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BATFE open letter scrutinizes post sample demo machine guns


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Here we go, BATFE scrutinizing Post-86 transfers. I see the next move BATFE will try to recall post samples from dealers as they no longer need them as "demo's."
Key points indicating additional scrutiny:
 
Indication of how the particular machine gun model requested is suitable for use by the government entity. A law letter that requests the demonstration of a machine gun that is no longer in production will be further scrutinized to ensure they are intended for government demonstration. The supporting documentation must provide information as to the availability of the machinegun to fill subsequent orders. A law letter that requests the demonstration of a machine gun that is generally recognized as being primarily suitable for the military will require further justification explaining how the machine gun is suitable for the requesting government entity.
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Well it’s been coming for awhile now. I’m shocked it’s taken this long. People have been playing fast and loose with the Post Sample regs are now going to screw the rest of us. Too many times now we are seeing “buddies” signing law letters for guns that a PD would NEVER use and they are just toys for the SOT or said “buddy” 

 

I’m waiting for the “no law letter” guns to fall under scrutiny next, or or post samples machine guns getting denied as they aren’t something that would need to be demo’d for LE or Gov’t use. 
 

People taking advantage/playing of the system is gonna screw everyone over in the end…

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1 hour ago, Schmeisser Guy said:

I know of one dealer in my area that has many post samples and always wondered how he could have Stens, Berettas, etc. As post samples when LE doesn't even use these guns. I'm sure he has a "good buddy" in LE. Glad it is coming to an end.

I would get you saying it wasn’t unexpected, but why would you be glad this is coming to an end…?

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Would the ATF accept other reasons on a law letter, rather than pre-purchase demonstration?

For example. Could a chief LEO write a letter requesting demonstration of machine guns that they might expect to see used by dirtbags?  Of course this would include MGs that would never be used by a LEO on duty..  Like stuff made from available parts sets?  And maybe a crappy 3d printed glock switch?

Edited by HHollow
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That is a fair argument-weapons familiarization. I would agree to that but the problem is-how often is that happening? I haven’t heard of LEO’s running into a STEN, PPSH-41, or M2HB that often. Now granted it all depends on what region you are talking about too. 
 

I’m cleaning my books up of post samples that I built just to see if I could do it. When it’s all said and done I’ll have my post sample HK trigger packs I use for demo work and testing. I have 5 of them as I have them setup for different calibers or can setup multiple guns of the same caliber for showing various options without swapping them around. That being said-I also have a transferable Fleming sear as well, so I’m not just an SOT to play with cheap packs. The only other post sample I’ll have when I get done with the simplification process is my post sample Swedish K….that one I’ll admit, it’s a play toy for me. But I also have a real one sitting in the safe. The postie is for beating on until the post SOT days and then it won’t matter. 

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6 hours ago, HHollow said:

Would the ATF accept other reasons on a law letter, rather than pre-purchase demonstration?

For example. Could a chief LEO write a letter requesting demonstration of machine guns that they might expect to see used by dirtbags?  Of course this would include MGs that would never be used by a LEO on duty..  Like stuff made from available parts sets?  And maybe a crappy 3d printed glock switch?

No they would not.  The only acceptable reason is for pre-purchase demonstration.

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9 hours ago, duza9999 said:

I would get you saying it wasn’t unexpected, but why would you be glad this is coming to an end…?

Because I think many SOTs use post samples to enhance their collections and not for the intended purpose. I say let them buy transferables like everyone else. ATF might start going after some SOTs for enhancing their collections. It would not surprise me at all.

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I assume this would put upward pricing pressure on both no-law letter eligible transfer post samples as well as to some extent transferables as the 01/03 route to easy access post samples is drying up.  Granted it sounds like this is just a formal letter to reinforce what the BATFE has been doing anyway over the past couple years.

That said if or when the BATFE either puts forth a formal proposed rule making for modification to 27 CFR 479.105(F) to clearly require demo letters for all transfers and/or just an takes on an internal "reinterpretation" of the existing regulation to "highly scrutinize" (and deny) transfers under the discontinue of business provision part (F) regulation exception to 922(o) it may result in significant negative pressure to the value of post-samples and at the same time cause transferables to sky-rocket in price.

Personally as a transferable only collector I hope they don't mess with the SOT post sample manufacturing and/or no-law letter transfers as in my opinion all of these folks who get FFL/SOTs to for reasons other than facilitating legitimate government sales (rentals, collections, etc.) help to keep the pricing of transferable machineguns down.

I would prefer to not have to compete in the transferable marketplace against folks who see transferable as cash-flow/income stream for rentals or have the current post-sample only machinegun collector group crowd into the limited transferable marketplace in the event the spigot for post samples is effectively turned off.  i.e. what is a transferable HK sear worth to somebody like Battlefield Vegas who can sell tens or even hundreds of thousands of dollars worth of rentals against that sear every year if post samples were effectively taken away from all of the hobbiest/rental/training SOTs  and only companies like Colt or FN whose primary MG business is support .gov sales are allowed to continue on making post samples uninhibited.

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I don't believe they would attempt to change the no law letter rule.... Guys have to give up the guns some how...... I do however believe they may apply more scrutiny to the FFL's out there who are building up an inventory of post sample MGs and then drop their license to cash in and immediately get another FFL... Often times repeating this process multiple times.... It may become more difficult for those individuals to get another FFL. Or the ATF will require a more detailed explanation of why they dropped one FFL and applied for another......

Of course this is just speculation.... We shall see..

Aaron

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Aaron hit the nail on the head for what’s going on with FFL/SOT’s playing the “no law letter” game. 
 

I don’t disagree that there are several SOT’s who are only SOT’s to have the “cheap machine guns” and I don’t agree with that. I’m going to demil or sell off most of what I have as they were more of a challenge to see if I could do them, not because I wanted to own and play with them. The post samples I use are for actual gun demo and testing purposes. But then again that’s just me….I have transferable guns as well as pre and post samples too. 

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Honestly good. Maybe guys with ffl/sot’s will get more involved in politics most of them have a crappy attitude regarding freedom. Give them a little more motivation to promote freedom… an less opportunity for them to bribe local police for letter’s lol.

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13 hours ago, shiklg said:

No they would not.  The only acceptable reason is for pre-purchase demonstration.

Please educate me.

How do gun rental joints  have post samples?

Private security?

What if someone formed a company to develop firearms technology and had a scientific reason to acquire a postie or two?

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9 hours ago, jbntex said:

I assume this would put upward pricing pressure on both no-law letter eligible transfer post samples as well as to some extent transferables as the 01/03 route to easy access post samples is drying up.  Granted it sounds like this is just a formal letter to reinforce what the BATFE has been doing anyway over the past couple years.

That said if or when the BATFE either puts forth a formal proposed rule making for modification to 27 CFR 479.105(F) to clearly require demo letters for all transfers and/or just an takes on an internal "reinterpretation" of the existing regulation to "highly scrutinize" (and deny) transfers under the discontinue of business provision part (F) regulation exception to 922(o) it may result in significant negative pressure to the value of post-samples and at the same time cause transferables to sky-rocket in price.

Personally as a transferable only collector I hope they don't mess with the SOT post sample manufacturing and/or no-law letter transfers as in my opinion all of these folks who get FFL/SOTs to for reasons other than facilitating legitimate government sales (rentals, collections, etc.) help to keep the pricing of transferable machineguns down.

I would prefer to not have to compete in the transferable marketplace against folks who see transferable as cash-flow/income stream for rentals or have the current post-sample only machinegun collector group crowd into the limited transferable marketplace in the event the spigot for post samples is effectively turned off.  i.e. what is a transferable HK sear worth to somebody like Battlefield Vegas who can sell tens or even hundreds of thousands of dollars worth of rentals against that sear every year if post samples were effectively taken away from all of the hobbiest/rental/training SOTs  and only companies like Colt or FN whose primary MG business is support .gov sales are allowed to continue on making post samples uninhibited.

I'm a transferable collector like you too but I think it won't make much difference if SOTs have to buy transferables because "investors" have already entered the market years ago and have already pushed prices past stone cold retarded. A few more SOTs won't make one bit of difference. That ship sailed years ago.

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11 hours ago, HHollow said:

Please educate me.

How do gun rental joints  have post samples?

Private security?

What if someone formed a company to develop firearms technology and had a scientific reason to acquire a postie or two?

my statement was in regards to "going forward" in regards to no-letter transfers.  What happened in the past is the past.  Also if the 07/02 owns the range or private security company, then there is no transfer to be approved.

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On 1/12/2023 at 9:49 PM, Schmeisser Guy said:

I know of one dealer in my area that has many post samples and always wondered how he could have Stens, Berettas, etc. As post samples when LE doesn't even use these guns. I'm sure he has a "good buddy" in LE. Glad it is coming to an end.

NFA, 68 GCA, and 922(o) are patently unconstitutional. All this stuff needs to be struck down.

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