I don't understand this statement because they are making you fill out a form that is sent to the state that they keep a record of and at the top of the form is a place to check off that says registration if a long gun is bought out of state so to me no matter how you slice it it is registration.
It's not registration in the typical sense because of a few circumstances:
-There are occasions where you can legally have guns that aren't registered here, ever. (EG, you are moving into the state, or you are operating as a nonresident in MA with a nonres LTC- none of your crap in MA has to be registered in either case!)
-Years ago the state destroyed a crapload of transfer documents because they were contaminated with bird/rat feces. These never got put into the electronic system. So any old guys who have owned lots of guns probably don't functionally have half their stuff in the MA system because of this.
-You're borrowing someone else's gun. Since you don't own it, there is no transfer, and no "registration".
-Another fun example- not so much now but in the old days- if a dealer forgot to file the FA-10 (or lost it, or screwed it up) when you bought the gun, it's their fault, not yours. (seller is obligated to file).
-You will NOT get sent to jail for having an unregistered firearm in MA. The compulsory element is "reporting a transfer". There is no onus on the gun owner legally to do anything other than that. If the state lost your FA-10 or didn't put it in the system properly it's not your problem- there is no onus for you to maintain correct records with the state. The only legal obligation is that you notify CHSB of transfers (when necessary) as outlined in the law. Anything beyond that = not your problem. Contrast this with typical compulsory registration setups,
where your gun not being in their database = prima facie evidence of a crime. That's not the case in MA.
I understand the typical argument that the state is maintaining a list of transfers you perform, which is an ugly thing, that is registration. I suppose in that realm it certainly is... it is not, however, a system like the one MI had (maybe still has?) in place where you can face criminal liability if you are caught with an unregistered handgun.
-Mike