No they are right.
Question 11.aq Actual Transferee/Buyer: For purposes of this form you are the actual transferee/buyer if you are purchasing the firearm for yourself or otherwise acquiring the firearm for yourselrf (e.g. redeeming the firearm from pawn/retrieving it from consignment, firearm raffle winner). You are also the actual transferee/buyer if you are legitamately purchasing the firearm as a gift for a third party.
Read the last sentence.
That's not the gift exception.