FINRA Updates Guidance on New Electronic Fingerprint Submission Process

In updated guidance, FINRA detailed its new electronic fingerprint process for broker-dealer firms and funding portals. The new process went into effect on Dec. 6, 2021. Broker-dealers and funding portals are now required to submit fingerprints to Sterling, FINRA's designated fingerprint provider for processing, for submission to the Department of Justice (the FBI).

FINRA offered clarification on, among other things:

• where to obtain fingerprint cards, barcodes or unique identifiers;

• whether individuals may be required to be re-fingerprinted;

• what steps are necessary for firms if no fingerprinting is currently required;

• where to send hard copies of fingerprints;

• fingerprinting accommodations for physical handicaps;

• FBI background checks that will provide results to Form U4s and CRDs;

• new FINRA-specific fingerprint cards from Sterling accepted for processing, although Sterling will accept current FINRA-specific cardstock through June 6, 2022; and

• non-registered firms' options for fingerprinting.