Again, FFL's are irrelevent for transfers between MA residents. What matters is that when one party no longer has a valid FID or, in this case involving a Luger, a valid LTC, the transaction no longer qualifies for the exemption language that allows private party "FTF" transfers in MGL 140/128 and 128A. In such a case, the gun then has to go through a party with a Massachusetts Gun Dealer's License. While it is true that almost all MA dealers have FFL01's, the problem is not that your C&R is any less of an FFL license--its that you don't also possess a MA dealers license.