There are many different variations of bay. Black bay, bay and blood red bay. I still say he's a bay and I have had many born with the black lower legs already present. He shows no sign of being a roan that I can see. Sire looks like a slow going grey so he could still start to grey out but you just have to wait and see!
I'm going to jump out there and say he'll shed out (eventually) to blue roan since I've seen babies that looked like this lil one change drastically by the time they were a yearling. Regardless what color he turns out he's going to be gorgeous though!
Sometimes it can still be really hard to tell even when they are older. This horse in the middle is a 4 year old and up until this year, you would have sworn that he was a blue roan because his head used to be the same color as his legs. Just recently did his head start graying and he still has a jet black mane, tail, and legs. Fortunately, I did know that he is a gray as both his parents are gray but it is still tricksy sometimes. :)
We had him genetic tested - he is seal brown. It is also become apparent that he is a roan (rabicano actually) though it's hard to see in his winter woolies. According to the AQHA that makes him a blue roan (black and brown roans are considered blue).
I was going to say dark bay, or bay roan, to early to be sure about roan (I didn't really get the comments about the lightening around the eyes either). I guess testing removes all doubt, personally I'd register him as brown, rabicano is really not the same as roan (Plus I'd never consider it blue roan). But I'm w/ the other poster, lets see pics!