NMLS recognizes that some institutions may have existing systems for fingerprint collections and a volume that makes it worthwhile to establish a direct connection. Due to the technical and legal requirements necessary to facilitate such an alternative fingerprint submission process, NMLS can only offer this option under the conditions listed below. If, after reviewing these conditions, your institution is interested in using existing fingerprint files collected outside of the NMLS network, please contact Fieldprint at 1-877-614-4365. Conditions are as follows:
Execution of a legal agreement between the institution and Fieldprint, approved by State Regulatory Registry LLC
In order to protect the integrity of fingerprints collected and maintained by NMLS, SRR requires certain quality controls be in place as institutions collect fingerprints that mirror those in place in the NMLS network. To ensure the required controls are in place and the agreement is consistent across participating institutions, the standard agreement cannot be adjusted.
Adherence to the Interface Control document
Fieldprint has developed an interface control document for the submission of existing fingerprints to NMLS. This document regulates submission of fingerprints and helps ensure that submitted fingerprints are connected with the correct mortgage loan originator’s record in NMLS. Institutions interested in submitting existing fingerprints or using its vendor to collect fingerprints for submission to NMLS must abide with the technical and policy requirements outlined in this document to ensure a uniform standard of all fingerprints collected by NMLS.
Institution must have a minimum of 1,500 MLOs registered in NMLS
Due to the costs associated with establishing monitoring, and maintaining this alternative submission process, SRR believes that the alternative process is only effective for institutions with a high volume of prints to process. As such, institutions must have a minimum of 1,500 MLOs registered in NMLS in order to participate in this alternative process.
The Institution’s fingerprint acquisition vendor must be an FBI approved channeler
To ensure the institution’s selected vendor meets minimum information security and auditing requirements, the vendor providing fingerprint acquisition and management services to the institution must be an FBI approved channeler. List of FBI channelers.
NOTE: All submissions must be completed through one connection. Institutions are responsible for the consolidation and management of prints from multiple livescan terminals
Please note that regardless of the submission method, fingerprints cannot be submitted to NMLS until the MLO’s MU4 or MU4R has been submitted and all appropriate fees have been paid. For more information on submitting prints through the NMLS network, see Criminal Background Check.