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.
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This is Izzy’s wild SBR based on a C39 Micro with our Orca handguard:
Here are the details from Izzy:
I put a 7 slot magpul one piece rail section, drilled and tapped on the actual [handguard and the] rail is very strong I may add. The micro was something in my head for awhile so when I saw this 6.5 in with a billet receiver I was sold. Not too much was added to make it what it is. My own design charging handle. VZ 58 side folding stock drilled and pinned then use para cord for the extension NRM Defense did the cerakote in Tungsten with all the controls in black SLR muzzle brake Red star adjustable trigger assembly Magpul grip and mags with a Bravo Company vertical fore grip