While we're talking about the 4473
I found an OMB report from 1997 that reported they'd found ATF was in violation of the Paperwork Reduction Act for a period of time, with its revised 4473:
Paperwork Reduction Act Violations Top of Page
Department of Treasury/Bureau of Alcohol, Tobacco, and Firearms (ATF)
Title: Firearms Transaction Record, Part I, Over-the-Counter, and Firearms Transaction Record, Part II, Non-Over-the-Counter (ATF F 4473, Parts I and II (5300.9))
Violation: Unauthorized Collection
How Discovered by OMB: In February 1997, the public notified OMB that ATF had revised Form 4473, Part I, without OMB approval.
OMB Action: ATF's submission of the revised forms to OMB, requesting an extension without change. were designated by OMB as improperly submitted.
Agency Response: ATF resubmitted the forms to obtain OMB approval of the revisions. Treasury has assured OMB that ATF will reexamine its internal procedures to ensure future compliance with the PRA.
The PRA requires an agency, before it issues a form asking info from the public, to get approval from OMB and to publish that at the bottom of the form. Every so many years, OMB reviews the forms to see if there is any way the time spent filling them out could be shortened.
Back in the Reagan years I urged NRA and GOA to raise the question when the 4473 came up, and a long list of suggested deletions went to OMB. They did nothing back then (the guy in charge kept saying his wife had been robbed with a gun, as a hint that they were spinning their wheels with him), but there's surely someone else in there today. I just haven't found when the form comes up for renewal, yet.