No, the lower alone is not an NFA item. SBR's & SBS's are classified in totality. A SBR lower without its short barreled upper or an upper that is atleast 16" is no longer a NFA item.I'm 99.999% sure that is incorrect. Once approved, the lower receiver is the NFA item. You can strip all the other parts off and sell the lower receiver, but it still has to transfer on a Form4.