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He's already directed the Department of Justice to propose regulations that would ban bump stocks,

I've read that memo. He may wish to give that appearance, but that is not what the memo actually says.

In the memo, Trump recites that he "asked my Administration to fully review how the Bureau of Alcohol, Tobacco, Firearms and Explosives regulates bump fire stocks and similar devices." "Although the Obama Administration repeatedly concluded that particular bump stock devices were lawful to purchase and possess, I sought further clarification of the law restricting fully automatic machineguns."

He goes oon to recite that DoJ "started the process of promulgating a Federal regulation interpreting the definition of 'machinegun' under Federal law to clarify whether certain bump stock type devices should be illegal."

Then the operative paragraph of the memo: "Today, I am directing the Department of Justice to dedicate all available resources to complete the review of the comments received, and, as expeditiously as possible, to propose for notice and comment a rule banning all devices that turn legal weapons into machineguns."

Nowhere in the memo does Trump actually: (1) state any belief or conclusion that bump stocks actually turn legal weapons into machineguns or that they otherwise are or ought to be illegal; or (2) direct anyone to promulgate any rule banning bump stocks or any other device per se.

In fact, the only logical outcome of this memo is that the Department of Justice will determine, just as the Obama Administration did, that bump stocks do not convert firearms into "machineguns" as defined under 28 U.S.C. § 5845(b), because a firearm outfitted with one does not "shoot, automatically more than one shot, without manual reloading, by a single function of the trigger." Constrained by the plain language of the statute, the Department of Justice would have to conclude that it is without authority to promulgate a rule banning bump stocks. Thus, any federal ban of bump stocks would have to come from Congress.

Maybe I'm wrong, but if there was a way to interpret the NFA in a way that bump stocks were illegal, I have to think the Obama Administration would have done so.

I think Trump's memo is a way of deferring the issue while giving the appearance of "doing something," and then giving him cover to punt the issue over to Congress.