On December 6, FINRA accepted a New York-based member firm’s Letter of Acceptance, Waiver, and Consent which addressed allegations of the firm’s failure to take required fingerprints of most associated persons prior to or upon association with the firm. The letter noted this process is used to screen individuals for statutory disqualification due to past misconduct. Since at least January 2016, the firm allegedly failed to fingerprint approximately 2,000 non-registered associated persons employed by its affiliates, in addition to an unknown number of former employees, resulting in violations of the Securities Exchange Act of 1934 and FINRA rules. Additionally, the firm allegedly failed to maintain required fingerprint records and establish a supervisory system with procedures to ensure compliance with fingerprinting requirements. As a result, the firm consented to a censure, a $950,000 fine, and a certification of compliance with fingerprinting requirements within 180 days.