Q: When can I join the program?
A: Banks can join the program any time by simply contacting the SDBA and ordering the supplies.

Q: Will the fingerprint actually be visible on the check?
A: Yes, the fingerprint will be immediately visible on the check so that a bank employee can tell if there is a good impression. The “inkless” feature refers to the fact that the fingerprint pad will not leave a residue on your hand. In addition, the print is clearly visible on a photocopy or microfilm of the check.

Q: Can we use the inkless fingerprint pads through the pneumatic tubes in the drive-through?
A: Although the pad will physically travel through the pneumatic tubes in bank drive-throughs, we do not recommend this. Banks that have sent the pads through the pneumatic tubes have not experienced favorable results. If your bank lobby is open, the SDBA recommends that the bank require all non-account holders to come inside the bank to cash checks and give their thumbprints. If the lobby is not open, your bank has a choice. You either can establish a policy of not cashing non-account holder checks after hours or of using the Thumbprint Signature Program in the closest drive-through window, where the teller is able to witness the thumbprinting. If your bank is using the inkless pads in drive-throughs, you must make sure the teller: 1) is physically able to see the individual place his or her thumbprint on the check, and 2) does not accept a check with a smeared print.

Q: Can a bank require a fingerprint on a government check?
A: Yes, a bank can require a fingerprint when cashing a government check for a non-customer, provided the bank has not entered into an agreement with a regulator or other government entity under which it agrees to cash government checks for non-customers on the same terms as it cashes checks for its customers.

Q: Must the bank obtain a fingerprint on every non-customer?
A: Each bank participating in the Thumbprint Signature Program is advised to have written policies and procedures governing how the program will be used. Although a bank has some discretion in establishing its policy, it is critical that the policy is applied consistently to avoid allegations of discriminatory treatment.

For example:
4 If a bank’s policy is to require a fingerprint on all non-customers cashing a check, whether an “on-us” check or otherwise, the policy must be applied consistently. Tellers and other bank personnel should not be authorized to waive or modify the policy.

4 A bank can establish a dollar threshold below which it will not require a thumbprint. Again, the policy must be applied consistently. Tellers and other bank personnel should not be authorized to waive or modify the policy.

4 A bank can choose to cash “on-us” checks without requiring a fingerprint; however, because stolen or forged payroll checks often account for a significant portion of bank losses due to fraud, such a policy could dilute the effectiveness of the program. Again, the policy must be applied consistently. Tellers and other bank personnel should not be authorized to waive or modify the policy.

4 A small town bank can choose to thumbprint only those non-customers living outside their county if the boundaries of the county are explicitly defined in the bank’s policy. A subjective determination by a teller or other bank personnel of whether a particular address is in the county should be avoided. The policy must be applied consistently. Tellers and other bank personnel should not be authorized to waive or modify the policy.

These are just a few examples of the way a bank can structure its policy on the Thumbprint Signature Program. Generally, the simpler the policy, i.e., requiring fingerprints on all non-customers, the easier it will be to carry out. In evaluating your policy, be mindful that unlawful discrimination can occur in three ways:

1) When a policy is discriminatory on its face;
2) When a policy is not discriminatory on its face, but is applied in a discriminatory manner; and
3) When a policy is neither discriminatory on its face nor applied in a discriminatory manner, but has the effect of discriminating against a protected class.

For more information about the Thumbprint Signature program, please contact Theresa Hanson at the SDBA (605-224-1653).