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The "rule change" says you had to have it prior to the "grace period".
This is correct for the brace amnesty.

You can always pay $200 and do normal sbr form 1 and then it doesn't matter. Timeline for these is faster than brace rule based on reports. I've heard as fast as 10 days (at the fastest) recently.
 
As stated above, if you are trying to do the "free" amnesty Form 1 the rule is that you were required to have a braced pistol prior to the rule change.

If you want to build a Form 1 SBR it does not matter what it starts life as, but you have to pay the $200 transfer stamp.
 
If you acquired the serialized lower pre Jan 31st I would imagine that you already had a brace and upper on it prior to that date, and you are merely asking for a friend .
 

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