[SenorZ]

No. It is no longer COTS if someone cannot buy it, in that configuration, in a store, or online.

A COTS part that has been painted is considered "fabricated" because it is not available in that "configuration" to the general public. A COTS controller board, memory card, etc., are all COTS on their own. But once you slap them together they become a "fabricated" item.