The short answer is Yes. FFLGuard has confirmed this in writing from the ATF.

Breaking down (disassembling) a firearm is not considered a firearms manufacturing process.

You do not need a manufacturing FFL (Type 07 or 10) to disassemble firearms. When you disassemble the firearm into a frame, receiver, or parts you will need to log the firearm (e.g., a rifle) out to your FFL on the day you strip the firearm down to a frame or receiver. Then you will acquire the resulting frame or receiver in from your FFL. You do not need to add your markings to the frame or receiver.