In the last few days a letter has surfaced on the Internet reportedly written to a small shotgun maker, which states that shouldering a Sig Sauer SB 15 pistol stabilizing brace could change a firearms classification to a short barrel shotgun.
The letter was written in response to Black Aces Tactical's request related to a short-barreled shotgun that was designed to incorporate the SB 15 Brace. Black Aces Tactical submitted a sample which they say had an overall length of 27 inches. The sample had a SigTac SB15 arm brace attached as well as a vertical foregrip. The brace is intended to allow a shooter to fire and an AR pistol with one hand using a Velcro strap to attach to the arm.
The ATF letter addresses the use of the SB 15 with a shotgun instead of AR pistol. The ATF response states that the submitted weapon, as described above... Is not a"firearm" as defined by the National Firearms Act provided" that it is used as originally designed and not used as a shoulder stock. The letter goes on to state, that if the weapon is fired from the shoulder, the firearm within the class I had as a"short-barreled shotgun".
Without knowing more details, it is hard to understand how this could be an AOW or an SBS. The length at 27 inches appears to be longer than the requirement for an SBS and because the firearm is not concealable, the forward grip should not change the status to an AOW.
Earlier this year the ATF stated that the misuse of the SB15 pistol brace would not change the classification of the firearm. While this letter does not address the use of the SB 15 with an AR style pistol, there is an obvious concern that the ATF could change its position in regards to that we Galletti of the use of an SB 15 pistol brace when fired from the shoulder.
If a pistol or shotgun with a SB15 pistol brace ends up being classified as a firearm subject to the NFA, a Gun Trust may provide flexibility in the use and possession of the firearm that individual ownership could not provide.
UPDATE For an indepth review of why the ATF is wrong see the Prince Law blog on this topic.
If you have and use a SB15 pistol brace, you should watch for developments on this topic. Below is a copy of the page of the ATF response that addresses this issue in relation to a shotgun.