PSA: PlumCrazy Polymer Lowers ILLEGAL Says Letter from BATFE

PlumCrazy-Lower

PlumCrazy was a brand of polymer AR-15 lower receivers that were manufactured by PCF Manufacturing until they mysteriously went out of business in late 2011. Recently, a company, whose name I have been asked not to disclose, sent in a sample of a PlumCrazy lower to the BATFE to find out if the method they used to attached the metal serial number plate to the polymer lower was legal. Turns out, its not! PlumCrazy lower receivers are illegal, and have always been illegal under Federal Law.

Metal serial numbers plates attached to polymer firearms must be embedded in such a way that removing them will significantly damage or destroy the firearm. In the BATFE letter, dated June 18 2013, Firearms Technology Branch technicians were able to remove the PlumCrazy serial number using just a hammer and a screwdriver in just one minute and without doing any damage to the receiver. The letter says …

During the examination of the submitted AR- 15 type firearm receiver section (serial number RM00501 ), FTB also found that both the height and depth of the serial number markings are acceptable and thus compliant with§ 478.92. With respect to the adequacy of the attachment of the insert for this frame, the FTB evaluation revealed that the serial number consisted of a thin sheet of metal-like material and was attached to the surface of the embedded metal insert. This serial number was easily removed when a hammer and screw driver were used to peel the sheet off of the metal insert. This action took approximately 1 minute and caused no damage to the receiver. (See enclosed photos depicting the removal of the serial number insert.)

… the method used to attach the serial number insert (serial number RM00501) on the partial receiver sample is not compliant with Federal Law.

PlumCrazy-illegal-reciever

A photo of the PlumCrazy lower from the BATFE Letter

batfe

Signed Earl Griffith, Chief, Firearms Technology Branch

The last thing posted on the PCF Manufacturing website, dated 6 October 2011, was this message (copied verbatim, including spelling errors and odd punctuation, emphasis added) …

If you’re confused because you were looking for PlumCrazy Firearms,don’t be -·you’re in the right place; we are just adding a variance to our licence. Our composite lowers will carry the new branding and maintain the high level of quality you’ve come to expect from our products. We wil,l however, be phasing out the Plumcrazy branded lowers, so get them while you can! So what’s the reason for the branding change? Well, as we have more law enforcement and military wanting to use our products, having “PlumCrazy” on the side of the magwell may not be the best· idea……, that’s it -·no conspiracy or anything, just a simple business decision that allows us to further broaden our market place. What’s this change mean to you? Well, nothing unless you just can’t live without seeing “Plumcrazy” on your lower. We plan to maintain the same price point as before, and·continue to provide you with·the best customer service in the industry

PumCrazy lowers were quite popular. There could be thousands of gun owners around the country who, in good faith, purchase an illegal product.

UPDATE: Just to clarify, this letter is not online anywhere as far as I know. I do have the entire letter. The letter covers a number of unrelated questions a manufacturer asked the BATFE. Nothing else in it is newsworthy or interesting. I was asked not to publish the rest of the letter and so I will not.

UPDATE: David Famiglietti and his company New Frontier Arms were not mentioned in the above post but David Famiglietti has been harassing us, making accusations and and throwing around insults (Apparently I am both Piers Morgan and also not a man).

Phil was about to call David, when I decided it would be better to have his response on file, so I instead emailed David asking him a number of questions and asking him to provide proof that the PlumCrazy lowers and his own lowers were legal. 

Hi David,

You want to share you side of the story with me. I am not actually sure how you were involved with PCF. While it is obvious that PlumCrazy lowers and your New Frontier lowers were at some point based on the same mold, you will notice I never mentioned New Frontier in my blog post. You are welcome to share any information with me. If I believe it is necessary, I will set the record straight.

I would ask that you also answer the following questions point by point. None of these are sensitive questions, but they provide context for this discussion.

1) What happened to PCF? Why did it go out of business?

2) How were you involved with PCF?

3) Who owned PCF?

4) Does New Frontier use the same or modified molds as PCF uses?

5) Which company just lost a lawsuit against New Frontier? What was the lawsuit about?

6) Are all PlumCrazy lowers illegally serialized, only some, or the only PlumCrazy lower serialized illegally as the one submitted to
the BATFE last year?

7) Can you provide me with a letter from the BATFE confirming that the PlumCrazy lowers are serialized legally?

8) Can you provide me with a letter from the BATFE confirming that the New Frontier lowers are serialized legally?

Regards, Steve Johnson

Our conversation was of course on record. He had been on TFB discussing this issue, hurling insults, saying we got it all wrong and that he could not get in touch with me to discuss it. He could not then claim in the 4th email I received from him, and in reply to my reply, that we were having an off the record conversation.

I want TFB readers to see his entire response in full so you can make up your own mind. David cannot accuse me AGAIN of taking things out of context.

Steve, again, I wish you would just call like a man so we can discuss the
issues, but if it’s easier to be behind a keyboard, I will re-type
everything I had to comment on today for you here. I understand that you
didn’t mention New Frontier Armory, but what you seem not to understand is
myself and other dealers sold thousands of Plum Crazy lowers as well as tens
of thousands of New Frontier polymer lowers and we are responsible to our
customers for those products, so we had to answer all the silly questions we
got today from concerned customers because of a one year old determination
letter you posted. You realize that a determination letter is not a law,
right? Or a regulation, right? It’s a onetime ruling/official stance on
ONE SINGLE PIECE OF PRODUCT that was sent in, not an entire product line.
You saying “ATF says Plum Crazy Polymer Lowers are ILLEGAL” is a blatant
misinterpretation of the facts, and you should clearly see that. Again, a
phone call would be much easier to clear up any confusion you have on this.
An easy question to ask you is if ATF sent this reply almost a year ago, did
they just decide to not enforce it or follow through with it after that? We
get traces all the time on PCF lowers. We’ve gotten ATF inspections where
agents have inventoried them along with thousands of other firearms on site.
Why were they not confiscated?

If you plan on using any of this e-mail in an article quoting me, I request
a phone call first for permission so I can check with other parties involved
in these matters that it may affect.

I will try to answer your questions the best that I can, but because of
pending legal matters and NDA’s that have been signed by myself, my
customers, and my vendors, I hope you can understand why I can’t disclose
some of the information requested.

Again, a friendly phone call from you anytime on my personal cell will
always be welcome and probably very helpful for both of us to better
understand each other’s point of view.

On to your questions:

1) PCF had earned a bad reputation in the industry for their horrible
customer service, and they were poor marketers. We were approached by an
injection molding company as PCF was failing about possibly selling their
products as well name branded for us, but they wouldn’t offer us an
exclusive deal because they had an ongoing relationship with PCF, who they
were also producing receivers on a variance for. We agreed to sell our
almost identical product alongside PCF’s, and within 3 months we had sold
more of our branded product than they had sold of their own PCF marked
lowers over an almost 2 year period. No one was buying their product any
longer because we offered the market an improved, more affordable, more
reliable product, with better parts, and extremely better customer service
and marketing to the public then they could offer. It got to a point where
they had no need to order anymore product and eventually withered on the
vine since they couldn’t compete. They also left the relationship with the
injection molder owing a substantial debt for product delivered.

2) I was not involved with PCF in any way besides being a dealer of their
product up until we released our own branded polymer lower, the LW-15

3) The original owners were Russ Maxwell and Ed Macinerney (2010 —
http://images.azcc.gov/scripts/cgi/dwispart2.pl) with Ed later leaving the
company on paper in 2012 (http://images.azcc.gov/scripts/cgi/dwispart2.pl)
after Russ took on an investor by the name of Brian Baumkirchner who
eventually bought all rights to PCF. There was much controversy over the
investment and not being able to pay back the investment, and from what I’ve
seen in legal documents that I had access to during litigation between
Baumkirchner and NFA, Baumkirchner was lied to about what PCF actually owned
(machines, molds, etc) and he came looking for his money from the molder and
NFA when the PCF guys pointed fingers are way. This has since played out in
court and is still an active court case where at this point, NFA has been
dropped from any accusations in the suit after being proved innocent of all
accusations, and the molder is in an ongoing leading preceding to recoup
lost profits, legal fees, etc from Baumkirchner.

Mcinerney later went on to start another similar company called E3 arms,
that has also withered away:

http://starpas.azcc.gov/scripts/cgiip.exe/WService=wsbroker1/names-detail.p?

name-id=L17393430&type=L.L.C.

Baumkirchner (with Maxwell in the background) started yet another similar
company which has also failed called U.S. Arms LLC which attempted to sell
the “Patriot 15″ polymer lower.

As stated in your article with a funny jab at the spelling and grammatical
errors on their website, they weren’t the best business man and could have
done much better with the product they had access to if they understood
public perception, customer service, and marketing. All of their ventures
have gone to shit with the fault only being them, not their products.

4) I can’t factually tell you that because I honestly don’t know as I have
the receivers made for NFA on a variance with an AZ company. I can tell you
that it is the same molder that was contracted by PCF, and the product is
almost identical with some minor design changes, and material changes on
several parts, including the receiver body itself to get more strength out
of the product.

5) The lawsuit details I am at liberty to share privately with you were
discussed in #3. For obvious reasons I can’t go into more detail at this
time because its an ongoing legal matter that involves friends and vendors
of mine. I will try to dig up the complaint for you with a link that was
made public about a year ago.
6) That I am aware of, and understand after speaking with the actual MFG,
there are NO illegally serialized Plum Crazy Firearm lowers that went out to
customers. Like stated several times today, and where your main
misunderstanding seems to be, is that I can send anything in with the New
Frontier name, or any company name to ATF for a determination. That does
not in any way mean that I will or should produce it that way in mass
production for distribution. It certainly would not be produced in that way
after ATF determines there is an issue with it. This has happened with
other products, and ATF simply asks the mfg to make changes to said products
to comply and everyone moves on with life. So no, according to ATF and the
actual mfg of the lower receivers, the lowers that made it to market are not
in any way illegal or in violation of any ATF regulation. If they were
action would have been taken on several occasions over the past year since
that determination letter was issued. I have good knowledge of the serial
number ranges produced as PCF and NFA, and I know the lower in that picture
was an initial demo lower produced for PCF, so I know one of the 3 mentioned
above (or one of their associates) sent that in after modifying it. I am
assuming it was E3 Arms and associates, since one of the captions on a
picture you posted in your article quoted “E3 Arms”.
7) No I can’t because I don’t possess that information since I am not / was
not the actual mfg of PCF lowers. I can however tell you from my experience
selling them, and later taking on a similar product line that the serial
number is on ONE piece of metal square tubing that is molded into the
receiver, very similar to Glock’s process, and meets all guidelines and
regulations posted by BATFE. Remember, just because you saw a letter that
says ONE sample that was sent in was not in compliance in NO WAY means all
produced were not. I read in the letter (or the small part of the letter
you revealed) That the serial number was on a second piece of “metal like
material” that could be peeled off. This is not the case on any PCF that I
sold as they all have box steel embedded with numbers engraved in them as
stated a few lines above. That leads me to believe it was modified before
sent to ATF to use as a “wild card” in ongoing legal battles with the
company involved.

8) Same story as #7. ATF has inspected the actual mfg as well as our
facilities and have assured us both that in no way are we having any
compliance or mfg issues. We ask every time a rumor like this pops on the
net and get the same answer: “If there was something we wanted change or
didn’t like, you’d hear it from us first, not a blog on the internet” (the
answer I got this morning from a local agent) and “If it wasn’t legal, do
you think we would let you keep making/selling them?” (the answer from an AZ
agent when the molder called them this morning)

Again, I hope you can see there is more to the story than you know, and I’m
not just some joker on the internet talking shit for no reason from Mom’s
basement. I hope there are no hard feelings, but hopefully even slightly
see where I’m coming from, and how this article could have startled some
already “scared of the gov” customers and vendors into a frenzy by not
understanding the whole situation. The upsetting part was the misleading
title and the article were based purely off the speculation that all lowers
were produced the same way to the one that was sent in to ATF for
determination. ATF made it clear in their response for a reason, so it
wouldn’t be misinterpurted. They clearly state that that ONE single part /
serial number is not in compliance. In no way has or will the ATF make a
statement saying that all PCF lowers are illegal (which is what your title
states vividly and in CAPS to emphasize “ILLEGAL”).
No hard feelings, and I’d love to hear back from you, especially a quick
phone call as time permits. Besides this article I enjoy following your
site, and have promoted links to articles on many occasions and will
continue to do so in the future. I hope we can move past this as industry
partners, if not friends.
Let me know if there’s anything else I can help explain!

-Dave

I am disappointed David could not provide any documents supporting his argument.

This ends the matter for TFB. Both sides have made their argument. Now you have Dave’s side of the story and you can make up your own mind.




Steve Johnson

Founder and Dictator-In-Chief of TFB. A passionate gun owner, a shooting enthusiast and totally tacti-uncool. Favorite first date location: any gun range. Steve can be contacted here.


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  • Sulaco

    Steve,
    Was there a BATF letter when they were developed and sold prior to the present determination? In other words were the lowers “legal” at one time and now they are not?

    • NightShade

      Likely not, manufacturer’s are not “required” to submit for approval but it is generally recommended. The problem is that the ATF can take years to send out a determination letter approving or disapproving an item.

      • Steve (TFB Editor)

        At risk of being flamed for defending the BATFE, I think they are better at replying to determination letters. But thats just anecdotal evidence (what I hear from manufacturers and inventors I know).

    • http://www.thefirearmblog.com/ Phil W “Senior Writer TFB”

      In short apparently not.

      • David M Famiglietti

        You spent a good bit of time on this, but actually never contacted the manufacturer of this receiver… what a joke! You should be ashamed of yourself for this piece of misleading fear mongering BS!

        • http://www.thefirearmblog.com/ Phil W “Senior Writer TFB”

          How would you know we didn’t?

          • David M Famiglietti

            Because I was sitting with the MFG all day long….thats how I know you haven’t spoke with them. Again, you’re confused and would love to clear it up over a polite phone call.

    • Steve (TFB Editor)

      These would never have been legal.

  • GhostalkerS

    Haha, whoops.

  • Ken

    This is stupid. Anyone who would not mind committing a felony by prying off the serial number plate also would not mind simply grinding the numbers off that plate if the plate itself were not easy to remove. I bet that a Dremel with a cutting wheel can remove the number in the same amount of time it takes to pry it off.

    • http://www.thefirearmblog.com/ Phil W “Senior Writer TFB”

      Yes but there are fairly easy methods to recover the serial number even if it’s gound down to nothing.

      • Giolli Joker

        Yes an No…
        If you blend the S/N up to just make it invisible most likely the layers of metal forming the new surface still carry the microstructural deformation that can be used to identify the markings (the same system is used to identify frames of vehicles when S/N has been deleted).
        But if you know this and you’re determined in your action, you just need to grind deeper.

        • http://www.thefirearmblog.com/ Phil W “Senior Writer TFB”

          From what I glean from the letter if you go deeper you do enough damage to make it inoperable by cracking the frame. I don’t know if that’s enough to do it but it’s enough damage for ATF.

          • scw

            I really doubted grinding deeper will crack the metal frame immediately. i.e. the gun may still function quite a few time before a failure cause render the gun un-usable. You will for sure weaken the structure in the long run by grinding deeper but it is determined criminal will just press ahead.

          • http://www.thefirearmblog.com/ Phil W “Senior Writer TFB”

            If a criminal does something along those lines it’s usually crud and easily recovered.
            I’ve never seen a thug that bothered to do much more than take a drill and grind it off less than 1/16th deep if that.

          • Ken

            I’m fairly certain you can straight up cut out the serial number on an aluminum lower and still have it be structurally sound. In that case, there’s no way they’re going to recover it by x-ray or acid etching.

          • BOB

            looking at the location of the SN on my aluminum lower, I have no doubt I could drill it out, completely, leaving a hole, and have a perfectly functional firearm

          • http://www.thefirearmblog.com/ Phil W “Senior Writer TFB”

            Probably so—

        • claymore

          DRILL out the offending metal no way to recover the number

    • Theo the Leo

      You could remove the serial number from a steel firearm without affecting the function. This seems to be a way to attack affordable guns, ala the Saturday Night Special BS.

      • http://www.thefirearmblog.com/ Phil W “Senior Writer TFB”

        Yea but you know that ATF is good at recovering serial numbers from steel guns.
        Maybe the point is they don’t find it as easy on a polymer gun therefore the policy they have.

      • Cymond

        I think it’s regarding the ease with which it can be removed. Sure, anything can be removed if you work hard enough, but how fragile is too fragile? Where do you draw the line? Serial numbers engraved directly in polymer? A paper sticker? There has to be a tipping point between the two extremes.

        • http://www.thefirearmblog.com/ Phil W “Senior Writer TFB”

          There is but the only way to know for certain is to read the law ATF goes by. Don’t expect it to be clear!

          Yes I do know it partly has to do with how easy it is to remove and how much damage it causes doing so.

      • http://www.thefirearmblog.com/ Phil W “Senior Writer TFB”

        This only applies to serializing polymer AR lowers

    • Michel_T

      Coming up on the 6 o’clock news: ATF to ban Glock pistols…

      Of course, said bans will not apply to government agencies…

      • http://www.thefirearmblog.com/ Phil W “Senior Writer TFB”

        No really this is just about the Plum Crazy and the method they used.

        • me

          I don’t speak for him, but I do believe that Glocks, and a number of other polymer framed handgun designs, have their serial numbers on a little bit of sheet metal embedded in the frame, very much like this. If BATFE can change their minds about one they can change their mind about the other, no matter that they’ve been saying it’s okay for 30+ years. BATFE makes it all up as they go along, always with an eye on ways to screw over gun owners. They’re not above contradicting themselves if it allows them to give gun owners a thumb in the eye.

          Does anyone else wish Reagan had disbanded BATFE when he took office, like he promised he was going to, and put enforcement of firearms laws and collection of Class II/Class III fees back in the hands of the Treasury Department?

  • OliverTabuger

    So are glock’s illegal? You can take the serial plate out of those without destroying it’s operability

    • http://www.thefirearmblog.com/ Phil W “Senior Writer TFB”

      No of course not—- It’s the method of attachment according to ATF rules.

      • OliverTabuger

        Of course, the serial number on any gun can be removed without destroying its function, but how is the glock serial number plate not removable like the PCF version?

        • http://www.thefirearmblog.com/ Phil W “Senior Writer TFB”

          It is but it’s still recoverable by ATF.

          • OliverTabuger

            What do you mean recoverable? And what is “it” referring to in your reply?

          • http://www.thefirearmblog.com/ Phil W “Senior Writer TFB”

            First ATF rules can make anyone’s head spin so the why is hard to figure.
            You can remove a serial number by grinding,prying etc. The division of the ATF that checks such things is very capable of recovering a serial number using various methods in the lab. That’s even if you think there’s no way they could.
            Simply ATF has approved methods of attaching serial number plates and the Plum Crazy was just not inline with the rules.

          • OliverTabuger

            Ok, so what I am asking is how is the glock method of inserting a metal plate different from the PCF method so that the glock method is acceptable, but the PCF method is not?

            ETA: The reg mentioned in your article doesn’t say anything about polymer guns so I assume this is all decided in private letters which ATF hasn’t released to the public.

          • http://www.thefirearmblog.com/ Phil W “Senior Writer TFB”

            That’s something you would have to ask the ATF or check the ATF website for the full criteria they use.
            The way the Glock plate is attached either causes significant damage and or leaves a print of the serial number under the plate. I’ve never pried a plate off so again that’s a question for the ATF.
            The letter above covers the legality of the Plum Crazy.

          • OliverTabuger

            The glock plate does not leave an imprint. I have never pulled one out to see exactly how it is attached, but there is no plastic behind the serial #. If you have one, take a look and see.

            My M&P plate seems similar to the PCF plate

            ETA: I’ll take a picture for you

          • http://www.thefirearmblog.com/ Phil W “Senior Writer TFB”

            Again I’m not an expert on this law. That’s something only ATF can answer with 100% certainty.

          • David M Famiglietti

            You should do more research before you keep posting more and more bullshit comments because you’re digging yourself a deeper and deeper hole of spreading unfactual information and misleading rumors.

          • http://www.thefirearmblog.com/ Phil W “Senior Writer TFB”

            The ATF letter is right there in what Steve posted. It seems pretty obvious.
            I’ve already said I’m not an expert on this law the ATF uses only the outcome.

          • http://www.thefirearmblog.com/ Phil W “Senior Writer TFB”

            Well David you say that’s what it is but what gives you the moral high ground and why should anyone believe what you’re saying without proof.

          • David M Famiglietti

            Its black and white in what you posted. I know exactly when and for who that serial number was made for, I know who submitted the lower to ATF, and I can read the black and white print in the letter that discusses one sample part sent in, not an entire production run of a certain product as your title and article clearly MISstates and MISinforms. We’re all in it together in this industry, so I hope you can understand why this upsets me when chaos is started from within without fact checking and researching. Again, a simple phone call from anyone on your staff (that have all received my cell phone number today) could solve this issue quickly and professionally and end all the back and forth banter.

          • http://www.thefirearmblog.com/ Phil W “Senior Writer TFB”

            I saw the copy of the letter after we posted here. I saw the pics they have over there.
            The point people are missing is this is about polymer AR lowers specifically the method Plum Crazy used.
            Other guns aren’t really a part of this since they have been approved obviously.

          • http://www.thefirearmblog.com/ Phil W “Senior Writer TFB”

            That is the case in this letter.

          • David M Famiglietti

            Where is this law you keep speaking of? Its attahced the same way as a Glock. You’ve been VERY misinformed my friend! You should get in contact for the facts. Spreading misinformation is very harmful to our cause as a community.

          • OliverTabuger
          • http://www.thefirearmblog.com/ Phil W “Senior Writer TFB”

            David I don’t know how many times I have to emphasize this is about the Plum Crazy lower. It was never meant to address any other gun.
            That law is what caused this letter to be written.

          • David M Famiglietti

            I understand that Phil,……..I don’t know how many times I have to explain to you why that affects me and my business, and my dealers, and my customers. We sold thousands of the PCF lowers and sell a very similiar product and the misleading title and blog post has confused many of our customers so we’re stuck dealing with that all day because of a fictional article that was slapped together about a year old letter.

          • http://www.thefirearmblog.com/ Phil W “Senior Writer TFB”

            Well you can clear that up pretty easy but I’ll leave that up to you and Steve.

          • Steve (TFB Editor)

            David, your spamming our inboxes has been noticed. One email would have sufficed. We will be in touch.

          • David M Famiglietti

            2 emails is not considered spamming, just following directions of the one person thats been responding to me all day! Thanks, can’t wait to speak with you!

          • Steve (TFB Editor)

            You know how many emails you sent and how many emails were CC’d.

          • David M Famiglietti

            Steve, for the second time today I believe you’re confused. I e-mailed 2 times. Period. End of story. I don’t like when people post things without fact online hiding behind a computer. You may be signed up for e-mail alerts everytime someone replies with a comment, as am I, and that would explain any e-mails you’ve gotten besides the 2 I sent from my @newfrontierarmory.com domain.

          • http://www.thefirearmblog.com/ Phil W “Senior Writer TFB”

            Steve just emailed you. so instead of posting over and over again answer his email response.
            We don’t all run on a Las Vegas schedule.

          • aaron

            “the method used to attach the serial number insert (serial number RM00501) on the partial receiver sample is not compliant with Federal Law.”

            Given that statement made by the FTB in writing and posted at the top of this page most reasonable persons would come to the conclusion that not compliant with federal law would mean illegal.

          • http://www.thefirearmblog.com/ Phil W “Senior Writer TFB”

            That’s sure how I read it.

          • smurf

            It would certainly serve their interests for all of us little people to believe their lab people can recover serial numbers removed from conventional steel guns.

        • David M Famiglietti

          You’re right Oliver, but the author doesn’t want to bring common sense into this since he’s just being used by a pawn by the guys from E3 Arms to spread misinformation and unfactual things around the net. This article is no better than a Pierce Morgan piece from CNN — You should be ashamed of yourselves!

          • http://www.thefirearmblog.com/ Phil W “Senior Writer TFB”

            We haven’t talked to anyone at E3. The letter speaks for itself. Of course I know you have a personal interest which I understand.
            You could be helpful in the discussion since you’re company sells polymer lowers I believe. Being in the business you could shed more light on this if you chose to.
            You could answer some of the questions readers have on New Frontier lowers you sell and how your method varies from what the Plum Crazy lower used.
            You do own New Frontier—correct or no?

          • David M Famiglietti

            Yes, I do. I’ve been trying to contact your staff all day, but no one will man up and give me a shout so we can discuss this in the proper forum and you can post an update to the article. Rather I have to sit here and field and chase innacurate and misinformed comments all day long. So you have a determination letter that was sent in by E3 and associates (can’t keep track of all the companies they’ve ran into the ground int he past 3 years) but you haven’t spoken to anyone there? I also know you haven’t tried to contact our company for an official comment that would help not sending people into a panic because someone knocked the dust off of a one year old letter for malicious reasons. I also know you didn’t contact the actual manfuacturer of the PCF receivers because I’m here with him. Like I said, I’ll shed all the light you want, and I’m not hiding behind a computer screen like others feeding you BS. Get in contact with me through the proper channels and I’m sure the story would make much more sense.

          • http://www.thefirearmblog.com/ Phil W “Senior Writer TFB”

            There is no number for you to call—-

            This entire post is about the ATF letter and the ATF findings period. It’s self explanatory.

          • David M Famiglietti

            The problem is its not self explanitory. The title says “PLUM CRAZY PLOYMER LOWERS ILLEGAL SAYS LETTER FROM ATF” Yet, thats NOT what the letter says at all, is it? The letter says one small piece of receiver sent in for evaluation over a year ago does not comply with regulations. It says nothing of the sort that all PCF lowers are illegal as your title CLEARLY states and your article leads people to believe. I can see by your lack of investigative skills when writing this article why you can’t find a way to contact me and get a phone number. I’m using my name when I post, not hiding like your source for that letter. Send me a PM on FB linked from my comments, or, you can e-mail my business at [email protected], or you can look for our phone number on our website. Its not hard to get ahold of me. You guys on the other hand only have one form of contact that I can’t get a reply from. Intresting.

          • http://www.thefirearmblog.com/ Phil W “Senior Writer TFB”

            Email Steve at Editor@thefirearmblog I didn’t write it so other than trying to answer some questions he would be the one to start a dialogue with.

          • David M Famiglietti

            I’ve done that. And I will e-mail everyone on the contact page again. I hope someone at your site will stand up for what they’ve published and contact me back.

          • http://www.thefirearmblog.com/ Phil W “Senior Writer TFB”

            I’m sure he’ll answer when he’s in—

      • David M Famiglietti

        Which if you had any clue about what you’re talking about in this article would know that Glock uses the exact same method of attatchment for their serial number.

        • http://www.thefirearmblog.com/ Phil W “Senior Writer TFB”

          David you’re talking to the ATF on this not us. It is a Plum Crazy lower and ATF wrote the letter. Seems rather obvious.

          • David M Famiglietti

            On one sample. The first lower PCF had mfg’d. Like I said, you didn’t do your research or you would have known that there is no law or regulation saying PCF receivers are illegal. All you are doing is taking words out of context from a letter making a determiniation about one way a serial number was attatched on one piece of plastic.

  • Cymond

    Well damn. Any word on the legality of other, competing products like the ATI Omni or the New Frontier Armory??

    Also, seems like a bad time for polymer AR lowers ..

    • http://www.thefirearmblog.com/ Phil W “Senior Writer TFB”

      If a company uses the same method to attach serial numbers it would seem the answer is no.

      • Cymond

        Understood, but there have always been questions regarding the similarity of the New Frontier and the Plum Crazy. They’re so similar that I’m worried they’re the same … or maybe not. I have no idea how the serial number is attached to a New Frontier, and I’m certainly not going to go get a NF receiver to test it.
        The same company also manufactures the Exetar pistol.

        • http://www.thefirearmblog.com/ Phil W “Senior Writer TFB”

          Yes and that poses a question only ATF can answer. Have they changed the methods or used another I have no idea since I don’t own one.

      • Mack

        How many ways is there to attach a metal plate into a polymer structure? i would think almost all polymer guns would be illegal just because they all look like a metal plate is melted into polymer. So what is the approved method that glock and all these other polymer brands are using?

        • http://www.thefirearmblog.com/ Phil W “Senior Writer TFB”

          Mack—I honestly don’t know how many ways there are to attach a serial number. It’s not an area I’ve had much interest in.

          • Mack

            I must of misunderstood, i thought by your comment you imply there is an approved method, as in you knew the method and this was not it. But why no interest my friend, i thought everybody woke up in the morning wanting to learn the next best way to attach numbers on an inanimate object!? :) i must be in the minority!

          • http://www.thefirearmblog.com/ Phil W “Senior Writer TFB”

            LOL—-yep it sounds about as interesting as paint drying.
            I can only say ATF must have one or more approved methods to judge these lowers by since they issue these letters.

    • Cymond

      I just emailed New Frontier, so we’ll see what they say.

      • http://www.thefirearmblog.com/ Phil W “Senior Writer TFB”

        Ok let us know what they say if you don’t mind.

        • New Frontier Armory

          You may have contacted us before writing a ridiculous article that has very little fact to it and has gotten customers in a nervous uproar over nothing real.

          • Ramsey

            If this is actually New Frontier Armory, your comment is the exact wrong tone to take in customer relations. The article is timely, factual, and relevant, as the BATFE just made several thousand gun owners potential felons.

          • David M Famiglietti

            Actually Ramsey, the article is NOT timely, since the letter that they’re taking ATF statements from (out of context) is almost a year old, and is being misconstrued greatly to cause fear and panic for no reason. This was one sample sent in. There is no ATF regulation or law that says PCF or any other serialized polymer lower on the market is illegal.

  • phil

    could you post the entire letter or a link to it

    • http://www.thefirearmblog.com/ Phil W “Senior Writer TFB”

      There is no link. This letter is not on the Internet only here. The portion listed above covers it. Some things on this I really can’t discuss.

      • phil

        you posted their “answer” but what was the question.

        • http://www.thefirearmblog.com/ Phil W “Senior Writer TFB”

          Is the Plum Crazy lower legal by the method used to attach the serial number to it.

  • Fuarock

    Post the entire atf letter

    • http://www.thefirearmblog.com/ Phil W “Senior Writer TFB”

      Nope it has nothing to do with the Plum Crazy lower.

      • David M Famiglietti

        It does, since the letter is from E3 Arms who are the owners of PCF. If it has nothing to do with it, why would you post some BS article like this that you can’t source ANY facts for?

        • http://www.thefirearmblog.com/ Phil W “Senior Writer TFB”

          David why is what happened to a company no longer in business such a big deal to you.
          They messed up according to the ATF. Simple as that.

          Sourcing facts—-ok the ATF letter above.

          • David M Famiglietti

            You realize PCF did not ever mfg anything right? It was done on a variance. You would have learned that if you did ANY research before writing this article. You also know that the facts your sourcing from that letter refer to ONE SMALL PIECE of a receiver that was submitted by someone other than the actual mfg of the firearms and may not be the way that those firearms were produced in mass, right? You realize that letter IS NOT A LAW OR REGULATION FROM BANNING PCF LOWERS LIKE THE TITLE OF THIS BLOG STATES AND THE CONTEXT LEADS USERS TO BELIEVE, RIGHT?

          • David M Famiglietti

            Its a big deal to me because I produce and successfully sell a very similiar product and because of this article I’ve wasted about 12 hours of my life and many man hours of my employees answering ridiculous questions from customers that are nervous because they read this article as if there is some truth to what the article states.

          • http://www.thefirearmblog.com/ Phil W “Senior Writer TFB”

            David there’s really not much sense in my continuing to answer the statements you’re making. We can do this all day long and achieve nothing.
            I’m very sure Steve will contact you if he feels it’s relevant or just wants to talk about it.

          • David M Famiglietti

            We can achieve a lot, or I can atleast by helping your confused readers understand the facts and the truth instead of misleading them to panic like you and your associates have done with this piece. I can understand why no one would want to contact me, I’d hate to look foolish in front of an audience of 138K as well……….

          • Charles

            Then put this to bed once and for all, post a copy of your BATFE approval letter! You seem intent on fighting a battle for a now out of buisness company, who submitted the sample themselves, if what you said is true. I know that makes me wonder if in fact NFA lowers are compliant. Instead of reassuring your customers that the two products are not the same you attack the guy that wrote the article, as if that will do anything to ease the doubts of your clientele. If anything your just fanning the fire. So why would someone do that? Maybe because they have something to hide?

          • http://www.thefirearmblog.com/ Phil W “Senior Writer TFB”

            Interesting and along what I was starting to wonder about Charles. All that needs to be done and answer the allegations once and for all is post the BATFE letter on those sold and those currently made by the present company. It’s really that simple.

        • http://www.thefirearmblog.com/ Phil W “Senior Writer TFB”

          It says nothing about E3. The first I heard of it was when you started commenting.

  • Battleshipgrey

    So just because it’s made out of polymer, attempting to destroy the serial number MUST cause damage to the firearm just so the firearm itself can be LEGAL (assuming the numbers aren’t obliterated). However, a metal receiver with stamped or engraved numbers is LEGAL, even though filing off the numbers DOES NOT damage the firearm.
    And we still have people in the U.S. that think we’re headed in the right direction…”forward” (??!).

    • gunslinger

      something to do with metal detection? metal guns w/o serial number sill no go through MDxs? but a 30 calibur assault magazine ghost clip gun can pass if you take out the metal SN plate.

      i think

  • john

    I know this only applies to polymer firearms, which makes it more ridiculous. A serial number can be removed from any firearm, just as easily. As with everything that atf does, this is stupid. Firearm restrictions will do nothing to prevent crime. It only hassles the good people. Bad people will do bad things, no matter what the law says. This is just another attempt by atf to justify their existence. They are a useless agency and a wast of tax payer funds!

  • BryanS

    Shall not be infringed, as long as the serial number is not removable in an easy manner.

    Missed that part, must have been hiding under a giant comma.

  • Mancave Heywood

    Is that the best thing that these NAZI’S could come up with? Plus there are quite a few firearms out there that are on palymar frames already, check out the Ruger SR9c, my serial number is on like a small sliver of metal. Uh-oh, well now I just gave the NAZI PIGS another crusade to oppress the people!

  • Jeff Smith

    Just wondering – could the ruling have something to do with the ability to not just remove, but switch serial numbers on the registered portion of a firearm?

    • http://www.thefirearmblog.com/ Phil W “Senior Writer TFB”

      I guess anythings possible but I really think the letter explains it well. It boils down to the method of attaching a serial number. ATF wants it made so that removal causes significant damage to the firearm. ATF determines the amount of damage as well.

  • Heinz

    So what does that mean for people who bought PlumCrazy lowers?

    • http://www.thefirearmblog.com/ Phil W “Senior Writer TFB”

      Great question. I’ve called three ATF offices and been referred to the tech branch who by the way don’t take civilian phone calls.

      • David M Famiglietti

        They will probobly help you read and understand the letter you are quoting out of context if you get them on the phone:

        “… the method used to attach the serial number insert (serial number RM00501) on the partial receiver sample is not compliant with Federal Law.” Does not translate in any way to the title of this article or that PCF are illegal per ATF.

        They even UNDERLINE to make sure its clear that the letter is speaking about ONE PARTIAL RECEIVER SAMPLE.

    • David M Famiglietti

      It means nothing because “The Firearm Blog” doesn’t create firearm law, the ATF does. The letter and misquoted text has nothing to do with any law that does not exist saying these are illegal. If they were indeed illegal, we would have been contacted by the ATF by now (since the letter that the article is based on is almost one year old) since we sold thousands of them. If there was a law making these illegal, you would hear it from the ATF, not an internet blogger reporting on a one year old piece of paper taken out of context.

    • http://www.thefirearmblog.com/ Phil W “Senior Writer TFB”

      If it were me I’d check with the local ATF office Heinz.

  • Rob

    Every serial number on every gun I’ve ever owned can be removed in under a minute without damaging the receiver. That’s a load of bunk.

    Fortunately, the government has no granted authority to render any arm illegal, so the issue is moot.

  • Jim Coloma

    this article is terrible, they didn’t go mysteriously out of business they are now New Frontier Armoury and still make the same dam lower with just a new name, I talked to the Plum Crazy owner myself. https://newfrontierarmory.com/catalog/

    • David M Famiglietti

      NOT the same company. I’m the owner of New Frontier Armory. PCF is now E3 Arms and Patriot Arms.

      • Jim Coloma

        Yes thats right, got them mixed up.

  • CrazyKg

    I have never been so happy to have avoided buying a firearm. Almost got sucked into this one by their low prices before all of this went down.

  • Jethro

    If I’m reading correctly, the problem isn’t that the serial number wasn’t engraved on the metal insert, but a thin strip of “metal like” material that was attached to the insert and was easily peeled off. Kinda like a serial number sticker.

  • TFB_Reader

    1. It sounds to me that the letter was sent by a manufacturer asking for feedback on what they were planning to do, using the old Plum Crazy lower as an example.

    2. I don’t have a plum Crazy lower to examine, but the attachment method must have been different than that used by Glock, etc., or similar rulings about them would have been issued years ago. The description and photo look like a serial number sticker was glued onto a blank metal plate rather than numbers embossed into the plate. My bad if I’m wrong.

    3. Like it or not, “infringements” exist, and, to me at least, it’s the manufacturer’s responsibility to comply with them.

    4. Whatever happened to “no politics?”

    • Caleb_Grey

      It’s more like a site sponser, that is in the polymer lower business, sent a competitors product into the atf to get it outlawed.

      • David M Famiglietti

        Nope, if you look at the pictures closely it says “E3 Arms” is who submitted the request to FTB. Those are the same owners as the old PCF. And the letter is a year old. TFB is being used as a pawn by angry business owners that don’t know how to runa firearms mfg business.

        • http://www.thefirearmblog.com/ Phil W “Senior Writer TFB”

          Where does it say E3?

          • David M Famiglietti

            On the caption for picture “1 of 5″ in the ATF determination letter.

    • http://www.thefirearmblog.com/ Phil W “Senior Writer TFB”

      It’s not a question of politics it’s a legal question based on the ATF letter. We owe it to the readers to pass along information such as this.

      • David M Famiglietti

        If you posted a legal ruling from ATF, that would be different. The lower in the picture is the first PCF lower ever made. It has a modified serial number area and they were not produced like this. The letter is an answer (that we can’t see because the PCF/E3 owners asked you not to) from ATF on one instance, not an entire product line or brand. Besides some quote taken WAY out of context, there is nothing from the ATF that says PCF lowers are illegal, so no need for a “public service announcement” that gets everyone in a frenzy because someone dug up a ONE YEAR OLD letter to stir some shit in the pot. Like I said, get ahold of me and we can have a nice phone conversation going over the article and the facts that you’re missing. Do you think these firearms were secretly traded for a year after ATF said they were illegal and they did nothing about it?? I don’t think so. And I know for a 100% fact that you DID NOT speak to the actual manufacturer of these lowers because I’m sitting here with him and spoke with him immedietly when the article came out. I’m not trying to give you shit, but I find it funny that no one on your editorial or writing staff was able to contact me all day where I would take the time to fill you in on many missing facts in the story and help explain why the title and the article is very misleading and causing stress in an industry that has enough legitimate BS going on it. Like I said, drop me a line if you’d like to do a factual follow up story.

        • http://www.thefirearmblog.com/ Phil W “Senior Writer TFB”

          That’s entirely up to Steve. He’s the editor and author.

          • David M Famiglietti

            The title of this alone is UNTRUE. Thats how you guys want to be known to report? I would love to speak with someone from your organization on the telephone so we don’t have to piss back and forth. Since you’re the one on here fielding all of the comments on Steve’s article, why don’t you give me a ring so you’ll be better informed when replying to comments.

          • http://www.thefirearmblog.com/ Phil W “Senior Writer TFB”

            Because we would be repeating it over and over again. If Steve wants me to call you I’ll be glad to.
            I’m not pissing back and forth. Geez I don’t get mad that easy.

  • clinton notestine

    good god i just cant catch a break… my first and favorite lower is a plum crazy and I just bought a poly lower from ares.

    • Mancave Heywood

      Don’t worry about it! Just buy and upper and keep using the plastic one for about a year until it breaks.

      • clinton notestine

        ive had my polymer one for 3 years

  • OliverTabuger

    Also, possessing a firearm with a serial which was attached in a deficient manner (or no serial) is not illegal. It is illegal to remove the serial. So the ATF is not going to confiscate all these lowers. They just want the manufacturer to attach the serials more securely.

  • smurf

    Serial numbers probably aren’t as helpful as regulatory agencies suggest.

  • Mack

    i highly doubt that the product that plum crazy actually sent out was in defiance of this letter. This was a letter asking if it was okay or not, they got the NO, so they changed the one thing they got wrong and went on there merry way selling these lowers legally. If they were illegal, the ATF would have a field day with the manufacture of PCF, this is a year old, we would of heard something by now. I own a plum crazy (no it has not broke) and i am not afraid of an ATF agent knocking on my door.

    • David M Famiglietti

      Mack, thanks for reading the article, understanding the words, taking a deep breath and stating the obvious facts! Its awesome to see that not everyone has lost their mind! Now only if the author would have done that before writing this article and its VERY misleading title, I wouldn’t have spent 60 man hours replying to e-mails and answering phone calls from angry customers about what to do and how to get their money back on these “illegal” lowers we’ve sold over the years! haha :-)

      • OliverTabuger

        Wow that sucks.

      • http://www.thefirearmblog.com/ Phil W “Senior Writer TFB”

        Nobody said a thing about New Frontier so what are you so concerned about?

        • David M Famiglietti

          I’ve explained that earlier. Wasting thousands of dollars of man hours today dealing with customers and dealers that you’ve mislead with your title regarding a firearm (Plum Crazy Firearms C-4 receiver) that we’ve sold thousands of, and our similiar product the New Frontier Armory LW-15 polymer lower. Thats why this concerned me.

          • http://www.thefirearmblog.com/ Phil W “Senior Writer TFB”

            Hum I have a hard time buying that.

          • David M Famiglietti

            Why would that be hard to believe? You can see a similiar response from the readers here in their comments on this article, as well as posts on various forums around the internet that I’d be happy to point you to. People like drama, and love to panic. Its human nature maybe, but it runs rabid in this industry unfortunately. I’m not the type of business owner not to express my views, stand up for what I believe in, or not engage with my customers. I, as well as several of my admin staff spent the majority of our days putting these customers at ease and reassuring our dealers and former dealers of PCF products (that we distributed) that there was some misinformation and a large misunderstanding in this article.

          • Mack

            I do have to say that the title could be worded a bit differently and some of the text is a little provocative. I am highly interested in what the legal method is and what makes it different from a glock. There is some missing facts here but it is a very interesting letter and i wonder how many companys get these letters and have to revise there product. Still don’t think these are illegal, not just because i have one and hoping there not, but this seems like a ticky tacky ruling the ATF in this letter.

          • http://www.thefirearmblog.com/ Phil W “Senior Writer TFB”

            I seem to remember a very long time ago that Glock had to make some changes. That was probably about 1988?

  • Radec

    This is probably one elaborate April Fool’s joke.

    Honestly, I’m not laughing. Post the entire letter, even if it has nothing to do with the article at hand. I spent a week once dissecting a lab report someone sent the company I worked for at the time because they thought conclusion X by showing parts of the report, when the FULL report showed conclusion Y.

    • http://www.thefirearmblog.com/ Phil W “Senior Writer TFB”

      It really doesn’t have a thing to do with the Plum Crazy. I can assure you of that.

  • Raoul O’Shaugnessy

    Oh sure…ATFE happily documents the removal of the serial number tag but ask them to actually produce photographic evidence of their testing procedures to determine ‘readily convertible’ or the like and…:::crickets::::

    • http://www.thefirearmblog.com/ Phil W “Senior Writer TFB”

      That’s not going to happen!

  • MrPhantom

    And in completely unrelated news, thousands across the nation were involved in tragic boating accidents this weekend – more at 11.

    • http://www.thefirearmblog.com/ Phil W “Senior Writer TFB”

      LOL

  • Sigivald

    27 CFR 478.92 applies to manufacturers – the ‘illegality’ is in the interpretation of “
    By engraving, casting, stamping (impressing), or otherwise conspicuously placing or causing to be engraved, cast, stamped (impressed) or placed on the frame or receiver thereof an individual serial number. The serial number must be placed in a manner not susceptible of being readily obliterated, altered, or removed, and must not duplicate any serial number placed by you on any other firearm.

    The key being “susceptible of being readily … removed”, in this context. “A minute with a screwdriver” probably counts as “readily removed” in a way that “take a power tool to it” isn’t, admittedly.

    However, possession of such a lower [that still has its serial number] is not illegal; 18 USC 922 mandates only that one must not remove or obliterate a serial number, or have such a de-serialized firearm.

    Possessing a firearm that has a serial number that the ATF has since determined was not sufficiently “permanent” is not illegal under any law I can find.

    That matters a lot for your final (pre-update) sentence; nobody’s in any legal jeopardy for owning such a firearm, so long as – with any firearm – they don’t remove the serial number.

    • http://www.thefirearmblog.com/ Phil W “Senior Writer TFB”

      Thank you for taking the time to hunt that down.

  • Paul Kisling

    So basically this article is screwing over another manufacturer of similar receivers, for the sake of fomenting BATF hate. Nice one guys. With friends like that you don’t need anti gunners.

    • http://www.thefirearmblog.com/ Phil W “Senior Writer TFB”

      No there was no intent on screwing over another company. His company was never mentioned only one no longer in business.