Fingerprinting for FINRA Registration: A Complete Guide

A FINRA registration can hinge on something as ordinary as a fingerprint appointment. Miss the deadline, submit the wrong card, or have the prints rejected, and a routine onboarding step can turn into a registration delay.

For firms, the challenge is not simply getting employees fingerprinted. It is knowing who needs to be printed, which submission route applies, what happens when prints are rejected, and how to keep the process moving when employees are working outside the U.S. This guide breaks down those requirements and the practical considerations behind the FINRA fingerprinting process.

For more information, check: What is FINRA screening?

FINRA fingerprinting is the process of collecting an individual's fingerprints and submitting them through the FINRA Fingerprint Program so the FBI can run a criminal history record check. The legal requirement comes from Section 17(f)(2) of the Securities Exchange Act of 1934 (15 USC 78q(f)(2)) and SEC Rule 17f-2.

Only fingerprints submitted through the FINRA Fingerprint Program satisfy the FINRA fingerprinting requirement. Fingerprints taken for any other purposes cannot be reused or repurposed for FINRA registration. For example:

• a state background check,
• a different licensing body, or
• a prior employer.

Why Does FINRA Require Fingerprinting?

FINRA requires fingerprinting to protect investors. The SEC mandates that member firms screen out individuals with disqualifying criminal convictions or regulatory violations before they gain access to customer funds, securities, or a firm's official books and records.

Fingerprint-based background checks are considered more reliable than name-based checks because they are tied to a unique biometric identifier rather than a name that could be shared or misspelled.

Under Exchange Rule 17f-2, firms must fingerprint all partners, directors, officers, and employees, unless they qualify for a narrow exemption. Specifically, fingerprinting is required for anyone who:

• Sells securities or is a registered representative or principal
• Regularly handles, keeps, or processes securities, money, or the firm's original books and records
• Has direct supervisory responsibility over anyone in the categories above

This applies broadly. It is not limited to licensed brokers. Operations staff, compliance personnel with recordkeeping duties, and supervisors of registered reps can all fall within the fingerprinting requirement even if they never touch a client account directly.

Who Is Exempt From FINRA Fingerprinting?

An employee is exempt only if they meet all three conditions simultaneously:

1. They do not sell securities.
2. They do not regularly access the handling or processing of securities, money, or original books and records.
3. They have no direct supervisory responsibility over anyone who does the above.

Because the exemption requires all three conditions to be true at once, many firms find it simpler and safer to fingerprint everyone rather than manage exemption documentation and monitor for role changes that could void the exemption.

Is There an Exemption for Foreign Nationals or Foreign Residents?

No. Being a foreign national or living outside the United States does not exempt anyone from the fingerprinting requirement. The only exemptions permitted are the ones defined in Exchange Rule 17f-2. Firms with personnel abroad still must arrange fingerprinting, though the collection method differs (see below).

Individuals do not submit FINRA fingerprints independently. The sponsoring firm is responsible for initiating and submitting the fingerprint transaction, while the individual completes the fingerprint collection through the firm's chosen submission method.

• Electronic Fingerprint Service (EFS) providers - third-party vendors approved by FINRA that collect fingerprints via livescan and transmit them electronically
• A firm's own livescan equipment located on-site
• Sterling collection sites (First Advantage Biometrics, FINRA's dedicated fingerprint processor)
• FINRA-approved hardcopy fingerprint cards, mailed in for individuals who cannot access electronic capture

Hardcopy cards must be purchased directly from Sterling (First Advantage Biometrics).

How Are Fingerprints Handled for Personnel Outside the U.S.?

Fingerprints for individuals located outside the United States or its territories must be captured on a FINRA-approved hardcopy card and mailed directly to FINRA, which forwards them to Sterling.

EFS vendors are prohibited from collecting, receiving, or processing fingerprints from anyone located outside the U.S. or its territories, even on a hardcopy card. FINRA recommends using a law enforcement agency or a trained fingerprint technician to capture prints on the approved card in these cases.

What Is the Deadline for Submitting Fingerprints for FINRA Registration?

For an initial fingerprint requirement, the firm generally has 30 days following the Form U4 filing to submit the required fingerprints. If a submission is later returned as ILEG or REJT, a new 30-day period applies for the additional submission.

Firms can request an extension from FINRA for good cause. For example, difficulty arranging fingerprinting for personnel in a foreign country.

Firms pay the FINRA and FBI processing fees collected through the firm's Flex-Funding account in E-Bill. They also pay the vendor collection/equipment fees charged separately by whichever EFS vendor or collection site performs the actual fingerprint capture.

Firms that use Sterling directly may benefit from FINRA's negotiated collection rates. But many firms instead work with third-party fingerprinting providers that specialize in bulk onboarding for cost and scheduling efficiency.

Fingerprints can be rejected for two distinct reasons:

Can Fingerprints Be Reused for a New FINRA Registration?

No. FINRA does not permit reuse of a previously submitted fingerprint set. A new, fresh set of fingerprints must be collected and submitted for every FINRA Fingerprint Program transaction, even if the individual was fingerprinted for a prior registration or a different purpose.

The FBI has been developing a broader "Fingerprint Reuse Policy," but as of the most recent FINRA update, no changes to current procedures are in effect. Firms must continue collecting and submitting new prints for each required transaction.

At minimum, a compliant submission needs:

• Full legal name and date/place of birth
• Social Security Number (required if born in the U.S. or its territories)
• CRD number, if already assigned
• Firm name and Org ID number
• Height, weight, hair color, eye color, race (using FBI-standard codes)
• Signatures of both the individual being printed and the official taking the prints

Missing fields, highlighter marks, or illegible handwriting on hardcopy cards are among the most common reasons submissions are rejected outright.

Do Non-Registered Employees Need Fingerprints Too?

Yes, if they fall into the categories described above (handling funds, securities, or original books and records, or supervising someone who does). These individuals are submitted through Form NRF (Non-Registered Fingerprint) rather than Form U4, since they are not seeking a securities registration themselves but still require an FBI background check under Rule 17f-2.

Does a Broker-Dealer Need Separate Fingerprints for Each Affiliated Firm?

No. Only one set of fingerprints is required across affiliated firms listed on a single Form U4, as long as the employment date is consistent across Section 1 and Section 6 of the filing. Firms can also establish a Simultaneous Filing Group so fees are deducted from one designated primary firm account.

Do Investment Adviser-Only Firms Use the FINRA Fingerprint Program?

No. Investment adviser-only firms do not submit fingerprints through FINRA. Fingerprinting requirements for IA representatives are handled at the state level, and not every state requires fingerprints for IA registration. Firms should confirm requirements directly with the relevant state securities regulator.

What About Funding Portals?

Funding portals follow the same statutory requirement under SEA Rule 17f-2 and must fingerprint all associated persons. New funding portals initially submit hardcopy fingerprint cards until their FINRA Organization ID is assigned, after which electronic submission becomes available.

Can a Firm Store Fingerprints for Later Use?

No. EFS vendors are not permitted to store fingerprints on behalf of a firm or funding portal. Per FBI rules, vendors must purge fingerprints and results as soon as the FBI result is received, or within 30 days at the latest. 

FINRA's own submission window is even tighter: EFS vendors must transmit fingerprints within 28 days of capture to leave buffer time for technical issues or FBI delays. This is one more reason firms benefit from working with a fingerprinting partner that has a reliable, repeatable process rather than an ad hoc one.

What Documentation Must Be Provided at a Fingerprint Appointment?

At minimum, firms (or their vendor) must provide each candidate with:

• written notice of how the FBI will use the fingerprints and associated information,
• a copy of the Noncriminal Justice Applicant's Privacy Rights,
• a copy of the FBI Privacy Act Statement,
• instructions on how the candidate can access and correct their criminal history record, and
• obtain the individual's written consent to be fingerprinted.

Skipping any of these steps can create compliance exposure independent of the fingerprint submission itself.

• Fingerprinting is required for virtually all registered and many non-registered personnel - treat exemptions carefully and document them if used.
• The 30-day clock starts at Form U4 filing, not at hire date, so scheduling fingerprinting early avoids "Inactive Prints" status.
• Reuse is not permitted; every registration event typically requires a fresh submission.
• Foreign-based personnel require special hardcopy handling and cannot use standard EFS vendors.
• Bulk hiring events, including new advisor classes, acquisitions, or seasonal onboarding, need a fingerprinting plan that can scale without creating bottlenecks in registration.

Meeting the 30-day fingerprinting deadline is manageable when there are a handful of new hires. It becomes a real operational challenge when a firm is onboarding dozens or hundreds of registered representatives at once. This can happen during:

• an acquisition,
• a new office launch,
• a seasonal hiring wave, or
• a large training class of incoming advisors.

Globeia provides fingerprinting services purpose-built for FINRA registration workflows. Our mobile fingerprinting model is designed to remove that bottleneck for broker-dealers, funding portals, and firms managing large-scale onboarding.

Compliant Fingerprint Collection

Globeia's fingerprint collection process is designed to follow FINRA, Sterling, and FBI requirements and reduce avoidable quality-related rejections.

Built for Group and Bulk Onboarding

Globeia is equipped to handle group fingerprinting events for hundreds of candidates in a single scheduled session. This is valuable for:

• Broker-dealers onboarding a new training or licensing class
• Firms integrating personnel after a merger or acquisition
• Funding portals scaling up associated-person onboarding
• Compliance teams facing a hard deadline tied to a registration filing date

Rather than routing each new hire to a separate collection site and tracking dozens of individual appointments, firms can coordinate a single on-site or scheduled group event and have an entire cohort printed efficiently.

On-Site and Mobile Options

For firms with large or geographically concentrated hiring events, Globeia can bring fingerprinting capability directly to the firm's location, reducing the logistical burden on both compliance staff and new hires.

This is useful for firms located outside major metro areas where local EFS vendor coverage may be limited.

A Strong Focus on Accuracy To Protect the 30-Day Window

Because rejected or illegible submissions require a full resubmission, and each cycle consumes time inside the 30-day window, collection accuracy is directly tied to registration risk. Globeia's trained associates focus on capturing rolled and flat fingerprints correctly the first time.

We also conduct an on-the-spot quality check to help reduce the chances of Sterling rejections or FBI illegible determinations.

Letter of Identity Verification

Every session includes a Globeia-issued Letter of Identity Verification which contains an encrypted QR code. The letter provides the firm with a documented record of the fingerprinting session and identity verification performed by Globeia. 

Coordination With Compliance and HR Teams

Globeia works directly with a firm's compliance or HR team to schedule sessions around Form U4 filing dates, track completion status across a candidate group, and flag any issues. This workflow is designed to help firms avoid registration status disruptions during high-volume hiring periods.

Firms preparing for a large fingerprinting event, whether it's 20 new hires or 500, can reach out to Globeia to plan collection logistics that keep FINRA registrations on schedule.

FINRA fingerprinting may look like a small administrative requirement, but small requirements often carry the weight of larger systems. A fingerprint has to be captured correctly, submitted through the right channel, and processed within the right timeframe. When those pieces align, the process almost disappears, doing its work quietly, so the professional can simply move forward.