Tenko Submissions 9mm CB 5.56 OB

[cbritt15]

The support remains unwaivered! Keep up the good fight Scott

 

[A&S Conversions]

The support remains unwaivered! Keep up the good fight Scott

Thank you so very much. I don’t think I can adequately express how much that means. I’m in this position because of the choices I have made. I first put money into this project eight years ago. This is the most difficult thing I’ve ever done. The last five years have been the most challenging of my life. The support here has been part of what has sustained me to continue with this project. Fingers crossed.

Scott

 

[Deerhurst]

We definitely want to see this project become a reality!

 

[Donut77donut]

https://www.wiley.law/alert-ATF-Ann...nd-Renewed-Partnership-with-Firearms-Industry

 

[A&S Conversions]

https://www.wiley.law/alert-ATF-Ann...nd-Renewed-Partnership-with-Firearms-Industry

Thank you so very much. I am very excited about:

• Improving response time from the Firearms & Ammunition Technology Division (FATD) to FFL inquiries: FATD has been criticized for delays in issuing guidance on firearm classifications and technology. ATF has committed to more timely responses to support industry compliance.

This is one of the points of the new directives in the article linked above. Hopefully we will hear something back soon from the Firearms and Ammunition Technology Department of the National Firearms Act Branch about the Tenko 10-16, open and closed bolt submissions. This is the best news I have gotten in years. Thank you so very much. It is so hard to plan when, even if we get two positive determinations, will that be next week, next month, next year. Thank you again for posting this.

Scott

 

[Galil#1]

If I were in your shoes Scott, call them - ask to speak to management folks like yesterday. Email too, nothing to loose at all and everything+++ to gain IMHO Sir. Will you total success, as many others here want for you as well!

 

[Donut77donut]

Thank you so very much. I am very excited about:

• Improving response time from the Firearms & Ammunition Technology Division (FATD) to FFL inquiries: FATD has been criticized for delays in issuing guidance on firearm classifications and technology. ATF has committed to more timely responses to support industry compliance.

This is one of the points of the new directives in the article linked above. Hopefully we will hear something back soon from the Firearms and Ammunition Technology Department of the National Firearms Act Branch about the Tenko 10-16, open and closed bolt submissions. This is the best news I have gotten in years. Thank you so very much. It is so hard to plan when, even if we get two positive determinations, will that be next week, next month, next year. Thank you again for posting this.

Scott

I hope we kept our places on your wait list.

 

[A&S Conversions]

I hope we kept our places on your wait list.

As far as I know Tina still has the list. Even if we got a positive Determination letter for both the open and closed bolt adapters tomorrow, it could still take six months to have the units made, put them together and start shipping them to the guys on the list.

There is also the issue of cost. The pricing quote we have is from early 2019. Inflation has risen around 25%. My understanding is that CNC machine time has gone up reasonably, but aluminum had shot up. I don’t know. I understand that the tariffs are paused right now. I can’t even get a quote until I have some kind of time frame. Once I have a time frame, then I need to secure financing. I can get a ballpark estimate but without financing in place, but I won’t be able to lock in a price because of the volatility of the market and how much or whether or not tariffs are on.

Then once I have a price, I will also need to come back to the community with the new price. Originally, we had planned on a retail price of $2,995.00. But that was based on pricing of materials, machine time, and anodizing based on First Quarter 2019. The price is bound to be higher. How much, I don’t know. I would think between a higher price and what is going on with the economy, some that are on the list will probably pass. Again, I don’t know.

One last point, I am not going to call or write the Tech Branch. If I had not pestered them in 2019, I would have been able to go to market with the Tenko 10-16 four months before the Lage Max-10/15. Of course I would have had to not pester them and have waited better than another year. Of course hind sight being 20/20, that would have been so much better than all the time and money we spent on the redesign because they were pissed at me for pushing for a determination. There is also how this whole project has put stress on me, my wife, and our family’s finances.

The listing of the changes for the ATF Firearms Division, just came out this week. Government Agencies move very slowly. I plan to wait until they have had the submissions for a year. Then write the FATD asking for a time frame. Other than that, I will patiently wait. Hopefully we’ll hear something soon. Thank you all, again for the support.

Scott
Manager A&S Conversions LLC

 

[Alaska_Shooter]

If I had not pestered them in 2019, I would have been able to go to market with the Tenko

There’s no way to know this. I know it’s hard not to second guess things but for all we know they might have even delayed you more. Never underestimate govt incompetence or outright ugliness

 

[Galil#1]

There’s no way to know this. I know it’s hard not to second guess things but for all we know they might have even delayed you more. Never underestimate govt incompetence or outright ugliness

BINGO ^^^^
But WE are Not the Winners!

 

[MACsAlot]

As far as I know Tina still has the list.

Yes, I still have the wait list. I am confident that one day I'll be contacting y'all to let you know that your number's up and it's time to rock and roll....

Good luck Scott.

t

 

[A&S Conversions]

There’s no way to know this. I know it’s hard not to second guess things but for all we know they might have even delayed you more. Never underestimate govt incompetence or outright ugliness

We are all adults here, entitled to our opinion. I know that our aluminum submission, because my NFA specific lawyer, that deals with the Technology Division specifically, told me so. This isn’t what he does for fun, or as a side business. In fact, I don’t have any way to corroborate this, but my NFA lawyer told me that our situation was the most egregious treatment of our determination he had seen in his 16 year career dealing with the ATF directly.

How could the determination be any worse? I suppose they could have charged me a tried to send me to prison? Our original submission was 3D printed. From the FATD receiving the submission, our determination was received back in 108 days. I had checked the timing but had never fired it. I didn’t think I needed to. The timing was correct and at the time the FATD used their Powder Springs M10 lower receiver and a 5.56X45 16” upper. The upper holds it the pressure of the explosive in the round. The adapter acting as the lower receiver. The AR lower receiver is under very little stress. I own a Caviler Arms and Armalite plastic lowers. The adapter was more than twice as thick as those commercially available lower receiver. The determination was that the original adapter was a firearm accessory and was not affected by the GCA ( Title I firearm) or the NFA (Title II firearm).

After about a year we submitted an aluminum version. About the only real differences were that the additional strength and heat resistance of aluminum. The aluminum submission allowed the thickness of the adapter to be thinner, much more heat resistant, and the pins were based on the captured pins of the AR. When the original adapter was returned, there was burnt powder residue inside the adapter. I didn’t bother to document that.

A year later, we submitted the aluminum adapter that we were planning to go to market. The FATD had the aluminum adapter for over a year from submission. This was around the time when the ATF was trying to “redefine/expand the definition of firearm frame or receiver. I would think that a message came from the top about holding up any determinations of anything that might fit into that. That is why I think that even though the Max-11/15 was being sold in the market, but the Max11A1/15 and the Max-10/15 were held up for about two years and four months.

When the submission was received, an email with the reference number and an approximate time frame for the determination, which was about six months. After that year, I wrote, I called. No response. It was suggested to become an FFL holder as we would be “in the business”. Still no response.

Through a friend of a friend who is a SOT manufacturer who had a notable NFA product recommended this lawyer. It was also suggested by a very close friend to contact one of my State Senators, as there is an ATF liaison in both Houses of Congress.

Apparently, one or both of these tacts pissed them off. So they put our adapter with an upper on it in a pipe vice bolted to a table, placed a piece of angle iron on the back of the adapter with a C-clamp, to hold the spring and buffer system into the adapter like the back of the lower receiver of the M10, and held it all together with zip ties. As with many other Mac style uppers with a magwell, the FATD got it to fire.

The determination was the aluminum version was a machine gun and since I was not an SOT, they kept everything other than my M10. The lawyer contacted the FATD and suggested that we were planning to take the 3D printed version to market as we had a determination for it. They said that we could not because the previous determination for the 3D printed version was machine gun because the determination of the 3D version was improper. That was because it was made of plastic and they were afraid to shoot it. Since I had not documented the infired condition when submitted and the residue from being shot by them when it was received back, I couldn’t prove that.

They lied. That pissed me off that the Government Agency would do so. They made the equivalent of a M10 lower receiver from the vice, angle iron, C-clamp, and zip ties. Doing the same thing with any Mac style upper with a magwell would tend to be made to fire. I pushed with the lawyer and State Senator’s office. They didn’t like that. I wanted to sue. The lawyer said that I could, but the courts give the ATF deference because the courts looks to the ATF for advice on what is or isn’t a firearm. What is or isn’t a machine gun. He said that with a $100,000 retainer, possibly more and he felt that would be a huge waste and not very good odds of winning.

We are now five years later. The situation at the ATF is different. But they could lie and use the parts from the original aluminum version that we changed to make the adapter much harder to fire without a M10 lower receiver. But I don’t know what they will do. Hopefully we’ll get an honest determination. But they could still be grinding an ax for us.

This represents the biggest risk I have ever taken, ever. I am scared. At 65, my family can’t afford to lose all that has been invested. But unless you have been in a similar situation with the ATF, with this much riding on this determination, it is just the opinion of a firearms enthusiast. As far as I am concerned this is how I am handling this situation. If you want to front me what we have invested, you can make that decision. But right now it is our money and I am the one making this decision. YMMV.

Thank you Tina.

Scott

 

[Alaska_Shooter]

I’m surprised to be attacked when I tried to make a supportive comment. Hopefully you can get to a better place

 

[A&S Conversions]

I sorry, but I felt attacked. Yes, you are right. I should have handled that better. I am trying to stay positive but a big part of why my family and I are in this position is because I was a bull in the china shop and pushed the ATF. Which monumentally backfired on me. And it is my fault because I was the one that pushed. But now my family is paying that price too. This is my fault.

This is an incredibly pivotal moment for not only me but my family. I am so very scared and I think about how big the steaks are for me and my family multiple times a day every day. I can not think of any time in my life that I have been more stressed in my life. You are right, you didn’t deserve that. Please accept my apology.

Scott

 

[Deerhurst]

I’m surprised to be attacked when I tried to make a supportive comment. Hopefully you can get to a better place

From my point of view you didn't know the history and also from my point of view the response was warranted as the story has been shared in the past.

You now know the story. It sucks, it's not fair and the AFT will do it again. I have absolutely zero faith in any government branch.


Scott, there is a guy that has a 100% track record of curb stomping the AFT on various things including a (NFA DD registered) grenade they stole from him . He does openly try to antagonize them. He is bringing a FRT to market soon, has plans to sue over the closed machine gun registry (just gotta grease some palms to get new MGs in from what I've heard related to that). I do not believe he is a lawyer and I believe he does represent himself every time. I can contact him if you would like another brain to pick on the determinations subject. He may be a good resource.

 

[Donut77donut]

From my point of view you didn't know the history and also from my point of view the response was warranted as the story has been shared in the past.

You now know the story. It sucks, it's not fair and the AFT will do it again. I have absolutely zero faith in any government branch.


Scott, there is a guy that has a 100% track record of curb stomping the AFT on various things including a (NFA DD registered) grenade they stole from him . He does openly try to antagonize them. He is bringing a FRT to market soon, has plans to sue over the closed machine gun registry (just gotta grease some palms to get new MGs in from what I've heard related to that). I do not believe he is a lawyer and I believe he does represent himself every time. I can contact him if you would like another brain to pick on the determinations subject. He may be a good resource.

Ben?

 

[strobro32]

I wish you luck Scott. I'm sorry this has taken a toll on you and your family. It's not your fault. The game's been rigged.

I mean you no offense when I say the pendulum is swinging. Hopefully it will swing far enough that we won't have to make adapters for old tools or create parts that circumvent unconstitutional regulation. I'm looking forward to the time when new tools are available. I believe it's coming.

 

[A&S Conversions]

I wish you luck Scott. I'm sorry this has taken a toll on you and your family. It's not your fault. The game's been rigged.

I mean you no offense when I say the pendulum is swinging. Hopefully it will swing far enough that we won't have to make adapters for old tools or create parts that circumvent unconstitutional regulation. I'm looking forward to the time when new tools are available. I believe it's coming.

Thank you for your kind words and support. It does mean a lot. The game certainly has been rigged. But I also need to take responsibility for the fact that I didn’t play my hand in the best way I should have. I have to hand it to Richard. He certainly played his hand so much better than I did. I should’ve respected his example so much more. I have certainly paid that price.

I think the saddest part is, like so many other things in our society, there is a source of wealth for those with money. There was a point between the dot com bubble collapse and the mortgage loan collapse when many of the machine guns being transferred (especially those rare or original in very good condition) weren’t going to collectors. Many of them were going to investors who were not going to shoot them. Why, because depending on the model, these transferables were going up in market value from 10 to 20% per year, very liquid, and through a private sale, there is no mechanism for the Government to make sure capital gains taxes were paid, unlike securities. Machine guns became a popular investment.

I think members here and the fact that the Mac style family of transferable machine guns represents some of the lowest market values in transferables and around 20% of the total transferables available to citizens. These circumstances could mess with the demographics of this group compared to the general sales of machine guns and those purchasing those transferables.

To give some reference numbers, it is my understanding that there is around 180,000 transferables in the NFA registry. If the market value of the average transferable is around $25,000. That would put the total market value of transferables at least $4.5 billion. Personally I think my estimate is very low.

Our family have almost $30,000 actual dollars in our current machine gun collection. As many members here have stated, I would gladly give up those dollars to be able to buy machine guns at the current Agency market value. I also think that many of the actual owners of that $4.5 billion plus in market value, might have a different opinion.

Could citizen ownership of machine guns be eliminated? Possibility, but there is a fair amount of money/political capital behind that ownership. How much money and political capital would be behind eliminating that $4.5 billion transferable value, but allowing citizens to purchase new modern machine guns at the Agency price? I would think very little. It would be cool, but I don’t think there is a snowball’s chance in hell that average citizens would be able to buy a SIG M250 belt fed at the same price as Homeland Security would. But we could all dream.

Scott

 

[Alaska_Shooter]

Today is a momentous day in the history of the internet. For the first time ever, a misunderstanding was resolved 🤣

I already knew the history. Regretting past actions is a hard place to be in. I know from personal experience.

Keep moving forward. You’ll get this.

 

[A&S Conversions]

Today is a momentous day in the history of the internet. For the first time ever, a misunderstanding was resolved 🤣

I already knew the history. Regretting past actions is a hard place to be in. I know from personal experience.

Keep moving forward. You’ll get this.

Thank you. Again, I apologize for my visceral response. Pushing the ATF was the biggest mistake and regretted of my life. Suggesting that pressure now might have a different result was overwhelming for me and I am very sorry. Thank you again.

Scott