This thread has become convoluted. My statement was in regard to your statement that everything (including lowers) had to be FA-10'd before her edict.
Personally, I would choose to ignore her "edict" for the following reasons:
- As a police officer (now retired) if I cited someone on criminal charges, I MUST put down MGL C. x S. y. Referencing a press conference, a memo, or an FAQ does not comply with MGLs on criminal prosecutions.
- MGL clearly delineates what is legal and illegal and it is a cut and paste from the Clinton Ban (Fed Law) with tons of BATFE Letter Rulings during those 10 years (1994-2004) to back up what is legal.
- Nobody has nor will be prosecuted because a good defense attorney would blow her BS out of the water due to the above. She's had almost 4 years to prove me wrong and nothing has been done by her office to do so. Keep in mind that AGs don't prosecute individuals, it is the local police and DAs, neither of which work for her (and thus she can't order them to do something . . . Harshbarger tried that and the police chiefs told him to stuff it back in 1998).
- Even regarding dealers, I've spoken with a few. Her letter stated that as of "date x" it is illegal to transfer . . . Yet those letters to every dealer were sent First Class Mail (no signature/receipt). One dealer I spoke with received his letter 3 days after the deadline for legal transfers, the other dealer received his letter 5 days after the deadline. Again, even prosecuting dealers wouldn't be possible when they weren't timely notified, so short of "threatening phone calls" about transfers long after they should have received those letters, she hasn't taken any action against them either. FUD has been effective (no doubt her intent) in shutting down sales, making owners scared to show them at the ranges, making private buyers paranoid, etc.
If one carefully registers a gun with the eFA-10 system, FRB has no idea where it came from. The AGO has been scouring FA-10s filed by dealers but not by individuals according to all the info I've read. PDs aren't "door-knocking" "papers please" either.
