Form 4473 Section C: The NICS Background Check Fields Explained

Section C of Form 4473 documents the NICS background check. It's one of the most frequently cited sections during ATF compliance audits — not because NICS is complicated, but because dealers routinely leave fields blank or enter information incorrectly under the pressure of a busy counter.

Question 27a — Date of NICS Contact

This is the date you contacted NICS for the background check. It should be the exact date the call or E-Check was made. This date is critical because it starts the 30-day clock for when the transfer must occur. Leave it blank and you've lost the ability to verify the proceed was valid when the transfer took place.

Question 27b — NICS Transaction Number (NTN)

Every NICS contact generates a transaction number. This number must be recorded in Question 27b for all responses — proceed, delayed, and denied. A missing NTN is one of the most common ATF audit findings. There is no legitimate reason for this field to be blank on a completed transfer.

Question 27c — Response

Circle or check the appropriate NICS response: proceed, delayed, or denied. This field must always reflect the actual response received. On a denied form, this field should show "denied" — and the transfer should not have occurred.

Question 27d — Delay Response

If NICS returns a delayed response, this field documents the follow-up. If NICS subsequently provides a proceed, record the date and proceed response here. If three business days pass after a delay with no further response from NICS, the dealer may (but is not required to) proceed with the transfer at their own discretion. If you choose to proceed after three days, note this in 27d with the date the three-day period expired.

Question 27e — State License Exemption

Some states have permit systems that qualify as a NICS alternative — meaning a valid state permit can substitute for a NICS check. If your state has this exemption and the buyer presents a qualifying permit, this field documents the exemption. Know your state's rules before using this field.

The Section C Completion Checklist

Before any transfer is finalized, verify: 27a has a date, 27b has the NTN, 27c shows the appropriate response, and 27d is completed if there was a delay. Every field must have an entry. A Section C with blank fields is a Section C with violations waiting to be found.