![]() Are there increased or additional costs to firms associated with this new service?Ī4: FINRA continues to collect FINRA and FBI processing fingerprint fees through the firm’s Flex-Funding account in E-Bill. Firms that choose to use another vendor to collect fingerprints should contact the vendor directly. If using a vendor, confirm that your vendor is approved and on the list of EFS vendors.įirms with questions about using Sterling as their fingerprint collection option should contact Sterling Client Support. See Question #6 for more information on hardcopy submissions. In addition, FINRA-specific hardcopy cards may be sent to Sterling for processing. Q3: With FINRA’s fingerprint provider, Sterling, what fingerprint collection options are available?Ī3: 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. Rule 17f-2 lists the bases for exemptions (see Question# 14). Q2: Is an individual exempt from the fingerprinting requirement based on being a foreign national or foreign resident?Ī2: No. Have direct supervisory responsibility over those who sell securities or have access to securities, monies, or the original books and records.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.Rule 17f-2 exempts employees from fingerprinting who do not: Q1: Which firm personnel are required to be fingerprinted?Ī1: 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.
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