Frequently Asked Questions (FAQ) About Fingerprint Processing
Effective Sep. 6, 2022, the SEC terminates exemptive relief from fingerprinting requirements for, among others, members and their associated persons; termination of additional temporary extension of time for submission of fingerprint information for registered persons and persons seeking registration under FINRA Rules.
On This Page
- FAQ Applicable to All Firms
- FAQ Applicable to Broker-Dealers Firms
- FAQ Applicable to Funding Portals
- FAQ Applicable to Investment Advisers
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?
A6: FINRA-specific fingerprint cardstock may be purchased from Sterling for $14.00 (includes 25 cards with shipping & handling). To order FINRA-specific fingerprint cardstock, contact Sterling Client Support at [email protected] or (833) 794-2009. NOTE: FBI Standard FD-258 cards and FINRA-specific fingerprint cardstock purchased from Media Source will be rejected.
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 to ensure fingerprints are processed:
- Barcodes are not required for fingerprints.
- All fingerprints must be taken in black ink.
- Complete the employer's name, main address, and Org ID number for every fingerprint submitted. Review the following data for accuracy and completeness:
- Individual's Name
- Social Security Number (SSN is required if born in the United States or territories.)
- CRD Number (See Q9)
- Date of Birth
- Place of Birth
- Race (Using one digit code.)
- Height (Allowable range is 4'00" to 7'11". Height below 4’00” will be set to 4’00”; height over 7’11” will be set to 7’11”.)
- Weight (Allowable range is 000 to 499. All weight in excess of 499 will be set to 499.)
- Hair Color (Using three-letter code.)
- Eye Color (Using three-letter code.)
- The fingerprint card must be signed by the person being fingerprinted and by the official taking the fingerprints.
- To prevent rejected fingerprints, do not highlight any portion of the fingerprint card and write clearly.
|Asian or Pacific Islander||A|
|American Island or Alaskan Native||I|
Q9: Why should firms and EFS providers include an individual’s CRD# with each fingerprint submission (for individuals who already have a CRD# assigned)?
A9: The CRD# is a specific number provided to identify each individual in CRD. It is an important source of identification for each fingerprint submission and ensures proper posting of information to CRD. Including the CRD# is particularly important for individuals that do not have an SSN as the CRD# will ensure proper posting of fingerprints to an individual’s CRD record. Fingerprint transactions that do not include a CRD# may result in multiple individual CRD records being created. As a result, firms may experience additional fingerprint fees being assessed because of multiple CRD records. (SSN is required if born in the United States or territories.)
Q10: What are the new fingerprint processing requirements as of 8/1/2022?
A10: FINRA will implement new fingerprint processing requirements to enhance identity and validation data. This data will be made available through FINRA Gateway and Classic CRD. Both electronic and hard copy fingerprints must meet the following new requirements for fingerprints to be processed.
Failure to meet any of these requirements will result in a fingerprint rejection.
- FINRA will require a Social Security Number (SSN) for all fingerprints submitted for an individual who was born in the United States or its territories. When an entry in Place of Birth (POB) is USA or one of its territories, an SSN must be provided in the SSN field.
- “Unknown” will not be permitted as a hair color.
FINRA is also making firms aware of two FBI policies that FINRA will use with fingerprints received from firms.
- The height range for an individual must be between 4’00” and 7’11”. FINRA will use the closest value in this range when a value provided for an individual is outside of this range, either the closest value to 4’0” or 7’11” respectively.
- FINRA will use the maximum allowed weight of 699 pounds when the value provided exceeds this number.
Please send any Fingerprint questions/concerns to [email protected]
Q11: What typically prevents a fingerprint transaction from being processed?
A11: Typically, there are two reasons that a fingerprint transaction cannot be processed:
- When mandatory information is not included such as the following:
- Date of birth
- Printed name for the individual
- Firm name and Org ID number, and
- Required signatures (individual and/or official)
- SSN is required if born in the United States or territories.
Firms are responsible for submitting fingerprints with all required fields completed.
- 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.
Q12: 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 FBI results are returned as illegible. Can my firm submit all three sets of fingerprints at once?
A12: No. Firms should submit only one set of fingerprints for an individual at a time and only send a subsequent set of fingerprints after an FBI disposition of ILEG posts to CRD or if a reject notice is received. If multiple sets of fingerprints for the same individual are submitted at the same time, only one set of fingerprints will be processed and the other set(s) will be immediately destroyed, following Sterling’s current process.
|Blonde or Strawberry||BLN|
|Gray or Partially Gray||GRY|
|Red or Auburn||RED|
Q14: What address is used to mail fingerprint cards?
A14: Firms should send hardcopy fingerprints from within the United States or its territories to:
10220 SW Greenburg Rd
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
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.
Q15: How do I annotate amputated or bandaged prints?
A15: 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.
Q16: How does the firm request an exemption from SEA Rule 17f-2 when an individual cannot be printed due to a physical handicap?
A16: 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
Q17: What happens to fingerprints after submission?
A17: 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. See the Funding Portal FAQ and/or Broker-Dealer FAQ for more information.
Q18: What is the turnaround time for fingerprint results?
A18: 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.
Q19: Does FINRA provide email responses when fingerprints are received and processed?
A19: No, FINRA’s Fingerprint Program does not provide emails acknowledging receipt by FINRA when hardcopy fingerprints for permitted conditions are mailed, or when fingerprints are systematically received and processed. Entitled system users must 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.
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.
Q20: How do I find out if a fingerprint submission was processed?
A20: Fingerprint submission status information is reported in CRD/FPRD.
Q21: Will Sterling perform FBI Name Checks?
A21: No, FINRA will continue to perform FBI Name Checks and assist firms with fingerprint-related questions.
Q22: Why are some fingerprints determined to be illegible?
A22: 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.
Q23: Under what conditions can FINRA request a Name Check?
A23: To request a Name Check, the FBI requirement states that at least one of the three sets of fingerprints must have been returned as ILEG / L0008 with the caveat that states “The quality of the characteristics is too low to be used. Candidate(s) were found. Please resubmit a new set of fingerprints for comparison to the candidate(s).” If this is the case, FINRA,'s Document Services Team will request a Name Check, which will occur automatically as part of the script.
Q24: Why are some fingerprints rejected by Sterling’s quality check prior to sending to the FBI?
A24: Sterling conducts a submission quality check that uses the latest FBI specifications for each electronic and hard copy fingerprint prior to sending to the FBI. The quality check may result in Sterling rejecting fingerprints for reasons such as:
- poor image quality, typically due to dry or unwashed hands
- improper fingerprint collection technique is used
- fingerprints are smudged
- flats are captured when rolled fingerprints are expected
- fingerprints are too dark or too light
- partial fingerprints are captured
- information missing when capturing prints
- personal information provided does not match ID documents
- information provided does not match exactly with FINRA CRD record
A rejection prevents the transaction from being sent to the FBI and, therefore, no fingerprint information 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 provider 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 rejection 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.
Q25. Can I use the FBI Standard FD-258 fingerprint card to submit hardcopy fingerprints?
A25: 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 FINRA-specific fingerprint cards from Sterling are accepted for processing. See Question #6 for more information on purchasing fingerprint cards.
Q26. Will Sterling process fingerprints for registered transfer agents and clearing agencies?
A26: No, at this time, FINRA continues to process fingerprints for registered transfer agents and clearing agencies.
Q27: How long do I have to submit fingerprints after the filing is submitted?
A27: Fingerprints must be received within 30 days after a Form U4 is filed in CRD. If fingerprints are not posted to CRD as 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.
long do I have to submit fingerprints after the filing is submitted?
A27: 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.
Q28: How do I retrieve my firm's fingerprint reports?
A28: 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.
Q29: Are fingerprints required for each affiliated firm on a Form U4 filing?
A29: 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.
Q30: A firm has Non-Registered Fingerprint individuals (NRFs) who are no longer with the firm. How does the firm terminate these individuals?
A30: 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.
Q31: 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?
A31: 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.
Q32: Why is the firm address updating to the firm’s main address once a fingerprint transaction is processed?
A32: 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.
Q33: My firm is applying for FINRA registration. How are fingerprints of associated persons submitted?
A33: 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.
Q34: My firm would like to submit fingerprints electronically. What do I have to do?
A34: 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.
Q35: Who at my funding portal needs to be fingerprinted?
A35: 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.
Q36: What is the Firm CRD or Org number?
A36: 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.
Q37: 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?
A37: 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.
Q38: Do investment adviser (IA)-only firms submit fingerprint cards to FINRA for processing?
A38: 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.
Q39: If an IA-only firm submits a fingerprint card to FINRA in error, what happens?
A39: 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.