Electronic Fingerprint Submission (EFS) Information
Last Updated: 8/7/2026
FBI Fingerprint Reuse Policy – No Action at This Time
Recently, the FBI notified FINRA that it continues to work on guidance to organizations related to its updated Fingerprint Reuse Policy, that was published in its January 2026 Outsourcing News newsletter, distributed to Authorized Recipients and available here for reference.
No Changes to Current Procedures at This Time
Firms must continue following existing FINRA Fingerprint Program requirements. Only fingerprints collected and submitted through the FINRA Fingerprint Program to satisfy the requirements under 15 USC 78q(f)(2) are acceptable.
For Firms Using Electronic Fingerprint Service (EFS) Providers
EFS providers have been instructed to maintain current FINRA Fingerprint Program procedures until further notice. EFS providers are not authorized to store fingerprints on behalf of firms or repurpose fingerprints originally captured for other statutory purposes for use in the FINRA Fingerprint Program. No action on reuse is to be taken at this time.
Next Steps
Earlier in 2026, FINRA submitted questions about the new policy to the FBI and is awaiting guidance, including details on the Authorized Recipient approval process required for fingerprint reuse. The FBI is working on responses to questions it received from FINRA and other organizations as well as information on policy implementation.
Please continue to monitor this page for updates.
Until additional information is available, please visit FINRA.org for the latest information.
Questions?
[email protected]
On This Page
EFS Instructions
Broker-dealer firms and funding portals can submit fingerprints electronically to First Advantage Biometrics (formerly known as Sterling Identity), FINRA’s designated fingerprint provider, by following the steps below.
1. Determine how your firm will submit fingerprints
There are two options for electronic fingerprinting:
- Send individuals to a participating EFS vendor’s location. The vendor will transmit fingerprints electronically on behalf of your firm to Sterling. Firms that use this option must contact the EFS vendor to use the vendor’s services and locations.
OR
- Purchase or lease electronic fingerprinting equipment provided by Sterling or another fingerprint equipment provider (e.g., Fulcrum Biometrics, LLC). Your firm will fingerprint associated individuals on-site and submit fingerprints directly to Sterling.
FINRA does not endorse any EFS vendor and EFS vendors offer different options and location availability. Please confirm service terms and conditions directly with the EFS vendor.
2. Select an EFS vendor
Contact an EFS vendor that can accommodate your submission preference. A list of EFS vendors actively submitting fingerprints to the FINRA Fingerprint Program are listed at the bottom of this page. These EFS vendors work with Sterling to process fingerprints on FINRA’s behalf. If your firm selects a certified vendor that will submit fingerprints from a vendor’s location, then you do not need to notify FINRA or Sterling.
EFS vendors not listed below must complete an integration process with Sterling before they can submit fingerprints. For additional information, contact Sterling at [email protected].
EFS Vendors
The certified EFS vendors listed below have entered into an agreement with Sterling under which they agree to collect fingerprints solely for the purpose of satisfying an organization’s obligation under Section 17(f)(2) of the Securities Exchange Act of 1934, (15 USC 78q(f)(2)), and Exchange Rule 17f-2 thereunder, as amended, for the FINRA Fingerprint Program (Program). The EFS vendors listed below currently submit fingerprints to FINRA. The vendors must comply with the requirements of the Program and requirements and standards of the FBI, including the FBI Criminal Justice Information Services Security Policy (Policy).
FINRA will update this list as new vendors participate. Please contact EFS vendors directly with any questions about their services and location availability.