BRMCII

"......your opinion concerning rewats is the exact opposite of what has occurred on my end. I have done many and never marked or added anything to the gun or paperwork." Only Form 1 applicants and FL07/SOTIIs are required to mark reactivations assuming the proper ATF/NFA transfer or application protocols were followed. Marking a reactivation by a Form 1 individual "maker" or an FFL07/SOTII is not my opinion but is an NFA regulation. Again, a Form 1 reactivation is a "making" under ATF/NFA rules and a "making" is a form of manufacturing under ATF/NFA definitions.. A "manufactured" firearm requires being marked with the "makers" ID and address. This is not rocket science and is the law under ATF/NFA regulations. The Form 1 applicant has legally applied to be the "maker" so must apply his ID and address to the receiver of the firearm. He does not have to to do the work himself, but he must mark it with his ID, and the person who actually does the work is not in the picture. The paperwork info remains exactly it appears in the NFRTR on the original registration and does not change for the reactivation. I have never said anything other than the above. There are a number of reasons why ATF might not make an issue of the reactivations that you did and that you "never marked" and here are some of them. You claim that your 'experience" is the opposite of my "opinion" on rewats but you do not explain any of the context of the reactivations to support your claim. You just claim that I am wrong despite the fact that I have never posted any comment other than the current regs for reactivations with specific responses to individual situations. The reasons for your "experience" could easily be as follows. You do not reveal the status of your licensing, if any, or the transfer status of the MGs that you reactivated so your experience has no context by which to understand your position. Many DEWATs have transferred on tax paid Form 4s rather than by the correct use of a tax exempt Form 5 and have been reactivated by regular FFL01 gunsmiths, by their owners or by others. I've repaired a lot of these for the owners whose reactivations were poorly done. These reactivations do not require marking with ID and address simply because they have transferred as "live" MGs and were not processed according to the correct ATF protocols for registered DEWATs. There is neither a record of a form 1 application or an 07/02 From 2 reactivation in the NFRTR for these MGs because neither of these processes were used for reactivation. The proper transfer of a registered DEWAT is tax exempt Form 5. Only DEWATs reactivated under Form 1 approval or by FFL07/SOTIIs who received them on tax exempt Form 5s are required to mark the guns. No one else is. You do not explain the transfer status of the guns that you reactivated so without that context info there is no way to know if you were required to mark the guns or not. Were you an FF07/SOTII at the time and did you receive the guns on Form 5s? If so you were required to file form 2s and mark the guns. Were you an FFL01 or 07/II and the registered DEWATs were currently on Form 4s when you received them under your license and did the work? If so you were under no legal requirement to mark the MGs since they were already live. If you did not have an FFL01 or an 07/II and were possession of a registered MG not registered to you, was the registrant in your shop while you did the work and be there at any time during which you had possession of the MG. If this was the context then you did not have to mark the guns. Did the owners of the DEWATs have approved form 1 applications and have you do the work? If so, you had no legal obligation to mark the guns. The above notes some contexts for the reactivation of registered DEWATs for which you must mark the gun and a couple where you do not have to. That you personally had experiences with ATF that appear to be at odds with the experiences of others does not invalidate the rules and I will give you the benefit of the doubt that you did know the rules. I have done about 150 reactivations, more or less, of all sorts of MGs with a wide variety of transfer status, but almost all under an FFL07/SOTII. Before being licensed, and I've had various FFLs since 1977, I reactivated quite a few registered DEWATs that transferred to me by taxed Form 4s so no marking requirement. MGs reactivated while registered by Form 4 do not have the correct paper trail for a reactivation. In my opinion ATF has no issue with that since they have some flexibility if an MG has been in the system for a long time and has multiple transfers giving it legitimacy. FWIW

1 - C+R MG08/15; 7.92mm; very good plus condition; some small dent sin fusee cover; 90% original finish; non-matching numbers; excellent runner with either inverted MG34/42 belts or canvas belts; all correct parts; correct vintage bipod; very good plus bore; includes one vintage canvas belt in very good condition $11.5k/offers Brokered MG from savvy NFA owner; out on taxed F4; buyer pays all taxes and SH&I charges on approval for transfer E-mail for pictures; have many: bmg17a1@gmail.com 2- MP40; 9mm; Wilson tube; Exc. condition; some mis-match;4 mags $15.5K/offers Brokered MG from savvy NFA owner; out on taxed F4; buyer pays all taxes and SH&I charges on approval for transfer E-mail for pictures; have many: bmg17a1@gmail.com

Not sure what I said that required invoking my name so please elaborate and tell me what I have said about C+R MGs with which you disagree. "I RESPECT BUBBA ALL THE WAY BUT WE DO NOT AGREE ON HIS VIEWS CONCERNING C+R'S AT ALL!" Just an aside, the use of all these CAPs doesn't make your comments more accurate or improve the content. No reason to SHOUT. It makes it difficult to take your comments seriously. By the way the C+R eligibility of an MG by being 50 years old or more from date of manufacture started already on Dec. 2, 2018. MGs remanufactured or newly made receivers between that date and today are now eligible for C+R status as being 50 years old. Not 2036. Very few were reman'ed so early but no doubt there are some and more and more will be added every year. By the end of 2036 all MGs remanufactured or newly manufactured will be C+R eligible since May 19, 1986 was the date that the last form 2 for a newly or remanufactured MG could be submitted for registration. A "reactivation" by an individual on form 1 does not need to be done by the applicant, but the applicant still must mark the gun with his name and address as the "maker" of the gun. A Form 1 reactivation is "making" and "making" is regarded as "manufacturing" under ATF's rules and thus REQUIRES the maker identified on the approved Form 1 to mark the MG with his name and address. An FFL07/SOTII who reactivates a registered DEWAT received on a Form 5 is also "manufacturing" when doing a reactivation under his license, and files a form 2 indicating "reactivation" and then is REQUIRED to mark the receiver with his name and address as the "manufacturer". A gunsmith or an 07/II can do the work as a "repair" and don"t have to mark the gun since they are not legally doing the reactivation. I don"t think anyone is really confused over this. I had several go arounds with ATF over 20 years ago trying to get them to eliminate the requirement to mark reactivations by individuals and by 07s but their lawyers insisted it was important for that regulation to remain. I don't believe the marking requirement has changed and have no information that it has. Too bad as it is defacing the gun. "one small but important "loophole" exists that ATF accepts concerns SOME not all, GERMAN MG-08's and RUSSIAN 1910 WW II GUNS only. during WW II BOTH sides used complete and partial guns to complete a running weapon in their caliber. if in the registry b-4 JUNE 1970 without modern SOT info they are legit C+R's." Explain the "before June 1970" date please. Submission for '68 amnesty registration had to be dated prior to Dec.2, 1968 for proper Form 4467 registration. However, the approval could be date long past the date of the end of the Amnesty but submission had to be within the dates of the prescribed Amnesty period. A complete, live receiver registered prior to the end of the Amnesty is regarded as a C+R regardless of the internals and caliber. There is no requirement that the internals of an MG be factory or matching or a specific caliber for C+R eligibility. If I am remiss in this understanding, point out the regulation, please. I've had a fair number of events with ATF concerning vintage MGs for which ATF no longer has a copy of the original registration to confirm registration prior to the end of the '68 Amnesty and thus C+R eligibility for transfer. In all cases ATF accepted that the MGs in question could be transferred as C+R because they had been in the system for many years and had been transferred many times. This is a forgone conclusion simply because the NFRTR is about 50% accurate, a figure actually authenticated by ATF in an agency meeting years ago, and also actually in the public record of a prosecution quite a few years ago, and ATF really does't want to be taken to court on such a minor paperwork issue and have to defend the accuracy of the registry. Plus it's only fair. Here's the rub concerning C+R transfer status of any MG whether an MG with a different model side plate than listed in the form 4, or an incomplete receiver, etc, etc. Using side plates from C+R eligible MGs to build a different model but same family MG: the examiners never see the guns, are not trained and have no means of assessing that the gun is no longer the gun identified on the paper work since the paperwork info remains the same after the conversion has been completed. The transfer application paperwork for the MG08 that has been changed into a 1910 Maxim still appears to the examiners as a C+R MG08 due to the date/form of original registration as listed in the registry and will be approved to an FFL03 applicant despite no longer having C+R status. Same for empty receivers of C+R MGs, most commonly MG08s, but also there have been Diggers, BMGs of various sorts, Vickers, Japan T92s and LMGs, quite a variety of other types of MGs. It may not proper, correct or "legal" but the system under which transfers take place does not filter for these transfers. I have built many, many side plate 1910s using C+R MG08 side plates to increase the number of available transferable 1910s in the NFRTR and have often been asked by the owners if they can appeal to have the ID changed on their paperwork to "1910 Russian Maxim" so that it reflects the actual hardware. No, they can't for a variety of reasons. Point of information: there are only about 10 verified C+R 1905 and 1910 Russian Maxims in the registry. I had two C+R 1910s for quite a while and know of several correct 1905s, but that is the number of actual C+R eligible Russian Maxims available to collectors.FWIW

Incorrect. If the MP was a registered DEWAT, registered prior to the end of the '68 Amnesty, it has C+R transfer status. As a reactivated DEWAT, noted by the seller, its transfer status does not change due to reactivation, and it remains C+R transferable. Transfer status, determined by date/form of original registration, stays the same for an MG unless: it is provably incorrect as it is archived in the NFRTR and then it can be corrected through appeal to ATF/NFA; the date of it's manufacture is verifiable as 50 or more years ago and then it's transfer status will include C+R. This has started to happen with post-'68 remanufactured MGs which are gradually acquiring C+R eligibility as they age to 50 years from date of manufacture. Eventually all registered MGs will qualify for C+R transfer.

1 -1917a1 DLO registered side plate, ready to install; $12k offers 2-Gwinn "Bushmaster"; marked "S.M.G.; 223: excellent condition w/98% original finish; uses AR mags $9k offers 3-C+R 1919A4; Saginaw Gear; 30-06; reparked and pristine, beautiful; $25k offers 4-Vickers; Registered C+R Colt aircraft complete receiver; receiver needs minor work; jacket and front endcap both disassembled from receiver but both screw on easily and properly; receiver and jacket reblued; internals mix of Brit and Aussie; complete restored tripod; missing front sight, but all other parts are there; $15k or offers 5-Vickers WWII "PETROL" type water/steam condensing cans; variety of 15 from which to choose; various condition and prices; contact me for pics, details 6-Vickers, WWII steam hoses with fittings; excellent and new; red hose w/twist, brass fitting; black hose w/claw fitting; contact for specific pics and details; pic of generic can below Call: 802-226-7204; or e-mail: bmg17a1@gmail.com for pics or further info

1 -1917a1 DLO registered side plate, ready to install; $12k offers 2-Gwinn "Bushmaster"; marked "S.M.G.; 223: excellent condition w/98% original finish; uses AR mags $9k offers 3-C+R 1919A4; Saginaw Gear; 30-06; correct, exc. minus 1945 dated, vintage M2 tripod w/T+E; 99% repark, pristine, beautiful; $25k offers 4-Vickers; Registered Colt aircraft complete receiver; receiver needs minor work; jacket and front endcap both disassembled from receiver but both screw on easily and properly; receiver and jacket reblued; internals mix of Brit and Aussie; complete restored tripod; missing front sight, but all other parts are there; $16k or offers Call: 802-226-7204; or e-mail: bmg17a1@gmail.com for pics or further info Edited 20 Dec 2019 by BRMCII Quote Edit

Here's some real world info concerning wear. Virtually all MP40s were upgraded to a sliding safety on the cocking handle that is used to lock the bolt in forward position for safety. The stud holding the sliding safety is peened on the inside of the bolt to secure it. Over time and use the peening will loosen, and the whole cocking handle loosen, and in many case flys out of the bolt when firing, onetime getting lost.This is repairable and I have repaired a large number of them. Verify the tightness of the handle in there bolt of any gun you consider. Keep in mind that original sliding safety handles are not available any more unless you are lucky to find one. A company in Eastern Europe is reproducing the MP40 parts and may be making the safety handles. Folding stocks will have vertical play when extended, from very minor to very sloppy. Sloppy play is a serious annoyance and detracts from the pleasure of handling and firing the guns. Unfortunately, the design and construction of the hinge and lock are not robust and will loosen up from stress with use over time. Some guns have play but the compression of the assembly of the hinge is such that there is quite a bit of friction and the play is dampened. Handle any prospective MP40 if you have the opportunity. The spring loaded plunger on the bottom of the foreshock that locates and retains the upper tubular receiver in the lower fits into a slot cut into the bottom of the receiver tube. The plunger is retracted, the receiver tube rotated while trigger is pulled to lower the sear from rising through the tube, and the upper receiver removed form the lower. Often the slot in the bottom of the receiver tube has enlarged slightly from rotational force on the upper and many disassemblies of the upper from the lower. This results in the receiver tube having rotational looseness in the lower, another source of annoyance. Repair can be done but is invasive. Recoil springs can be soft and compromised just from use and time, resulting in failure of the bolt to fully recoil to catch on the sear but will recoil enough to pick up the next round and the gun will "tun away", firing until the mag is empty. Probably most shooter Mp40s have had the springs replaced to spec but I still get a couple for repair every year. Replacement barrels are very expensive, both repros and especially vintage. If the barrel on an original, matching gun is damaged and ringed by a squib round, there is no replacement for the matching barrel with subsequent loss of value. Use only ammo on the market that is well known for reliability. Check barrel of any prospective purchase for excellent condition and no rings. Barrel nuts and muzzle nuts will loosen up and the muzzle nuts fall off and possibly get lost if not monitored or tightness. A small dab of lactate can keep them inlace and not bond them too tightly. There are other practices that you will hear about for protecting vintage parts, etc that are not germane to my observations above, but about which you will hear if you should acquire and MP40. FWIW

Pics would be very helpful. I have a live '41 and am always interested in spares for my gun and parts for repairs for a number of customers who own and shoot these guns. If you can, please send pics to: bmg17a1@gmail.com Thanks

.....1918 Vickers in French use. It is the standard louvered jacket and has a brass mounted inscription in French on the rear top of the jacket advising caution that oscillating rods do not hit the jacket. I do not know which system of the many used would require this warning. $800

Will send pics today.

1-1928 COLT marked 7.65 ARG. Kit AA/optic sight brackets; mixed numbers; missing grip panels and rear sight ladder; very good condition; $1500.00, offers 2 -1917a1 DLO registered side plate, ready to install; $12k 3- Reising; .45; C+R; Numrich Military build on commercial numbered receiver; excellent wood; all correct military parts; 99% park; military mag; tested $5000 4-Gwinn "Bushmaster"; marked "S.M.G.; 223: excellent condition w/98% original finish; uses AR mags $9.5k, offers 5-C+R 1919A4; Saginaw Gear; 30-06; reparked and pristine, beautiful; $25k 6-Vickers; registered Colt aircraft complete receiver; receiver needs minor work; jacket and front endcap both disassembled from receiver but both screw on easily and properly; receiver and jacket reblued; internals mix of Brit and Aussie; complete restored tripod; missing front sight, but all other parts are there; $17k or offers 7-1918 BAR; Marlin-Rockwell; .30-06; correct 5/19 dated barrel with excellent bore; superb restoration; gorgeous and 100% perfect appropriate bluing; and wood; all correct 1918 parts; many mags; extra set of excellent carefully refinished wood $32K Call: 802-226-7204; or e-mail: bmg17a1@gmail.com for pics or further info

1 -1917a1 DLO registered side plate, ready to install; $12k offers 2- Reising; .45; C+R; Numrich Military build on commercial numbered receiver; excellent wood; all correct military parts; 99% park; military mag; tested $5000 3-Gwinn "Bushmaster"; marked "S.M.G.; 223: excellent condition w/98% original finish; uses AR mags $9.5k offers 4-C+R 1919A4; Saginaw Gear; 30-06; reparked and pristine, beautiful; $25k offers 5-Vickers; Registered C+R Colt aircraft complete receiver; receiver needs minor work; jacket and front endcap both disassembled from receiver but both screw on easily and properly; receiver and jacket reblued; internals mix of Brit and Aussie; complete restored tripod; missing front sight, but all other parts are there; $17k or offers Call: 802-226-7204; or e-mail: bmg17a1@gmail.com for pics or further info

What you describe above is the standard FFL03 privilege for purchasing Title I firearms that are C+R eligible. I don't believe anyone with an FFL03 is confused about that. Nothing unusual about the procedure of purchase by an FFL03 and I was not addressing that at all. What I was addressing was that you appeared to mix together FFL03 privileges for Title I purchases with Title II purchases in your original comment. There is no "instant possession" with purchase of C+R Title II firearms by an FFL03. Just trying to clarify that.

Some clarification of the following: "........a C+R HOLDER need not file ANY form 5 or seek prior approval to move to another state any C+R MACHINE GUN. of course a C+R holder can be in ANY state and buy from ANYONE , ANY C+R on impulse and take instant possession." Form 5 is not used for this purpose at any time. I think what you meant to refer to is the 5320 notification of ATF of intent to move NFA interstate which is optional for FFL03 licensees. Traveling or moving with NFA interstate can be subject to state laws. A C+R licensee may never take "instant possession" on purchase of any NFA controlled item. By including mention of this privilege for Title I purchase by an FFL03 in the discussion of MGs, Title II, and the use of the FFL03 for Title II, the implication is misleading. All NFA C+R transfers to an FFL03 are completed after taxed F4 application approval (with the exception of use of untaxed F5 transfer of registered C+R DEWAT). An interstate F4 transfer application can be written to go directly to the FFL03 buyer on approval, so the FFL03 licensee can receive the NFA interstate directly from the seller. Personally, I see no need for an FFL/SOT to also have a C+R FFL. Also, a buyer taking possession of any firearm is restricted to the FFL's premises but I don't understand the restriction on the 4473 allowing non-premises transfers of Title I, and approved transfers of Title II, firearms to "qualified shows". Is there a difference between being absent from the premises at a show and absent from the premises at a buyer's home or elsewhere? 4473s are portable and phoning NICs can happen from anywhere. What am I missing here? Amend as you see fit......

1-1928 COLT marked 7.65 ARG. Kit AA/optic sight brackets; mixed numbers; missing grip panels and rear sight ladder; very good condition; $1500.00 2 -1917a1 DLO registered side plate, ready to install; $12k 3- Reising; .45; C+R; Numrich Military build on commercial numbered receiver; excellent wood; all correct military parts; 99% park; military mag; tested $5000 4-Gwinn "Bushmaster"; marked "S.M.G.; 223: excellent condition w/98% original finish; uses AR mags $9.5k Further info and pics on request: MGs/plates out on taxed F4s from NFA savvy owner; buyer pays tax, SH+I