ATF Update re: Franklin Armory Reformation


Franklin Armory ATF RulingThe ATF has just invented a new class of firearm because of Franklin Armory’s Reformation and it has effectively banned the transfer of these firearms to non-FFLs (individual citizens) until new regs have been established.

Franklin Armory came out with an AR-15-like firearm with straight lands and grooves in the barrel so that the barrel was neither smooth nor did it have rifling that would make the bullet spin when fired.

Why was the barrel important? The Reformation had a barrel length that would classify the firearm as an NFA firearm (subject to extra regulations like silencers and machine guns) if it were determined to be a rifle or shotgun.

Under federal law, a firearm which is designed and intended to be fired from the shoulder (it has a buttstock) with a rifled barrel is a “rifle” and if it has a smooth barrel it is a “shotgun.” Rifles must have barrels at least 16″ long and shotguns must have barrels at least 18″ long.

By making a barrel that was neither smooth nor rifled, Franklin Armory found a loophole and made a firearm that is neither a rifle nor a shotgun. This allowed them to sell their AR-15-like firearm with a short barrel.

In no uncertain terms, although the Reformation is a creative idea to get around some laws, we think it is an absurd product. It is so much easier to get a quality AR-15 with a short barrel and a pistol brace that will actually hit a target.

The ATF has apparently been receiving questions about how to handle these firearms and just released a ruling.

According to the ATF, they agree that it is not a rifle for the reasons above. They also agree it isn’t a short barreled shogun under the NFA (e.g. silencers and machine guns) because it isn’t intended to fire shotgun shells. However, the ATF says it is a shotgun under the GCA (regular firearms).

This is a mistake.

Yes, the shotgun shell distinction applies to the NFA and it has nothing to do with the GCA. Instead, a smooth barrel is all that is required to be a shotgun under the GCA. Although the Reformations lands and grooves are straight, I think it’s easy to argue that the barrel is NOT smooth and therefore can’t be a shotgun.

Regardless, as a shotgun under the GCA but not the NFA, a reformation with a barrel under 18″ falls somewhere in between the two laws. So, the ATF is inventing a new category of firearm called the GCA/SBS.

The ATF is allowing FFL to FFL transfers of these firearms but it says that transfers from an FFL to an individual are not allowed until the ATF determines a regulatory procedure for handling these new class of firearms.

Again, I disagree with this interpretation because it shouldn’t be a shotgun and should simply be a “firearm.”


ATF ruling below:

ATF Ruling – Franklin Armory Reformation

U.S. Department of Justice

Bureau of Alcohol, Tobacco, Firearms and Explosives

Enforcement, Programs & Services

Washington, DC 20226

December 19, 2019

Open Letter regarding the Franklin Armory Reformation Firearm

The Bureau of Alcohol, Tobacco, Firearms and Explosives (ATP) has received questions from industry members and the general public regarding a new type of firearm produced by the Franklin Armory®. This ‘firearm, known as the “Reformation”, utilizes a barrel that is produced with straight lands and grooves. This design contrasts with conventional rifling, in which the barrel’s lands and grooves are spiral or twisted, and are designed to impart a spin onto the projectile.

The ATP Firearms and Ammunition Technology Division (FATD) has examined the Reformation firearm for purposes of classification under the applicable provisions of the Gun Control Act (GCA) and the National Firearms Act (NFA). During this examination, FATD determined that the straight lands and grooves incorporated into the barrel design of the Reformation do not impart a spin onto a projectile when fired through the barrel. Consequently, the Reformation is not a “rifle” as that term is defined in the GCA and NFA. 1 Moreover, because the Reformation is not chambered for shotgun shells, it is not a shotgun as defined in the NFA.2 Given these determinations, the Reformation is classified as a shotgun that is subject only to the provisions of the GCA (i.e., it is not a weapon subject to the provisions of the NFA).3

Under the provisions of the GCA, if a Reformation firearm is equipped with a barrel that is less than 18-inches in overall length, that firearm is classified to be a short-barreled shotgun (SBS).4 When a Reformation is configured as a GCNSBS, specific provisions of the GCA apply to the transfer of that firearm from a Federal Firearms Licensee (FPL) to a non-licensee, and to the transport of that firearm by a non-licensee in interstate or foreign commerce. These provisions are:

1) 18 U.S.C. § 922(a)(4) requires that an individual wishing to transport an SBS in interstate or foreign commerce obtain approval by the Attorney General to transport the firearm.

2) 18 U.S.C. § 922(b)(4) requires authorization from the Attorney General consistent with public safety and necessity prior to the sale or delivery of an SBS to an individual by an FFL.

The Attorney General has delegated the authority for approval of requests pursuant to these sections·to ATF. · ‘

The Franklin Armory Reformation is the first firearm produced and sold by an FFL that ATF has classified as a GCS/SBS. Because GCA/SBS firearms have not previously been available in the marketplace, existing federal firearm regulations do not provide a mechanism to process or approve requests from FFLs for approval to transfer a GCA/SBS to a non-licensee pursuant to section 922 (b)(4) or requests from non-licensees to transport a GCA/SBS pursuant to section 922(a)(4).

ATF is currently developing the procedures and forms to address this new type offirearm. Once promulgated, these new procedures and forms will provide the mechanism necessary for FFL holders and owners of GCA/SBS firearms to request the statutorily required approvals. Until such time, you should be aware of the following:

  1. 1)  An FFL may lawfully sell/transfer a GCA/SBS, such as the Reformation, to the holder of an appropriate FFL (a GCA/SBS cannot be transferred to the holder of a type 06 or type 03 FFL).
  2. 2)  No mechanism currently exists for ATF to authorize a request from an FFL to transfer a GCA/SBS, such as the Reformation, to a non-licensee. Therefore, until ATF is able to promulgate a procedure for processing and appr.oving such requests, an FFL may not lawfully transfer a Reformation configured as a GCA/SBS to a non-licensee.
  3. 3)  No mechanism currently exists for an unlicensed individual who possesses a GCA/SBS, such as the Reformation, to submit a request and receive approval to transport the GCA/SBS across state lines. Therefore, until ATF is able to promulgate a procedure for processing and approving such requests, the possessor or owner of a GCA/SBS, such as the Reformation, may not lawfully transport the firearm across state lines.

Any questions pertaining to this Open Letter may be sent to the Firearms Industry Programs Branch at or (202) 648-7190.

~ ~ Curtis Gilbert Acting Assistant Director

Enforcement, Programs and Services

1 See 18 U.S.C. 921(a)(7) and 26 U.S.C. 5845(c).

2 See 26 U.S.C. 5845(d).

3 See 18 U.S.C. 921 (a)(5).

4 See 18 U.S.C. 92l(a)(6).


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  • Anonymous
    Posted December 19, 2019 3:38 pm


  • Anonymous
    Posted December 19, 2019 10:42 pm


  • Gary Reed
    Posted December 21, 2019 8:31 am

    Well written article that explains what is happening at the ATF and how their ruling will change definitions of firearms. Adding more confusion to more bureaucracy. Thanks Ryan for pointing this out.

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