CRD FAQ - Form Filing for Individuals - Fingerprint Cards

What are some important tips for the successful submission of fingerprint cards?

 

  • Always complete the employer's name, address, and org number on every fingerprint card submitted. This is especially important when submitting large batches of fingerprint cards as the cards could get separated during processing.

  • All fingerprint cards should contain a barcode. If using a barcode sticker, the sticker should be placed in "OCA" field on the card. If you need a supply of barcode stickers, contact the Gateway Call Center to order a supply. There is no charge for the barcode stickers.

  • Query an individual's record before processing the U4 to determine if a fingerprint card has been processed for that individual previously for your firm. If one has, and the individual has been continuously employed, click the second radio button which indicates that the individual already has a card on file with your firm.

  • All fingerprints should be taken in black ink.

  • Before submitting the fingerprint card to FINRA, review the following data for accuracy:

    • Social Security Number
    • Date of Birth
    • Place of Birth
    • Sex
    • Height
    • Weight
    • Hair color (using the three letter code)
    • Eye color (using the three letter code)

  • When completing fingerprint cards for submission to FINRA, please write the individual's name and physical description clearly on the cards to ensure that the fingerprint card is processed in a timely manner by the FBI. This information must be legible or the card is rejected by the FBI.

  • Write the individual's CRD Number in the "CRD Number" field on the card.

  • Do not highlight any information or any portion of the fingerprint card. Fingerprint cards with highlighting are rejected by the FBI.

 

Do firms need to fingerprint their college interns?

It depends on what duties the intern will perform for the firm. Firms can impose their own requirements on top of those required by law, but Rule 17f-2 (Fingerprinting of Securities Industry Personnel) under the 1934 Securities Exchange Act exempts employees from fingerprinting who do not:

 

  1. sell securities;
  2. regularly have access to the keeping, handling or processing of securities, monies or the original books and records relating to the securities or monies; or
  3. have direct supervisory responsibility over those who sell securities or have access to securities, monies or the original books and records.

 

Most interns will likely not perform any of these three functions, but if they do, firms must fingerprint those interns.

 

How long do I have to submit the hard copy fingerprint card to FINRA after the filing is submitted electronically?

The fingerprint card MUST be received by FINRA within 30 days after a U4 filing is submitted to Web CRD. If the fingerprint card is not received within the 30-day time period, the individual's FINRA registration status will be changed to "Inactive-prints", and the individual will have to cease doing business until such time as the card is received and entered into the Web CRD system.

 

A registered representative with my firm has a Fingerprint Card status of "LGCY." What does this mean?

This status was added to the record of any individual who, at the time of the Web CRD conversion, had an approved FINRA registration with a member firm but did not have a fingerprint card record converted to Web CRD for that firm. The main reasons for the lack of the fingerprint card record were: 1)The individual was part of the original CRD conversion in 1981, where fingerprint card records were not converted; 2)The individual had a fingerprint card record with the firm on Legacy CRD but it preceded the employment date indicated on the Form U4 Filing; or 3)The individual was part of a Legacy Agent Mass Transfer and the fingerprint record was not transferred to the new firm.

 

Where does the barcode sticker go if a card needs one?

If you need to place a barcode sticker on a fingerprint card, the sticker should only be placed in the area marked "Your No: OCA" in the upper left corner of the card. This is for the purposes of barcode scanning by the FBI.

 

How do I retrieve my firm's Fingerprint Reports?

Your firm's Fingerprint Reports can be retrieved by entitled Reports users by accessing Reports and then clicking on the View Reports tab. To open the report, single click for viewing.

 

Is it okay for my firm to resubmit a fingerprint card for one of our registered individuals for the purpose of current disclosure verification, and will we be charged the Fingerprint Fee?

Your firm can re-fingerprint the individual and submit a new set of fingerprint cards to FINRA. FINRA will contact the firm to be sure it is aware of submitting duplicate fingerprint cards prior to processing. The Fingerprint Fee will be assessed.

 

How does a firm complete the Social Security Number (SS#) block of a fingerprint card for a Foreign Associate who does not have a SS#? Should the firm indicate that the person is "foreign" on the card? Should the firm indicate on a fingerprint card that a SS# has been requested but not yet issued?

The SS# block on the fingerprint card is NOT mandatory. A firm should only provide a SS# on the card if the person has one. If there is no SS# (or the individual is in the process of applying for one), the firm should leave the SS# blank. A firm should NOT write "foreign" anywhere on the card. The "Citizenship" block indicates if the individual is a US citizen or not (providing the country designation where the person was born).

 

Is a foreign national or foreign resident exempt from submitting a fingerprint card?

Pursuant to Section 17(f)(2) of the Securities Exchange Act of 1934 and Rule 17f-2 thereunder, the SEC requires broker-dealer firms to require their partners, directors, officers and employees to be fingerprinted and to have their fingerprints processed, unless they are exempt under those same provisions. A firm is responsible for determining whether an individual or the employing firm itself is eligible to claim one or more of the exemptions specified in Rule 17f-2, and for preparing and maintaining records supporting any claimed exemption as required by the Rule.

 

I am having difficulty getting an associated individual in a foreign country fingerprinted promptly. What can I do?

Pursuant to Section 17(f)(2) of the Securities Exchange Act of 1934 and Rule 17f-2 thereunder, the SEC requires broker-dealer firms to require their partners, directors, officers and employees to be fingerprinted and to have their fingerprints processed, unless they are exempt under those same provisions. If the firm or individual is not exempt, it is the responsibility of the firm to get its personnel fingerprinted and to submit the prints to FINRA for processing.1

 

Since the implementation of Web CRD, firms typically submit Form U4 electronically and, by selecting the first radio button in Section 2/Fingerprint Information, simultaneously represent that they are submitting or promptly will submit fingerprint cards as required under applicable SRO rules (see e.g., FINRA Rule 1010, which provides generally that firms must submit fingerprint cards to FINRA within 30 days of filing Form U4). FINRA members have informed FINRA staff, however, that it is difficult to fingerprint associated persons located in certain foreign countries,2 and that they may not be able, therefore, to submit fingerprint cards within the 30-day period prescribed in Rule 1010. Accordingly, FINRA member firms may wish to apply to FINRA for an extension of the 30-day period prescribed in Rule 1010, within which a firm must submit fingerprints to FINRA after the electronic submission of an Initial Form U4, a Relicensing Form U4, or a Form U4 amendment to add a jurisdiction or SRO. In particular, Rule 1010 provides that FINRA may, upon application and a showing of good cause, extend the 30-day period within which a firm must submit fingerprints to FINRA. An application for extension should include the name, address and CRD numbers of the firm and individual, and a detailed "good cause" explanation for the firm's request (e.g., the firm may wish to identify steps that have been taken to attempt to fulfill the fingerprinting requirement). Letters of application may be sent, faxed or e-mailed within the 30-day fingerprint window to:

 

Richard E. Pullano
Associate Vice President and Chief Counsel
Registration and Disclosure
9509 Key West Avenue
Rockville, MD 20850
Fax: (240) 386-4752
Email

 

FINRA will respond in writing to a request. Please note that the above e-mail address was established solely to receive extension requests in the circumstances described above.

 

The firm employs an individual with a foreign address, and is receiving a fingerprint deficiency for this individual when it attempts to submit an Initial Form U4, a Relicensing Form U4, or a Form U4 Amendment to add a jurisdiction or SRO. How can the firm resolve the deficiency?

A firm submitting an Initial Form U4, a Relicensing Form U4, or a Form U4 Amendment to add a jurisdiction or SRO for an individual with a foreign residential address should select the first fingerprint radio button to acknowledge that a card will be submitted (assuming that an exemption is not claimed and documented). The individual will receive an "Approved Pending Prints" registration status, and the firm will have 30 days to submit the card before the individual's registration will go "Prints Inactive."

 

Is a fingerprint card required for each affiliated firm on a Form U4 Filing if the affiliated firms are not part of a Simultaneous Filing Group?

No.  Only one fingerprint card is required for affiliated firms in connection with the Form U4 filing as long as the Forms U4 are filed on the same date.

 

Is a fingerprint card required for each firm on a Form U4 Filing, if the filing firms are part of a Simultaneous Filing Group (SFG)?

No. Only one fingerprint card is required for all SFG firms in connection with the Form U4 Filing.

 

A firm has Non-Registered Fingerprint individuals (NRFs) that are no longer with the firm. How does the firm terminate these individuals?

As of March 18, 2002, the personal data fields (e.g., hair/eye color, weight) are no longer mandatory on the NRF Filing for termination. The firm should terminate the individual by submitting an NRF Amendment Filing that includes the Date of Termination. As the Completeness Check has been relaxed, it is no longer necessary for FINRA to enter the Date of Termination on the firm's behalf. Therefore, firms should submit NRF Amendments to terminate their NRF individuals rather than contacting FINRA to terminate these individuals.

 

To What Address Should I Mail Fingerprint Cards?

All fingerprint cards should be mailed to one of the two following addresses, depending on the method used:

 

First Class Mail should be sent to:

 

FINRA
P. O. Box 9495
Gaithersburg, MD 20898-9495

 

Overnight/Courier Mail should be sent to:


FINRA
Document Processing
9509 Key West Avenue, 3rd Floor
Rockville, MD 20850

 

(Note: When sending Overnight/Courier Mail, please include the following phone number: (301) 869-6699.)

 


1 In this regard, firms may be able to have personnel fingerprinted at the local consulate or through local law enforcement authorities. Alternatively, firms may also designate persons within the firm to roll fingerprints as necessary.

 

2 See Exchange Act Rel. No. 45385 (Feb. 1, 2002), 67 FR 5862 (Feb. 7, 2002).

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