DEPARTMENT OF THE TREASURY
                Bureau of Alcohol, Tobacco and Firearms
                         Washington, DC 20226

                              MAY 11 1998

                                                F:SD:FTB:CHB
                                                3311



Dear Mr :

This refers to your letter of April 13, 1998, in which you ask
about modifications to certain semiautomatic rifles.

Title 18, United States Code (U.S.C.) section 922(r) prohibits
assembly of certain semiautomatic rifles from imported parts. 
The implementing regulation in Title 27, Code of Federal
Regulations, part 178, section 178.39, provides that no person
shall assemble a semiautomatic rifle using more than 10 of
imported parts listed in paragraph(c) of this section if the
assembled firearm is prohibited from importation under section
925(d)(3) as not being particularly suitable for or readily
adaptable to sporting purposes.

Certain firearms including the MAK 90 semiautomatic rifle were
prohibited from importation, on April 6, 1998, and they cannot
now be assembled from imported parts as provided in the cited
sections.  Such firearms which were imported or assembled prior
to April 6, 1998, in compliance with the cited section may still
lawfully be possessed.

Adding a pistol grip and buttstock to a MAK 90 rifle using more
than 10 imported parts would still constitute assembly of a
semiautomatic rifle subject to the provisions of 18 U.S.C.
section 922(r) and 27 CFR section 178.39.

Adding a thumbhole stock to an AK style semiautomatic rifle using
more than 10 imported parts would now also constitute assembly of
a semiautomatic rifle subject to the cited sections.

A MAK 90 style rifle having a thumbhole style stock with a pistol
grip, but none of the other features listed in the definition of
a semiautomatic assault weapon in 18 U.S.C. section
921(a)(30)(B), would not meet the definition of a semiautomatic
assault weapon.  The "grandfather" exemption in 18 U.S.C. section
922(v)(2) applies only to a semiautomatic assault weapon which
was lawfully possessed on the date of enactment of the statute. 
A rifle which did not meet the definition of a semiautomatic on
September 13, 1994, does not qualify for this exemption.  A
firearm which became a semiautomatic assault weapon after
September 13, 1994, is subject to the prohibition in section
922(v).

We trust that the foregoing has been responsive to your inquiry. 
If you have further questions concerning this matter, please
contact us.

                           Sincerely yours,


                         Curtis H.A. Bartlett
               Acting Chief, Firearms Technology Branch