Attachment A to Subpart B of Part 147 – Standard A – National Agency Check With Local Agency Checks and Credit Check (NACLC)

Quick Answer: What This Section Does

Standard A—known as the National Agency Check with Local Agency Checks and Credit Check (NACLC)—defines how the government investigates individuals applying for:

• Confidential clearances
• Secret clearances
• “L” access authorizations

It establishes:

• what records are reviewed
• how far back investigators look
• what information is verified
• when reinvestigations occur

👉 In practice, this section answers a key question:

“What does the government actually check for a Secret-level clearance?”

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What This Means in Practice

Most applicants assume a Secret clearance investigation is:

• limited
• surface-level
• based primarily on forms

That is not accurate.

A NACLC investigation includes:

• federal database checks
• local law enforcement checks
• credit and financial review
• identity verification
• multi-location record review

Adjudicators are not asking:

👉 “Did you fill out the form correctly?”

They are asking:

👉 “Does the record confirm what you disclosed—and does it raise risk?”

This is explained more broadly in the security clearance investigation process and how background checks are actually conducted.

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How This Standard Is Actually Used

Standard A applies to:

• initial Secret and Confidential investigations
• reinvestigations at those levels
• individuals entering or continuing in cleared roles

It is less intensive than Top Secret investigations, but still thorough.

👉 and it is often where issues first surface

This is why even lower-level clearances can generate problems, as explained in what disqualifies you from a security clearance and how issues are evaluated across cases.

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Full Text of Standard A (NACLC)

Attachment B to Subpart B of Part 147 – Standard B – Single Scope Background Investigation (SSBI)

(a) Applicability. Standard B applies to initial investigations for;

1. Access to TOP SECRET (including TOP SECRET Special Access Programs) and Sensitive Compartment Information;
2. “Q” access authorizations.

(b) Investigative Requirements. Investigative requirements are as follows:

1. Completion of Forms: Completion of Standard Form 86, including applicable releases and supporting documentation.
2. National Agency Check: Completion of a National Agency Check.
3. National Agency Check for the Spouse or Cohabitant (if applicable): Completion of a National Agency Check, without fingerprint cards, for the spouse or cohabitant.
4. Date and Place of Birth: Corroboration of date and place of birth through a check of appropriate documentation; a check of Bureau of Vital Statistics records when any discrepancy is found to exist.
5. Citizenship: For individuals born outside the United States, verification of US citizenship directly from the appropriate registration authority; verification of US citizenship or legal status of foreign-born immediate family members (spouse, cohabitant, father, mother, sons, daughters, brothers, sisters).
6. Education: Corroboration of most recent or most significant claimed attendance, degree, or diploma. Interviews of appropriate educational sources if education is a primary activity of the subject during the most recent three years.
7. Employment: Verification of all employments for the past seven years; personal interviews of sources (supervisors, coworkers, or both) for each employment of six months or more; corroboration through records or sources of all periods of unemployment exceeding sixty days; verification of all prior federal and military service, including discharge type. For military members, all service within one branch of the armed forces will be considered as one employment, regardless of assignments.
8. References: Four references, of whom at least two are developed; to the extent practicable, all should have social knowledge of the subject and collectively span at least the last seven years.
9. Former Spouse: An interview of any former spouse divorced within the last ten years.
10. Neighborhoods: Confirmation of all residences for the last three years through appropriate interviews with neighbors and through records reviews.
11. Financial Review: Verification of the subject’s financial status, including credit bureau checks covering all locations where subject has resided, been employed, and/or attended school for six months or more for the last seven years.
12. Local Agency Checks: A check of appropriate criminal history records covering all locations where, for the last ten years, the subject has resided, been employed, and/or attended school for six months or more, including current residence regardless of duration

      13. Public Records: Verification of divorces, bankruptcies, and other court actions, whether civil or criminal, involving the subject.

14. Subject Interview: A subject interview, conducted by trained security, investigative, or counterintelligence personnel. During the investigation, additional subject interviews may be conducted to collect relevant information, to resolve significant inconsistencies, or both. Sworn statements and unsworn declarations may be taken whenever appropriate.

15. Polygraph (only in agencies with approved personnel security polygraph programs): In departments or agencies with policies sanctioning the use of the polygraph for personnel security purposes, the investigation may include a polygraph examination, conducted by a qualified polygraph examiner.

(c) Expanding the Investigation. The investigation may be expanded as necessary. As appropriate, interviews with anyone able to provide information or to resolve issues, including but not limited to cohabitants, relatives, psychiatrists, psychologists, other medical professionals, and law enforcement professionals may be conducted.

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Why This Matters for Your Case

This standard reflects a key principle:

👉 even “lower-level” clearance investigations are comprehensive

Many applicants underestimate:

• how much is reviewed
• how many databases are checked
• how easily inconsistencies are found

Two individuals may apply for Secret clearance:

• one is approved quickly
• one is delayed or flagged

Because:

👉 one record raises additional questions

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Where NACLC Cases Often Go Wrong

Problems arise when:

• disclosures do not match records
• financial issues are unresolved
• prior arrests are incomplete or inconsistent
• employment history contains gaps
• applicants assume older issues will not appear

From the applicant’s perspective:

👉 “It’s just a Secret clearance”

From the system’s perspective:

👉 “We are verifying the full record”

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How This Standard Fits Into the Clearance Process

Standard A operates within the broader framework of the security clearance statutes and regulations governing investigation and adjudication standards.

It directly affects:

• what investigators review
• what issues are identified
• what becomes part of the clearance record

Those findings are then evaluated under the security clearance adjudication process and how decisions are made based on risk and credibility.

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How This Standard Interacts With Other Rules

Standard A works alongside:

• investigation scope rules (§147.20 and §147.21)
• National Agency Check requirements
• SF-86 disclosure requirements

Together, these determine:

👉 what is reviewed
👉 how deeply it is examined
👉 how issues develop into concerns

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Why Insight Into the System Matters

Security clearance decisions are not made in a vacuum.

They are made by:

• adjudicators
• administrative judges
• agency decision-makers
• reviewers who rely on the written record

Understanding how these individuals evaluate risk, credibility, and mitigation is not theoretical—it is structural.

At National Security Law Firm, our security clearance lawyers include attorneys who have worked:

• as administrative judges and adjudicators responsible for deciding clearance cases
• inside federal agencies evaluating whether individuals should be approved or denied
• within military legal systems handling sensitive national security matters
• in roles directly applying the adjudicative guidelines to real-world cases

Our cases are not handled by a single attorney working in isolation.

They are reviewed through our internal Attorney Review Board, where multiple experienced attorneys analyze the record, test arguments, and refine strategy before submission.

This mirrors how the government evaluates cases—through layered review and institutional scrutiny.

Clients often come to us after receiving advice that focuses only on:

• legal arguments
• explanations of past conduct

But security clearance cases are not decided that way.

They are decided based on:

👉 how the record will be read, reused, and defended by decision-makers

That is the difference between a response that explains—and a record that supports approval.

You can read what clients say about their experience working with our team in our 4.9-star Google reviews, which reflect both outcomes and the level of strategic guidance we provide throughout the process.

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Speak With a Security Clearance Lawyer Before the Investigation Defines Your Record

The most important question is not:

👉 “What will they check?”

It is:

👉 “What will they find—and how will it be interpreted?”

Before your investigation progresses, review the security clearance lawyer free consultation guide explaining what can be evaluated early in the process.

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The Record Controls the Case.

Attachment A to Subpart B of Part 147 – Standard A – National Agency Check With Local Agency Checks and Credit Check (NACLC)

(a) Applicability. Standard A applies to investigations and reinvestigations for;

1. Access to CONFIDENTIAL and SECRET (including all SECRET-level Special Access Programs not specifically approved for enhanced investigative requirements by an official authorized to establish Special Access Programs by sect. 4.4 of Executive Order 12958) (60 FR 19825, 3 CFR 1995 Comp., p. 333);
2. “L” access authorizations.

(b) For Reinvestigation: When to Reinvestigate. The reinvestigation may be initiated at any time following completion of, but not later than ten years (fifteen years for CONFIDENTIAL) from the date of, the previous investigation or reinvestigation. (Attachment D to this subpart, Table 2, reflects the specific requirements for when to request a reinvestigation, including when there has been a break in service.)

(c) Investigative Requirements. Investigative requirements are as follows:

1. Completion of Forms: Completion of Standard Form 86, including applicable releases and supporting documentation.
2. National Agency Check: Completion of a National Agency Check.
3. Financial Review: Verification of the subject’s financial status, including credit bureau checks covering all locations where the subject has resided, been employed, or attended school for six months or more for the past seven years.
4. Date and Place of Birth: Corroboration of date and place of birth through a check of appropriate documentation, if not completed in any previous investigation; a check of Bureau of Vital Statistics records when any discrepancy is found to exist.
5. Local Agency Checks: As a minimum, all investigations will include checks of law enforcement agencies having jurisdiction where the subject has lived, worked, and/or attended school within the last five years, and, if applicable, of the appropriate agency for any identified arrests.

(d) Expanding the Investigation: The investigation may be expanded if necessary to determine if access is clearly consistent with the national security.