I dug out the letter from BATFE. It defined "Engage in the business" as buying and selling C&Rs. The term was further defined as "a person or entity that devotes time, attention, and labor to dealing in firearms as a regular course of trade or business with the principle objective of livelihood and profit through the repetitive purchase and resale of firearms."
I would read that to mean I can ship a piece to another C&R holder, as long as I don't do it on a regualr (repetitive) basis with the purpose of making a profit.
There is an Authorization clarification near the end of the memo:
"Licensed Collectors are authorized to:
* Acquire curios and relics at any location.
* Dispose of curios and relics to an FFL, or a non-licensee residing in the same State, who is not otherwise prohibited by the CGA, and to an FFL in any state."
Again, I would read this as a C&R is a FFL since they did not clarify as an 01.
My memory was faulty in thinking I could not ship to a C&R. I can ship to another FFL. I can't ship to another state if the person is NOT in posession of an FFL, but they could ship to me if I provide them a copy of my C&R.
Sorry for any confusion I may have caused. The memo is question was dated January 5, 2005.
PS. There was no mention of UPS, USPS, or any other shipping company.
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Art in metal and wood
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