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For context here’s a quote from my introduction post:

Along with two partners I own a firearm training facility. Last year we made the decision to expand and diversify our business model by entering the retail market to offer products that compliments our service line. This includes the sales of firearms, parts and accessories, and the development of other high performance gear for EDC, urban preparedness, and outdoor survival.

We have downloaded the complete NFA Handbook and researched all ATF rulings and articles. But still, our biggest headache with this endeavor has been trying to construe and understand (unsuccessfully) the innumerable and nebulous laws associated with sales, manufacturing, gunsmithing, workshops, build parties, and all other activities we will be promoting…in hopes that our products and services will bring individuals and families together into our spacious and open well-equipped studio.

Our priority concerns are: 1. protecting the privacy of our clients/customers, 2. operating under strict adherence to all federal and state laws, rules, guidelines, regulations, etc., and 3. staying out of jail.
As stated, we’re a firearms training outfit that is branching into retail by expanding our service line to include an interactive firearms workshop designed to give our customers the opportunity to build, repair, restore and refinish their firearms alongside like-minded gun owners and shooters. The studio will house a row of gunsmithing stations, a sandblasting cabinet, a degreasing/parts washing station, a paint booth, a gun oven and a Tormach PCNC 1100 Personal CNC Mill.

Naturally, out of necessity, a grouping of of all the services related to this endeavor generates another group of related products that must be carried to complete the project, i.e., barrels, stripped upper and lower 100% receivers, 80% lower receivers, LPK’s, butt stock kits, gas blocks, , sights, gunsmithing tools, etc…the retail end of the business. After much debate with the other partners it was also decided that we would retail firearms. But I’m in no hurry to apply for an FFL.

And this is what lead me here. Over the years my partners and I have amassed a considerable personal collection of some 800 firearms (including cases of 100% stripped lowers) and over 80,000 rounds of ammunition. I want to showcase this in the shop but my partners are absolutely against it for fear it will call the ATF’s attention. Their argument is that it’s bad enough we will be retailing 80% lowers with a CNC mill on the premises; that we will be selling complete upper receivers; and that we will be teaching our customers to build complete weapons from scratch - all without an FFL. My argument is that we are doing nothing illegal.

My question, do any of you think it would be a problem to showcase our personal weapons in the store while we are waiting on an FFL?
 

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I'm way out of my depth here but I'm pretty sure that meets the federal definition of an "arsenal" and therefore just might get you some attention that you might rather not have... that and if the public sees all of that you better have some top notch security for when you go home at the end of the day.
 

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Yes, security has been addressed. Is there a federal definition of "arsenal" and are there laws that prohibit individuals from maintaining one? Can't tell if your post is tongue-in-cheek.:redface:
 

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as I said... I'm out of my depth. All I really know about FFL is what it stands for. Somewhere in the cobwebs between my ears I remembering hearing years ago about if an individual had an "arsenal" the federalies wanted you to register it - this was long ago enough that it may well have been during the Brady years and thus not even be relevant anymore. It was based on some number of guns and ammunition. I don't remember the gun count but for whatever reason the ammo count stuck with me. If memory serves it was 10,000 rounds - which I thought markedly low...

More than likely once you're no longer just an individual but a business with a FFL you'll get all the scrutiny you could ever want anyway.
 

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For context here’s a quote from my introduction post:



As stated, we’re a firearms training outfit that is branching into retail by expanding our service line to include an interactive firearms workshop designed to give our customers the opportunity to build, repair, restore and refinish their firearms alongside like-minded gun owners and shooters. The studio will house a row of gunsmithing stations, a sandblasting cabinet, a degreasing/parts washing station, a paint booth, a gun oven and a Tormach PCNC 1100 Personal CNC Mill.

Naturally, out of necessity, a grouping of of all the services related to this endeavor generates another group of related products that must be carried to complete the project, i.e., barrels, stripped upper and lower 100% receivers, 80% lower receivers, LPK’s, butt stock kits, gas blocks, , sights, gunsmithing tools, etc…the retail end of the business. After much debate with the other partners it was also decided that we would retail firearms. But I’m in no hurry to apply for an FFL.

And this is what lead me here. Over the years my partners and I have amassed a considerable personal collection of some 800 firearms (including cases of 100% stripped lowers) and over 80,000 rounds of ammunition. I want to showcase this in the shop but my partners are absolutely against it for fear it will call the ATF’s attention. Their argument is that it’s bad enough we will be retailing 80% lowers with a CNC mill on the premises; that we will be selling complete upper receivers; and that we will be teaching our customers to build complete weapons from scratch - all without an FFL. My argument is that we are doing nothing illegal.

My question, do any of you think it would be a problem to showcase our personal weapons in the store while we are waiting on an FFL?
You are going to need an 07-FFL. An 01-FFL won't cut it for any manufacturing (CNC milling, finishing, assembly). I would recommend you do not display your personal collection at your premises. Is any of it NFA? You will need to at minimum tag all of your personal as NOT FOR SALE. You should think about the additional insurance and securing of your personal collection. Not a good idea IMO. At some point your business premises will be inspected by ATF before your FFL license is approved. If your collection is there and not properly secured, it will at a minimum cause some dialogue you should avoid between you and an ATF examiner.
 

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The proprietor of 5280 Armory here in Denver Metro proudly displays his vast collection of personal firearms (pre-Civil War to modern) inside his store.
 
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You need an ffl to SELL firearms, not display a personal collection. A personal collection would not be subject to handling by anyone but the owner of them IMO. Certainly not something to be passed around to customers across a counter.

Town hall in a past life had numerous originals from the revolutionary and civil wars. They were all behind glass and protected with alarm system, for viewing only through the glass. The town didn't hold an ffl to do so.

Most museums are privately owned, doubt any have ffl to display various gun collections. They aren't selling them.

However, the definitive answer would be to write a letter to your local a t f office for clarification. Then you've got it in writing, one way or the other. If they agree you can, that's going to be the fall back if there's a problem down the road with some field agent.
 

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I am pretty sure guns over 100 years old can be considered antiques and do not need to follow FFL rules. Don't quote me but I remember hearing that somewhere
 

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You don't need a FFL to display the firearms. If customers are building guns at your facility and you get paid for use of the space or tools, you do need a 07 Manufacturing FFL.

Jeff

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You need an FFL to be "engaged in the business" of making or selling firearms. Because they aren't for sale and are decoration only, then you don't need an FFL.
 

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The federal definition of "arsenal" is: 1 High Point, 1 SKS, a Red Ryder BB gun, and 3 or more assorted airsoft toys - as long as they are photographed on the same bunk bed, ideally next to some banded cash or plasticine wrapped bricks of white powder. Absent the cash or drugs, a dog-eared copy of "Catcher in the Rye" is acceptable.
 

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I remember a truck stop in Virginia that had a rather large firearms display on the wall that included some NFA weapons (tax stamps displayed alongside) and as far as I could find out the owner did not have a FFL.
 

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Can you display them, yes if they are all legally yours and you can provide proof of same. Can you let others fondle or play with them, a very bad idea. You are going to be engaging in activities that may require multiple licenses. ATF has become quite strick on enforcing their interpretations of the law. You need to sit down with them, with your attorney present, and go over your questions point by point and get a written decision on what you propose to do. As for curios and relics, there is a complete list of these weapons on their web sight. If you are serious about this, you had better have all the licenses in hand proir to starting. Licenses can take awhile to get, as in months, not weeks. Then theres the issue of personal and business liability insurance. ATF is not the group you to get on wrong side of.
 

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. . . we will be retailing 80% lowers with a CNC mill on the premises; that we will be selling complete upper receivers; and that we will be teaching our customers to build complete weapons from scratch - all without an FFL.
Wanting to display our guns is the least of your worries. Sorry to break it to you, but the "services" you are planning to provide will make you a "manufacturer" under the changes enacted back in 2015 to address the rise of "build parties" By providing the machinery for others to build a firearm makes YOU a manufacturer.

https://www.atf.gov/firearms/docs/ruling/2015-1-manufacturing-and-gunsmithing/download
Any person (including any corporation or other legal entity) engaged in the business of performing machining, molding, casting, forging, printing (additive manufacturing) or other manufacturing process to create a firearm frame or receiver, or to make a frame or receiver suitable for use as part of a “weapon … which will or is designed to or may readily be converted to expel a projectile by the action of an explosive,” i.e., a “firearm,” must be licensed as a manufacturer under the Gun Control Act of 1968 (GCA); identify (mark) any such firearm; and maintain required manufacturer’s records. A business (including an association or society) may not avoid the manufacturing license, marking, and recordkeeping requirements of the GCA by allowing persons to perform manufacturing processes on firearms (including frames or receivers) using machinery or equipment under its dominion and control where that business controls access to, and use of, such machinery or equipment. ATF Ruling 2010-10 is hereby clarified.
 
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