As expected, the Pennsylvania State Police have informed Federal Firearm Licencees in that state that they must begin performing background checks for the sales of “Partially-Manufactured Frame(s) or Receivers” (PMFR) and record that transaction on a new form. As Pennsylvania attorney Joshua Prince notes, this is problematical because the letter doesn’t really specify just what a PMFR is.
For that, we go to the original opinion letter from Attorney General Shapiro. He has established that everything is a PMFR. If you can turn something into a gun with $65,000 in thirteen hours, it’s a gun.
In that case, I think it’s very important that every Keystone State FFL comply with this completely, taking AG Shapiro at his own literal word.
If an FFL sells anything, he should fill out the application and make the background check call. Individually list every item a customer wants, be it a bottle of solvent (plastic bottles can be melted down and molded into a receiver), a block of wood (stock), a metal gun case (sheet metal can be formed and cut into a frame), or whatever.
Use your imagination. Overload their switchboard and smother them in paperwork. Better safe than sorry, and the the PSP will come down on you later if you miss something.
If they later insist you don’t need to do this for item X, get it in writing, over a real signature. Document everything.
Until then, make them work for their new regulation.