Snowman wrote:^^ sure sounds like it to me. You described the requirerments, and the pistol meets them.
No round under the hammer? Check.
No round in position where a single pull of the trigger will fire a round? Check.
Are to actions required to fire? Yes.
Yeah... but I've heard officers who memorized "nothing under the hammer, nothing in the next chamber... so downloaded by two".
Ah well, get your CFP and don't worry. Besides, it would be kinda hard to open carry that little gun.