I am having difficulty getting an associated individual in a foreign country fingerprinted promptly. What can I do?
Pursuant to Section 17(f)(2) of the Securities Exchange Act of 1934 and Rule 17f-2 thereunder, the SEC requires broker-dealer firms to require their partners, directors, officers and employees to be fingerprinted and to have their fingerprints processed, unless they are exempt under those same provisions. If the firm or individual is not exempt, it is the responsibility of the firm to get its personnel fingerprinted and to submit the prints to FINRA for processing.1 Since the implementation of Web CRD, firms typically submit Form U4 electronically and, by selecting the first radio button in Section 2/Fingerprint Information, simultaneously represent that they are submitting or promptly will submit fingerprint cards as required under applicable SRO rules (see e.g., NASD Rule 1140, which provides generally that firms must submit fingerprint cards to FINRA within 30 days of filing Form U4). FINRA members have informed FINRA staff, however, that it is difficult to fingerprint associated pe
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