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.
Investment Adviser Firms: FINRA does not process fingerprint submissions 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 processed or returned to the firm.
For the fastest turnaround of fingerprint results, submit fingerprints electronically rather than sending hard copy fingerprint cards.
Electronic fingerprints provide the following benefits over hardcopy fingerprint cards:
- reduced cost (lower processing fees and no card or postage expense)
- faster turnaround
- better image quality
- fewer illegible results
When to Submit Fingerprints
Broker-dealers and transfer agents are responsible for complying with the Securities Exchange Act (SEA) of 1934, as amended, and SEC rules promulgated thereunder, as well as FBI requirements. Visit the FBI website for its fingerprinting policies and requirements, including the FBI Privacy Act statement. Section 17f-2 of the SEA requires that a firm submit fingerprints for individuals who perform certain roles within a firm. 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 resubmit fingerprints when an individual’s fingerprint submission does not meet image quality standards or FBI requirements as determined by Sterling, or when the FBI returns a result of Illegible (ILEG) or Rejected (REJT).
Required Fingerprint Information
See FP Frequently Asked Questions (FAQ) #23 for information on Required Fingerprint Information.
Fingerprint cards that include all required information will be processed with applicable fees. 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 be processed at the expense of the firm.
To Submit Fingerprints Electronically
Firms may either:
- Buy or lease equipment to submit their firm’s fingerprints electronically, or
- Select an EFS certified vendor to submit electronic fingerprints on behalf of their firm.
To Submit Hardcopy Fingerprints
FINRA-specific fingerprint cardstock may be purchased from Sterling. To order new FINRA-specific fingerprint cardstock, contact Sterling Client Support (see the Need Help? Section on the right-hand side of the page).
Barcode stickers will not be required with FINRA’s new service. Sterling will assign a new barcode number upon receipt of each fingerprint submission. Firms and EFS vendors will 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. 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. Firms and EFS vendors will use the Sterling assigned barcode as the unique identifier for each submission.
Firms with questions on this process should contact Sterling Client Support, and EFS vendors should contact Sterling EFS Support. See the Need Help? Section on the right-hand side of this page for contact information.
Firms should send hardcopy cards mailed within the United States or its territories to:
10220 SW Greenburg Rd
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
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