The letter pokinfun posted a link to concerns FFLs and unlicensed manufacturers doing work on firearms without a manufacturing license. Loaning (not renting) a friend a jig to complete a 80% lower is not illegal unless he is pumping them out by the dozens to sell for profit, in other words doing it as a business.
It's basically the same thing as selling your firearms. Technically, you are not supposed to buy and sell firearms on a routine basis without an FFL. It's all about your intent.
Disagree. It specifically applies to Gunsmiths, FFLs, and businesses, but per the following, not limited to:
**************************
"
Held,
any person (including any corporation or other legal entity) engaged in the business
of performing machining, molding, casting, forging, printing (additive manufacturing) or other
manufacturing process to create a firearm frame or receiver, or to make a frame or receiver
suitable for use as part of a “weapon ... which will or is designed to or may readily be converted
to expel a projectile by the action of an explosive,”i.e., a “firearm,” must be licensed as a
manufacturer under the GCA; identify (mark) any such firearm; and maintain required
manufacturer’s records.
Held further,
a business (including an association or society) may not avoid the
manufacturing license, marking, and recordkeeping requirements of the GCA by allowing
persons to perform manufacturing processes on blanks or incomplete firearms (including frames
or receivers) using machinery, tools, or equipment under its dominion and control where that
business controls access to, and use of, such machinery, tools, or equipment.
"
**************************
By my reading of that, if any entity (non individual person) charges for or holds control of access to the tools/machinery, then it is illegal.
An individual (not group, business, trust, etc) may allow someone else to use their tools/machinery, and control access to such, and be legal; however if they charge for such then it is illegal.
My understanding of the context is that this is not aimed at the buddies working on an 80% lower in their private shop, but the publicized "build parties" with any kind of entry fee or using business property.