No License, No Problem: America’s Machine Gun Parts Dealer Loophole

The American firearm regulatory framework treats guns as one serialized part. Revoke a dealer’s right to sell that part, and they can legally pivot to sell every other component of the exact same weapon with no oversight.

That’s a loophole by design.

Parts sales do not require a license, a background check, a Form 4473, or any recordkeeping. Parts for what? How about an automatic rifle or a machine gun?

Custombilt Firearms Manufacturing of Overland Park, Kansas lost its Federal Firearms License in July 2023 because ATF found that it wasn’t tracking who was buying. There were 43 documented failures to record acquisitions, dispositions, and background checks. ATF said the failures were wilful.

On February 6, 2026, it filed for Chapter 11 bankruptcy. Meanwhile, the website still lists parts for sale: complete uppers, complete lowers, multi-cal stripped lowers, CFM M16 bolt carrier groups, and trigger guards. Everything you need to build a functional AR-15 except the serialized lower receiver, which is the only part that legally counts as a “firearm” and requires an FFL to sell.

This company that ATF determined couldn’t be trusted to track firearm sales is legally selling some of the most concerning firearm components with zero oversight.

The M16 bolt carrier group is the part worth flagging. It’s legal to own and common in semi-auto builds. But it’s also a prerequisite for converting an AR-15 to full-automatic because the geometry of a standard AR-15 carrier won’t work with an auto sear. Under ATF’s constructive possession doctrine, possessing an AR-15 lower alongside M16 fire control parts and an M16 BCG constitutes possession of an unregistered machine gun under 26 U.S.C. § 5861(d), meaning a felony carrying up to 10 years, even without any assembly, just parts.

Custombilt isn’t openly selling the auto sears. It’s selling a major component of the full-automatic equation from a bankruptcy liquidation inventory, with no record of who’s buying. The part is called an M16 bolt carrier group because, well, it’s the bolt carrier group from the M16. Custombilt is plainly listing it as “CFM M16 bolt carrier group.”

They’re literally selling a machine gun designation without keeping records.

This fits into the Trump administration removal of ATF’s zero-tolerance policy. Gun dealers who failed to keep their licenses “may reapply” now. Kansas Rep. Tracey Mann even created a RIFLE Act to reinstate revoked licenses and reimburse the affected dealers.

You can find Rep. Mann’s office at 7011 West 121st Street, Suite 100, Overland Park, KS 66209.

And Custombilt is not too far away at 6201 Robinson Street, Overland Park, KS 66202.

Mann isn’t actually from Overland Park and he doesn’t represent it. He’s from Western Kansas, an area known for two things lately.

  1. Mann was born in Gove County, which during the COVID-19 pandemic was called the “deadliest place in America“. People there apparently were so anti-life, they maintained the highest death rate from COVID-19 compared to any other county in the nation: One death out of every 132 people.

    Gove County is 93% white. … “Rural America has always been insulated to some degree to the problems that plague more urban areas,” [county health officer] Rempel says. “I think that gave some people a false sense of security. I think there was maybe a public perception we would be OK.”

    Disinformation about “urban people plague” gave a false sense of security? Apparently being a white supremacist didn’t stop COVID. And for the record, rural Americans are more at risk. They typically are air rescued direct to urban areas when someone wants them to live.

    The county’s sheriff, Allan Weber, remains hospitalized 300 miles west in Denver, where he was flown by medical plane on Oct. 18.

  2. Speaking of heavily armed white supremacists being anti-life, Mann today still lives in an area known for the 1989 naming of “noose road“, near a sundown town of many lynchings. It was said in Hays, Kansas that “Blacks were not allowed to stay overnight”, keeping alive a Jim Crow “legacy that kind of hung over the town going back to the lynching.”

That’s a very particular legacy, just like this one:

Trump refuses to apologize after posting racist meme…

On the same day Custombilt filed for bankruptcy, California Attorney General Rob Bonta filed a lawsuit against distribution of 3D-printable ghost gun files and machine gun conversion devices. One state is suing over digital blueprints. Another is goosing a revoked dealer to liquidate physical machine gun components from a bankruptcy warehouse into unknown “noose” hands, no questions asked.

One thought on “No License, No Problem: America’s Machine Gun Parts Dealer Loophole”

  1. This is exactly the loophole I’ve been worried about. I own AR-15s and I buy M16 BCGs because they’re mil-spec standard for better gas ring seating, longer service life. Every AR owner I know runs one for the fun of it. And that’s precisely the problem you’re describing. The part is so common in legal builds that its sale as a machine gun prerequisite is invisible. I could walk into Custombilt’s bankruptcy liquidation right now, buy an M16 BCG, and nobody writes down my name. I already own an AR-15 lower. If I bought M16 fire control parts from a second no-record source, I’m holding a federal felony under § 5861(d) and no one in the regulatory system would ever know until something went very wrong.

    The Hays connection hit harder than I expected. My wife got her degree at Fort Hays State and we never talked about Noose Road. I had to look it up. Named in 1989? Whoa. I was alive. The sundown town history isn’t something that gets taught at the university or mentioned in the tourism brochures. That’s kind of your point about Mann, isn’t it? He comes from a place that actively buries its racial violence history while pushing legislation to put untracked weapons components back into circulation. You don’t have to prove he’s a white supremacist. You just have to notice he’s never had to answer for the exact pattern.

    I’m probably going to buy one of those BCGs as a spare. And the fact that I can do that from a revoked dealer’s bankruptcy sale with no record is… not how this should work.

Leave a Reply

Your email address will not be published. Required fields are marked *

This site uses Akismet to reduce spam. Learn how your comment data is processed.