FINRA Announces Fingerprint Process Change

FINRA has announced it has reached the final stages of the change in fingerprinting processing for broker- dealer firms and funding portals, as the regulator onboards new fingerprint provider, Sterling. Expected late September 2021, Sterling, an experienced and technically advanced fingerprint services vendor, will process and submit fingerprints (electronic and hardcopy) to the Department of Justice (FBI) on FINRA’s behalf. This change is expected to expedite fingerprint processing based on state-of-the art technology, processing efficiencies, along with a reduced price for broker-dealer firms.

For broker-dealer firms that have contracted with other fingerprint service providers such as Business Information Group, Inc. and Fieldprint, Inc., services will continue to be offered without any foreseeable impact. FINRA has provided a list of electronic fingerprint service vendors that intend to work seamlessly with Sterling. Should member firms choose to utilize Sterling’s fingerprint services either electronic or hardcopy, FINRA asks all members complete a brief questionnaire provided by Sterling no later than August 20, 2021. The questionnaire will request identifying information that will in turn be used for Sterling’s account preparation to support a smooth transition to the new process. FINRA is aware that select member firms will continue to utilize hardcopy fingerprint methods and has advised FINRA-specific hardcopy cards may be sent to Sterling for processing. Hardcopy fingerprint processing will require an account set-up with Sterling and the vendor will process hardcopy fingerprint cards accordingly. However, whether member firms choose to utilize electronic or hardcopy processing, it is still required to complete the questionnaire by the deadline date.

Member firms interested in utilizing Sterling’s electronic and hardcopy fingerprinting services will also have access to a variety of services and features:

  • Convenient, nationwide retail locations in all 50 states and Washington DC

  • State-of-the-art equipment with easy-to-use touch-screen interface (equipment leasing opportunity available)

  • Real-time fingerprint quality assurance to avoid FBI rejection

  • Hold and release functionality so you can collect prints a single time

As FINRA continues to explore routes that will make the registration process more efficient, FINRA will continue to closely work with Sterling to ensure all fingerprints will be processed efficiently and effectively all while providing status updates to member firms. As the implementation date approaches, FINRA will communicate additional details to member firms accordingly, however, until then member firms are directed to use the current fingerprint processing instructions.

As for registered transfer agents and clearing agencies, FINRA has not yet received FBI approval to process fingerprints for such groups. FINRA will continue to process fingerprints until an effective transition has been identified and approved. For additional details and FAQs regarding the fingerprint change, please consult the FINRA fingerprint transition notice here.

How To Prepare

  •  August 20, 2021, Deadline - Member firms utilizing electronic and hardcopy services hosted by Sterling must complete the questionnaire. You may access the brief questionnaire here. After completing the questionnaire, firms will be directed to an account setup form in DocuSign and also receive an email with instructions and a link to the account setup form.

  •  Firm contact information, a list of users who will submit fingerprints to Sterling, and the Firm’s current encryption certificate will be required for account setup.

  • Be sure to respond to all communications from FINRA and Sterling for further account setup instructions and fingerprint processing transition details.

  • Already have an electronic fingerprint services provider? – Reference FINRA’s Fingerprint Vendor list that will be working with Sterling and will not be impacted by this change.

 Quick Facts

  • Sterling will process and submit fingerprints of broker-dealer and funding portal personnel to the FBI on FINRA’s behalf and will provide processing status updates and FBI results to FINRA for posting in CRD, FINRA Gateway and FPRD.

  • Firms are not required to use Sterling fingerprint collection services or any other services that Sterling offers.

  • 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.

 

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