Fingerprints

Is fingerprinting required for bank employees??

I have only been fingerprinted once in my banking career. I don't think there are any requirements, but maybe a management decision. I think it's a good idea.

Not for bank employees it is not. It is if your will become Insurance/Security licensed.

While it is true that banks are not required to fingerprint employees, there is one thing you need to keep in mind. Section 19 of the FDI Act basically says that a bank cannot hire anyone convicted of dishonesty, breach of trust or money laundering, with certain exceptions. In most cases, the only way you can confirm whether or not a person has been convicted of dishonesty, breach of trust or money laundering is to obtain fingerprints and have them checked by the FBI. So, fingerprints are not required, but that is the easiest way to comply with Section 19. I believe the ABA still offers a service to banks that will facilitate the fingerprint checking process. The penalties for hiring someone with a conviction for dishonesty, breach of trust or money laundering can be severe, particularly if you made no attempt to try to run a criminal background check via fingerprints or some other reliable method.

It is going to be a year now that we had everyone in our bank fingerprinted so we made it a procedure at our bank to fingerprint new hires.

We became aware of fingerprinting when we received a faxed newsletter from the ABA Insider dated April 21, 2006. We then contacted the ABA (1-800-BANKERS) and asked for more information.

I found it interesting that penalty under FIRREA for hiring a know criminal is $1,000,000 per day fine. And that on average, 10% of fingerprint cards submitted uncover a criminal record. "Personnel in high-risk areas, such as those having access to cash, wire transfer, investments, securities, and sensitive information should be fingerprinted every three to five years."

At the time we started fingerprinting our employees the cost of the fingerprint service from the National FBI Fingerprint Service was $30.00 per card. We had a local police officer come in and do the fingerprintes for us for $5.00 a card, we did 2 cards per employee so that we could keep one in their personnel folder.

There may not be a regulatory fingerprint requirement for retail/deposit/lending activities of a bank. There are however regulatory fingerprint requirements that are applicable to a bank involved in certain activities. Specifically the Securities Exchange Act of '34 says banks acting as registered transfer agents must fingerprint any director, officer, or employee who was access to or hamdles any securities, records or monies relating to transfer agent activities.

In addition, fingprinting may be required, not by regulation, but by your bank's fidelity bond coverage for employees involved in specific activities.

As a matter of internal policy, every single one of our employees in the trust division are fingerprinted. Management here believes that the message they want to send to their high net worth clientel is that our trust employees are of high character. The fingerprinting is just one way of demonstrating that we are trustworthy and capable of managing their assets for them.

Our fingerprint cards are prepared locally but are sent through the ABA's Fingerprint Service and filed with the FBI. There is not a charge locally for rolling the prints, but the ABA charges $30.00 per card. Part of that fee covers the FBI filing, the rest covers their administrative costs in handling.