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In this article we are going to review the types of activities that may be performed by non-registered individuals who are subject to the fingerprint requirements of FINRA. While these individuals are not required to become licensed to perform the permitted activities, their roles often provide access to sensitive information and documents.
A non-registered fingerprint (NRF) person may assist with administrative duties. When conducting these duties, it’s important to know that there can’t be any involvement in making a securities recommendation or making any sort of investment decisions for your clients.
Clerical Responsibilities of NRF Individuals
Clerical responsibilities of an NRF can include data entry and processing documents, filing and record-keeping, preparing and distributing marketing materials without making a specific investment recommendation and without drafting the specific investment language in that material.
NRF duties often support and schedule appointments for registered representatives, process paperwork and information, as well as handle mail and other communications.
As noted, it’s important to pay attention to the things that an NRF individual may not do in general and then ensure individuals cannot conduct any activities that would require a securities license.
NRF individuals cannot offer investment advice or product recommendations, cannot directly execute, process, or solicit security transactions, and cannot oversee or manage registered representatives. While they can have access to customer and other non-public information, it’s important to limit access to that type of information and make sure that the data is not used for making investment decisions by the NRF individual.
NRFs cannot recommend securities or determine product suitability, and again, as an NRF, individuals must have limited access to sensitive data to ensure they stay within the scope of their roles and responsibilities.
Operational Support Functions
In addition to administrative functions, an NRF individual will often provide operational support. In providing operational support, an NRF can perform back-office functions such as trade reconciliations, settlements, and trade confirmation processing.
NRFs can assist with compliance and regulatory reporting tasks under the supervision of a licensed individual, and an NRF can assist a licensed individual with managing account transfers and updates.
Common NRF duties can include acting as an administrative assistant or office manager, a client services representative, or providing compliance or other operational support.
Administrative Assistant or Office Manager Role
In general, the job overview of an administrative assistant or office manager is to provide essential support to the operations of the firm, ensure smooth day-to-day office activities, and assist staff members with administrative tasks.
This position requires handling confidential information, managing schedules, and coordinating office functions, but does not involve any direct involvement with securities transactions or investment advice.
Key responsibilities of this individual can include:
- Performing administrative duties including answering phone calls, managing correspondence, and organizing files.
- Maintaining office supplies and ensuring smooth functioning of office equipment.
- Managing and updating schedules for senior executives, including arranging meetings and appointments with clients.
- Supporting the preparation of internal reports, documentation, and presentations as needed.
- Assisting with general clerical tasks.
The qualifications of an administrative assistant will typically include strong organizational and multitasking skills, proficiency with Microsoft Office and other required technology suites. Experience working in financial services or related industries is always a plus for NRF individuals conducting administrative assistant or office manager roles.
Client Services Representative Role
Additional functions of an NRF can include acting as a client services representative. The client services representative serves as the contact for clients, providing high-quality customer service and administrative support.
The role includes managing client inquiries, maintaining accurate client records, and ensuring that customer requests are processed in a timely and efficient manner. This position does not involve providing investment advice or executing securities transactions.
Some key responsibilities of a client service representative can include:
- Handling incoming client inquiries via phone, email, or in person, and providing excellent customer service.
- Updating and maintaining client records within the firm’s database.
- Assisting clients with basic account-related inquiries such as account details, information, or where they can access certain books and records related to their account.
NRF associates often ensure timely resolution of client issues by working closely with other departments, including compliance, operations, and sales. These functions can include preparing and distributing client correspondence, including account statements, confirmations, and supporting documentation, and assisting with maintaining compliance with FINRA regulations regarding communications and confidentiality.
IT, Compliance, and Operational Support Roles
In the role of IT, compliance, or other operational support, the NRF individual plays a vital role in ensuring the smooth operation of technology systems, compliance processes, or operational functions within the firm.
This position supports the firm’s registered staff by managing data, performing clerical functions, and helping to ensure compliance with FINRA regulations. This role does not involve any direct client involvement with securities transactions, product recommendations, or suitability determinations.
Key Differences Between Advisors and NRF Individuals
It’s important to note the key differences between what advisors do versus what NRF individuals do.
An NRF individual may not execute direct trades, deal with clients, or approve account openings or closings without the supervision of a licensed person.
Customer service, again, can include answering phone calls, answering general inquiries, and providing customers with general account information. The majority of customer service roles for NRFs involve the facilitation of information and connecting clients with the appropriate licensed registered person or with the appropriate piece of information clients are looking for.
Final Thoughts
NRF individuals perform a wide range of administrative, client service, and operational functions that help financial firms operate efficiently and stay compliant. By understanding what NRFs can and cannot do, firms can ensure that all investment-related activities remain properly supervised while still providing exceptional support to both clients and registered representatives.
