922r compliance

[mut617]

Alright folks I know someone here has got to have some experience with 922r compliance crap.
Here's the deal.
Im itching pretty bad for a cx4 storm carbine in 9mm and having the barrel threaded for a suppressor.
BUT, since its an imported SPORTING firearm to thread the barrel it has to be 922r compliant. The information I have found lists 20 parts that count toward a total of no more than 10 of these parts to be foreign made.

1.Receiver 11.Triggers
2.Barrel 12.Hammers
3.Barrel extensions 13.Sears
4.Mounting block 14.Disconnectors
5.Muzzle attachments 15.Buttstocks
6.Bolts 16.Pistolgrips
7.Bolt carriers 17.Forearms
8.Operating Rods 18.Mag bodies
9.Gas pistons 19.Mag followers
10.Trigger Housings 20.Mag floorplates

Parts not found on the weapon do not count toward the total. By my count parts #3,5,8,9,and 16 do not count toward my total, leaving 15 foreign made parts. I have found american made parts #11,12,18,19, and 20 just squeaking me by at exactly the limit of 10 parts. Someone please tell me I'm right.

[Diomed]

Oh man, I have seen people go around and around on the CX4. Most don't care. There's a pic floating around with the Governor of Texas holding his personal suppressed CX4, I highly doubt he's 922(r) compliant (I think the pic was taken before the US-made replacements were available). I've only seen one letter from ATF on the CX4, and they dodged the question of which of the twenty regulated parts are applicable to the gun. So you're on your own a bit.

One thing to keep in mind is that with a silencer, you will have a muzzle device. It will, of course, be American made.

Some may try to tell you that if you SBR it, you won't have to worry about 922(r) compliance. They are wrong.

My advice, worth what you paid for it, is to add the US-made parts and thread. If the feds are so far up your nethers that 922(r) compliance is an issue, you're already far down the road to prison.

[mut617]

Thanks diomed, good man. I've no feds picking through my garbage yet I just like to keep my ducks in a row. I guess since you didn't mention it you don't see any problem with my part count. If I can get a gunsmiths opinion on my part count that should make me bulletproof-ish.

[Diomed]

I guess since you didn't mention it you don't see any problem with my part count.

I don't, but I'm not intimately familiar with the CX4 so I'm hardly qualified to opinionate. You can ask FTB to render a written opinion, but that'll take anywhere from three months to two years, or never if they don't want to answer for some reason.

The problem with getting a gunsmith to give an opinion is that what ATF calls a given part is not necessarily what a gunsmith (or other firearms-knowledgable person) would call the same part.

[jdonovan]

Someone please tell me I'm right.

The only opinion that matters about 'right' is the FTB in WV.

You seem close on the parts that are are-not in the CX4, but ATF often issues some interesting rulings.

Like the cocking handle on a H&K is an operating rod. ???? but its their sand box, and they interpret the rules congress makes.

I would be very leery of guessing on a part and be one part to the bad if you get caught. If you are going to error make sure you are several parts to the good so that in case a judgment goes the other way you have a a few more US parts than you need.

Also the ATF is clear that 922 DOES apply to SBR's so don't go down the path of making an SBR out of it to be able to be exempt from 922.

#5 would be present as a suppressor if you were to attach one, but in stock trim #5 would not be present, but it is a US part, so thats a non-issue.

If I was wearing the ATF hat, I would say 15,16,17 are all present as a single molded part. And if that was the case, then you would be one short of the 10 parts.

I'm not a lawyer, I've never worked for the ATF, and I didn't stay at a Holiday Inn Express... these are just my opinions.

[mut617]

Good information all around as usual from vgof. Guess I'm just using this thread as a way to settle my itchy buyin finger. I suppose what I should do is save my pennies and get myself a good AR-9mm... eventually. By then I might not even want one anymore. Seems like a lot of $$ for what is really just a "fun" gun.