From what I understand your Option 1 is just fine. An approved Form 1 allows someone who is not a manufacturer to build an SBR, SBS, AOW, sound suppressor, etc. If you read the fine print on the Form 1 you'll see that a Class 2 manufacturer is not required to file a Form 1, only someone who is not a manufacturer. This allows you to build an SBR from an existing weapon. You will need a serial number so if you use an Ace blank or U-Fold-It type then you will need to stamp the receiver with a serial number of your own choosing before sending in the paperwork.
The order of assembly is probably an important issue when building a weapon of this type. If you assemble the receiver, then press in the barrel prior to lengthening the barrel to the legal 16" then you have illegally build an SBR and if someone were to walk in to your shop at that moment you would have a problem. The better way to do it would be to permanently fasten the fake can to the barrel prior to installing the barrel in the receiver. Of course if you already have an approved Form 1 in your hands before the barrel is installed then this would be a nonissue.
I believe that your main question was "Is a licensed gunsmith required for building an NFA weapon?" I really think the answer to this is no. A homebuilt 100% receiver is considered identical to one that was built commercially, from a legal standpoint anyway, once you add the serial number to it. Therefore, since a receiver is considered to be a complete firearm from the point of view of the law, why would any kind of licensed manufacturer be required just to cut off the end of a barrel? Why would the Form 1 even exist since a Class 2 manufacturer doesn't need it?
One more reminder which you probably already know, don't forget that the AWB still applies to SBRs despite their NFA status. In other words, as silly as this is, you cannot put a folding stock or flashhider on a postban SBR. Make sure you wait until September if all goes well.
If I were you I would double check the information given above. I believe that it is correct and it is what I am planning on using for my own build, however you may want to double check for your own peace of mind.
Hope this helps. :cheers:
If there is something here that I have posted and is blatantly incorrect please correct me. We are all here to learn and I am not above being corrected by someone who knows more than I.
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