"Modular" silencers such as Salvo not approved by ATF

[[email protected]]

I'm looking for help settling a bet/debate/argument I'm having with adealer/mfg. The debate is whether or not modular silencers particularly the SCo Salvo is legal for civilians to own in its current configuration. I believe it is for a number of reasons:

1. I don't think SCo would spend the time/money/manpower in R&D, marketing, manufacturing, etc.... Only to have an product that the ATF deems is illegal for civilians to use. Especially since this particular silencer seems(imo)geared more towards civilians versus LE/Mil.

2. SCo has already stated that this silencer has been approved for civilian ownership by the ATF.

3. The Salvo has already been sent to dealers and purchased by civilians, although it's highly unlikely that any civilians have had their form 4's approved and have taken ownership yet.

However I'm being told by the dealer/mfg that I'm debating with that "As for the bet, its far from settled. ATF tech branch has not issued a letter on the matter yet that I have seen. When they do, I have no doubt in my mind that they will not allow it to be in civilian hands without changes."

After reading that statement I have a few questions first off, does the ATF tech branch issue approval letters to mfgs. Like after they send in paperwork to the ATF to get approval to commence the manufacturing, sales, and distribution of newly designed silencers? If so, are these letters released to the public? Can I request/find a copy of said letter?

I have called SCo and asked them if they received approval from the ATF for civilian ownership of the Salvo in said configuration, and they answered in the affirmative. I then explained to them my dilemma, and asked him where/if I could find any documentation from the ATF that may settle this bet. He then stated there was no need for me to see an approval letter(I guess he just wants people to invest $100's in a product that some say may turn out like the Atkins Accelerator. **Disclaimer** I am not one of those people, I'm just saying there are some naysayers out there). When I asked again he stated he did not feel comfortable attempting to find said letter and started trying to get off of the phone. I told him that I understood he was busy and that all I wanted was some guidance or assistance in finding this approval letter/proof. After a couple moments of awkward silence and a bit of huffing and puffing on his end of the line he finally stated that he would speak to someone in the compliance department and see if he could accommodate my request. I said that would be great, he quickly said "ok so I'll try to do that, have a great da...." I barely had time to stop him from hanging up on me. I then asked him how he planned on getting back in touch with me since he had none of my contact information or even my name. I asked for his email address and his reply was "well I'll just get yours." After giving him my email address I asked for his email address again, once again he was very hesitant to give it or any other contact info to me. He then became extremely standoffish, and attempted to invalidate my request for info several times. He finally gave me his name/email I and still haven't heard from him.

Any and all help is greatly appreciated, R.M.

P.S. I'm not knocking Solencerco's CS, I'm sure I just caught this person(who will remain unarmed)on a really really bad day, then he found out I wasn't buying anything right then which just exacerbated his already bad mood.

Sent from my smart phone, so please excuse typos.

[Prince Yamato]

The reasoning behind the law is that you can make an existing can shorter, but you cannot add length to a can without "making" a new can. The idea is you cannot make a more effective silencer off of an existing one (the tube being the silencer). You basically buy the Salvo 12 at its largest size and then lessen the effectiveness each time you reduce it by a segment. A bunch of companies are already making changeable length silencers.

[Bendersquint]

The reasoning behind the law is that you can make an existing can shorter, but you cannot add length to a can without "making" a new can. The idea is you cannot make a more effective silencer off of an existing one (the tube being the silencer). You basically buy the Salvo 12 at its largest size and then lessen the effectiveness each time you reduce it by a segment. A bunch of companies are already making changeable length silencers.

Agreed, however it is only allowed to shorten the length of the can to accommodate rethreading of the tube.

[batman4706]

You can make a FOIA request from ATF for the letter.

[Bendersquint]

You can make a FOIA request from ATF for the letter.

FOIA requests are not granted for letters.

[[email protected]]

You can make a FOIA request from ATF for the letter.

FOIA requests are not granted for letters.

So Bender, are you saying there's no way I can prove that the ATF has approved them/ruled that they are legal for civilians?

[[email protected]]

The reasoning behind the law is that you can make an existing can shorter, but you cannot add length to a can without "making" a new can. The idea is you cannot make a more effective silencer off of an existing one (the tube being the silencer). You basically buy the Salvo 12 at its largest size and then lessen the effectiveness each time you reduce it by a segment. A bunch of companies are already making changeable length silencers.

Not what I'm asking at all. Maybe I wasn't clear enough.

[Bendersquint]

You can make a FOIA request from ATF for the letter.

FOIA requests are not granted for letters.

So Bender, are you saying there's no way I can prove that the ATF has approved them/ruled that they are legal for civilians?

Correct, there is no way to verify it if the letter writer does not distribute the response letter.

[whiterussian1974]

It seems like if ATF approves a F4 Transfer to an Individual, Trust, LLC; then that is De Facto proof of their acceptance.

I was SHOCKED when I read an article about this item in a Gun Mag. But if the Mfr publishes their ATF Letter or F4s go through, it seems like future prosecutions would be tinuess(sp.) (ie: difficult)
Maybe these are only for Foreign/LE/Mil Sales?

[Bendersquint]

It seems like if ATF approves a F4 Transfer to an Individual, Trust, LLC; then that is De Facto proof of their acceptance.

I was SHOCKED when I read an article about this item in a Gun Mag. But if the Mfr publishes their ATF Letter or F4s go through, it seems like future prosecutions would be tinuess(sp.) (ie: difficult)
Maybe these are only for Foreign/LE/Mil Sales?

What is proves is that the letters on the Form4 matched the NFRTR database and NOTHING more.

Doesn't prove that they are legal just that the form matches the database entry.

[whiterussian1974]

It seems like if ATF approves a F4 Transfer to an Individual, Trust, LLC; then that is De Facto proof of their acceptance.

I was SHOCKED when I read an article about this item in a Gun Mag. But if the Mfr publishes their ATF Letter or F4s go through, it seems like future prosecutions would be tinuess(sp.) (ie: difficult)
Maybe these are only for Foreign/LE/Mil Sales?

What is proves is that the letters on the Form4 matched the NFRTR database and NOTHING more.
Doesn't prove that they are legal just that the form matches the database entry.

So the AFT and US Gov are CoConspiritors to any Unlawful Activity. And as Gov't Entity they have Sovereign Immunity.
Thanks Progressives/Erosionists!
Only the Gov't can lawful disregard the Laws they Themselves have: Authored(House), Passed(Senate), Approved(Executive), and Sustained(US SupCourt).
Hence my Profile Pic.

[savagetactical]

I may be mistaken since I'm not a manufacturer, but I believe that in order to get approved to make the suppressor they had to submit the design to the ATF prior to making/marketing the cans. If not, they've expended a lot of money and effort in marketing and development of the can.

The OSS suppressor already does that with the Signature Reduction Module (SRM) for their suppressor and it's been in the wild for a while now.

[[email protected]]

I may be mistaken since I'm not a manufacturer, but I believe that in order to get approved to make the suppressor they had to submit the design to the ATF prior to making/marketing the cans. If not, they've expended a lot of money and effort in marketing and development of the can.

The OSS suppressor already does that with the Signature Reduction Module (SRM) for their suppressor and it's been in the wild for a while now.

That's what I thought, but perhaps I'm wrong. Perhaps the mfg can make and sell whatever they want. Then if the ATF finds said item to be illegal, they confiscate them....idk.... I know that a rep from SCo told me that they submitted "something" (maybe an application or drawings/sepcs) to the ATF which was in fact approved by the ATF prior to the media release of the Slavo. Maybe I was misinformed.

[whiterussian1974]

I may be mistaken since I'm not a manufacturer, but I believe that in order to get approved to make the suppressor they had to submit the design to the ATF prior to making/marketing the cans. If not, they've expended a lot of money and effort in marketing and development of the can.
The OSS suppressor already does that with the Signature Reduction Module (SRM) for their suppressor and it's been in the wild for a while now.

That's what I thought, but perhaps I'm wrong. Perhaps the mfg can make and sell whatever they want. Then if the ATF finds said item to be illegal, they confiscate them....idk.... I know that a rep from SCo told me that they submitted "something" (maybe an application or drawings/sepcs) to the ATF which was in fact approved by the ATF prior to the media release of the Slavo. Maybe I was misinformed.

They submit an idea and request a "Determination Letter." Which is essessially a pre-authorization.
ATF can (and has) changed its mind and later revokes permission, and invalidates its own Determination.
Then the Mfr is stuck w Inventory. THey can still try to sell to LE Agencies or Military. Though sometimes at a loss, though better than a complete loss through inventory distruction.
Sometimes Gov't really gets nasty and just confiscates Inventory. Just like any good Dictatorship.

[savagetactical]

One thing you're forgetting about is ATF stands to loose a lot of money in the form of $200 tax stamps if they disapprove the sale of Salvos. Most of the things that ATF changes their determination letter on are things that try to get around the NFA - like the Sig brace, their MPX muzzle brake, the stock that used springs to bump fire before the slide fire (forgot it's name), etc. at this point in the game if ATF wasn't going to approve it I'm sure we would have heard about it by now from an official source besides a forum.

I may be mistaken since I'm not a manufacturer, but I believe that in order to get approved to make the suppressor they had to submit the design to the ATF prior to making/marketing the cans. If not, they've expended a lot of money and effort in marketing and development of the can.
The OSS suppressor already does that with the Signature Reduction Module (SRM) for their suppressor and it's been in the wild for a while now.

That's what I thought, but perhaps I'm wrong. Perhaps the mfg can make and sell whatever they want. Then if the ATF finds said item to be illegal, they confiscate them....idk.... I know that a rep from SCo told me that they submitted "something" (maybe an application or drawings/sepcs) to the ATF which was in fact approved by the ATF prior to the media release of the Slavo. Maybe I was misinformed.

They submit an idea and request a "Determination Letter." Which is essessially a pre-authorization.
ATF can (and has) changed its mind and later revokes permission, and invalidates its own Determination.
Then the Mfr is stuck w Inventory. THey can still try to sell to LE Agencies or Military. Though sometimes at a loss, though better than a complete loss through inventory distruction.
Sometimes Gov't really gets nasty and just confiscates Inventory. Just like any good Dictatorship.

[Bendersquint]

It seems like if ATF approves a F4 Transfer to an Individual, Trust, LLC; then that is De Facto proof of their acceptance.

I was SHOCKED when I read an article about this item in a Gun Mag. But if the Mfr publishes their ATF Letter or F4s go through, it seems like future prosecutions would be tinuess(sp.) (ie: difficult)
Maybe these are only for Foreign/LE/Mil Sales?

What is proves is that the letters on the Form4 matched the NFRTR database and NOTHING more.
Doesn't prove that they are legal just that the form matches the database entry.

So the AFT and US Gov are CoConspiritors to any Unlawful Activity. And as Gov't Entity they have Sovereign Immunity.
Thanks Progressives/Erosionists!
Only the Gov't can lawful disregard the Laws they Themselves have: Authored(House), Passed(Senate), Approved(Executive), and Sustained(US SupCourt).
Hence my Profile Pic.

Most of the time the ATF doesn't know what a product is till they receive one for a determination or someone sends a opinion letter asking about it.

Every F2 i have dropped includes basic specs and NO details about it being serviceable, or anything I don't choose to disclose/ask about.

They approve the transfers because the data on the F3/4 matches the F2 NFRTR entry.

If you ask your mom for $20 and never explain what it was for because thats your allowance then does it make her a co-conspirator because you bought drugs with it?

Remember we are all ASSUMING that all the manufacturers making user configurable silencers submitted requests for determinations.........why not post them if they did?

[Bendersquint]

I may be mistaken since I'm not a manufacturer, but I believe that in order to get approved to make the suppressor they had to submit the design to the ATF prior to making/marketing the cans. If not, they've expended a lot of money and effort in marketing and development of the can.

The OSS suppressor already does that with the Signature Reduction Module (SRM) for their suppressor and it's been in the wild for a while now.

There is no requirement to submit designs to the ATF, it is on the companies shoulders to be certain that it is legal if they choose not to use the legal service of verification that the ATF provides manufacturers.

If it is determined at a later point that it is prohibited then the ATF steps in to correct the situation, often at the penalty of the manufacturer.

Case in point......YHM pistol can pistons.

[Bendersquint]

They submit an idea and request a "Determination Letter." Which is essessially a pre-authorization.
ATF can (and has) changed its mind and later revokes permission, and invalidates its own Determination.
Then the Mfr is stuck w Inventory. THey can still try to sell to LE Agencies or Military. Though sometimes at a loss, though better than a complete loss through inventory distruction.
Sometimes Gov't really gets nasty and just confiscates Inventory. Just like any good Dictatorship.

No requirement to submit samples for determination....its a smart idea but it is not required. If its something new or radical its really suggested so you don't have to recall or deal with ATF issues.

Yes, the ATF does change their mind at times and there are ways for manufacturers to deal with those contradictions.

I have yet to see or hear of any licensed manufacturer having inventory confiscated by the ATF. You can PM me if you have details and don't want to publicly divulge about a company that has had that happen.

[Bendersquint]

One thing you're forgetting about is ATF stands to loose a lot of money in the form of $200 tax stamps if they disapprove the sale of Salvos. Most of the things that ATF changes their determination letter on are things that try to get around the NFA - like the Sig brace, their MPX muzzle brake, the stock that used springs to bump fire before the slide fire (forgot it's name), etc. at this point in the game if ATF wasn't going to approve it I'm sure we would have heard about it by now from an official source besides a forum.

The ATF doesn't stand to loose much, $200 is 1/10 pennies to the .gov.....if they approved 1000 of them its only 200K million......look at our debt, 200K is not a big deal.

Now refunding everything in the NFRTR, THAT would cause a little concern in the .gov seniors lounge.

[[email protected]]

Bender, So there is a determination letter out there some where? If not, should I just write the ATF ?

[[email protected]]

Is anyone here leery of purchasing a Salvo due to all the skepticism regarding the "extra parts" issue?

[whiterussian1974]

The ATF doesn't stand to loose much, $200 is 1/10 pennies to the .gov.....if they approved 1000 of them its only 200K million......look at our debt, 200K is not a big deal.

Now refunding everything in the NFRTR, THAT would cause a little concern in the .gov seniors lounge.

Spot ON!
"A 100 Billion here, 80 Billion there, and pretty soon you're talking about real money." - Unknown Budget Committee Member.

[whiterussian1974]

IIRC in the Article I read, it intimated that they sell the full size device. Then, the End-user can (temporarily) remove individual sections for specific applications. (Want it shorter, lighter, louder, whatever on 1 firearm, but not another.) This case would be similar to a user servicable can having a baffle removed and later the same baffle replaced.
Has a New Suppressor Part been created?
Does cleaning the part outside of its tube constitute a crime?
My guess is no.
But, Bender knows FAR more about Industry Specific legal issues/updates than I do.

[whiterussian1974]

So the AFT and US Gov are CoConspiritors to any Unlawful Activity. And as Gov't Entity they have Sovereign Immunity.
Thanks Progressives/Erosionists!
Only the Gov't can lawful disregard the Laws they Themselves have: Authored(House), Passed(Senate), Approved(Executive), and Sustained(US SupCourt).
Hence my Profile Pic.

If you ask your mom for $20 and never explain what it was for because thats your allowance then does it make her a co-conspirator because you bought drugs with it?

Remember we are all ASSUMING that all the manufacturers making user configurable silencers submitted requests for determinations.........why not post them if they did?

A: Depends upon which neighborhood in Houston you are in. (Truly.) That's why parents should always ask what money is intended for. Otherwise they HAVE committed Conspiracy to Transfer Schedule (2-4) Controlled Substance.
B: You make a good point about Mfr posting Determination Letters.
Yet, it is remarkably stupid to spend $10,000s on R&D, then more $$$ on Marketing, and more $$$ on Production making something that is even ?able w/o getting and Opinion or Determination Letter.
Hard to Imagine a Large or Established Corp making such a noobie mistake.

ETA: I posted the above. Then switched tabs and later learned that this post never went through. So I'm resending it.

[Bendersquint]

Is anyone here leery of purchasing a Salvo due to all the skepticism regarding the "extra parts" issue?

I know at least a dozen people that want to buy it but won't until they know their investment is safe. Dozen is a small number but I think its a good idea of scale.