Help me understand 922(r) and how it relates to my semiauto shotgun (non-saiga)

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I thought I had this figured out but am now concerned that this may not be legal. I have a Beretta 1201-FP with a non-removable mag that has a 5 round capacity. I am planning on putting a pistol grip stock on it, but some people have the idea that this would not be in compliance with 922r. I don't understand how it would be any different than current Benelli M4's...and thus how it would be illegal.
 
922 have to do with # of foreign parts on a rifle / shotgun.

Siagas are a prime example. They come in a sporting configuration (imported with pistol grip is not for sporting) but everyone changes them to a traditional AK style. The problem is that once one part is removed with a US part the # of foreign parts must be below certain # as you are effectively turning it from a foreign rifle into a US made one.

If you use a US made stock then the # of parts would need to be in check with 922r. If it is Semi-auto then you need to watch MA AWB regs as well.

Use this chart as a guideline.

http://gunwiki.net/G...erifyCompliance

There is another one that would let you pick shotgun or rifle but the link is not working or I cannot find it at this time.
 
922(a) essentially prohibits using imported parts to convert an imported rifle or shotgun into a (non-sporting) configuration that it was not imported in. AFAIK it appears that the 1201-FP was imported in pistol grip configurations, therefore the conversion suggested would not be subject to 922(a).

IANAL. YMMV. More info here.
 
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