A&S Conversions
UZI Talk Life Member
To be clear, we sent an adapter in, back in October. We are past 150 days. I to hope we get the determination tomorrow.
Scott
Manager A&S Conversions L.L.C.
A Sad Update For The Tenko 10-16
- Thread starter A&S Conversions
- Start date
UZI Talk Life Member
To be clear, we sent an adapter in, back in October. We are past 150 days. I to hope we get the determination tomorrow.
Scott
Manager A&S Conversions L.L.C.
A&S Conversions
UZI Talk Life Member
It had been that if a new product was developed, that product would be sent to the Firearms and Ammunition Technology Division of the National Firearms Act Branch for evaluation for determination as to whether the item is or is not regulated under the Gun Control Act of '68 (whether the item is considered to be a firearm) or the National Firearms Act (whether the item is considered a NFA regulated like a machinegun or SBR, etc.) On October 11, 2018, the FATD emailed me that they received the Mac conversion item and gave a reference number.
On December 10, all SOTs were notified via email that effective immediately, all accessories would require installation in and the sending of a complete firearm for the FATD to evaluate for determination. The email was only sent to SOTs. There was never any change to the "how to submit an item for determination" page on atf.gov website.
The FATD sent a form letter dated March 1, 2019 that they would be returning the conversion device without a determination because the conversion device was not installed in a complete firearm. We waited three weeks and did not receive the Tenko adapter back. We have three Beta test units with 10,000 rounds of use. I pulled one, adjusted it to one of my transferable M10 RRs and shipped it to the FATD.
On March 6th, the FATD sent an email confirming they had received our submission, a reference number, and a phone number to call after 150 days. I called and asked about the status of the original submission and if the new submission would take the place of the original submission.
On March 8th the FATD wrote back that the evaluation of the evaluation of the reference number with the complete firearm was "completed and is pending the Chief's review and signature. Once the evaluation has been reviewed and signed; a copy of these results will be emailed to you and the sample will be returned utilizing the accompanying USPS label and postage stamps."
I called the following Tuesday the 12th to ask about the original submission. That submission had a feature that was not on the completed firearm submission. Would I need to spend another $120.00 to send it back for the FATD to give a determination of that feature?
On March 15th we received an email from the FATD that the original submission was mailed back on March 11th period. Of course my wife had messaged me earlier in the day to say that the original submission was delivered that day.
Hopefully this step by step has made it clear why I feel we have waited over 160 from when the FATD acknowledged receiving the original submission on October 11, 2018. If there is a problem with a Form 4, the transferer is notified. Once the problem is corrected, that Form 4 doesn't go to the bottom of the pile. That to me is why the evaluation is complete and waiting for the Chief's review and signature. So like a Form 4 with a problem, once the problem is clarified, the Form 4 is approved or denied. Since I don't know the process, I wrote and asked how long the Chief's review and signature take. If you called about Form 4 wait times, you are given a ballpark as to approval times, so I asked. No response. So we are patiently waiting.
Scott
Manager A&S Conversions L.L.C.
On December 10, all SOTs were notified via email that effective immediately, all accessories would require installation in and the sending of a complete firearm for the FATD to evaluate for determination. The email was only sent to SOTs. There was never any change to the "how to submit an item for determination" page on atf.gov website.
The FATD sent a form letter dated March 1, 2019 that they would be returning the conversion device without a determination because the conversion device was not installed in a complete firearm. We waited three weeks and did not receive the Tenko adapter back. We have three Beta test units with 10,000 rounds of use. I pulled one, adjusted it to one of my transferable M10 RRs and shipped it to the FATD.
On March 6th, the FATD sent an email confirming they had received our submission, a reference number, and a phone number to call after 150 days. I called and asked about the status of the original submission and if the new submission would take the place of the original submission.
On March 8th the FATD wrote back that the evaluation of the evaluation of the reference number with the complete firearm was "completed and is pending the Chief's review and signature. Once the evaluation has been reviewed and signed; a copy of these results will be emailed to you and the sample will be returned utilizing the accompanying USPS label and postage stamps."
I called the following Tuesday the 12th to ask about the original submission. That submission had a feature that was not on the completed firearm submission. Would I need to spend another $120.00 to send it back for the FATD to give a determination of that feature?
On March 15th we received an email from the FATD that the original submission was mailed back on March 11th period. Of course my wife had messaged me earlier in the day to say that the original submission was delivered that day.
Hopefully this step by step has made it clear why I feel we have waited over 160 from when the FATD acknowledged receiving the original submission on October 11, 2018. If there is a problem with a Form 4, the transferer is notified. Once the problem is corrected, that Form 4 doesn't go to the bottom of the pile. That to me is why the evaluation is complete and waiting for the Chief's review and signature. So like a Form 4 with a problem, once the problem is clarified, the Form 4 is approved or denied. Since I don't know the process, I wrote and asked how long the Chief's review and signature take. If you called about Form 4 wait times, you are given a ballpark as to approval times, so I asked. No response. So we are patiently waiting.
Scott
Manager A&S Conversions L.L.C.
I was once told that dealing with the federal government was like having sex with an elephant.
It's carried on at a high level,
It takes 18 months to see any results,
and you stand a very good chance of being trampled in the process.
It's carried on at a high level,
It takes 18 months to see any results,
and you stand a very good chance of being trampled in the process.
A&S Conversions
UZI Talk Life Member
Apparently, unlike a Form 4 transfer, we started over with a complete firearm submission. The FATD acknowledged receiving the complete adapter unit with a M10 registered receiver on March 6th. I wrote and asked about the previous submission and was notified on March 8th that the evaluation was completed and submitted to the Chief of the FATD for review and signature. See details from 3/23 update.
We wrote back requesting a time frame for the review and signature. No response.
After waiting a couple of weeks we wrote again asking for a time frame. This time we received a form type of email that stated the would be assigned a technician to do the evaluation. SOT submissions would take 6 months and non SOT submissions would be filled in after that.
We wrote back asking for clarity, as we had one email stating the evaluation was completed and waiting for review and signature and another stating that the evaluation had not been assigned. Again no response.
We waited a couple of more weeks and then sent a letter via registered mail to the Chief stating we had received two different status updates. We requested clarification twice (we included copies of those requests and copies of the original status emails) and had gotten no response. That was seven weeks ago. We have not received any response.
We have the first batch of Tenko adapters and are finishing putting them together. We will then be shipping them to Sam. We have a second batch at the fabricator. Those should be done in two weeks. Lead time for fabrication takes months. This delay has certainly created financial challenges.
This is probably the most frustrating situation I have ever experienced in my life. At least with a Form 4 transfer it is possible to get a ballpark estimate. Not with this. We could get the determination today or six months from now, or even longer. We don't know. Once we get the determination it could take a couple of months to get the Tenko back into the fabricator's que. We are sorry that there is no real update. We are still waiting and have no idea when we will be able to sell the units we have.
Scott
Manager A&S Conversions L.L.C.
We wrote back requesting a time frame for the review and signature. No response.
After waiting a couple of weeks we wrote again asking for a time frame. This time we received a form type of email that stated the would be assigned a technician to do the evaluation. SOT submissions would take 6 months and non SOT submissions would be filled in after that.
We wrote back asking for clarity, as we had one email stating the evaluation was completed and waiting for review and signature and another stating that the evaluation had not been assigned. Again no response.
We waited a couple of more weeks and then sent a letter via registered mail to the Chief stating we had received two different status updates. We requested clarification twice (we included copies of those requests and copies of the original status emails) and had gotten no response. That was seven weeks ago. We have not received any response.
We have the first batch of Tenko adapters and are finishing putting them together. We will then be shipping them to Sam. We have a second batch at the fabricator. Those should be done in two weeks. Lead time for fabrication takes months. This delay has certainly created financial challenges.
This is probably the most frustrating situation I have ever experienced in my life. At least with a Form 4 transfer it is possible to get a ballpark estimate. Not with this. We could get the determination today or six months from now, or even longer. We don't know. Once we get the determination it could take a couple of months to get the Tenko back into the fabricator's que. We are sorry that there is no real update. We are still waiting and have no idea when we will be able to sell the units we have.
Scott
Manager A&S Conversions L.L.C.
A&S Conversions
UZI Talk Life Member
A&S Conversions
UZI Talk Life Member
Sadly, no there has been no progress. After receiving our 07 FFL, I have written to the FATD twice without any response. The whole point of getting our FFL now was that the FATD was supposed to be more responsive to FFL holders. In both emails I included our license number. I was ignored by the FATD just as much as a private individual.
We have contacted our senior US Senator. She is a Democrat, but has a major focus on small business. The staffer that I have been communicating with has been very responsive. We have had some technical problems getting the staffer all the documentation that she needs. We have held off upgrading our Office equipment waiting for cash flow. My wife has the day off and I hope that she will finish up the documentation today. Thank you for the inquiry. The next step would be to hire a lawyer.
Scott
Manager A&S Conversions L.L.C.
rybread
UZI Talk Life Member
Probably! I subscribed to the ATF emails to get some perspective or insight into this, and chose ALL the updates, thinking I might get too many emails and have to trim that back. So far crickets.
rybread
UZI Talk Life Member
I think tomorrow maybe. Finally got one of those ATF emails, this one from the San Fran branch:
“(The) ATF’s National Integrated Ballistic Information Network (NIBIN) linked guns recovered during enforcement actions to Fresno mass shooting that occurred on November 17, 2019.
“(The) ATF’s National Integrated Ballistic Information Network (NIBIN) linked guns recovered during enforcement actions to Fresno mass shooting that occurred on November 17, 2019.
A&S Conversions
UZI Talk Life Member
The FATD Office is over an eight hour drive one way from my home. Currently I am working six days a week and the NFA Office would only be open Monday through Friday. From my perspective, going down and knocking on the front door would probably cost me three times more than hiring a lawyer to write a letter about legal action against them for interfering with our ability to engage in commerce. We are at 15 months since our original submission. They have had my transferable M10 registered receiver for 10 months. Nowhere have I found an explanation as to why we got our first determination in 108 days and have now been waiting 448 days.
Thank you all for the kind words. I know we will get to market. This is a big part of why so few people actually bring their idea to the market place.
Scott
Manager A&S Conversions L.L.C.
A&S Conversions
UZI Talk Life Member
That is not my intention at all. But I have gotten no communication at all. When we originally submitted the acceptance confirmation email quoted 120 days for a determination. The same confirmation email when we resubmitted four months later as a complete firearm quoted 150 days. We are at double that with no response or explanation. I am just a guy with an idea and I put a big part of my net worth into bringing that idea to market. If the FATD had done what they said they would do then we would be selling the M11/NINE version and working on the AK version. We should have been shipping the Tenko 10-16 almost a year ago if we were not waiting for the determination. Why is that? I can't seem to get a response even as a FFL holder. Maybe a staffer for my Senator or a lawyer who specializes in NFA issues can contact through other channels, because I have gotten no response since August. If this was some home project I'd be annoyed but it would not be a big deal. I am not an engineer, or a programmer, or a machinist. I paid professionals from my own pocket to bring this product to life. Apparently I need others to "squeak" to get some "grease". Hopefully these others have alternative contracts because I can't seem to get any response through the means of contact I have.
Scott
Manager A&S Conversions L.L.C.
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