No NFA. Not an SBS. The Black Aces FIREARM is what the ATF calls it
The new “firearm” by Black Aces Tactical has all the characteristics of a short shotgun, without the name. It shoots 2 3/4″ shotgun shells, uses a pump for cycling, and even leaves a big hole in whatever it shoots. But the ATF’s own wording was used to design a firearms that cannot be called a shotgun, an SBS, an SBR, a pistol, an AOW.