From the legal stand point. Yes. You don't need a membership. That only applies to the ATT (which you can apply for at a later time)
Having said that, all CFOs use it as a carrot to hold over peoples head with their "need to satisfy the CFO as to the cause of acquiring firearm" BS.
NFA is trying to get all these denials documented for a case against them.
If you speak to a CFO tell them to put the denial in writing as to why. Also do remind them that nowhere in the provisions range membership is required for acquiring a firearm. Only to acquire the ATT