December 19, 2019
The Bureau of Alcohol, Tobacco, Firearms and
Explosives (ATF) 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
The ATF 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. Moreover, because
the Reformation is not chambered for shotgun shells, it is not a shotgun
as defined in the NFA. 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).
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). When a Reformation is
configured as a GCA/SBS, specific provisions of the GCA apply to the
transfer of that firearm from a Federal Firearms Licensee (FFL) to a
non-licensee, and to the transport of that firearm by a non-licensee in
interstate or foreign commerce. These provisions are:
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.
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.
Franklin Armory Reformation is the first firearm produced and sold by
an FFL that ATF has classified as a GCA/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).
currently developing the procedures and forms to address this new type
of firearm. 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:
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).
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 approving such requests, an
FFL may not lawfully transfer a Reformation configured as a GCA/SBS to a
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 FIPB@atf.gov or
Curtis W. Gilbert
Acting Assistant Director
Enforcement, Programs and Services
Originally Posted By LHA-2:
Just read it again, it makes perfect sense. It isn’t a shotgun, but it’s a shotgun.
Moreover, because the Reformation is not chambered for shotgun shells, it is not a shotgun as defined in the NFA. 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).