This isn't my first rodeo either. I've been licensed for 20+ years. I got my info straight from the senior field agent ,out of OKC. This was at a ATFE Training/informational Seminar I attended. The Dallas District Director was right there, too (OKC is a satellite office of the Dallas/Mid-South district). She didn't contradict the senior field agent. This info was presented, first to the group of approx. 250 and then I got the same question answered "one on one" from that same field agent. You find it hard to believe that new or existing regulations are now being enforced? There have been new regulations written and old ones that were not enforced being implemented daily in most every industry you can think of. Oil/Nat. Gas/ Coal, banking, car makers (emission & fuel stds.), health care, immigration,,,,,, the list is endless. As for the guy building uppers, he doesn't need to be licensed, unless he handles the lower in any way. For firearms with no serial number, I'd bet they were made prior to 1968, when the GCA was enacted. Same for no Mfg./location markings they weren't required until the GCA of '68. Have I seen may custom rifles with the makers trade name and city/town and state on the arm? Yes, I've seen quit a few. I've seen more that do not. I've seen plenty, just here lately, with no caliber designation. I, also, know of many who are building rifles (and providing the receiver) that are operating with a 01 Dealers License. If ATFE discovers that is the case they will insist you get a 07 Manufactures License. And then, there seem to be quit a few lately who operate with no license at all, strictly on the "buddy" deal. If I was a licensee reading this, I think I'd call my local ATFE office and ask questions. I wouldn't take my word for it and I wouldn't take Butches'. Get your info from those who will, at some point, be doing a compliance inspection on you/your business. There is a hugh amount of info concerning manufacture that doesn't make much sense, but, it's enforced none the less. And yes, the German government required serial numbers for tracking. That is why the current marking regs are what they are,,, for tracking. There is a reason most barrel makers will install one of their barrels on your action, but, state they do not provide actions (I'm thinking Hart, Krieger here, and most likely some others. Check their web sites!) Installing a barrel on a customer owned action is a gunsmithing task and requires a 01 license and a lot less paper work. If, on the other hand, the licensee provides the action he is considered the manufacture, no matter whose barrel he puts on it, and, 11% excise tax is required for 50 or more. 07 Manufacture requirements/regs are much more complicated than having a 01 Dealers' license, I have had both. I started as a 01 as a sole proprietor, when my business became a LLc, which required applying for a license all over again, and the field agent that came for the pre-license interview discovered I was building rifles and providing the actions occasionally, he insisted I be 07 licensed if I wanted to continue business as I had been.. It's been 4 or 5 times the paper work! The result has been follow the rules and regs or ??????? Much more than I had ever intended to post in this thread. Think what ya'want, get the straight info from those who will be doing a compliance inspection some day. (they try to inspect manufactures at least every 5 years. I've known of dealers who have gone 15+ without an inspection)