This might be a dumb question but are these cash and carry?
So what if the lower was built into a pistol?
I believe they are sold as a rifle lower thus only 4473 and not hql paperwork so no on pistol I'm guessing.
My nearest shop/range called MSP on this, took them 3 days to get the right person, but they a got a definite yes, C&C gun. They hadn't been carrying them as they thought they were illegal. They are probably the most conservative shop I know of but now know they can sell them.
As an aside, in talking to them about getting RRA in that cal since it's a dedicated lower they told me that RRA will not ship ANY GUNS to MD. When they were at the SHOT Show RRA wouldn't even talk to them when they found out they were from MD. So if you are thinking of buying any parts from RRA I would think again and spend your money someplace else. Glad I sold my RRA AR during the rush. Only sorry I'm still stuck with 2 lowers. I wouldn't buy a screw from them.
How much do they run?