Frequently Asked Questions (FAQ) About Fingerprint Processing

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: SEA Rule 17f-2 (Fingerprinting of securities industry personnel) under the Securities Exchange Act of 1934 requires that a firm submit three sets of fingerprints if FBI results are returned as illegible. Can my firm submit all three sets of fingerprints at once?
A2: 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. 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.

Q3: Is it permitted for an EFS vendor to receive and electronically process fingerprints for an individual on a hardcopy fingerprint card?
A3: Yes, an EFS vendor may receive and electronically process fingerprints collected on a hardcopy card that was sent to the EFS vendor from a broker-dealer or funding portal organization provided that the collection of the fingerprints was within the US or its territories.  EFS vendors are required to transmit only electronic fingerprints to the FINRA Fingerprint Program, and therefore, at no time is it permitted for an EFS vendor to forward a hardcopy card to Sterling.  The FINRA Fingerprint Program prohibits an EFS vendor from collecting, directly receiving, or processing fingerprints from individuals outside the US or its territories.

Q4: Is an individual exempt from the fingerprinting requirement based on being a foreign national or foreign resident? 
A4: No. Rule 17f-2 lists the basis for exemptions.  

Q5: Is it permitted for an EFS vendor to process hardcopy fingerprints for people residing outside the US or its territories?
A5: No, FINRA’s Fingerprint Program prohibits EFS vendors from collecting, directly receiving, processing and/or forwarding hardcopy fingerprints from individuals outside the US or its territories. Per FBI requirements, fingerprints of individuals collected outside the US or its territories must be captured on a hardcopy fingerprint card and mailed to FINRA and the FINRA Fingerprint Program requires that only a FINRA-approved hardcopy card be used for capture.  FINRA recommends firms use either a law enforcement agency or a fingerprint trained individual to capture fingerprints on the FINRA-approved hardcopy card.

For mailing address information, see Question #25.

Q6: How does the firm request an exemption from SEA Rule 17f-2 when an individual cannot be printed due to a physical handicap?
A6: 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

Q7: Will Sterling process fingerprints for registered transfer agents and clearing agencies?
A7: Yes, FINRA launched the new Fingerprint Program for Transfer Agents and Clearing Agencies (TA/CAs) on October 2, 2023, as the SEC declared FINRA's updated Fingerprint Plan effective September 22, 2023. This Program outsources fingerprint processing to Sterling Identity (Sterling), the same FBI-approved channeler that processes fingerprints for broker-dealers and funding portals on FINRA’s behalf. For more information, visit the Fingerprint Program for Transfer Agents and Clearing Agencies website.

Q8: Are any changes to the FINRA Fingerprint Program planned for 2024?
A8: FINRA anticipates making changes to the FINRA Fingerprint Program to ensure EFS vendors submit fingerprints to FINRA’s designated channeler, Sterling, within the required timeframe. When implemented, all participating EFS vendors must submit fingerprints to Sterling within 28 days from the date the EFS vendor captured an individual’s fingerprints or received the fingerprints directly from a broker-dealer or funding portal organization. In each case, the EFS vendor must provide the specific fingerprint capture or receipt date to Sterling for audit and compliance purposes. Although the FBI requires EFS vendors to purge fingerprints after successfully disseminating prints to the FBI or within 30 days, whichever is sooner, the FINRA Fingerprint Program uses 28 days to enable time for Sterling to channel the fingerprints to the FBI. FINRA will provide advance notice to firms and EFS vendors. Note: Firms that submit hardcopy fingerprints or livescan fingerprints directly via encrypted email to Sterling are not subject to the 28-day requirement.

Q9: With FINRA’s dedicated Fingerprint Provider, Sterling, what fingerprint collection options are available?
A9: 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-approved hardcopy cards may be sent to Sterling for processing. See Question #21 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 at [email protected] or (833) 794-2009. Firms that choose to use another vendor to collect fingerprints should contact the vendor directly.  

Q10: What happens to fingerprints after submission?
A10: FINRA’s Fingerprint Provider, Sterling, transmits the non-deficient fingerprints to the FBI. The FBI performs a criminal history record check using the fingerprints and returns information from the FBI’s database.

Q11: How do I find out if a fingerprint submission was received?
A11: Fingerprint submission status information is reported in CRD and FPRD. See the Funding Portal FAQ and/or Broker-Dealer FAQ for more information.

Q12: Does FINRA provide email responses when fingerprints are received and processed?
A12: No, FINRA’s Fingerprint Program does not provide emails acknowledging receipt or processing for hardcopy fingerprints are received or when fingerprints are systematically received and processed. Entitled system users must confirm the 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 or hardcopy fingerprint submission. Notification is sent to the email address of the EFS vendor or firm that submitted the fingerprints.

Q13: What is the turnaround time for fingerprint results?
A13: The FBI’s turnaround time is typically 24-36 hours. Results will be made available in CRD/FPRD to entitled users.

Q14: How do firms pay for their fingerprint services?
A14: FINRA collects FINRA and FBI processing fingerprint fees through the firm’s Flex-Funding account in E-Bill.

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

Q15: Why should firms and EFS vendors include an individual’s CRD# with each fingerprint submission (for individuals who already have a CRD# assigned)?
A15: 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.)

Q16: What typically prevents a fingerprint transaction from being processed?
A16: Typically, there are several 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)
   • SSN is required if born in the United States or territories
   
   Firms are responsible for submitting fingerprints with all required fields completed.

2. Using a highlighter or having extraneous writing on a hardcopy fingerprint cards will cause the fingerprint to be rejected. Deficient fingerprint cards that cannot be processed will not be returned to firms.
3. Fingerprints submitted to the FINRA Fingerprint Program undergo a quality check on fingerprints submitted to FINRA that uses the latest FBI specifications prior to sending to the FBI. The quality check may result the rejection of fingerprints for poor technique or image.
4. See Question #17 for additional information on fingerprint submission requirements.

Q17: Why are some fingerprints rejected by Sterling’s quality check prior to sending to the FBI?
A17: Sterling conducts a submission quality check that uses the latest FBI specifications for each electronic and hardcopy 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 the individual’s 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 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 hardcopy 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.

Q18: Why does the FBI determine some fingerprints as illegible?
A18: 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.

Q19: Will Sterling perform FBI Name Checks?
A19: No, FINRA will continue to perform FBI Name Checks and assist firms with fingerprint-related questions.

Q20: Under what conditions can FINRA request a Name Check?
A20: 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.

Q21: Where does my firm get fingerprint cards?
A21: FINRA-approved fingerprint cards must be purchased from Sterling. To order FINRA-approved fingerprint cards, contact Sterling Client Support at [email protected] or (833) 794-2009. 

Barcode stickers are not required. Firms and EFS vendors do not need to provide barcodes with fingerprint submissions.

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

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

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 assigned by Sterling as FINRA has access to this information.

Firms with questions on this process should contact Sterling Client Support at [email protected] or (833) 794-2009, and EFS vendors should contact the Sterling EFS Support.

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 FINRA-approved fingerprint cards from Sterling are accepted for processing.

Q23: Our firm is planning to send in a large volume of hard cards from our overseas location. Are there any special instruction or notification required prior to sending?
A23: At least 2 weeks prior to mailing a large volume of fingerprint cards, contact FINRA at [email protected] to alert us of the expected number of fingerprint cards and anticipated timing. FINRA defines a large volume as more than 500 cards that are mailed all at once or over several days.

Q24: How do I complete a hardcopy fingerprint card?
A24: The following information is required to ensure fingerprints are processed:

1. Barcodes are not required for fingerprints.
2. All fingerprints must be taken in black or dark blue ink. 
3. 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 Q#15)
   • Date of Birth
   • Place of Birth
   • Sex
   • 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.)
4. The fingerprint card must be signed by the person being fingerprinted and by the official taking the fingerprints.
5. To prevent rejected fingerprints, do not highlight any portion of the fingerprint card and write clearly.

Q25: What address is used to mail fingerprint cards?
A25: 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 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.

Q26: What are the codes for hair color and eye color?

Q27: How do I annotate amputated or bandaged prints?
A27: 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.

Q28: How long do I have to submit fingerprints after the filing is submitted?
A28: Fingerprints must be received within 30 days after a Form U4 is filed in CRD. If fingerprints are not posted 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.

Q29: My firm is having difficulty getting an associated individual in a foreign country fingerprinted promptly. What does the firm need to do?
A29: FINRA-registered firms may apply to FINRA for an extension of the 30-day period prescribed in FINRA Rule 1010, within which a firm must submit fingerprints to FINRA after the electronic submission of a Form U4. Pursuant to FINRA Rule 1010, FINRA may, upon application and a showing of good cause, extend the 30-day period within which a firm must submit fingerprints to FINRA. An application for extension should include the name, address and CRD numbers of the firm and individual, and a detailed explanation for the firm's request (e.g., the firm may wish to identify steps that have been taken to attempt to fulfill the fingerprinting requirement). Letters of application should be emailed using the link below within the 30-day fingerprint window.

Email

FINRA will respond to the email request. Please note that the above email address was established solely to receive extension requests in the circumstances described above.

Q30: Since barcodes are generated by Sterling as part of the FINRA Fingerprint Program, what do I provide in the barcode field on the Form U4 and NRF?
A30: The barcode field on the Form U4 and NRF no longer accept barcodes and is grayed out to indicate no information is to be entered. When fingerprints are successfully processed, Sterling provides the barcode associated to the fingerprint transaction for the individual to the firm. See Question #21 for more information on how Sterling provides the barcode to organizations.

Q31: How do I retrieve my firm's fingerprint reports?
A31: Your firm's fingerprint reports can be retrieved in CRD by entitled users. See the CRD Reports Quick Reference Guide for detailed navigational information.

Q32: Are fingerprints required for each affiliated firm on a Form U4 filing?
A32: 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.

Q33: A firm has Non-Registered Fingerprint individuals (NRFs) who are no longer with the firm. How does the firm terminate these individuals?
A33: The firm can terminate the individuals by submitting an NRF Amendment 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.

Q34: 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?
A34: Yes, non-FINRA registered firms may continue to submit their fingerprints through their SRO for processing and send FINRA the FBI results for processing.

Q35: Why is the firm address updating to the firm’s main address once a fingerprint transaction is processed?
A35: The FINRA Fingerprint Program uses the firm’s main address for all fingerprint transactions and, as part of fingerprint processing, FINRA will associate any individual to the firm’s main address unless the individual is actively associated to the firm in CRD. If a firm needs to update the address for a particular person in CRD, the firm will need to file a NRF for a non-registered person or a Form U4 for an individual who is registered or seeking registration.  Firms should file a Form BD amendment in CRD to update their firm’s main address with FINRA as appropriate.

Q36: My firm is applying for FINRA registration. How are fingerprints of associated persons submitted?
A36: 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 FINRA-approved fingerprint cards purchased from Sterling. To order FINRA-approved fingerprint cards, contact Sterling Client Support at [email protected] or (833) 794-2009.

Q37: My firm would like to submit fingerprints electronically. What do I have to do?
A37: 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.

Q38: Who at my funding portal organization needs to be fingerprinted?
A38: 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.

Q39: What is the Firm CRD or Org number?
A39: 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.

Q40: 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?
A40: 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.

Q41: Do investment adviser (IA)-only firms submit fingerprint cards to FINRA for processing?
A41: 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.

Q42: If an IA-only firm submits a fingerprint card to FINRA in error, what happens?
A42: 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.