Yes. As with most laws, it's a lot more complicated, and the words used frequently legally mean something considerably different than common English indicates.
Any idea what "service" a retail gun dealer provides to a customer that knows what he wants and why, and doesn't need any hand-holding about it, that's worth the markup?
Very little.
- Compliance with unconstitutional regulations
- Possibly having the item in stock, eliminating need to order
- Warranty-type repairs.
I've considered opening a shop (yes, RP, it would be a Type 01 FFL, with storefront and posted hours, fully complying with both the letter and anal-retentive spirit of the law) that would ONLY provide transfers. Stock full of catalogs, web-browsing computers, etc. - all to facilitate complying (or, per RP, "evading") with relevant federal firearms transfer laws without the overhead of inventory etc.
Point out that "law" for me, would you? You keep referencing it. I can't find it.