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Welllll...... sure.Can you transfer a unserialized firearm between private parties in states that allow private transfers without FFL?
But not legally.
Once built into a firearm it requires a serial number before it can legally be transferred. All this s**t about ghost guns is already covered, but adding nonsense regulations on top of other nonsense regulations is what they do. The new ATF regulation is to keep the ORIGINAL owner from having an unserialized firearm.