I have also had the monkey wrench of the FATD change in policy as to determination. The letter stating that they were returning the Tenko adapter without a determination was dated the February 1, 2019. I have still not received that Tenko adapter back yet. I had hoped to install the one I had shipped to the FATD on a M10 lower and send it back. Since I have not received that one back yet, I pulled one of the Beta units that has had 10,000 rounds through it and installed that one on a M10 lower.
That has brought up shipping. It is my understanding that registered mail is the way to ship machineguns. The postal regulations do not say anything about machineguns specifically that I could find, just long guns and firearms that are "concealable" i.e. handguns. It does state that a SBS or SBR are concealable.*
So I installed a 16" upper on the Tenko adapter. On Friday, I took it to my local Post Office. I did say that I was shipping a machinegun as I wanted to be sure it would be insured. I was shipping it in a box from PSA. With the stock collapsed it just fit in the 39" box. The counter person sold me the return shipping postage and gave me labels and insurance/registered mail to put inside the box for return shipping. While I was filling out that stuff, the Postmaster came up to me. He said that he checked with the Postmaster General's office. He said that they told him that machineguns were not allowed to be shipped via the U.S. Mail. They returned my money for the postage and I left. I had not prepared for that. I didn't just want to argue, I wanted to have facts.
So I went to FedEx. After a bunch of round and round, I could ship to the FATD and back but the maximum return insurance was for only $1,000. That did work for me. So I went home. I posted about this on subguns NFA Board as it seems there are some industry guys there. I didn't get much help there. I started going through the Postal regulations. There is an exception for "concealable" if you are mailing to an Agency. "12.1.7 Addressed to a scientific laboratory or crime detection bureau of any federal, state, or local law enforcement agency whose members are authorized to serve warrants of arrest or commitment."
This was after my local Post Office was closed. There was another Post Office near me that was open until 2:00P.M. I was able to ship using this statue. I find this whole shipping situation ridiculous. If something where to happen I would not want my claim disallowed because I didn't describe what they were insuring. As with a problem with the Forms, I am hoping that once they receive the complete firearm, the FATD will do the determination right away. Time will tell.
We are still moving forward with production of the first run of Tenko adapters. I am in hopes that we will have the first run finished by the time we get the determination. We are moving forward. Thank you all for your patience.
Scott
Manager A&S Conversions L.L.C.