Cite as FFL newsletter, Summer Issue 1988, Bureau of Alcohol,
Tobacco and Firearms, page 2, Washington, D.C.

REGISTERED MACHINEGUN CONVERSION KITS

Prior to the effective date of Public Law 99-308, thousands of
machineguns were registered by manufacturers on Forms 2 in
anticipation of the pending legislation.  A this time, approximately
16,000 of these registrations have been identified as combinations
of parts to convert semiautomatic rifles into machineguns, rather
than machinegun receivers.

Several months ago, our National Firearms Act Branch became aware
that many of the conversion kits that had been registered were not
capable of converting a rifle without the receiver being modified
by drilling and/or milling operations.  Modifying a semiautomatic
receiver in this manner constitutes manufacturing a machinegun
receiver, and such manufacture is prohibited as of May 19, 1986
(except for government use or export).  It was evident that what
some manufacturers had registered as conversion kits, were in fact,
just parts, not machineguns, and therefore not subject to
registration.

To determine which registrations should be accepted as machineguns,
teams made up of an ATF inspector, special agent and firearms
specialist, visited most of the Class II manufacturers to determine
whether the items reported as manufactured should be registered.

The NFA Branch is now in the process of writing to the registrants
advising them of which items can remain registered and which will
be removed from registration.

Since a number of the parts kits have already been installed in
rifles by modifying the receiver, and are now possessed by
individuals as well as manufacturers or Class III dealers, a
determination must be made as to the status of these registrations. 
We realize that some persons acquired these firearms in good faith
and there may be circumstances where we will continue these
registrations.  The NFA Branch will review each of these
registrations after the registrant has submitted a signed statement
providing the details surrounding the acquisition of the firearms. 
A final decision will be made on a case-by-case basis.

Please direct your questions to the NFA Branch; 202/566-7371 or the
Firearms Technology Branch: 202/566-7131.