There is in fact another option. We all tend to use the terms "dealer" and FFL as if they were interchangeable. The EOPS and AG regulations apply only to dealers who are licensed by the state. Since all of these people are "in the business", they all have to have federal licenses in addition to their state licenses. However, a person can hold an FFL without meeting the state criteria for being in business. There are very few such people, since BATF (with the encouragement of larger dealers and their trade association) has actively attempted to refuse licenses or renewals for them. Wtill, there are a few people who manage to satisfy BATF that they are indeed engaged in business, even though they do not have state licenses. Of course that means that, just like you and me, they're limited to no more than 4 sales per year, except to other dealers. One of those people could legaly do the transfer for you, although they'd have to be a very good friend to be willing to use one of their four sales for a transfer. This isn't just hypothetical, since I know one such person; he was licensed by the state until they refused his renewal arguing that his separate building (from shich he'd done business for over 10 years) suddenly didn't meet their new secret criteria for a business.
Ken