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I suspect the intent is for all private sales to go through an FFL. I also suspect there will be a sudden increase in people trying to get an FFL with the ATF denying most applications due to HOA and local ordinances from city( the main things they look for on new applications). BTW, don't ever trust what the IOI's tell you ( the IOI's are the ones that do the interviews and inspections), 9 times out of 10 they are wrong and usually they cannot even agree with each other and they make their own interpretations. Get the reg book and read through it.