Submit Fingerprints
FBI Fingerprint Reuse Policy Update – No Action at This Time
The FBI recently issued an updated fingerprint reuse policy in its January 2026 Outsourcing News newsletter. This update, referred to as the "Reuse Information Letter," was distributed to Authorized Recipients (ARs) and is available here for reference.
What This Means for Your Firm
FINRA is currently reviewing this update and consulting with the FBI on questions related to the Authorized Recipient approval process required for fingerprint reuse.
No Changes to Current Procedures at This Time
Firms should 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. No action on reuse is to be taken at this time.
Next Steps
FINRA will provide additional information and guidance once our review is complete and next steps are determined. Please monitor FINRA.org for updates.
Questions?
[email protected]
The process for submitting fingerprints differs for broker-dealers and funding portals. Funding portals should review the EFP Quick Reference Guide for Funding Portals for their fingerprint submission process.
Organizations that collect or receive information in connection with fingerprinting personnel, including Criminal History Record Information (CHRI), are responsible for complying with requirements set forth in the current FBI Criminal Justice Information Services Security Policy (Policy) located here https://le.fbi.gov/cjis-division/cjis-security-policy-resource-center. This Policy establishes the minimum set of security requirements an organization must implement to maintain appropriate controls to protect and safeguard CHRI.
Investment Adviser Firms: FINRA does not process fingerprints for investment adviser (IA) firms. An IA-only firm must submit fingerprints directly to those states that require fingerprints for an RA registration. Contact the applicable state to verify state requirements. Fingerprint submissions received from an IA-only firm will not be processed or returned to the firm.
When to Submit Fingerprints
Section 17(f)(2) of the Securities Exchange Act of 1934, (15 USC 78q(f)(2)), and Exchange Rule 17f-2 thereunder, as amended, requires that a firm submit fingerprints for individuals who perform certain roles within a firm. For broker-dealers, when a firm submits a Form U4 for an individual requesting registration with a fingerprint-participating SRO, the firm has 30 days from the filing date to submit fingerprints for the individual.
If the firm does not submit the fingerprints within the 30-day timeframe, the individual's registration status will be set to "Inactive Prints” (INACTIVE_PRINTS). Business activities requiring a securities registration must be suspended while an individual’s registration is inactive. Individuals who remain “Inactive Prints” for two years will have their registrations terminated with the status “Terminated No U5” (T_NOU5).
If FINRA receives fingerprints at any point before the registration terminates, the individual’s registration will update to “Approved Pending Results” (APRSLTS), a status that permits an individual to conduct business while waiting for the FBI result.
A firm will be required to submit additional fingerprints when an individual’s previous fingerprint submission does not meet image quality standards or identified by FINRA’s designated fingerprint provider, Sterling, if the fingerprints do not or when the FBI returns a result of Illegible (ILEG) or Rejected (REJT)..
LEARN MORE ABOUT ADDITIONAL FINGERPRINT SUBMISSIONS
Required Fingerprint Information
See FP Frequently Asked Questions (FAQ) for information on Required Fingerprint Information.
Fingerprint cards that include all required information will be processed with applicable fees assessed to the firm’s Flex-Funding account. Firms will be contacted when possible to confirm missing FINRA-required information in order to process deficient fingerprints; however, it is the responsibility of a firm to submit fingerprints with all required fields completed.
Only one submission per individual should be sent at a time. Duplicate fingerprints will not be returned to firms and will not be processed.
To Submit Fingerprints Electronically
Firms may either:
- Buy or lease equipment to submit their firm’s fingerprints electronically, or
- Select a certified EFS vendor to submit electronic fingerprints on behalf of their firm.
To Submit Hardcopy Fingerprints
FINRA-specific hardcopy fingerprint cards may be purchased from FINRA’s designated fingerprint provider, Sterling. To order, contact Sterling FINRA Client Support at [email protected] or (833) 794-2009.
Sterling will assign a barcode number upon receipt of each fingerprint submission. Firms and EFS vendors do not need to provide barcodes with livescan or hardcopy fingerprint submissions.
If a legacy barcode number is used on a fingerprint transaction, it will be overwritten by a new barcode number assigned by Sterling. Sterling will notify firms or EFS vendors of the barcode number. Organizations that use encrypted email will receive their barcode numbers via email and organizations that use an API connection will receive barcode numbers via API. Firms and EFS vendors should use the Sterling assigned barcode as the unique identifier for each submission.
Firms with questions on this process should contact Sterling FINRA Client Support, at [email protected] or (833) 794-2009 and EFS vendors should contact Sterling EFS Support, at (833) 794-2009.
Firms should send hardcopy cards mailed within the United States or its territories to:
First Advantage Biometrics (fka Sterling Identity)
10220 SW Greenburg Rd
Building 3, Suite 301
Portland, OR 97223
Per FBI requirements, hardcopy cards from outside the United States or its territories must be sent directly to FINRA’s 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