When I bought Selene, she was already USCG registered, Even so, the paperwork was tricky. I used a title company to deal with background checking, ownership paperwork, transferring the ownership and the USCG updating. It cost a bit, but that part of the process went smoothly. But equally you can do it yourself - but it can get confusing with many forms required.....
Regarding your concern, I am no expert but I looked on the USCG vessel documentation site (
http://uscg.mil/hq/cg5/nvdc/default.asp), and to be honest it looks pretty straightforward (my underlining!):
"If the vessel is new and has never been documented, ownership may be established by submission of a Builder's Certification (Form CG-1261), naming the applicant for documentation as the person for whom the vessel was built or to whom the vessel was first transferred. Also acceptable are a transfer on a Manufacturer's Certificate of Origin, a copy of the State Registration or Title, or foreign registration showing that the applicant owns the vessel.
In the case of a previously owned vessel, the applicant must present bills of sale, or other evidence showing transfer of the vessel from the person who last documented, titled, or registered the vessel, or to whom the vessel was transferred on a Builder's Certification or Manufacturer's Certificate of Origin. If title was transferred by some means other than a bill of sale, contact the NVDC for assistance."So it would appear a bill of sale will work fine.