Q: Our state regularly lists only middle initials on state-issued drivers licenses. How do we proceed when the state drivers license lists only an initial, but the customer lists their full middle name on the ATF Form 4473. For example: Drivers License lists John A Smith. 4473 lists John Allen Smith.
A: We have asked ATF HQ this very question and received the below response. While supplemental governmental ID is usually accepted for purposes of address, it can also be accepted for purposes of verifying other aspects of the identification as shown by Question # 4. The source of the below questions and answers is in ATF correspondence to FFLGuard dated January 17, 2017.
Question #1: Some identification documents reflect only an initial as a middle name even though the individual has an actual middle name. Must a transferee record his/her middle name initial, or his/her actual full middle name?
Response: The ATF Form 4473 Question #1 heading requires the transferor to record his/her complete middle name if the person has a middle name or, if no middle name, to record ?NMN.? Form 4473 further states that ?[i]f legal name contains an initial only, record ?IO? after the initial.? A valid government issued document may be used to verify identification even if it reflects only a middle initial rather than the person?s full middle name.
Question #4: May supplemental identification be used only to verify a current address?
Response: ATF Ruling 2001-5 states as follows: Licensees may accept a combination of valid government-issued documents to satisfy the identification document requirements of the Brady Act. The required valid government issued photo identification document bearing the name, photograph, and date of birth of the transferee may be supplemented by another valid, government-issued document showing the transferee’s residence address. (emphasis added) The revised ATF Form 4473, instructions to Question 18.b, states: Licensees may accept a combination of valid government-issued documents to satisfy the identification document requirements of the law. The required valid government-issued photo identification document bearing the name, photograph, and date of birth of the transferee/buyer may be supplemented by another valid, government-issued document showing the transferee’s/buyer?s residence address. (emphasis added) Accordingly, a valid government-issued identification bearing the name, photograph, and date of birth of a transferee may be supplemented with another valid government-issued document for the purpose of verifying the transferee?s current residence address and/or any of the other identifying information required to be verified by the FFL.
View the answer to this and thousands of other questions in our client-only Support Center.View Answer