Benelli M2 Field and Federal 922r

solv3nt · Mar 29, 2021

I've been wanting a Benelli M2 for playing three gun later, but haven't gotten around to it. Biden mentioned imports on Friday. Seeing as the Benelli is an import, I jumped on a 21" Field model with a C-Stock.

My question regards 922r, I'm finding a lot of information on the M4, but not as much on the M2. All the information is from a few years ago. I've got an outstanding call to the ATF, but does anybody know if I can add my magazine extension without swapping for American parts?

ORhutner · Mar 29, 2021

You will find two distinct camps here as I have done the same research for an M4. Group one firmly believes that 922R doesn't apply to individuals and there is no case law precedent to backup their stance one way or another which is the argument they use for 922R not applying. The other group believes that it does apply and that you have to swap out 3 parts for USA made for 922r compliance (as you likely know, # of parts varies from gun to gun but I believe the M2 is the same as the M4 for # of parts to be swapped). For me the parts I wanted to change are USA made and of a quantity it is a mute point as I will be 922r compliant whether it applies or not.

solv3nt · Mar 29, 2021

Since it has the C-Stock, it looks like it may be allowed one evil feature such as the extended tube as long as it doesn't have a pistol grip.

solv3nt · Mar 29, 2021

478.11 definitions states if you have two evil features, you're required to comply. The evil features are pistol grip, more than x rounds, or detachable magazine. Since it is a C-Stock, my interpretation is that I can add my monster extension tube and 922r doesn't apply unless I have a pistol grip stock.

L84Cabo · Apr 10, 2021

ORhutner said:
You will find two distinct camps here as I have done the same research for an M4. Group one firmly believes that 922R doesn't apply to individuals and there is no case law precedent to backup their stance one way or another which is the argument they use for 922R not applying. The other group believes that it does apply and that you have to swap out 3 parts for USA made for 922r compliance (as you likely know, # of parts varies from gun to gun but I believe the M2 is the same as the M4 for # of parts to be swapped). For me the parts I wanted to change are USA made and of a quantity it is a mute point as I will be 922r compliant whether it applies or not.

Agree on the two camps. However, if the references that have been posted to the interwebz are legit, I would note that the ATF has responded in writing with regards to 922r compliance and modifications to the m4 (maybe to other guns as well but I'm not familiar with those). Clearly the ATF believes it's relevant and that was good enough for me when I was doing my m4.

OP, I believe the m4 list would apply to the m2 as well. Freedom Fighter Tactical has a video on the m2 and 922r so give that a check. Linky below and scroll down.

Learn 922(r)

**READ THIS PAGE THOROUGHLY AND WATCH THE VIDEOS AT THE BOTTOM OF THE PAGE FOR AN UNDERSTANDING OF 922(r). If you call us to ask questions about 922(r), you'll just get linked back to this page. Anything I could possibly tell you in an email, you'll find here. This page specifically addresses...

freedomfightertactical.com

If you still have questions you may try posting on the forum on Benelli's website. That was always the best resource I found for all things Benelli and the folks were always pretty helpful.

SCARed · Apr 10, 2021

Maybe 3 camps are out there. The 3rd would be that Yes, 922 applies, but really, who cares. There is no way to prove where something was made. With all the small parts in a firearm, not you, not the ATF can prove where each part was made. They aren't marked. There has also not been a single action taken by the ATF with 922r being the primary cause.

solv3nt · Apr 10, 2021

SCARed said:
Maybe 3 camps are out there. The 3rd would be that Yes, 922 applies, but really, who cares. There is no way to prove where something was made. With all the small parts in a firearm, not you, not the ATF can prove where each part was made. They aren't marked. There has also not been a single action taken by the ATF with 922r being the primary cause.

I did call up the ATF, the agent's understanding was that 922r only applies to the importer, and doesn't apply after it has been imported.