RE: Benelli M4 / M1014 - Does 922(r) Only Apply to Importers?
In this video, I tackle one of the biggest misconceptions I hear in the Benelli M4 and M1014 builder community: does 922(r) only apply to importers? As a recovering attorney who’s been in this space for nearly two decades, I break down the law, the ATF letters, and how this statute applies to all of us—not just licensed importers. Whether you’re building a range gun or a home-defense setup, I explain the difference between the “import” and “assembly” sections of the law, how to avoid getting caught up in legal ambiguity, and how to achieve compliance with minimal extra cost. This is essential knowledge for every M4 owner looking to build smart, stay safe, and avoid unnecessary risks. I also share how you can find more info on my website and why I won’t walk through this stuff over the phone.
00:00 - Intro: Does 922(r) Only Apply to Importers?
00:14 - Subscribe, Comment, Contact Info
00:40 - How to Reach Me Anytime (Phone/Text/Email)
01:03 - My Legal Background & Ethics Around 922(r)
01:34 - Why I’ve Taught 922(r) for 18+ Years
02:22 - What Makes 922(r) So Confusing
02:58 - When Your Gun Might Come Under Scrutiny
03:19 - 922(r) Compliance Is Cheaper Than Legal Fees
03:42 - Most Parts You’re Buying Already Help Compliance
03:59 - Where to Learn 922(r) on My Website
04:21 - The Importer Myth Explained
04:45 - Why Internet Misinformation Spreads
05:02 - New 2024 ATF Letter (Redacted) from a Customer
05:26 - Letter Breakdown: Import Section vs. Assembly Section
06:34 - Assembly Law Applies to All of Us
07:02 - You Must Replace Parts to Be Legal
07:26 - Why the Import Section Targets FFLs, Not Civilians
07:47 - “Assembled Firearm” Clause and Why It’s Crucial
08:05 - I'd Love to See This Law Repealed, But It Exists
08:29 - Why I Ethically Share 922(r) Details
08:52 - I Don’t Enforce Compliance – That’s on You
09:10 - It’s Like Selling a Porsche – What You Do Is Up to You
09:35 - Why Many Customers Care About 922(r) for NFA Items
09:52 - Could the ATF Audit You? It’s Possible
10:08 - This Law’s a Mess, But It’s Real
10:29 - The Law Has Two Parts: Import + Assembly
10:46 - 922(r) = Harassment Law, But Still on the Books
11:08 - Other Companies Also Share 922(r) Info
11:27 - 922(r) Origins: AK-47 Imports
11:56 - Why I Require You to Learn It Through My Website
12:23 - Don’t Say You’ve Watched My Videos If You Haven’t
12:43 - I’ll Answer Fine-Point Questions, Not Basic Overviews
13:00 - Final Thoughts: Stay Safe, Stay Informed
Transcript:
00:00:00:00 - 00:00:12:09
Unknown
Hey, folks at Freedom Fighter Tactical, welcome to the latest video. Today we're going to talk about does 922 are only apply to importers? Let's get started. Right now.
00:00:14:09 - 00:00:23:22
Unknown
Hey folks. Again Todd at Freedom Fighter Tactical. Welcome to my channel. Be sure to hit the subscribe button down below. Hit the bell so you're notified of future videos and leave a comment if you'd like.
00:00:23:22 - 00:00:40:22
Unknown
And you can also reach me at the phone number here on the video for numbers on the website as well. If you're over there and don't want to come back to YouTube to fetch the phone number, it is at the top of every page on my website. You can call me, you can text me. You can use the little chat feature down in the lower right hand corner, or you can email me on the contact page.
00:00:40:23 - 00:01:03:17
Unknown
Whatever your preference, it all goes to my cell phone. I'm easy to get Ahold of 365 days of the year. I am a, recovering attorney. I stopped practicing law in 2009 ish, and during that time, between the time I went to law school and then I worked in the prosecutor's office in that in one of the local cities.
00:01:03:19 - 00:01:34:14
Unknown
I've also done, plenty of private work, but I've also written gun law books, and I just, I know how to deal with the gun laws, and one of them is nine 22 hour. Excuse me. And when I started this business, I felt like as a even though I'm a recovering attorney, I'm still a licensed attorney. And I felt like it would be unethical to sell parts that have any potential legal ramifications to them and not explain the law so you can make an educated decision about how you want to conduct yourself.
00:01:34:16 - 00:01:58:18
Unknown
And, and so I started doing that 18 years ago. And the law hasn't changed in 18 years. I've reviewed it, multiple times through all these years. I've had customers send me their letters. I've had my own letter sent and gotten answers. I go to the shot show and talk to the ATF whenever I'm at the shot show and try to see if I can get them to, you know, tell me one thing and then tell me another.
00:01:58:18 - 00:02:22:12
Unknown
I want to see if there's any sort of wiggle room or what's going on. And, it's out there. It's, I've always said it was vague and ambiguous, and probably hard to prosecute. I stand by the hard to prosecute. I don't know necessarily. It's vague that it's vague and ambiguous. It's vaguely ambiguous in the sense that the law is kind of comprised of more than, 18 U.S.C. 922.
00:02:22:17 - 00:02:58:01
Unknown
It's there's a number of code sections and case law and ATF writings and things that kind of all come together and create what we know and call. 922 are we all hate the law? We don't like the law. We want no gun laws. If it was our choice. But it's out there, it's, unlikely that, you're going to be in any trouble over it in the big scheme of things, but you never know how your gun can come under scrutiny, particularly if you're using it as a self-defense home, defense type weapon, or if you are.
00:02:58:03 - 00:03:19:08
Unknown
Yeah, that's mainly it. I mean, if you're at the range, you don't have to worry. Nobody's going to be looking at your gun or anything like that. But, again, you don't know how it's going to come under scrutiny and by who some of us live in very red, freedom loving jurisdictions and some of us don't. So, what I've always told people is, is that you can have nine 22 hour compliance for the cost of one hour.
00:03:19:11 - 00:03:42:14
Unknown
Actually, it's probably half the cost of an hour in the chair of an attorneys, who just, criminal and defense for gun issues. So if you were the test case, you know, you're going to pay probably $1,000 an hour. You can wrap up nine, 22 hour for probably, 400 bucks. And actually some of the parts that you're probably going to buy for your gun anyway are nine, 22 hour compliance.
00:03:42:14 - 00:03:59:21
Unknown
So, it may be only an additional 50 bucks or an additional 70 bucks to get to gain compliance once you were buying it, if you're already buying the magazine tube or whatever. So anyway, I'm not going to go into how to solve nine 22 hour for your gun. You can go to my website under the Learn the Laws tabs.
00:03:59:21 - 00:04:21:21
Unknown
There is a comprehensive section there with all that you need to know about the law. And there's videos where I'm telling you about it there. I don't teach it on the telephone because that's why I have the videos. Because there's nothing that I can say on the phone that isn't covered in the videos. So you that's where you can get your information on that.
00:04:21:21 - 00:04:45:13
Unknown
But does it imply only to importers, which is a popular, internet myth? When people show up on the internet and chat on Facebook or wherever and ask, hey, you know, do I need to worry about nine 22 hour? They get flooded by the same guys over and over again that jump up and down and scream and yell and talk down to them for, you know, even asking the question in the first place.
00:04:45:13 - 00:05:02:09
Unknown
People just want to know and they want to be able to make an educated decision for themselves. They don't. A lot of the people out there are new to guns. They're new to all this, and they just want to be able to make an educated decision. So that's why I try to help with it. And recently, a customer sent me a letter that was written to him.
00:05:02:09 - 00:05:26:15
Unknown
And I can't face it to you because I haven't redacted this copy, but, he received this letter in 2024, earlier 2024. And, you know, it goes into the background. I'm not going to sit here and read the whole letter, and I'm actually going to get this posted on my website at some point in the near future so that you can reference it, but it will be plenty redacted so that the customer, cannot be identified in any way.
00:05:26:17 - 00:05:52:21
Unknown
Not that it matters, but I just think that that's how I would do it if I'm going to post it. So there's a there's a page here where it's on page two where it starts into, well, first of all, it goes into the import and there's an import section and it says it tells you what you can not import.
00:05:52:22 - 00:06:34:08
Unknown
And then it goes into an assembly section. And in the assembly a section it says this. 922 prohibits the assembly of certain semi-automatic rifles and shotguns from imported parts. The implementing regulations contained in 27 CFR for 7839 Sam Code of Federal Regulations. So that's what I'm saying. There's a, a number of places that they pull this together from, and include the stipulation that no person shall no person shall assemble, a semi-automatic rifle or any shotgun using more than ten imported parts.
00:06:34:10 - 00:07:02:21
Unknown
And if you buy this gun and all you do is put a magazine tube on there that's longer or a two round extension on the end, then it's going to be more than ten parts. And you can go to my web page to learn how that works. But, and what it says is that you can't build a shotgun if the assembled firearm, once you've built it, would have been prohibited of of to being imported.
00:07:02:23 - 00:07:26:06
Unknown
So unless you jump through the hoops and change out the required amount of parts. So that's the part that applies to all of us. There's a clearly the import okay. So they don't even have to say no importer shall because they know that civilians aren't going to be individually importing this gun. At least they're not going to be doing it if they're doing it legally.
00:07:26:08 - 00:07:47:06
Unknown
Importers are going to be efl's importers are going to be people that are federally licensed to import guns. So that's who they're talking about in the import section as far as bringing the guns in. But then when it talks about assembling the guns and assembling them in a fashion that if they were being brought in after they were built in the new fashion, they would have been prohibited from being brought in.
00:07:47:08 - 00:08:05:02
Unknown
That applies to us all. I don't like that it applies to us all. I don't like that the law is there. I would rather the law get wiped off the books. If Trump wipes it off the books, that's totally fine with me that I would love to see it. I'd love to see most gun laws just totally get, you know, thrown straight in the garbage.
00:08:05:04 - 00:08:29:02
Unknown
But this law is out there. And again, I feel ethically bound by one being a, you know, even though I'm a recovering attorney, I feel ethically bound to share that information with you. I think also as a business, even if I wasn't an attorney, I think as a business, I think that I would want to inform my customers so that they can make an educated decision as to whether they want to abide by the law or not.
00:08:29:04 - 00:08:52:10
Unknown
I don't require that you abide by the law. I don't check your parts for you. I don't count your parts for you. I don't, you know, I don't do any of that stuff. I don't care what you do. That's your business. It would be the same thing if I sold you a Porsche and or a Lamborghini. You know, when you drive it off the lot, if you want to drive 180 miles an hour and crash into a pole, or you want to drive 180 miles an hour and risk everyone's life out there, do I care?
00:08:52:10 - 00:09:10:23
Unknown
Of course I care. But is it my business? No. You're an adult. You can make a decision for yourself, but I give you the opportunity to make a fair and educated decision so that you can decide what you want to do and that you don't have any surprises. Sitting in your gun safe. A lot of my customers are, they have, tax stamps.
00:09:10:23 - 00:09:35:08
Unknown
They've bought suppressors, they've bought, short barreled rifles, short barreled shotguns. They've bought, you know, fully automatic stuff. And when you have that stuff, it's no jokes. You want to make sure everything in your safe is buttoned up and the legalities are addressed and everything is in there, and it's nice and clean and tidy. Because the ATF, I mean, they can come and catalog.
00:09:35:08 - 00:09:52:02
Unknown
I looked at being an FFL at one point and unless I'm mistaken, they can come and I probably can do it anyway. But, take to your safe and catalog its contents and make sure everything is right. What do they do that will they do that? I don't know, I don't I have no idea. If they do. That is common practice.
00:09:52:02 - 00:10:08:10
Unknown
But, I've always thought that this is one of those laws that you're already in trouble for something else. If you're in trouble for this. But for those of us who want to make sure that we don't have any sort of hiccups in our life, this is what nine 22 hour is about. So anyway, it's a mess.
00:10:08:12 - 00:10:29:00
Unknown
Importers only. That's a myth. The law has two facets to actually, it has more than two, but it has two primary components. It has the how you bring it in component and then how you build it component and how you build it can't be, how it would be prohibited if it were brought in, unless you switch out the requisite number of parts in order to change it.
00:10:29:02 - 00:10:46:22
Unknown
It's a dumb law. It's a finger in the eye. It's a it's almost kind of a one of those harassment laws, but it's there. It's there. I mean, most of these laws are harassment laws, even stuff in the tax law. And I mean, the business and business law and the code that involves restaurants and how they operate.
00:10:46:22 - 00:11:07:21
Unknown
I mean, so much of it is a finger right in the eye. And, you know, control and money and power and, aggravation. So, you know, it's out there for you, you know, resources on 922 are I'm not the only person out there company out there that puts them on the website. I think some of my competitors do as well.
00:11:08:03 - 00:11:27:07
Unknown
There's tons of videos on YouTube that talk about nine 22 hour in regards to this gun that are not my videos. There's tons of videos out there talking about them in relation to AK 47, which I think was the main intent of this law in the first place, was kind of going after AK 47 and it was like, hey, let's just get everything in the kitchen sink in there while we're at it.
00:11:27:07 - 00:11:56:02
Unknown
So anyway, for what it's worth, folks, you can reach me at the phone number on the website, phone numbers on the video here. You can call me, text me anytime. You can, you know, text blurb, email. I'm pretty much available 365 days a year. I hope this video helped you out. I hope that the Learn the Laws page on my website again, I don't teach 922 on the telephone, and I've answered the phone probably about 125,000 times in the 18 years or going on 18 years.
00:11:56:02 - 00:12:23:09
Unknown
I've been in business and, one of my things that I used to be really good at as an attorney was discovery. I love discovery, I love going through discovery. I love going to depositions and and asking, you know, I love dealing with hostile witnesses. And, you know, I, I know when you know, I know, I know after all these years, if you call me up and you start asking me nine 22 hour and you start it with, yeah, I've read and watched everything and, you know, and then you come back and ask me the most basic of questions.
00:12:23:09 - 00:12:43:10
Unknown
I already know you didn't watch everything and read everything. So, you know, I do require that you learn it on my website. It's there for you. I've got videos where I'm teaching it to you. You can replay them all that you need. I will answer, you know, a question or two about it. If you've got a fine point that is interesting that maybe I you know, it's kind of hard to figure out.
00:12:43:10 - 00:13:00:04
Unknown
It's a little gray area or something. By all means, call me up. I just don't start at scratch and spend an hour going through it on the phone with you. That's what I don't do. So anyway, folks, thanks for watching. Subscribe. Hit the bell. Leave a comment. Thanks for watching. Take care and be safe.
💬 Got questions about 922(r)? Drop them below 👇
Just please watch the video and check out the "Learn the Laws" section on my website first—most of your questions are already answered there.
Stay safe, stay legal, and build smart. – Todd @ Freedom Fighter Tactical