It absolutely does, unless the only thing you are doing is shortening the barrel. The common misconception is, for example, you can make up your own SBR via Form 1 and use all imported parts. This is not true. You still have the burden, as the manufacturer/assembler, of complying with 922(r), even for an NFA item. The so-called "NFA exception" addresses the specific instance of shortening the barrel on a lawfully imported weapon. The weapon would not be importable as an SBR. And ATF would then be in the awkward position of giving "permission" via an approved Form 1, to create a violation. So you can do a barrel chop on your HK94 that was brought in before all this gibberish commenced and be good. But you cannot "roll your own" using more than 10 imported parts. Confusing, ridiculous, and I have absolutely no clue what public safety issue is being served by keeping it.

I can say that 922(r) does have *many* convictions... It just never has been the lead charge. And 922(r) is *only* a making offense, not a possession offense.