I'm reading the February, 2019 magazine from Washington Arms Collectors (WAC), and they are indicating there might be an exemption based on the Federal Curio & Relic (C&R) license. The C&R license allows the license holder to transfer firearms older than 50 years and other specifically-listed firearms without using a dealer FFL. Per the WAC, some likely benefits of having your own C&R license: The C&R license holder can purchase a C&R firearm without a NICS check. C&R firearms are for your collection, enter them into your record book, but no registration at State or Federal levels. The C&R license holder can purchase C&R-compatible semi-auto rifles and possibly avoid some of the legislation under I-1639. Do your research on this one though. The above is in no way legal advice, but one might want to explore it. One may apply at atf.gov to apply, perhaps a $30 fee.