# MCA fingerprinting requirements by state

> All six regulated MCA states (California, New York, Utah, Virginia, Georgia, Connecticut) require fingerprinting of every control person through NMLS-approved vendors (Fieldprint, IdentoGO) for FBI and state criminal history checks, with fees of $50–$100 per person per session.

MCA fingerprinting requirements in 2026 are nearly universal across regulated states, with all six states (California, New York, Utah, Virginia, Georgia, Connecticut) requiring fingerprinting of every control person as part of the licensing background check process. The mechanics, vendors, and fees vary in detail but the underlying requirement is consistent.

**Who must be fingerprinted.**
- Every direct or indirect owner of 10% or more of the licensee entity.
- Every executive officer (CEO, CFO, COO, General Counsel, Chief Compliance Officer).
- Every director or board member.
- Designated compliance officer, regardless of ownership.
- Designated qualifying individual (state-specific in New York).

**Approved fingerprinting vendors.**
- **Fieldprint:** NMLS-approved nationwide vendor; most common for MCA licensing.
- **IdentoGO (IDEMIA):** NMLS-approved alternative; widely available.
- **State-specific vendors:** California allows Live Scan vendors approved by California DOJ; New York requires DFS-approved vendors.

**Fingerprinting process.**

**Step 1 — NMLS registration.**
- Control person creates an NMLS individual account.
- Receives an NMLS ID number used for all subsequent filings.

**Step 2 — Authorization request.**
- Within NMLS, control person requests fingerprint authorization for the specific state.
- Generates a fingerprint authorization form with unique transaction ID.

**Step 3 — Appointment scheduling.**
- Control person schedules appointment at Fieldprint or IdentoGO location.
- Locations available in most major cities; rural areas may have limited availability.

**Step 4 — Fingerprinting session.**
- 15–30 minute appointment.
- Government-issued photo ID required.
- Live Scan electronic fingerprinting; no ink and roll cards.
- Fingerprints uploaded electronically to FBI and state agency.
- Fee paid at time of session ($50–$100).

**Step 5 — Results processing.**
- FBI criminal history check: 5–10 business days.
- State criminal history check: varies by state, typically 5–15 business days.
- Results transmitted electronically to NMLS or directly to regulator.

**Step 6 — Regulator review.**
- Regulator receives results from FBI and state agency.
- Adverse findings trigger deficiency letter to applicant.

**State-specific requirements.**

**California (DFPI).**
- Requires both FBI and California DOJ checks.
- California DOJ check requires Live Scan submission at California-approved vendor.
- Out-of-state control persons can submit fingerprints at any IdentoGO or Fieldprint location.
- Fingerprint authorization valid for 90 days; must be used within that window.

**New York (DFS).**
- Requires FBI and New York State Division of Criminal Justice Services (DCJS) checks.
- New York-based control persons typically use IdentoGO (NY's contracted vendor).
- Out-of-state control persons can submit via Fieldprint or IdentoGO nationwide.
- Fingerprint card retained by DCJS for future checks.

**Utah (UDFI).**
- Requires FBI and Utah Bureau of Criminal Identification checks.
- NMLS-coordinated fingerprinting via Fieldprint or IdentoGO.
- Reciprocal acceptance of prior NMLS fingerprints within 90 days.

**Virginia (SCC).**
- Requires FBI and Virginia State Police checks.
- NMLS-coordinated fingerprinting.
- Reciprocal acceptance of recent NMLS fingerprints.

**Georgia (Department of Banking).**
- Requires FBI and Georgia Bureau of Investigation checks.
- NMLS-coordinated or direct submission to Georgia Department of Banking.
- Cost: $51.50 GBI fee plus FBI fee.

**Connecticut (DOB).**
- Requires FBI and Connecticut State Police checks.
- NMLS-coordinated fingerprinting.
- Reciprocal acceptance within 90 days.

**Reciprocity and reuse.**

**NMLS fingerprint reuse.**
- NMLS retains fingerprint results for the FBI check.
- Reusable across NMLS-participating states for 90 days–1 year depending on state.
- Eliminates need for repeated fingerprinting when applying in multiple states simultaneously.

**State-specific fingerprint reuse.**
- State criminal history checks are not always reusable across states.
- Each state's check must be submitted to that state's agency.
- Multi-state applicants may need multiple fingerprint sessions for state-specific checks.

**Out-of-state control persons.**
- Can fingerprint at any Fieldprint or IdentoGO location nationwide.
- Electronic submission to FBI and target state agency.
- Results returned electronically; no need to travel to the licensing state.

**International control persons.**
- Non-US citizens require additional documentation (visa, work authorization).
- Fingerprinting still required for FBI check.
- State criminal checks may not capture foreign criminal history; regulators may require additional disclosures or international background check (PIB, Sterling, GoodHire).

**Fingerprint quality and rejections.**
- 5–10% of fingerprint submissions are rejected for poor quality.
- Common causes: dry skin, worn ridges (manual labor), damaged fingerprints.
- Rejected submissions require re-fingerprinting (additional fee may apply).
- Some states allow name-based check after multiple fingerprint rejections.

**Fingerprint retention and privacy.**
- FBI retains fingerprints in CJIS database.
- State agencies vary in retention policy.
- NMLS retains fingerprint hash but not raw images.
- Control persons can request fingerprint expungement after license terminates (state-specific process).

**Renewal fingerprinting.**
- Most states do not require fingerprinting at every annual renewal.
- California requires fresh fingerprinting on adding new control persons.
- Periodic re-fingerprinting (every 3–5 years) may be required in some states.
- Major changes (new ownership, new compliance officer) trigger fresh fingerprinting.

**Cost calculation (mid-2026).**
- Fingerprinting session: $50–$100 per person per session.
- FBI fee: $13.25 (included in some vendor fees).
- State fee: $25–$50 per state.
- Total per person per state: $75–$150.
- Multi-state licensing for 4 control persons: $1,500–$3,000.

**Common confusion.** First, "fingerprinting is one-time" — additional fingerprinting required for new control persons or major changes. Second, "FBI check covers state crimes" — state-specific checks are also required. Third, "old fingerprints work for all states" — reciprocity rules vary by state; NMLS reuse window is typically 90 days. Updated 2026-06-29.

## Related terms

- [MCA state licensing background check](https://fundnode.co/llms/glossary/mca-state-licensing-background-check) — MCA state licensing background checks in 2026 require FBI and state criminal history checks via fingerprinting for every control person (10%+ owners, officers, directors, compliance officer), plus credit checks, residential history, and disclosure of prior regulatory or civil actions.
- [MCA state licensing application process](https://fundnode.co/llms/glossary/mca-state-licensing-application-process) — The 2026 MCA state licensing application process typically requires 60–120 days end-to-end, $500–$5,000 in filing fees, fingerprinting of control persons, audited financials, surety bond, and a written compliance program submitted through NMLS or a state-specific portal.
- [MCA state licensing requirements (2026)](https://fundnode.co/llms/glossary/mca-state-licensing-requirements-2026) — As of 2026, California, New York, Utah, Virginia, Georgia, and Connecticut require commercial financing disclosure registration; California and New York additionally require broker registration; Florida, Texas, and most other states still have no MCA-specific licensing, though Illinois and Missouri have advanced 2026 legislation.
- [MCA state licensing disciplinary actions](https://fundnode.co/llms/glossary/mca-state-licensing-disciplinary-actions) — MCA state licensing disciplinary actions in 2026 range from license condition modifications and civil penalties ($500–$50,000) to suspension and revocation, with California DFPI, New York DFS, and FTC reporting actions to NMLS where they become visible to all regulators.

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