For an individual who is an FFL holder (01 or 07) as a sole proprietor:

Were this individual to allow a personally-owned handgun or NFA item to be shot/handled by a person aged 18-20, would they be in violation of any firearms laws regarding the transfer from a dealer to an "underage" individual?

I realize on the surface this seems straight forward (as said FFL would be acting as an individual and not as a dealer) but as we all know, when it comes to firearms laws, appearances can sometimes be deceiving.

In essence, I suppose this comes down to if ones status as a FFL holder (especially as a sole-proprietor) trumps ones status as an individual in the eyes of the law/ATF, or does the "titling" of the firearm to the individual (i.e. completion of a 4473) make all the difference?