I was reading the latest ATF FFL Newsletter and ran across something I found interesting:
an FFL/SOT (Class 2 manufacturer of firearms) who manufactures a silencer part for the sole purpose of repairing a registered silencer 1) is not required to mark the part; 2) is not required to register the part on ATF Form 2; 3) is not required to submit and receive an approved ATF Form 3 to transfer the part to FFL/SOT; and 4) is not required to maintain records of manufacture or other acquisition and records of disposition (A&D) pursuant to 18 U.S.C. § 923(g), 26 U.S.C. § 5843, 27 CFR § 478.123, and 27 CFR § 479.131, provided the part is transferred to an FFL/SOT for the purpose of repairing a registered silencer.
If someone other than an FFL/SOT wants to acquire a silencer part, that part must be marked in accordance with regulations and registered by filing a Form 2. A Form 5 must be filed if the part is being acquired by a government entity. A Form 4 must be filed if the part is being acquired by an unlicensed person or FFL who is not qualified under the NFA.
So… if you don’t tighten the end cap on your suppressor, it works loose, and you spew the end cap and all the baffles all over the lake you can’t purchase new components from the manufacturer and repair it yourself. You local dealer can purchase the parts and repair it for you.
In either case you end up with a new set of serialized components. But in one case you and the manufacturer spend some quality time in Club Fed and are never again allowed to own a firearm. In the other case you go about your business as you see fit.
It’s just a law. It doesn’t have to make sense.