I hadn't chatted with the NFA branch for a while, figured it'd be a good time and to find out when my stuff went pending too (mid June, looking at clearing in December).
Per specialist Janice Fields:
Shorter barrel than on the Form 1? No problem, an SBR is an SBR. A permanent change requires a form of course.
Ordering parts before you have a form 1 in hand? I don't like the answer:
It's OK to get parts but don't store them in the same place as the other parts that would allow an SBR to be assembled until you get the Form 1. Before anyone points out that makes no sense and is contrary to the FAQ, I agree, that position has more holes than Swiss cheese.
What does make sense is that realistically in some cases you absolutely NEED the parts in hand in order to correctly fill out the form 1 (like overall length). Sounds like the NFA branch is willing to "overlook" short-term possession (but not assembly, of course) of the necessary parts. No, I don't like being told "Don't worry, be happy, we won't arrest you."
I was referred to one of their technical folks for my questions about possessing a mix of short and long uppers and a mix of normal and SBR lowers, as well as engraving. That will have to wait until sometime next week.
O2
Ps. On engraving: Your firearm is a title I firearm, not governed by any kind of NFA rules until it becomes a title II by approval of the Form 1. At THAT point what Ken Mason has to say matters. Until that time, it’s a plain-Jane title I firearm, and you can engrave anything your heart desires on a title 1 firearm (for example it might be a good idea to engrave your name, city and state on the receiver in case it gets lost or stolen). But I’m still going to chat with the technical folks about it.