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Fingerprint Card Requirements

Any individual that is applying to register as an Associated Person, Floor Broker, Floor Trader or to be listed as a Principal must send a completed fingerprint card to NFA unless:

  • the individual is currently registered with the CFTC in any capacity or is listed as a principal of a current CFTC registrant;
  • NFA has received fingerprint card results from the Federal Bureau of Investigation within 90 days preceding the date the individual's Form 8-R is filed with NFA;
  • the individual is a director but is not also an officer or employee of the firm ("outside director") may file with NFA a Notice Pursuant to CFTC Regulation 3.21(c). A firm that has filed a Notice Pursuant to CFTC Regulation 3.21(c) with respect to an outside director described therein must file with NFA on behalf of such outside director a Form 8-R completed in accordance with all pertinent instructions and verified by the outside director. The exemption provided for by this paragraph is limited solely to the outside director's fingerprint requirement and does not affect any other duties or responsibilities of the firm or the outside directors under these Rules. In appropriate cases, NFA may require additional information from the firm with respect to any outside director referred to in the Notice Pursuant to CFTC Regulation 3.21(c);
  • any sponsor that is registered as a Broker/Dealer that files a Form 8-R on behalf of an AP applicant or a principal may, in lieu of submitting a fingerprint card for the applicant or principal, represent in the Form 8-R that, within the last 90 days, an application for registration as a General Securities Representative has been filed on behalf of the applicant with the Financial Industry Regulatory Authority and that a fingerprint card containing the applicant's or principal's fingerprints accompanied the application.

Digital images of fingerprints are sent by NFA to the Federal Bureau of Investigation (FBI) to determine if the applicant has a criminal record. Results are received in three days or less and in some cases within several hours resulting in a faster registration process.

To conduct a check of its records the FBI must be able to analyze the print pattern of all 10 fingers. The FBI will reject fingerprint cards that do not have legible patterns for all 10 fingers. For this reason it is very important that you have your fingerprints taken by a person properly trained in rolling fingerprints.

NFA can only accept and process a complete FBI "applicant card". Applicants are encouraged to submit more than one set of fingerprints with their application to avoid delays in obtaining additional sets if necessary for processing.

NFA will return to the applicant fingerprint cards that are incomplete or that are not applicant cards and will request new cards.

Completed fingerprint cards should be sent to NFA at the following address:

National Futures Association
Attention:  Registration Department
300 S. Riverside Plaza, Suite 1800
Chicago, IL 60606-6615

NFA offers a fingerprinting service for NFA applicants at the Chicago office (300 South Riverside Plaza, Suite 1800) between the hours of 8:30 a.m. and 4:00 p.m. for $15 (cash, check or money order). All individuals being fingerprinted will be required to present two forms of identification, one of which is a valid picture ID issued by a government agency, in order to verify the identity of the person being fingerprinted.

In order to use NFA's fingerprint service, visitors must be pre-registered in the building's visitor registry. Visitors should contact NFA's Information Center (either by phone at 312-781-1410 or send an email to information@nfa.futures.org) to register their name and date of visit so they can receive access to NFA's offices on the 18th floor. NFA recommends that visitors pre-register at least a day prior to their visit.

NFA has issued a Registration Advisory that provides guidance concerning fingerprinting to assist those who submit applications via the Online Registration System. If you have any questions regarding the fingerprint card process, please contact NFA's Information Center at 312-781-1410 or 800-621-3570.

On December 11, 2012, the Commodity Futures Trading Commission Division of Swap Dealer and Intermediary Oversight issued no-action relief from the requirement to submit fingerprint cards in connection with registration applications for principals who have not resided in the United States since reaching 18 years of age ("non-U.S. Principal"). The no-action letter can be found by clicking on CFTC Letter No. 12-49.

On June 21, 2013, the Commodity Futures Trading Commission Division of Swap Dealer and Intermediary Oversight also issued a no-action relief from the requirement to submit fingerprint cards in connection with registration applications for associated persons who have not resided in the United States since reaching 18 years of age ("non-U.S. Associated Person"). The no-action letter can be found by clicking on CFTC Letter No. 13-29.

In order to qualify for the relief, the principal/associated person's firm must:

  1. file a Form 8-R for each non-U.S. Principal/associated person;
  2. notify NFA within 30 days if the firm does not intend to submit a fingerprint card for the non-U.S. Principal/associated person;
  3. submit a certification stating that:
    1. a reasonable criminal history background check using a reputable commercial service was conducted;
    2. such criminal history background check did not reveal any matters that constitute a disqualification under Sections 8a(2) or 8a(3) of the Commodity Exchange Act, other than those disclosed on the principal/associated person's Form 8-R; and
    3. the firm shall maintain, in accordance with Commission Regulation 1.31, records documenting that such criminal history background check was performed and the results thereof; and
  4. list each non-U.S. Principal on the firm's registration application. 

The no-action letter also stated that in accordance with the Paperwork Reduction Act (PRA), the Commission will be publishing in the Federal Register a notice and request for public comment on the burdens associated with the collection of information associated with the no-action relief. After this process is concluded and subject to any changes as a result of comments received, NFA expects that the registration application forms will be amended to incorporate the required certification.

Until the PRA process is completed, firms are not required to submit the certification or list of principals in order to qualify for the no-action relief. Firms will, however, need to notify NFA if they are not submitting a fingerprint card for a non-U.S. Principal/associated person within 30 days of filing that principal/associated person's Form 8-R. Firms must send this notice to NFA via email to Non-USPrincipalPrintCardAlternative@nfa.futures.org.

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