Sorry, Cheapshooter, a consignment sale is a perfectly legal and correct way for anyone to sell a firearm; it is not a "loophole" or cheating. The 01 dealer is legally the seller as far as BATFE is concerned, and AFAIK it is perfectly legal for a C&R licensee to sell a gun (C&R or not) to/through a licensed dealer. BATFE is concerned when a C&R licensee sells guns obtained under the license to non-licensees.
There are some states where for some guns, a C&R licensee cannot legally sell ANY gun directly to a buyer even to another C&R licensee. In MD, for example, the C&R license is NOT recognized for in-state transfers of regulated firearms. So if a C&R licensee wants to sell, say, a Luger, to ANYONE, even another C&R licensee, he/she has to go through a MARYLAND LICENSED (not only an FFL) dealer. In that case, the C&R license isn't worth the paper it is printed on.
Jim