"One need not be an SOT to have NFA weapons transferred to him for
repair. One does need to have a type 01 FFL to work as a gunsmith
though."
http://www.cs.cmu.edu/afs/cs.cmu.edu...st/nfa_faq.txt
I don't believe that a type 03 C&R ONLY... will take the place of the type 01 DEALER/gunsmith FFL, however!