I and more importantly, my lawyer disagrees. While I am producing, but have sold the item, I simply am holding it in trust. Once it is complete, I can ship it once to the actual owner. Just as the CFO offices completed transfers for restricteds after the OIC... as long as the transaction began before the prohibition.
But didn't the FRT you are trying to ride the coattails of just went prohib yesterday? so you are selling because you said you don't have an FRT yet and you don't need one, if this is what you are standing on, then what is stopping another vendor in the future to mass produce a copy of a "Newly" prohibited firearms (with different name and minor modification) and start selling 2 minutes after an FRT application? this can be repeated multiple times in the next 23 month as long as you submit a new FRT application every time and make sure it is named differently.
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