Read the language of the instructions to 11.a. Right there in the example is Mr. Brown using his own money to buy a gun as a gift for Mr. Black. No familial relationship is mentioned, nor required, but third party is specifically mentioned in the instructions. The only issue is whether or not you know, or have reasonable cause to believe the person is prohibited from owning a firearm.
I agree that in the scenario it's a grey area, primarily because the person is not the parent/guardian of the child in question, and the child is obviously under 18.
From the bottom of the training: Carla - What if a customer who qualifies to own a gun buys a firearm as a gift for someone else?
Mr. Lucas - The same rules apply. A transaction is legal as long as the person who fills out form 4473 does so truthfully and completes it as the actual purchaser. In that particular situation, we usually like to make sure they are aware of the rules associated with ATF I 5300.2. Again, you should feel comfortable denying the purchase if you think the customer is being dishonest in any way.
Carla - Suppose Bobby wanted to buy something other than a handgun, like a rifle or a shotgun? Would he still be ineligible?
Mr. Lucas - Bobby would have to be 18 or older to buy a long gun from a Federal firearms licensee. Even then, if he cant provide the appropriate photo identification, or if you believe hes misrepresenting himself, you should deny the sale.
Narrator - Keep in mind that a straw purchase is a purchase in which the actual purchaser uses someone else a.k.a. the straw person to purchase the firearm and complete the paperwork. Generally, the straw purchaser is used because the actual purchaser is not eligible to conduct a transaction because he or she is a felon or other prohibited person. However, a straw purchase occurs even when the actual purchaser is not a prohibited person. The crime committed is knowingly making a false statement on the Form 4473 indicating that the straw purchaser is the actual purchaser, when this is not the case. Additionally make sure you familiarize yourself and anyone who purchases a firearm as a gift with the rules associated with the ATF I 5300.2 pamphlet.