To whom TSA rules apply
All aliens/foreigners who apply for training.
Now, what is considered "training"?
What is training? – training that a candidate could use toward a new airman certificate or rating.Especially Instrument rating and Multi engine rating. These rules do not apply for US citizens. Therefore the flight school has to obtain proof of US citizenship (U.S. birth certificate or U.S. passport)
So, NO backgroundcheck is required if you come to the USA for:
* BFR (Biennial Flight Review)
* IPC (Instrument Proficiency Check)
* Rental checkout
* Aircraft rental
* Hour building
Hope this helps..