Random question here. I've never purchased a lower or built an AR but my understanding is that you have to fill out the federal 4473 when you purchase a lower but you don't have to do the EFA10 until the rifle is assembled and operating. What happens now when someone tries to do an EFA10 for a rifle that they just built from parts and pieces that may or may not have been purchased before 7/20/16? Do they track the purchase date of the lower and use that date? What about 80% lowers? I feel like this whole thing is so confusing that there must be tons of NEW loopholes.