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I believe it depends upon the condition of the firearm when being bought by the FFL. What I mean is if you sell your firearm to a dealer in parts then the dealer can sell it as parts. If you sell the firearm as an operating whole then the dealer has to sell it as a firearm and would not have follow the 1639 non-sense.
I see the FFL I normally use for transfers advertising both whole firearms and 'assembly required' firearms. So, I would suggest taking apart your firearm before selling or transferring to a FFL.
I see the FFL I normally use for transfers advertising both whole firearms and 'assembly required' firearms. So, I would suggest taking apart your firearm before selling or transferring to a FFL.