FINRA Fingerprint Process Change
VENDOR TO PROCESS FINGERPRINTS TO FBI FOR FINRA
FINRA’s new fingerprint process for broker-dealer firms and funding portals will route fingerprints to Sterling, its designated fingerprint provider. Sterling, an experienced and technically advanced fingerprint services vendor, will process and submit fingerprints to the Department of Justice (FBI) for broker-dealer firms and funding portals. Benefits of this process change include state-of-the-art technology, processing efficiencies and reduced pricing for firms.
Firms are not required to use Sterling fingerprint collection services or any other services that Sterling offers. Broker-dealer firms and funding portals will continue to have several fingerprint submission options. For more information, see the Fingerprint Transition FAQ below.
Note: FINRA will continue to process fingerprints for registered transfer agents and clearing agencies. FINRA does not process fingerprint transactions for investment adviser (IA) firms. An IA-only firm must submit fingerprints directly to those states that require a fingerprint check for an RA registration. Contact the applicable state to verify state fingerprint requirements. Fingerprint submissions received from an IA-only firm will not be returned to the firm.
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Complete the questionnaire: FINRA recommends that firms complete a brief questionnaire on Sterling’s website as soon as possible. The questionnaire will provide information to FINRA and Sterling about your firm, including its current and future fingerprinting methods, to support a smooth transition to the new service. Sterling (Joy Henry) may follow up with firms throughout the process to offer support. To ensure communications from Sterling are received, work with your IT department and consider whitelisting Sterling’s email address domain (sterlingcheck.com).
Dates and additional information will be provided in the coming weeks. If you would like to receive future notifications about this process change and other registration-related updates, please subscribe to FINRA’s Registration and Testing Information email service.
Q1. Will individuals at our firm who have already met fingerprinting requirements need to be fingerprinted again with the new process?
Although FINRA is implementing a new fingerprint process, current fingerprint requirements remain the same. Individuals who have met fingerprint requirements with their current firm are not required to be re-fingerprinted as a result of the new process.
Q2. My firm does not expect to have individuals who will need to be fingerprinted in the foreseeable future. Does my firm need to take any action concerning this new process?
To ensure firms’ current and future fingerprinting needs can be met with the new process, FINRA strongly encourages firms to complete the questionnaire on Sterling's FINRA Fingerprinting Resource Page as soon as possible to identify fingerprinting options. FINRA and Sterling will use this information to prepare for a smooth transition. Consider the options that are available with the new process and decide on which option(s) best meets the needs of your firm in the event your firm has new individuals who will require to be fingerprinted. Note that firms may choose “undecided” as an option regarding future collection and submission methods if more time is needed to decide.
Q3. What does my firm need to do to prepare for the transition to the new service?
FINRA requests that firms perform the following tasks:
- Complete a brief questionnaire on Sterling’s FINRA Fingerprinting Resource Page as soon as possible. The questionnaire will provide details about your firm, including how fingerprints are currently submitted to FINRA and options for submitting fingerprints with the new service. This information will be used to facilitate a smooth transition to the new service.
- Consider what option(s) your firm will choose with the new service. Although all fingerprint transactions must be sent to Sterling for FBI processing, firms will continue to have options for how fingerprints are collected. See question 8 for additional information about these options.
- Respond to all communications from FINRA and Sterling as directed. Depending on the option your firm chooses, Sterling may reach out to your firm or ask you to set up an account. This includes large organizations, organizations that submit directly to FINRA today (electronic and/or hardcopy cards) or organizations that wish to use Sterling services.
- Read through the additional communications FINRA will send regarding the new process, including the effective date, in the coming weeks.
Q4. What is the transition timeframe for sending prints?
FINRA's process transition to Sterling will not occur before November 2021, and the effective date will be announced in advance. Until the transition occurs, firms should continue to follow the current process described on the Submit Fingerprints page. More information about the new process will be announced in the coming weeks.
Q5. What should my firm do with emails from Sterling (email domain sterlingcheck.com)?
Sterling (Joy Henry) may follow up with firms throughout the process to support a successful transition. Based on your firm’s responses to the questionnaire, Sterling will reach out to large organizations, organizations that submit directly to FINRA today (electronic and/or hardcopy cards) or organizations that wish to use Sterling services. Please respond to these emails accordingly. To ensure communications from Sterling are received, work with your IT department and consider whitelisting Sterling’s email address.
Q6. Are there increased or additional costs to firms associated with this new service?
FINRA will continue 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.
Note that for firms that choose to submit hardcopy fingerprint cards, the processing costs remain the same — $30 per card (and the FBI fee), which FINRA assesses. Sterling does not charge an additional processing fee for hardcopy fingerprint cards.
Q7. Is my firm required to use Sterling fingerprint collection services?
No, firms have options for how fingerprints are collected, though choosing a Sterling location or leasing Sterling equipment may result in savings. Firms are not required to use other Sterling services.
Q8. What are my firm’s fingerprinting options?
Firms may choose to use a Sterling collection site, another electronic fingerprint services (EFS) vendor collection site that is contracted with Sterling, a firm’s current in-house equipment, or lease Sterling equipment. In addition, FINRA-specific hardcopy cards may be sent to Sterling for processing. See question 11 for specific information on where to mail hardcopy fingerprint cards sent from outside the United States.
Q9. My firm directly submits fingerprints electronically to FINRA today. What does my firm need to do?
To prepare for the transition, your firm will need to exchange security certificates with Sterling so that fingerprints will route to Sterling for processing. If your firm has not done so already, visit Sterling’s FINRA Fingerprinting Resource Page as soon as possible to complete the brief questionnaire to get you started. If your firm will continue to submit fingerprints directly, your firm will need to create an account with Sterling in order for Sterling to process these fingerprints.
Q10. My firm uses an Electronic Fingerprint Service (EFS) vendor today. How will my firm know this vendor is set up with Sterling to process fingerprints to the FBI following the transition?
FINRA and Sterling are reaching out to EFS vendors to make them aware of the new service requirements and will work with these vendors to ensure a smooth transition for firms that use these vendors. In addition, FINRA will continue to post a list of EFS vendors that have met the new service requirements. Please refer to the list of EFS vendors at the end of this page that have expressed an intent to participate in FINRA’s new fingerprint process.
Q11. What does my firm need to know about submitting hardcopy fingerprint cards with the new process?
Your firm will need to create an account with Sterling in order for Sterling to process your firm’s hardcopy fingerprint cards. Visit Sterling’s FINRA Fingerprinting Resource Page as soon as possible to complete the brief questionnaire to get you started.
The fees for processing hardcopy fingerprint cards remain the same — $30 per card (and the FBI fee), which FINRA assesses. Sterling does not charge an additional processing fee for hardcopy fingerprint cards.
Once FINRA implements the new process, hardcopy cards mailed from within the United States or its territories are to be sent directly to Sterling to the address below. Due to FBI requirements, hardcopy cards mailed from outside the United States 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.
Cards mailed within the United States or its territories
10220 SW Greenburg Rd
Portland, OR 9722
Cards mailed from outside the United States
First Class Mail
Q12: Can I use my existing stock of FINRA-specific fingerprint cards to submit hardcopy fingerprints?
Existing FINRA-specific fingerprint cardstock may be used for six months from the new process go-live date. Following the six-month period, 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. NOTE: Do not submit FBI Standard FD-258 cards as this format will be rejected.
New FINRA-specific fingerprint cardstock may be purchased from Sterling for $14.00 (includes 25 cards with shipping & handling). Sterling invoices monthly and accepts ACH/wire transfers or credit card, which includes a processing fee. To order new FINRA-specific fingerprint cardstock, contact Sterling Client Support at [email protected] or (833) 794-2009.
Q13: Can I use the FBI Standard FD-258 fingerprint card to submit hardcopy fingerprints?
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, during the six-month transition period, Sterling will also accept current FINRA-specific cards.
Q14. How do I get barcode stickers or FINRA-specific fingerprint cards with the new process?
With the implementation of the new process, barcode stickers will not be required. Firms and EFS vendors will not need to provide barcodes with livescan or hardcopy fingerprint submissions.
Sterling will assign a barcode number through an automated process upon receipt of each fingerprint submission. Sterling will immediately send 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 will receive their barcode numbers via email. Those that use an API connection will 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 will 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 will have access to this information.
Firms with questions on this process should contact Sterling Client Support at [email protected] or (833) 794-2009.
EFS vendors should contact Sterling EFS Support at [email protected] or (503) 536-5086.
Q15: 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?
With FINRA's new fingerprint process, the barcode field on the Form U4 and NRF will no longer accept barcode numbers and will be 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 will be provided to the firm by Sterling. See question 14 for more information on how Sterling will provide the barcode information to firms.
Q16. Will Sterling perform FBI Name Checks?
No, FINRA will continue to perform FBI Name Checks and assist firms with fingerprint-related questions.
Q17. Will Sterling process fingerprints for registered transfer agents and clearing agencies?
No, at this time, FINRA will continue to process fingerprints for registered transfer agents and clearing agencies with a goal to transition these groups to the new service upon FBI approval.
Q18. Will non-FINRA registered firms (i.e., FINRA nonmembers) continue to have the option to send fingerprints to their SRO (e.g., CBOE) for processing and sending the FBI results to FINRA for posting to CRD?
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.
The vendors listed below have expressed an intent to participate in FINRA’s new fingerprint process. FINRA will update this list as more information becomes available. Please contact vendors with any questions about their current or future arrangements with Sterling.
- Accurate Biometrics Inc.
- Biometrics4ALL, Inc.
- Business Information Group, Inc.
- Fieldprint, Inc.
- Fingerprint Solutions Inc.
- First Advantage
- Fulcrum Biometrics, LLC
- HID Global (fka Cross Match Technologies, Inc.)
- Inquiries Screening
- National Fingerprint, Inc.
- Print Scan LLC
- Telos Identity Management Solutions, LLC
- Trusted Biometrics