Since Jason worked with BATF to get the serial numbering system approved and done, i would think that they also approved C&R status.
It is truely funny how contradictory the system is...
A frame has a serial number so it is therefor considered a "firearm" in and of itself. But that same "firearm" may not be considered a C&R because it is not complete.
OR
A firearm manufactured prior to 1968 need not have a serial number, but these fox parts, being made way before that, now need a serial number to be sold.