DEPARTMENT OF THE TREASURY
                BUREAU OF ALCOHOL, TOBACCO AND FIREARMS
                         WASHINGTON, DC 20226

                              MAY 3 1999

                                                           903050:RDC
                                                           3311

Dear :

This refers to your letter of April 5, 1999, in which you once
again inquire about the legality of possessing replacement parts
for your registered M-16 machinegun while also possessing an AR-15
type semiautomatic rifle.

In our previous correspondence we stated that an individual, who
possesses a registered M-16 machinegun, certain AR-15 type
automatic rifles and M-16 type fire control components may have a
combination of parts from which an additional and unregistered
machinegun can be assembled.  We therefore strongly advise against
the stockpiling of additional M-16 fire control components.  You
may, on a one for exchange basis, replace M-16 fire control
components when necessary.  This would avoid the possibility of
possessing an unregistered machinegun.  Unless or until an actual
need arises for you to replace an M-16 part, we strongly advise
once again that you resist the urge to maintain an inventory of M-
16 parts.  However, possession of replacements parts for your
registered machinegun and AR-15 Sporter type semiautomatic rifle
designed not to accept standard M-16 fire control components would
not place you in jeopardy of possessing an additional, and
unregistered, machinegun.

                                 - 2 -

Mr. 

We trust the foregoing has been responsive to your inquiry.  If we
may be of further assistance, please contact us.



                           Sincerely yours,

                               [signed]
                          Edward M. Owen, Jr.
                   Chief, Firearms Technology Branch