Under the new §121F, it looks like they're trying to say "expired isn't expired if you've applied for a new one", but what they really say is that an expired LTC is still valid. "still valid" and "not expired" aren't exactly the same thing. (but probably close enough)
And §121F(t) says it's a crime to be in possession of an expired LTC or FID, ((not with a gun", but just "in possession") and further makes a distinction between "invalid" and "expired"
So, who knows?
§121F:
(s) Notwithstanding any general or special law to the contrary, an expired license to carry firearms issued under
section 131 or an expired firearm identification card issued under
section 129B shall remain valid for all lawful purposes if:
(i) the licensee or card holder applied for renewal before the license or card expiration date and shall remain valid until the application for renewal is approved or denied;
(ii) the licensee or card holder is on active duty with the armed forces of the United States on the expiration date of the license or card; provided, that the license or card shall remain valid until the licensee or card holder is released from active duty and for a period of not less than 180 days following their release; provided, however, that, if the licensee or card holder applied for renewal prior to the end of that period, the license or card shall remain valid for all lawful purposes until the application for renewal is approved or denied; or
(iii) the expiration period has not yet exceeded 90 days beyond the stated date of expiration, unless such license to carry or firearm identification card has been revoked or suspended.
(t)
Any person in possession of a license to carry issued under sections
131 or
firearm identification card issued under
section 129B whose respective license or card is invalid for the sole reason that it has expired, not including licenses and cards that remain valid under subsection (s), and not otherwise disqualified from renewal upon application, shall be subject to a fine of not less than $100 nor more than $5,000 and section 10 of chapter 269 shall not apply; provided, however, that this exemption shall not apply if such license or card:
(i) has been revoked or suspended unless such revocation or suspension was caused by failure to give notice of a change of address;
(ii) is the subject of pending revocation or suspension unless such revocation or suspension was caused by failure to give notice of a change of address; or
(iii) has had an application for renewal denied.
Any law enforcement officer who discovers a person to be in possession of a firearm after such person’s license or card has expired, meaning after 90 days beyond the stated expiration date on the license or card or has been revoked or suspended solely for failure to given notice of a change of address, shall confiscate such firearm and the expired or suspended license or card then in possession and such officer shall forward such license or card, as soon as practical, to the licensing authority that issued the expired license or card. The officer shall, at the time of confiscation, provide to the person whose firearm has been confiscated, a written inventory and receipt for all firearms confiscated and the officer shall exercise due care in the handling, holding and storage of these items. Any confiscated firearm shall be considered surrendered and subject to the conditions of section 129D; provided, however, that the confiscated firearm shall be returned to the owner if proof of license or permit reinstatement is provided within 1 year of confiscation. This subsection shall not apply to temporary licenses to carry under
section 131F.