Mandatory Fingerprinting?
Some marketing pieces have been so enthusiastically touting the advantages of fingerprinting that some bankers have read into the copy that fingerprinting is mandatory for all banking employees.
There is a good reason for concern about fingerprinting. But the law has not changed and it is not a requirement that all banking employees be fingerprinted.
What has changed is the penalty for hiring a felon. The laws passed under the Financial Institutions Reform, Recovery and Enforcement Act (FIRREA) says that if a financial institution hires a convicted felon, it can be fined up to a million dollars a day.
This part of FIRREA takes the place of the old law that said you could be fined up to a thousand dollars a day. That, in turn, took the place of the law that used to say you could be fined up to $100 a day!
An interesting point here is to realize that to the best of anyone's knowledge or memory, the fine has never been imposed on any institution in any amount. However, that is not to say that it won't be imposed in the future.
There are certain areas of your institution where it is necessary to check employees' fingerprints. Anyone who handles collateral, and all employees who are in the trust department or who handle stocks or securities must be fingerprinted and checked.
If you have never done pre-screening of employees, including fingerprint checks, now might be a good time to incorporate such a practice. The American Bankers Association can provide you with material regarding fingerprinting of your employees. Information can be obtained by calling the Security and Risk Management Division of the ABA in Washington, D.C. They can be reached at (202) 663-5296.
Copyright © 1990 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 1, No. 8, 8/90