbreviations in the NFRTR, how to maintain application files, how often to contact applicants with pending applications, the proper method for fixing or working around NFRTR technical flaws, and who has the responsibility for correcting errors in NFRTR records. Therefore, staff members relied on each other or on managers to verbally explain what they believed the procedures were for processing applications and navigating the NFRTR database.

Additionally, the OIG said training for new NFA Branch staff members is ad hoc and not uniform. Staff members said that due to inadequate training, it was difficult to become familiar with the NFRTR and navigate easily through the database, a vital skill needed to process applications and conduct record checks. Staff also said inadequate training hampered their ability to learn about the NFA and the process for registering and transferring NFA weapons. Supervisors’ inadequate training led to variations in their direction and inconsistent decisions about approving or disapproving NFA weapons registration and transfer applications.

The OIG also found that the NFA Branch did not hold regular staff meetings so that the staff would stay current on changes in NFA weapons regulations. However, in March 2007, after the fieldwork for the OIG review was completed, the NFA Branch Section Chiefs began conducting monthly staff meetings to improve the flow of information within the Branch.

Backlog of NFRTR Errors

The NFA Branch is not promptly correcting discrepancies between the NFRTR records and licensee inventories, the OIG says. The NFA Branch is responsible for addressing the errors and discrepancies, identified by Industry Operators Investigators (IOIs) during compliance inspections of licensees. However, there are no established guidelines for the Branch on reconciling the errors within a certain amount of time, and as of March 2007 the Branch had a backlog of 61 discrepancy reports to reconcile. This means that some corrections to records do not get made before a licensee receives their next inspection, which could be 3 years later. At the time of the OIG’s review, one staff member was working part-time on the backlog. About one of four discrepancies could not be resolved without research by NFA Branch staff.

In a survey taken of IOIs by the OIG, 46.5% (139 of 299) reported that they found a discrepancy between the NFRTR inventory report and a licensee’s inventory “always” or “most of the time.” Further, 44.4% (133 of 299) said that the discrepancy was due to an error in the NFRTR “always” or “most of the time.” In comparison, none said that the error was “always” on the part of the licensee, and only 2% (6 of 299) said that the error was on the part of the licensee “most of the time.”

While licensees worry that discrepancies could result in their investigation by ATF Special Agents for violations of the NFA and GCA, IOIs told the OIG they only refer cases involving discrepancies to Special Agents when the discrepancy cannot be resolved or when there is a suspicion ofa deliberate violation of law. Between the years 2000 and 2006, only 15 federal firearms licensees were charged criminally for violating the NFA. In 2006, ATF conducted 7,292 compliance inspections and issued 12,176 violations. Of that total, less than 1% (53) was for NFA violations. In 2006, ATF issued an average of 1.7 violations per inspection, but only 0.007 NFA violations per inspection.

The OIG review could not identify any instances in which an NFRTR error resulted in inappropriate seizure of an NFA weapon or in appropriate criminal consequences to an individual weapons owner or FFL-holder. The OIG further asked the NFATCA for examples of its members’ weapons being inappropriately seized due to inaccuracies in the NFRTR, and none were received in response.

While the OIG could not find instances of wrongful seizure or prosecution of individuals or licensees based on ATF errors, it did note two examples (one provided the NFATCA and the other by ATF):

• 1. The NFA Branch incorrectly approved the sale (transfer) of a machine gun from a law enforcement agency to a federal firearms licensee. The licensee subsequently tried to sell (transfer) the weapon to another licensee. However, the NFA Branch discovered its original error and subsequently disapproved both the first and second transactions. The licensee was not allowed to retain possession of the machine gun, and the law enforcement agency did not have the funds to return the $10,000 paid by the licensee for the arm.
• 2. An NFA Branch Examiner processed an application to transfer an NFA weapon from a licensee to another licensee. The seller had purchased the arm from a police department that had, in turn, purchased the weapon ten years before from an importer. The Examiner who handled the original transaction should have stamped the approved application form “restricted” as only holders of certain licenses could possess and transfer the arm. Because the first application form was never stamped, the licensee did not know that he could only resell the weapon to certain license holders. The NFA Branch had to disapprove the licensee’s application to sell the weapon.

ATF Enforcement Actions

In 2006, ATF seized 3,030 NFA weapons, including 1,280 machine guns, 550 sawed-off shotguns and rifles, 571 silencers, 415 destructive devices, and 214 devices categorized as any other weapons. These totals included unregistered NFA weapons seized during criminal investigations as well as registered and unregistered NFA weapons seized as a result of compliance inspections of licensees.

In the OIG-conducted survey, IOIs were asked how many times in the past year they had referred a licensee to an ATF Special Agent based on a discrepancy between the NFRTR inventory report and the licensee’s inventory. Of the 298 IOIs who responded, 91% said they had made no referrals, 7% had made one referral, 1.6% had made 2 and less than 1% had made 3. IOIs interviewed emphasized they only refer cases when an NFA weapons registration in the NFRTR cannot be established after discussion with the licensee, the NFA Branch, and extensive searches of the NFRTR, or when they suspect deliberate criminal activity involving NFA weapons.

In fact, the OIG found that few licensees were criminally charged with NFA violations. Between 2000 and 2006, only 15 licensees were charged with violating 26 U.S.C. Chapter 53, the chapter of the Internal Revenue Code that includes the NFA. This represents only 6.5% of the total number of licensees (230) criminally charged with any violation.

NFRTR Database

As of November 2006, the NFRTR contained registrations for 1,906,786 weapons. The total number of weapons included 1,186,138 destructive devices (including 918,517 flash bang grenades), 391,532 machine guns, 150,364 silencers, 95,699 short barreled shotguns, 33,518 short barreled rifles, 48,443 weapons categorized as any other weapons, and 1,082 “unknown” devices or weapons not classified in the other categories (this includes older weapons or devices registered with ATF before the NFRTR was automated that are not clearly identified or do not fit in any other category of weapon).

On a percentage basis, the weapons in the NFRTR as of November 2006 break down into: 62.2% destructive devices, 20.5% machine guns, 7.9% silencers, 5% short barreled shotguns, 1.8% short barreled shotguns, 2.5% any other weapon and 0.1% unknown.

Each record in the NFRTR contains the make, model, and serial number of the weapon, the date of its registration, and the name and address of the person entitled to possess the weapon. For weapons registered prior to 1983, the NFRTR contains record entries of the three most recent transactions. After 1983, the records contain all transactions. Another database linked to the NFRTR database contains electronic images of the related applications forms for both pre- and post- 1983 registered weapons.

The reason for this is that when the NFRTR was automated in 1983, the NFA Branch chose to focus on entering all transaction information for newly registered weapons, so NFA Branch staff entered only the three most recent records for each NFA weapon registered prior to 1983. A full transaction history of the pre-1983 weapon is available in the imaging database, which contains scanned copies of original application forms. All transactions of an NFA weapon registered after 1983 are entered into the NFRTR.

ATF Database Flawed

The NFRTR’s programming has not been modified since 1997 when ATF converted the original 1983 electronic database to an Oracle platform. Several NFA Branch personnel described the NFRTR programming as obsolete and identified flaws: (1) older NFRTR records with empty data fields can improperly exclude the records from search results, (2) the NFRTR can erroneously generate two separate records for one weapon, (3) the system lacks controls to prevent inconsistent data entry, (4) the system lists incorrect owners of NFA weapons on queries and reports, and (5) when multiple weapons are registered on a single form, a change entered in the NFRTR for one weapon incorrectly applies thechange to all the weapons listed on that form.

One IOI, in making a comment about the need to update the NFRTR computer system, said, (ATF should) “…stop operating like a third world Department of Motor Vehicles office.” For the last five years, ATF would not make system enhancements to the NFRTR as ATF planned to integrate many of the databases of its National Tracing Center, Firearms and Explosives Imports Branch, and NFA Branch through the Firearms Integrated Technology (FIT) project. ATF received budget allocations for FIT in fiscal years 2001 and 2002. However it reallocated the funds to another mission which exhausted the funding by 2004. ATF’s subsequent funding requests for FIT have not been successful. During 2006, the NFA Branch processed and entered 402,151 NFA weapons applications forms into the NFRTR.

As of March 2007, the NFA Branch had a staff of 20 ATF personnel and 12 contractors. The NFA Branch is authorized to have a complement of sixteen Examiners, eight Specialists, one Special Occupational Tax (SOT) Specialist, and one Information Technology Specialist. As of March 2007, it had only ten Examiners, four Specialists, one SOT Specialist, and one Information Technology Specialist.

Not All NFA Staff on “Same Page”

One Examiner interviewed by the OIG stated that, due to poor training, not all staff members are “on the same page” on how they approach their work and applications may be processed incorrectly. He cited an instance in which an Examiner needed to know whether a state allowed a certain type of NFA weapon, and rather than researching the current state law or regulation, the Examiner simply queried the NFRTR to view a similar transaction in that state that had been approved in the past. State laws and regulations may change since a previous transaction the OIG pointed out in its report, but that Examiners are not kept current on these changes and are not trained to research the laws and regulations appropriately, instead of following old transactions.

Members of industry have long complained that the same question on the regulations posed to NFA staff will bring different responses, depending on who is asked. The OIG research bore this out as it noted that “inadequate training could affect the direction given to NFA Branch staff as well as information provided to the ATF field offices.”

For example, the lack of training on NFA-related state laws and regulations affected the guidance from Section Chiefs to Examiners. Further, an IOI survey respondent commented, “We can call (the) NFA (Branch) and speak to different people (on the same issue) and get different answers. This has happened more than a few times in the past.”

The Section Chiefs are usually selected from the Examiner pool and do not receive additional training, either supervisory or NFA-related. “They receive the same ad hoc training as other NFA Branch staff, and the quality of the information received during the training is not standard,” the OIG noted.

“Because new staff members receive different training from different people who also were not formally trained, the quality of the training in terms of topics covered and accuracy of information is insufficient,” the OIG reasoned. “Incomplete and inaccurate training leads to errors in the NFRTR and in decisions based on the NFRTR. Moreover, variations in direction based on inadequate training could produce inconsistent approvals or disapprovals of NFA weapons applications.”

One of the NFATCA representatives who maintains a federal license for NFA weapons estimated for the OIG that during his compliance inspections the NFRTR inventory reports were 25 to 30% inaccurate. He added that NFA licensees fear compliance inspections because the NFRTR is inaccurate, not because their inventory records are inaccurate. Another NFATCA representative said that NFA licensees “should not be afraid of compliance inspections because their records are probably better than ATF’s.”

Multiple Registrations Linked

NFA Branch staff noted that the NFRTR does not always indicate the correct owner of weapons on queries and reports. The NFA Branch Program Manager stated to the OIG that this problem was identified almost immediately after the new NFRTR system was deployed in 1997, but the information technology staff was unable to correct the problem and ATF did not pursue resolution.

When multiple NFA weapons are registered or transferred on the same form they are initially linked by their NFRTR-generated control number. This control number is based on the form and not the weapon and applies to the records of all weapons registered on that form. The link between weapons registered on the same NFA weapon application is broken only after weapons have been transferred to new owners two subsequent times. The weapons would then have their own NFRTR-generated control numbers. This programming flaw is most evident when a transfer of a weapon is canceled by the applicant and that weapon’s preceding transaction involved multiple weapons registered or transferred on the same form. If no action is taken to correct the record to show the true current owner, all NFRTR queries and reports will incorrectly list the transferee from the canceled transaction as the current owner. However, when an NFA Branch staff member manually fixes the record that show the correct owner of the weapon, the NFRTR will apply that change to all the weapons on the form, which are still linked by the same control number. Since it takes a significant amount of time and effort to ensure that only the relevant weapon on that record is changed, Examiners often do not fixvsuch records, the OIG said.

Non-Completion of Vital Projects

ATF has initiated, but not completed due to budget constraints, two projects that the OIG said would improve the accuracy of the NFRTR and increase the efficiency of the NFA Branch. The first involves scanning all NFA weapons transfer and registration applications since 1934 into digital files in a database and establishing an indexing system to search this new database. The second project, titled e-Forms, is creating an electronic filing system for individual weapons owners and federal firearms licensees to submit NFA weapons applications online.

The OIG found that ATF has a oneyear backlog worth of NFA weapons applications to image and index. In 2005, the NFA Branch had four contractors working on imaging and indexing, and the backlog was only 6months. In June 2006, budget cuts forced ATF to reduce the number of contractors to two, which has increased the backlog significantly.

ATF has not completed the e-Forms project it initiated in 2004. The capability for individuals and industry to submit applications online would reduce data entry errors by NFA Branch personnel, detect errors on applicant’s registration and transfer forms before entry into the NFRTR, and allow importers and manufacturers to check the status of forms they submit electronically for processing.

In fiscal year 2002, ATF received funding for the e-Forms project and developed the requirements document for an electronic filing system and a prototype of the system. By 2006, a prototype of the system was demonstrated to the industry. However, due to budget constraints, ATF suspended the project before the system was finalized and implemented. ATF estimated that it needed just under $14 million to complete the e-Forms system and to operate it for the first two years and that $200,000 would be needed to operate it each year thereafter.

Recommendations

To help improve the processing of NFA applications and reduce errors in the NFRTR, the OIG recommended that ATF:

• Improve the ATF website by making it easier to find NFA information, such as frequently asked questions, applications forms and instructions, NFA Branch contact information, and the NFA Handbook.
• Develop and disseminate to all NFA Branch staff a comprehensive standard operating procedures manual that includes all NFA weapons application processes, NFRTR processes and data entry codes and abbreviations.
• Develop uniform and structured training for staff members that includes standard operating procedures and hands-on experience with the NFRTR. Ensure that all NFA Branch staff members attend the training and that the staff trainers are themselves properly trained. Provide training for the Section Chiefs on supervisory techniques.
• Establish regular and recurring methods of communication to NFA Branch staff.
• Resolve discrepancies between the NFRTR and inventories of federal firearms licensees in a timely manner.
• Develop and implement an action plan to fix technical programming flaws and errors in the NFRTR.
• Develop and implement an action plan for eliminating the backlog of imaging and indexing forms for the imaging database.
• Develop and implement an action plan for completing the e-Forms project.

The OIG concluded that since 2004, the NFA Branch has reduced the overall average processing time by more than two-thirds for the most used forms and has improved its responsiveness to customer service inquiries and requests for information; however it has much more work to do to improve its operations.

The author publishes two of the small arms industry’s most widely read trade newsletters. The International Firearms Trade covers the world firearms scene, and The New Firearms Business covers the domestic market. He also offers FFL-mailing lists to firms interested in direct marketing efforts to the industry. He may be reached at: FirearmsB@aol.com.

By John Brown

In the several visits that the NFATCA board has made to Martinsburg, we have always been amazed at the technology and the energy it takes to keep up with the firearms trade in our great land. We read and hear a lot of self pronounced experts criticize the BATFE, their efforts, and the regulations. Most don’t have the courage to let the rest of us know exactly who they are; therefore you can never really get the help you think they might be able to offer. Out of this frustration, the NFATCA was born nearly two years ago. The NFATCA has grown to represent an organization run by the NFA community for the NFA community.

As most of you know from reading the past articles we have published, the NFATCA has been working collaboratively with the Bureau for almost two years. For the first time in history we have jointly developed the NFA Owners Manual for all members of our community. This effort is completed and has been done so in total excellence. Both the BATFE and the NFATCA have worked diligently to represent the NFA community as a whole, on rulings, explanations and understanding the law. We have accomplished many things with the combined energies.

It is unfortunate that we are unable to convince more of the NFA community to dig in and help out. What we do costs a lot of money. Some of the community complains that the dues are too expensive, yet they don’t hesitate to write a check for a $10,000 NFA weapon. I heard someone say, “The difference is my gun is an investment.” I did have the opportunity to smile at this gentleman and ask him, “And who is watching out to make certain that your investment is protected?” The look on his face would have stopped a truck.

That’s why the NFATCA is a group of individuals and corporations, just like you, interested in finding and defining the best way to protect our futures with NFA ownership. This is exactly what we do. We don’t fight battles on an individual basis, although we have been asked to do so. We work collectively for the entire community.

The standard question is, “What have you done for me lately?” The answer is a simple one, but will get very complex as the future presents itself.

With a new BATFE Director and a host of issues, we will need all the help we can muster including a robust membership and funding that continues to strengthen our organization’s efforts. In late 2006 we will be working many issues that are critical for many of you in the NFA community. We are being faced with technology questions, and the side effects of our work being recognized by ATF. They value our opinion and we are being asked on a more frequent basis to offer opinions on a variety of issues, again, critical to all NFA owners.

Today we are being asked, by BATFE, some very pointed questions on the use of sears in conversions and opinions on how the NFATCA feels about many technical issues concerning machine guns and manufacturing issues. We are participating in discussions on the use of various uppers and the effects on regulations. We are being invited into halls we have never been asked to visit until this time. For the first time, our opinion is valued, listened to, and used in the design of the NFA community’s future. We have realized a major objective in our goals: designing a more collaborative effort with the ATF. Mission accomplished!

The NFATCA today, with a membership of over 100 members, including major manufacturers, is the only organization that stands unified in representing the entire NFA community.

In the future we will be involved with counsel, ATF, and our membership to resolve a host of issues that we will detail in these articles. We will need the top 10% of our membership to handle these issues, offer opinions, and work jointly with ATF in forming policy for the future. At every turn I still see many NFA owners lethargic in their approach to offering any financial or other expertise to work NFA issues.

Even with only 100 members we will forge onward and work to the best of our efforts to stay strong, unified, and powerful in our energies to represent the best interests of the NFA community.

If you care at all, and want fair representation, join the NFATCA today and help this organization bring the strength necessary for the best representation in Washington, D.C. Our success will be a success for the entire community. Join today!

WWW.NFATCA.ORG

How far back in time would you have to travel to find a Ruger 10/22 that fires at 800 rounds per minute, accurately and controllably, that retails under $1,300? Thanks to the Akins Group, Inc., that time is now.

One of the newest innovations in the recreational firearms industry is now a reality. Under development for several years, the Akins Group, Inc. is releasing their latest product, the Akins Accelerator. The Akins Accelerator is a rifle stock designed to be used with a Ruger 10/22. It contains a linear motion device that in simple terms allows the rifle to recoil inside the stock. This slight rearward travel allows the trigger to be reset upon firing. Upon resetting the trigger, the return-forward motion of the firearm brings the trigger back into contact with the trigger finger of the shooter starting the process over again. It will continue until the magazine has emptied or until the shooter takes his finger off the trigger.

When first contacted by the principals of the Akins Group, Inc. regarding this project a few years ago, while the mechanism description made perfect sense, it definitely sounded a little “too good to be true.” Over the last few decades we have seen several gimmicks and gadgets that were “guaranteed” to create a legal and inexpensive alternative to transferable machine guns and very few have delivered as promised.

About a year ago this writer was asked to participate in a group of BETA testers who would utilize and push the mechanical limits of this new Akins Accelerator learning whatever we could about it and its abilities. This testing would take place while mass quantities were being produced for a future, public release. The testers were given specific instructions not to publicly display the device but were given the option of sharing its existence with close members of their individual firearms community. There have been over 100 BETA test units in all corners of the United States for over a year. The collective test results have been shared within this group, and this knowledge has been utilized to create an even more reliable design. Such a wide test, in regard to environment, ammo, and accessories has helped the Akins Group to fine tune the Accelerator far before making a public release. Much to the pleasure of everyone who has been privy to this testing, the release time is now and units are already being delivered.

Unlike almost all other devices designed to give the shooter a simulated full automatic fire effect, the Akins Accelerator is held and utilized in exactly the same fashion as a traditional rifle or stock. During fire, the stock remains solidly in the grasp of the shooter with a tight cheek weld, and solid grip on the pistol grip and forend. This allows for unprecedented accuracy and control. The only movement is happening inside the stock and it is so smooth and fluid-like, the shooter is almost unaware of it happening at all.

Something else that makes the Akins Accelerator unique is the ability to fire a single shot when desired just by squeezing the trigger in a conventional manner. During our testing it was easy to shoot a single burst of 10-15 rounds, engage a different target and shoot a few rounds in semi, and then empty the remainder of the magazine in a single burst.

How exactly does it work?

As already briefly explained, the rifle actually recoils inside the stock. It is attached to a device called a Linear Motion Assembly. This device takes the place of the standard V-block barrel retainer supplied with the 10/22 and is firmly attached to the receiver, solidly holding the barrel in place like the factory V-block. The Linear Motion Assembly is then secured into the stock. Once fastened into the stock, the top of the device along with the rifle and barrel are allowed to move rearward and return forward again while the bottom of the Linear Motion Assembly is fastened tightly to the stock.

When correctly adjusted and assembled, the firing sequence works in the following manner. The firearm is loaded and charged in a typical fashion and the safety still works in the normal manner as well. When the shooter wishes to fire several rounds in a single burst, the trigger finger of the shooter is “bridged” over the trigger, touching both sides of the stock. As the trigger is depressed, the finger remains static. The recoil of the rifle causes the whole barreled action to move slightly rearward with the assistance of the Linear Motion Assembly. There is a return spring in the Linear Motion Assembly that brings the barreled action to its forward position after the recoil stroke is completed. As the rifle returns to its beginning position, the trigger finger of the shooter now acting as a “bridge” across the trigger area of the stock, comes back into contact with the trigger, starting the process over again. A properly assembled and well-fed 10/22 will continue to function in this way until the magazine is empty. If the shooter wishes to stop shooting the finger is simply removed like any traditional firearm. If the shooter wishes to fire single shots instead of bursts, regular pressure is applied to the trigger instead of using the “bridge” type hold described above. The gun may be used with either the left or right hand.

Why is this NOT considered a machine gun?

Simply enough, it does not meet the definition of a machine gun as defined in the National Firearm Act (NFA), 26 U.S.C. Chapter 53. Machine gun: “The term “machine gun” means any weapon designed to shoot, or can be readily restored to shoot, automatically more than one shot, without manual reloading, by a single function of the trigger. The term shall also include the frame or receiver of any such weapon, any part designed and intended solely and exclusively, or combination of parts designed and intended, for use in converting a weapon into a machine gun and any combination of parts from which a machine gun can be assembled if such parts are in the possession or under the control of a person.”

During the exchange of letters between the Firearms Technology Branch of ATF and the Akins Group, Inc., ATF said, “…As noted previously, the proposed theory of operation of this stock involves the application of the movement of the counter recoiling device to initiate a rapid succession of semiautomatic fire. Our examination and subsequent classification revealed that the stock did not constitute a “machine gun” as that term is defined in the National Firearms Act (NFA), 26 U.S.C. Chapter 53…”

Not only are the Akins Accelerator stock and assembly not considered a machine gun, they are not even classified as a firearm. This is only an accessory, needing a legal, semiautomatic host firearm to even function. The semiautomatic firearm (in this case the 10/22) added to the stock assembly still only has the ability to discharge one shot per function of the trigger as required by law. The rapid succession in which these shots are fired has no bearing on the legality of the system as noted in the above letter from the Firearms Technology. This is the same logic used in rulings for decades on the numerous hand cranks and similar rapid-fire devices offered on the market today and in the past.

Assembling your Akins Accelerator

When you receive your new stock assembly it will come with an owner’s manual, a few pins and clips, and a special Bondhus Ball End Wrench for removal of and replacement of the barrel retaining screws. Read the manual from front to rear and everything will immediately become crystal clear. It is a simple task to mount correctly but it must be done exactly as directed to function as well as it has the ability to do.

The factory trigger and magazine catch pins must be replaced with new provided pins before firing. The factory pins have a tendency to “walk-out” and these new retaining spring pins will stay firm.

The factory barrel retaining V-block must be removed and replaced with the new Linear Motion Device. Before removing or loosening this V-block it is wise to use a felt pen to mark the position of the barrel in relation to the receiver. This way during reassembly it will be in exactly the same position and the chance of malfunction from contact with the ejector will be drastically reduced.

After the V-block has been completely removed, the Linear Motion assembly will be installed in its place using the factory screws. This is most easily accomplished with the assistance of the ball end of the provided wrench. Making sure the barrel is lined up with the receiver with your previous markings, the Linear Motion Assembly can be tightened up. When doing this, only tighten each screw a little then alternate to the other one for a few turns. The necessity to line up the operating rods so they are completely parallel with the barrel is of extreme importance. Over-tightening one side may cause the rods to lean to one side. By slowly tightening them in an alternating manner getting them parallel with the barrel should be no problem.

After the device is tightened to the barrel block it is time to install the assembly to the stock. Care must be made when positioning the system into the stock so that the trigger mechanism is not too far forward. Upon firing, it has to break clean and allow the receiver to move rearward of the placement of the shooters finger. It should be positioned very close to the rearward most area. A little adjusting of this placement may be all the “fine tuning” necessary once everything is assembled and it is time to hit the range.

The whole trick to this running dependably is realizing that there is very little residual energy left from the recoil stage in this little Rimfire and anything allowed to rub anywhere will further rob that much needed power. This includes a good cleaning of the entire rifle mechanism not withstanding the trigger group and chamber area. If the rifle is dragging on the stock in any area it must be adjusted so it can float freely to ensure the fullest potential available.

Range Test Time

Range test time has been the greater portion of a year. This is a long time to work with something compared to most gun testing. We were fortunate in assembling a gun that ran well from the very beginning. It has been noticed that a small “break-in” period may be necessary to loosen up tight tolerances caused by factory finishing when using new firearms. A well-used rifle was chosen, being completely disassembled and given a thorough cleaning and lube prior to being assembled in the new unit. The guide rods of the Linear Motion Assembly were lined up correctly and it fit well in the stock. The factory 10-round magazines just whistled through it so immediately went on to 30-rounders and even a 50-round teardrop drum. All worked flawless.

An early concern was the number of accessories that could be added to the system and still work reliably. We ended up using a 12-inch barrel with an AWC MKII Silencer for the majority of the testing and the rifle was topped with a PRO-MAG scope mount and ADCO Mirage electronic sight. Nothing caused any type of regular malfunction and every combination of ammo, magazine and accessory worked just fine. Our test model ate everything it was fed.

The correct function testing procedure recommends factory 10-round magazines with CCI Mini-Mag solid point ammo to lessen the variables. After running reliably with that combination it is recommended to upgrade or change only one thing at a time to keep a firm grip on potential problems. In dealing with Rimfire guns, some guns are finicky with specific types of ammo while others only like specific magazines and this configuration will not be any different.

During our numerous trips to the range it was easy to complete 30-round and 50-round magazine dumps regularly. Keeping the gun clean was the key. Other than the excellent functionality of this system, the controllability was really what set it apart from other systems we have tried in the past. It is very easy to keep an entire magazine of ammo on a small target from 50 feet away due to the lack of felt recoil and muzzle rise.

We used a mixed bag of almost every type of .22LR ammo readily available with most functioning fine. We extensively fired the 550-round Federal bulk pack ammo and the Remington Golden Bullet bonus pack ammo, both retailing under $9. We also used lots of CCI Blazer. Testing has shown that the use of CCI Mini-Mag Solid Point ammo is one of the most dependable. We recorded rates of fire from the 650rpm range to almost 900rpm depending on ammunition used.

This device has brought smiles to the Class III enthusiasts I have allowed to view and handle it. It is not the amazing firepower or the availability of reliable and inexpensive ammunition. It isn’t even the number of available accessories like high capacity magazines and sound suppressors it seems to work fine with. The real allure seems to be the technological aspect that just keeps people grinning from ear to ear.

People quickly grasp the concept and then balk when they inquire about the price. A demonstration is necessary to really grasp how well this system works. A 30-round or 50-round mag dump is usually sufficient to solicit a, “Hey, let me look at that. That’s really just a semi? I gotta get me one of these!” Words alone, even sprinkled with a few photos just don’t convey how well this actually runs. For that purpose, Akins Group, Inc. has set up a little space in the web to share thoughts, ideas, photos and videos and you are welcome to participate. You can find them at www.firefaster.com. You will be very impressed with what you see and hear there.

The Akins Accelerator is currently offered in three configurations. The Full Stock retails for $975, the Folding Stock retails for $1,125 and the Pocket Folding Stock retailing for $1,185.

Akins Group, Inc Dept. SAR P.O. Box 430 Cornelius, OR 97113 (503)359-1359 www.firefaster.com