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Frequently Asked Questions (FAQ) about Fingerprint Processing

SEC Provides Temporary Exemptive Relief from Fingerprinting Requirements for, Among Others, Members and All of Their Associated Persons; FINRA Provides Additional Temporary Extension of Time for Submission of Fingerprint Information for Registered Persons

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General FAQs Applicable to All Firms


Q1: Which firm personnel are required to be fingerprinted?
A1: Pursuant to Section 17(f)(2) of the Securities Exchange Act of 1934 and Rule 17f-2 thereunder, as amended, the SEC requires firms to submit fingerprints for all partners, directors, officers and employees, unless they are exempt under those same provisions. Rule 17f-2 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; and
  • Have direct supervisory responsibility over those who sell securities or have access to securities, monies, or the original books and records.

Q2: Is an individual exempt from the fingerprinting requirement based on being a foreign national or foreign resident?
A2: No. Rule 17f-2 lists the bases for exemptions (see Question# 14).

Q3: With FINRA’s fingerprint provider, Sterling, what fingerprint collection options are available?
A3: Firms may choose to use a Sterling collection site, another electronic fingerprint services (EFS) vendor collection site, a firm’s current in-house equipment, or lease Sterling equipment to capture and submit fingerprints. In addition, FINRA-specific hardcopy cards may be sent to Sterling for processing. See Question #6 for more information on hardcopy submissions. If using a vendor, confirm that your vendor is approved and on the list of EFS vendors.

Firms with questions about using Sterling as their fingerprint collection option should contact Sterling Client Support. Firms that choose to use another vendor to collect fingerprints should contact the vendor directly.  

Q4. Are there increased or additional costs to firms associated with this new service?
A4: FINRA continues to collect FINRA and FBI processing fingerprint fees through the firm’s Flex-Funding account in E-Bill. At this time, these processing fees remain unchanged. There are no additional fingerprint processing fees for firms with the new process, regardless of which option(s) firms select, whether it is using Sterling, another electronic fingerprint service (EFS) vendor other than Sterling, submitting through existing in-firm equipment, or sending hardcopy fingerprint cards. 

Note that Sterling and other EFS vendors assess equipment and/or collection fees, which firms will pay directly to vendors as they do today. Firms that choose to use FINRA’s designated vendor to collect fingerprints may save on fingerprint collection and equipment costs as a result of FINRA’s negotiated rates with Sterling. For additional information on Sterling fees, visit Sterling’s FINRA Fingerprinting Resource Page.

Q5. Will individuals at our firm who have already met fingerprinting requirements need to be fingerprinted again with the new fingerprint process with Sterling?
A5: Fingerprint requirements remain the same with FINRA’s new fingerprint process. Individuals who have met fingerprint requirements with their current firm are not required to be re-fingerprinted as a result of the new fingerprint process.

Q6: Where does my firm get fingerprint cards and/or barcodes?
A6: Existing FINRA-specific fingerprint cardstock may be used through June 6, 2022. After this date, new FINRA-specific fingerprint cardstock must be used for all hardcopy fingerprint submissions as the new format includes specific information required for FINRA’s vendor to process. New FINRA-specific fingerprint cardstock may be purchased from Sterling for $14.00 (includes 25 cards with shipping & handling). To order new FINRA-specific fingerprint cardstock, contact Sterling Client Support (see the Need Help? Section on the right-hand side of the page for contact information). NOTE: Do not submit FBI Standard FD-258 cards as this format will be rejected.

Effective Dec. 6, 2021, barcode stickers are not required. Firms and EFS vendors do not need to provide barcodes with livescan or hardcopy fingerprint submissions.

Sterling assigns a barcode number through an automated process upon receipt of each fingerprint submission. Sterling immediately sends to firms and EFS vendors the barcode number it auto-generates for each fingerprint transaction. The way in which firms and EFS vendors are notified of the barcode numbers depends on how they connect with Sterling. Organizations that use encrypted email receive their barcode numbers via email. Those that use an API connection receive barcode numbers via API.

If a legacy barcode number is included on a fingerprint transaction, it will be overwritten by a new barcode number assigned by Sterling and the firm or vendor will be notified of the new barcode number.

Firms and EFS vendors are to use the Sterling-assigned barcode as the unique identifier for each submission. When making fingerprint inquiries to FINRA, use the barcode numbers assigned by Sterling as FINRA has access to this information.

Firms with questions on this process should contact Sterling Client Support, and EFS vendors should contact the Sterling EFS Support. See the Need Help? Section on the right-hand side of the page for contact information.

Q7: Since barcode numbers will be generated by Sterling as part of FINRA’s new fingerprint process, what do I provide in the barcode number field on the Form U4 and NRF?
A7: With FINRA’s new fingerprint process, the barcode field on the Form U4 and NRF no longer accepts barcode numbers and is grayed out to indicate no information is to be entered. When fingerprints are successfully processed through Sterling, the fingerprint barcode number associated to the fingerprint transaction for the individual is provided to the firm by Sterling. See Question #6 for more information on how Sterling provides the barcode information to firms.

Q8: How do I complete a fingerprint card?
A8: The following information is required for best practices:

  1. Effective Dec. 6, 2021, barcode stickers are not required on the card.
  2. All fingerprints must be taken in black ink. 
  3. Always complete the employer's name, main address, and Org ID number on every fingerprint card submitted. Review the following data on the card for accuracy:
  4. 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 card will be rejected.
  5. The fingerprint should be signed by the person being fingerprinted and by the official taking the fingerprints.
  6. Do not highlight any information or any portion of the fingerprint card or the the card will be rejected.

Q9: SEA Rule 17f-2 (Fingerprinting of securities industry personnel) under the Securities Exchange Act of 1934 requires that a firm may need to submit three sets of fingerprints if results are returned as illegible. Can my firm submit all three sets of fingerprints at once?
A9: No. Firms should submit only one set of fingerprints for an individual at a time and only send a subsequent set of fingerprints if an FBI disposition of ILEG posts to CRD. All non-deficient fingerprint cards are processed at the time of submission and fingerprint fees are charged accordingly.

Q10: What typically prevents a fingerprint transaction from being processed?
A10: Typically, there are two reasons that a fingerprint transaction cannot be processed:

  1. When mandatory information is not included such as the following:
    • Date of birth
    • Address
    • Printed name for the individual
    • Firm name and Org ID number, and
    • Required signatures (individual and/or official)

    Firms are responsible for submitting fingerprints with all required fields completed.
     
  2. Using a highlighter or having extraneous writing on a fingerprint card will cause the fingerprint to be rejected. Deficient fingerprint cards that cannot be processed will not be returned to firms.

Q11: 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

Q12: What address is used to mail fingerprint cards?
A:12 Firms should send hardcopy fingerprints from within the United States or its territories to:

Sterling Identity
10220 SW Greenburg Rd
Suite 301
Portland, OR 97223

Due to FBI requirements, hardcopy cards mailed from outside the United States or its territories cannot be sent directly to Sterling and will be rejected. Send hardcopy cards mailed from outside the United States to FINRA at the address below. FINRA will forward these fingerprint cards via express mail to Sterling for processing.

First Class Mail
FINRA, Document Services
P.O. Box 9495
Gaithersburg, MD 20898-9495

Overnight/Courier Mail
FINRA, Document Services
9509 Key West Avenue, 3rd Floor
Rockville, MD 20850

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

Q13: How do I annotate amputated or bandaged prints?
A13: Use the code "XX" for amputated or bandaged digits, or "UP" for unprintable digits.
However, if all 10 of an individual’s fingers are amputated, bandaged, or are otherwise unprintable, please contact FINRA at [email protected]. There is a separate process for these individuals.

Q14: How does the firm request an exemption from SEA Rule 17f-2 when an individual cannot be printed due to a physical handicap?
A14: Firms that need to request an exemption from the requirement to submit fingerprints under Rule 17f-2 may submit a request to:

SEC-Division of Trading and Markets
Office of Clearing and Settlement
Mail Stop 70-10
100 F Street, N.E.
Washington, DC 20549

Q15: What happens to fingerprints after submission?
A15: FINRA’s fingerprint provider, Sterling, transmits the non-deficient fingerprints to the FBI. The FBI performs a background check using the fingerprints and returns information from the FBI’s database. CRD or FPRD is updated with FBI results and disposition details. in See the Funding Portal FAQ and/or Broker-Dealer FAQ for more information.

Q16. Will Sterling perform FBI Name Checks?
A16: No, FINRA will continue to perform FBI Name Checks and assist firms with fingerprint-related questions.

Q17: What is the turnaround time for fingerprint results?
A17: The FBI’s turnaround time is typically 24-72 hours, although most print results come back within 24 hours. Results will be made available in CRD/FPRD to entitled users.

Q18: Does FINRA provide email responses when fingerprints are received and processed?
A18: No, FINRA does not provide email responses for received and processed fingerprints. Entitled system users should confirm current status of a fingerprint submission in CRD/FPRD. See the Funding Portal FAQ and/or Broker-Dealer FAQ for more information about monitoring fingerprints.

Electronic: FINRA or Sterling will notify firms when there is an error processing an electronic fingerprint submission. Notification is sent to the email address provided on your certificate to identify the field(s) to correct.

Hardcopy: Sterling or FINRA will notify firms when hardcopy fingerprint cards cannot be processed. 

Q19: How do I find out if a fingerprint submission was processed?
A19: Fingerprint submission status information is reported in CRD/FPRD.

Q20: Why are some fingerprints determined to be illegible?
A20: The FBI may determine that fingerprints are illegible for a number of reasons. For example, if the individual's ridges on their fingerprints are worn down or prints do not meet minimum quality thresholds. When the FBI determines that fingerprints are illegible, the illegible result is posted in CRD and another fingerprint is required, unless it is a third illegible result that meets the Name Check requirements.

Q21. Why are some fingerprints rejected by Sterling’s quality check prior to sending to the FBI?

A21: Sterling conducts a pre-FBI submission quality check on each electronic and hard copy fingerprint, which may result in Sterling rejecting fingerprints for reasons such as when improper fingerprint collection technique is used (smudged prints, flats captured where rolls should be, extremely dark or extremely light images) or when cards are missing information. These rejections prevent the transaction from being sent to the FBI and, therefore, no result is posted to CRD (i.e., these rejections are not FBI illegible results). Sterling does take into account that candidates with poor quality prints (degraded fingerprint ridges) will need to have their fingerprints processed through to have the FBI make its determination that a print is illegible. Firms using EFS Vendor services are notified of Sterling rejections by their EFS vendor so that new fingerprints may be collected. Firms that submit livescan fingerprints directly to Sterling via encrypted email, or hard copy cards by mail, will receive Sterling reject notifications by email from [email protected] with instructions to provide new fingerprints. To ensure your firm receives rejection notifications from Sterling, work with your IT department and consider whitelisting Sterling’s support email address.

Q22. Can I use the FBI Standard FD-258 fingerprint card to submit hardcopy fingerprints?

A22: No, the FBI Standard FD-258 fingerprint card format does not include fields that capture specific information required for processing and will be rejected. Only new, FINRA-specific fingerprint cards from Sterling are accepted for processing; however, Sterling will also accept current FINRA-specific cardstock through June 6, 2022.

Q23. Will Sterling process fingerprints for registered transfer agents and clearing agencies?

A23: No, at this time, FINRA continues to process fingerprints for registered transfer agents and clearing agencies with a goal to transition these groups to the new service upon regulatory approval.

FAQ Applicable to Broker-Dealers Firms


Q24: How long do I have to submit fingerprints after the filing is submitted?
A24: Fingerprints must be received within 30 days after a Form U4 is filed in 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 fingerprints are received and processed. Please see the Fingerprints page for more information.

Q25: How do I retrieve my firm's fingerprint reports?
A25: Your firm's fingerprint reports can be retrieved in Classic CRD by entitled Reports users. See the CRD Reports Quick Reference Guide for detailed navigational information. 

Q26: Are fingerprints required for each affiliated firm on a Form U4 filing?
A26: No. Only one set of fingerprints is required for affiliated firms included on a Form U4, provided the employment date for all affiliate firms listed in Section 6 is the same as the employment date in Section 1. Affiliated firms can also establish a Simultaneous Filing Group (SFG) to ensure that FINRA fees are deducted from the designated “primary” firm’s account.

Q27: A firm has Non-Registered Fingerprint individuals (NRFs) who are no longer with the firm. How does the firm terminate these individuals?
A27: The firm can terminate the individuals by submitting an NRF Amendment Filing that includes the Date of Termination or by using the Bulk Termination function available in CRD. See the Form NRF Quick Reference Guide for additional information.

Q28. Will non-FINRA registered firms (i.e., FINRA nonmembers) continue with the option for fingerprints to be processed through their SRO (e.g., CBOE) and sending the FBI results to FINRA for posting to CRD?
A28: Yes, non-FINRA registered firms may continue to submit their fingerprints through their SRO for processing and send FINRA the FBI results for CRD posting.

Q29. Why is the firm address updating to the firm’s main address once a fingerprint transaction is processed?
A29: The new fingerprint process uses the firm’s main address for all fingerprint transactions and will update the address when necessary to match the firm’s main address. A firm will need to submit a form filing to change the address on CRD. For individuals who are to be registered, firms will submit a U4 and for non-registered individuals, submit an NRF, or an NRF amendment for an NRF already on file.
 

FAQ Applicable to Funding Portals


Q30: My firm is applying for FINRA registration. How are fingerprints of associated persons submitted?
A30: Funding Portals will need to initially submit fingerprints on fingerprint cards until their FINRA Organization ID # (Org ID#) is assigned as part of the FINRA entitlement process. A funding portal will be able to submit fingerprints electronically once its Org ID # is assigned. Fingerprints must be submitted on fingerprint cards that meet FBI requirements. New FINRA-specific fingerprint cardstock may be purchased from Sterling for $14.00 (includes 25 cards with shipping & handling). To order new FINRA-specific fingerprint cardstock, contact Sterling Client Support. See the Need Help? Section on the right-hand side of the page for contact information, and see Question 6 above for more information.

Q31: My firm would like to submit fingerprints electronically. What do I have to do?
A31: Funding portals are able to submit fingerprints electronically once an Org ID# is assigned as part of the FINRA Entitlement Process. See Sterling's FINRA Fingerprinting Page for more information on submitting electronically.

Q32: Who at my funding portal needs to be fingerprinted?
A32: All associated persons at the funding portal are required to submit fingerprints to FINRA for processing as required by Securities and Exchange Act (“SEA”) Rule 17f-2.

Q33: What is the Firm CRD or Org number?
A33: Fingerprint cards have a section called Org ID number. Enter your firm's Organization ID# (assigned after your firm is entitled to the FINRA Entitlement Program) in this section.

Q34: My firm is a broker-dealer with the intent to be designated as a funding portal. Does the firm need to submit additional fingerprints for our associated individuals?
A34: If fingerprints have already been submitted to FINRA for individuals associated with the broker dealer to comply with SEA 17f-2, no additional fingerprint submissions are required.
 

FAQ Applicable to Investment Advisers


Q35: Do investment adviser (IA)-only firms submit fingerprint cards to FINRA for processing?
A35: No. IA-only firms submit fingerprints directly to the appropriate states. Not every state requires fingerprints for an RA registration and an IA-only firm should contact the relevant state to verify state fingerprint requirements.

Q36: If an IA-only firm submits a fingerprint card to FINRA in error, what happens?
A36: The fingerprint card will not be returned to the firm. The firm will need to re-print the individual and submit the fingerprint card directly to the state with the fingerprint requirement.