DD - I can appreciate your experience, but following the letter of the law in a situation like this can not be argued.

The AECA is covered in detail by the ATF at the link below and its requirements are not gray.

http://www.atf.gov/pub/fire-explo_pub/aeca.htm

The title of the AECA may imply that it is for exports only, but in fact, registration is required to import articles contained on the US Munitions Import List by Section 38 of the AECA of 1976.

See Subpart C, 447.21 "The U.S. Munitions Import List" for details:
(a) Nonautomatic and semiautomatic firearms, to caliber .50 inclusive, combat shotguns, and shotguns with barrels less than 18 inches in length, and all components and parts for such firearms.

If you're trying to import a "Nonautomatic or Semiautomatic firearm to caliber .50 inclusive..." then to get the import permit approved from the ATF, you will have to be registered under the AECA and approved to import Category I(a) articles. If it is larger than .50 caliber then you must be registered under the AECA and approved to import Category II(a) articles.

If not, you're import permit will not be approved.

So, without a Arms Export Control Act number, you can't get a form 6 for a Category I(a) article. If your FFL holder (type 01) has an Arms Export Control Act number, you could get an approved form 6.

If the rifle has a value of more than $2,000.00, you can't clear it yourself (licensed or not), as you know, it's then a formal entry and has to be done by a licensed customs broker.

As for an unlicensed person trying to import a firearm and then take them to the approved (form 6) importer for licensing back to them... I just can't imagine how that's a sound decision.