Question regarding status as a dealer and "informal range transfers"

[sillycon]

For an individual who is an FFL holder (01 or 07) as a sole proprietor:

Were this individual to allow a personally-owned handgun or NFA item to be shot/handled by a person aged 18-20, would they be in violation of any firearms laws regarding the transfer from a dealer to an "underage" individual?

I realize on the surface this seems straight forward (as said FFL would be acting as an individual and not as a dealer) but as we all know, when it comes to firearms laws, appearances can sometimes be deceiving.

In essence, I suppose this comes down to if ones status as a FFL holder (especially as a sole-proprietor) trumps ones status as an individual in the eyes of the law/ATF, or does the "titling" of the firearm to the individual (i.e. completion of a 4473) make all the difference?

[samot]

I was always under the understanding that while the FFL was present letting someone shoot or *demo* a firearm was an acceptable practice.
Is letting someone shoot one off your guns at a range considered a "transfer" ? I hope not

[BWE Firearms]

I have been told by ATF that letting someone use one of my NFA items is not considered a transfer so long as I am at the range. I shoot the Florida Subgun match every month and asked ATF if someone could use one of my subguns and shoot on a different squad. So I would be on one bay and they would be on another bay. ATF told me as long as I did not leave the clubs property it would not be a problem.

I do let the kids shoot the 22 LR full autos at the range if they want and there parents say its OK. There is nothing better then the smile on a kids face when they get to shoot a full auto.

[wlake75]

We operate a range where we rent firearms, including NFA items. The ATF has consistently told us that to rent a firearm to any individual that remains on the premises is NOT considered a transfer, only a loan. They cannot remove it from the premises without a legal transfer. If you and the individual were on a range not owned by you, both the NFA item and the owner would have to remain on premises. BTW, since a transfer is not occurring, age is not a limiting factor legally.

[ExecDirector]

This is the *current* mode of thought. With that said, NFA rentals are coming under intense scrutiny by ATF. I would not be surprised to see several flip-flops on currently regulatory implementation.

[sr71]

I keep getting conflicting answers on this: Can you transport a suppressor across state lines without the ATF approval, Form 5320???. Assuming it is legal in the state you are taking to.

[CitizenClark]

I keep getting conflicting answers on this: Can you transport a suppressor across state lines without the ATF approval, Form 5320???. Assuming it is legal in the state you are taking to.

From the NFA handbook (http://www.atf.gov/files/publications/download/p/atf-p-5320-8/atf-p-5320-8.pdf):


Section 13.8. Requesting permission to transport certain firearms in interstate or foreign
commerce. A person, other than an FFL/SOT, may not lawfully transport in interstate or foreign
commerce any destructive device, machinegun, short-barreled shotgun, or short-barreled rifle, without
prior written approval of ATF, specifically the NFA Branch.214 For definitions of these firearms and
devices, refer to 27 CFR 478.11. Licensed collectors are not required to obtain such approval if the
firearms and devices being transported are “curio or relic” firearms under the GCA. Approval for the
transportation may be obtained by (1) a written request or (2) an approved application filed with ATF on
Form 5320.20.

So in other words, the answer to your question is "yes."