NICS is the system FFLs use. The FBI is using IAFIS, NCIC, and the Interstate Identification Index to process NFA background checks. The results are essentially the same.
You are not required to provide your SSN. If it was required, ATF/FBI would have to state so on their forms, pursuant to The Privacy Act of 1974 (Public Law 93-579).
Sec. 7. [5 U.S.C. 552a note] (a)(1) It shall be unlawful for any Federal, State or local government agency to deny to any individual any right, benefit, or privilege provided by law because of such individual’s refusal to disclose his social security account number.
(2) the provisions of paragraph (1) of this subsection shall not apply with respect to—
(A) any disclosure which is required by Federal statute, or
(B) the disclosure of a social security number to any Federal, State, or local agency maintaining a system of records in existence and operating before January 1, 1975, if such disclosure was required under statute or regulation adopted prior to such date to verify the identity of an individual.
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Arguably, the system of records for the NFRTR and NFA forms was established in 1934, but I find no attempt by BATFE to claim such exemption.
The back of the FD-258 (Instruction 2) states: The Privacy Act of 1974 (PL 93-579) requires that local, state, or federal agencies inform individuals whose Social Security number is being requested whether such disclosure is mandatory or voluntary, the basis of authority for such solicitation, and the uses which will be made of it.
According to FBI
Guidelines for Preparation of Fingerprint Cards, the required fields are:
Name (NAM)
Originating Agency Identifier (ORI) Number
Date of Birth (DOB)
Sex (SEX)
Charge (not applicable to FD-258 civil prints)
Fingerprint Impressions
Therefore the SSN is not required by the FBI on their FD-258 form for civil applicants.
(Your SSN may be requested pursuant to 28 U.S.C. § 534 however disclosure is not mandatory.)
When reviewing ATF documentation for SSN submission guidance, we find it is not required on Form 4473:
Must a transferee provide his or her social security number on the ATF Form 4473?
This FAQ cites 27 CFR 478.124
(c)(2) In order to facilitate the transfer of a firearm and enable NICS to verify the identity of the person acquiring the firearm, ATF Form 4473 also requests certain optional information. This information includes the transferee's social security number. Such information may help avoid the possibility of the transferee being misidentified as a felon or other prohibited person.
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Similar language referring to the SSN being optional is also found in the latest law changes, relative to
ATF-41F (81 FR 2721).
From Section III, Paragraph B. "Amendment of §§ 479.62 and 479.63"
• A completed ATF Form 5320.23 for each responsible person. Form 5320.23 would require certain identifying information for each responsible person, including each responsible person’s full name, position, social security number (optional), home address, date and place of birth, and country of citizenship
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Language requiring a SSN does not appear in 27 CFR §§
479.62 and
479.63