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From what I have understood, concealment holster rigs escape the "AOW" designation if the slide is exposed. such as the DeSantis example below.
In Ocarolan's linked ATF literature, the old Galco holster is shown, which completely covers a pistol like the AMT .380 Backup, (although in this example an old High Standard 2 shot derringer) thereby making it an AOW.
DeSantis:
https://www.budsgunshop.com/catalog/images/hiRes/411553118_3.jpg
Old Galco: (out of production)
https://www.atf.gov/firearms/firear...irearms-national-firearms-act-definitions-any
My Wife had bought one of those Galco ones shortly after she started to carry. Was using it for a little .22 auto. She of course did not like it. If I had known she was going to buy it I would have tried to talk her out of it. It did work and you could fire the pistol in the holster. It was just VERY hard to be accurate at all with it. It got tossed into the junk box of holsters that we both tried and did not like. Years later I heard what the BATF had done. I dug it out and put it up on Ebay. With the warning that to use it was now an AOW. People went nuts biding the damn thing. It's such a simple design any kid with a Tandy leather kit could make one in no time. Someone won it and paid. He paid me about 4 or 5 times what the Wife bought the stupid thing for which I did not understand. I figured what the hell. He was happy and I was sure happy.