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new question on 922R compliance


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I know this subject has been discussed extensively but I have a possibly new question that I have not seen addressed and would appreciate an opinion from those who are more well versed than myself.

I have a Benelli M4 that for personal reasons would like to keep as stock as possible, but at the same time I would like to make some changes to it. I have read that in order to maintain compliance with the 922R ruling, in order to install a full length magazine tube, you would have to replace 3 original parts with US made parts. The list of those 13 parts as set forth by Federal law is as follow:




Bolt Carrier

Gas Piston

Trigger Housing




Buttstock (with integral pistol grip)





So far, what I have done to mine was to replace the magazine with the Carriercomp full length magazine, replaced the follower, and replaced the original forends with FFT forends. From what I have read, replacing those 3 parts with US made parts have allowed me to have a full length magazine and still maintain compliance with the 922R ruling.

The new part of this question involves replacing the standard pistol grip stock with the Benelli collapsible stock. From what I have read the M4 collapsible stock is comprised of 2 parts, the stock itself and the pistol grip. So if you want to add the M4 collapsible stock, you must replace a 4th original part with a US made part to be legal.

If you were to replace the original pistol grip stock with the Benelli collapsible stock, but use an American made pistol grip such as the grip from the ProMag collapsible stock, would you still be in compliance with the 922R ruling?

The way I see it, you are replacing the original foreign made pistol grip with an American part, and this should count as the necessary 4th part replacement which would allow for the legal addition of the Benelli collapsible stock.

My reasoning for this is as follows. I would like to keep my M4 as stock as possible internally and cosmetic-wise, but still add the extra magazine capacity and the Benelli collapsible stock. I have tried the ProMag collapsible stock and find it lacking in the same quality of the Benelli C-stock. The ProMag pistol grip however is indistinguishable from the Benelli pistol grip. If I use the ProMag pistol grip instead of the Benelli pistol grip, this allows me to maintain a stock appearance, and also allows me to legally add the Benelli C-stock, with it's superior quality, without changing any internal parts. I realize that a hammer change for example is fairly simple, but I would prefer not to change anything internally.

That is my reasoning on this subject. I would appreciate any additional opinions on this. Am I correct in my thinking, or am I wrong?

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Thank you M2_shootr for your help. Replacing the internals is a great way to improve the M4, but I'm just a little funny about keeping the internals stock.

As far as the ProMag stock, I purchased it when it was first introduced at a great price thinking that it was going to be better quality than it turned out to be. So rather than just let that be a waste, I wanted to see if I could use the pistol grip with the Benelli C-stock and still be 922R compatible and not have to spend more money and change any internal parts. The pistol grip part of the ProMag C-stock package is totally indistinguishable from the Benelli pistol grip, so I feel that I am not compromising anything by using it (as far as the C-stock part of it, there is no comparison, the Benelli is far superior). My only concern is how to distinguish it as a US made part just in case the question ever comes up.

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Just keep your receipt. I'd try fitting Benelli OEM parts into the collapsible stock to make it functional. Some of the small hardware like the pins that engage the receiver extension would be rather easy to replace.


I might give your suggestion a try. On the other hand, I had in the past, considered buying the bare Benelli C-stock and transferring the internal parts from the ProMag into it, thinking that it was the ProMag frame that was inferior. Many (not all) of the replacement parts for the C-stock are available and I would think that they would interchange with the ProMag parts. The only reason I haven't done that was that the price on the original Benelli C-stock has dropped dramatically from the panic induced pricing the last few years. Now that the price on the original Benelli is once again reasonable, there's no reason to consider the inferior ProMag C-stock.

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Personally, I chose to change the internals. Installing the Geissele hammer and FFT trigger was a wonderful addition!
I made this choice as well ... easy to do and easy to reverse if desired. One option to consider: you can buy a stock fire control group from Brownells and modify it and retain the one in your M4 in stock condition. Easy and quick to exchange the FCG's.
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