Tom, I am not sure how it is done; my take would be, it's not legal, but they have not yet pushed the envelope, hard enough. A 1903 Springfield does not qualify, C&R, but suppose it did. Would then, a Sedgely Sporter, made from such a rifle, NOT qualify? In essence, it would be a 'modified' C&R, and should not, yet it is a far rarer and more desireable collectible, than the original Rifle! 'Governmental logic', by definition, is like 'Military Intelligence', an oxymoron, by definition, but one I have no desire to challenge, out of the potential costs involved, should I guess different than they did! I'm not sure anyone will ever know the answer.