The new Remington Ultimate Muzzleloader is built on a standard 700 action and DOES require a FFL to ship just like any of the other 700 actions.
Has nothing to do with the 209 ignition.
That is my understanding; forgive me if I am wrong.
God Bless, Louis
I was told it is the same as a encore muzzleloader. The "receiver" is still a firearm readily converted to cartridges.