DEPARTMENT OF THE TREASURY
BUREAU OF ALCOHOL, TOBACCO AND FIREARMS
WASHINGTON, DC 20226

JAN 04 2000

901040:GS
5320/990519

Mr. XXXXXXX X. XXXXXXXX
XXXXX X.X. XXXXXX XXXXXX
XXXXXXX, XX XXXXX

Dear Mr. XXXXXXXX:

This is in response to your letter dated December 15, 1999 asking whether the Bureau of Alcohol, Tobacco and Firearms (ATF) requires an ATF Form 5 for the repair of a National Firearms Act (NFA) firearm.

We do not consider the conveyance of an NFA firearm for repair or gunsmithing to be a transfer as defined in the NFA. You may wish to refer to item 15 in the "Questions and Answers" section of ATF P 5300.4, Federal Firearms Regulations Reference Guide, for a discussion of this subject. An ATF Form 5 application is not required in this situation; however, we recommend that the repair or gunsmithing be documented in your records.

Should additional information be needed, please contact ATF Specialist Gary Achaible at (202) 927-8330.

Sincerely yours,

[signature]

Kent M Cousins
Chief, National Firearms Act Branch