CRD - Fingerprint Cards Frequently Asked Questions (FAQ)
- 1. What are some important tips for the successful submission of fingerprint cards?
- Query an individual's record before processing the U4 to determine if a fingerprint card has been previously processed for that individual 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 fingerprints on file with your firm.
- All fingerprint cards should contain a barcode. If using a barcode sticker, the sticker should be placed in the " Your No: OCA " field on the card. If you need a supply of barcode stickers, contact the FINRA Gateway Call Center at (301) 869-6699 to order a supply. There is no charge for the barcode stickers.
- All fingerprints should be taken in black ink.
- 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.
- Review the following data on the card for accuracy:
- Write clearly on the card to ensure that the fingerprint card can be processed in a timely manner. Information on the card must be legible or the FBI will reject the card.
- Ensure that the fingerprint card is signed by the person being fingerprinted AND by the official taking the fingerprints.
- Do not highlight any information or any portion of the fingerprint card or the FBI will reject the card.
- 2. 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 the country designation where the person was born.
- 3. 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 purpose of barcode scanning by the FBI.
- 4. SEC Rule 17f-2 requires that I may need to submit up to three sets of fingerprints. Can I submit all three sets of fingerprints at once?
- FINRA does not accept duplicate sets of fingerprints for the same individual. Duplicate cards are returned to the applicable firm.
- 5. 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:
- sell securities;
- 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
- have direct supervisory responsibility over those who sell securities or have access to securities, monies or the original books and records.
- 6. How long do I have to submit fingerprints to FINRA after the filing is submitted?
- Fingerprints MUST be received by FINRA within 30 days after a U4 filing is submitted to Web CRD. If fingerprints are 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.
- 7. A registered representative with my firm has a Fingerprint 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 record converted to Web CRD for that firm. The main reasons for the lack of a fingerprint record were: 1)The individual was part of the original CRD conversion in 1981, where fingerprint records were not converted; 2)The individual had a fingerprint 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.
- 8. 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.
- 9. Is it okay for my firm to resubmit fingerprints 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 fingerprints to FINRA. The Fingerprint Fee will be assessed.
- 10. Is a foreign national or foreign resident exempt from submitting fingerprints?
- 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.
- 11. 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 fingerprints as required under applicable SRO rules (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 fingerprints 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 emailed within the 30-day fingerprint window to:
Richard E. Pullano
Vice President and Chief Counsel
Registration and Disclosure
9509 Key West Avenue
Rockville, MD 20850
Fax: (240) 386-4752
FINRA will respond in writing to a request. Please note that the above email address was established solely to receive extension requests in the circumstances described above.
- 12. 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 fingerprints 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 fingerprints before the individual's registration will go "Prints Inactive."
- 13. Are fingerprints 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 set of fingerprints is required for affiliated firms in connection with the Form U4 filing as long as the Forms U4 are filed on the same date.
- 14. Are fingerprints required for each firm on a Form U4 Filing, if the filing firms are part of a Simultaneous Filing Group (SFG)?
- No. Only one set of fingerprints is required for all SFG firms in connection with the Form U4 Filing.
- 15. A firm has Non-Registered Fingerprint individuals (NRFs) that are no longer with the firm. How does the firm terminate these individuals?
- Personal data fields (e.g., hair/eye color, weight) are not 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.
- 16. What happens to my fingerprints if they cannot be processed?
- If fingerprints were submitted by card, FINRA will return the deficient fingerprint card to the appropriate firm if sufficient identifying information such as a Firm CRD# and address are provided on the cards.
- 17. What are the codes for hair color and eye color?
Hair Color Code Bald BAL Black BLK Blonde or Strawberry BLN Brown BRO Gray or Partially Gray GRY Red or Auburn RED Sandy SDY White WHI Blue BLU Green GRN Orange ONG Pink PNK Purple PLE Eye Color Code Black BLK Blue BLU Brown BRO Gray GRY Hazel HAZ Maroon MAR Multicolored MUL Pink PNK
- 18. 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:
P. O. Box 9495
Gaithersburg, MD 20898-9495
Overnight/Courier Mail should be sent to:
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).