For NR, I don't think so at this time. Post C71 is still anyones guess.
IF the RCMPee decided that the MS is classed a restricted , I could see some significant fallout. The only way I would consider going ahead and releasing them prior to the FRT would be by recording each purchasers R PAL details so in the event of a restricted classification, ATRS could then register them and transfer the rifles that had been sold. This then becomes a nightmare logistically and I think there would be significant backlash from the public who had the rifles already.
Pretty much a no win situation to be in really. On 1 hand many thousands of dollars are at stake for ATRS versus the potential nightmare the RCMPee could unleash on ATRS.
Glad it is not my dilemna. Personally I will await the FRT.
Oddly most of the folks we have sold MH's and MV's to have RPALs. I would have thought the appeal was more to the standard PAL holders. Who knew?
We have always been of the opinion that the
less client info we have on file, the
better. I DO see where you are going however. A CYA plan for us should we get an undesirable legal classification should we elect to sell these prior to the FRT.
Reading the letter Wolverine shared re their new rifle Etter is very clear that should they (SFSS/RCMP) deem their version of the 180 to be anything but NR Wolverine would then be responsible for any fall out.
With their being absolutely no rhyme nor reason to the legal classifications of firearms in Canada and knowing how expensive and likely it would be to be put out of business should the feds elect to pursue some possible wrong doing, it is the "what IF" that concerns me.
It is easy for guys to say go ahead I will take the risk, but their total exposure is about $1000.00, my exposure is significantly greater.
"Good day John:
With respect to your statement: - “If Wolverine Supplies was to manufacture a semi auto center fire rifle in Canada with a 19 inch barrel I assume we could simply go ahead and market her without your inspection as there is no legal requirement to have an FRT”.
1. For the purposes of the FRT, I would like to draw a clear distinction between the “manufacturer” who makes all components from “scratch” including the receiver and barrel and is not just an assembler of components with metal working, metal finishing and woodworking skills, which accurately describes the average “gunsmith”. The former is a “manufacturer”, the latter is not.
2. I presume that Wolverine (the business entity) in the hypothetical statement above, and their supply chain have all the required licences and authorities.
Then the answer is
YES, BUT the manufacturer assumes full responsibility for assuring accurate classification of the firearm and accessories such as stocks and cartridge magazines.
Be aware that other regulators may require an FRT Record for their purposes.
Regards.
Bill Etter
F.A. William (Bill) Etter
Chief Firearms Technologist
Specialized Firearms Support Services
Firearms Investigative and Enforcement Services Directorate
RCMP-CFP
Specialized Policing Services"