Please note that I am not an attorney and this does not constitute legal advice.
The topic of 922r compliance and parts counts came up the other day as whether it applies to Short Barreled Rifles (SBR). In reading the conflicting ATF documentation, the last guidance given in technical branch letters from 2009 and 2010, the ATF does say it applies. I put it this was as you should look at the trend over time which does seem to point towards 922r being applicable.
I am a very conservative guy and always try to stay on the safe side of legal issues so I would recommend ensuring your SBR is compliant with the 922r parts count requirements. If you do this then you do not need to worry about it and I am sure there are folks who would disagree with me.
Here is the 2009 letter:
Here is the three page 2010 letter:
Again, please let me stress that I am not an attorney. If you have any questions on this, I would recommend doing your own research and/or retaining legal counsel.
If you find this post useful, please share the link on Facebook, with your friends, etc. Your support is much appreciated and if you have any feedback, please email me at firstname.lastname@example.org. Please note that for links to other websites, I may be paid via an affiliate program such as Avantlink, Impact, Amazon and eBay.