Thumbprint Signature Program - FAQs
Have I missed the deadline for participating and ordering supplies?
- No, banks can join the program at any time simply by contacting BancSource at the Oregon Bankers Association. BancSource is maintaining an inventory of Thumbprint Signature program supplies which allows us to fill the majority of orders the same day we receive them.
What supplies do I need and how do I order?
- Ordering supplies is easy. Just click here for our PDF order form and fax or mail it us. BancSource recommends ordering the following Thumbprint Signature program supplies, which all feature the Thumbprint Signature logo printed in black and red:
Touch Pads: The touch pads have a shelf live of 18 months or a minimum of 400 impressions. Financial institutions should order enough for all tellers and drive-through staff.
Teller Window Displays: Financial institutions should post these 6" x 3" tent-style display signs at all teller windows as an additional reminder that they participate in the program.
Statement Stuffers: These 3½" x 7½" brochures explain the mechanics of the program. Financial institutions should send them as a public service announcement to all account holders and have plenty on hand for anyone who might have questions about the program. Please order in increments of 500.
Decals: Institutions should post decals at all entrances to let people know they are participating in the program and to warn potential criminals that their crimes will not go undetected. They may also want to post decals in their drive-through windows.
Will the fingerprint actually be visible on the check?
- 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 the users hand. In addition, the print is clearly visible on a photocopy or microfilm of the check.
Will the inkless fingerprint pad fit through the pneumatic tubes in the drive-through?
- Yes, the pad is only about two inches in diameter and should easily travel through the pneumatic tubes in the drive-through.
Can a bank require a fingerprint on a government check?
- Yes, a bank can require a fingerprint when cashing a government check for a non-customer, provided that, 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.
Where are the thumbprints stored, and is a database maintained?
- The thumbprint check travels through the normal channels of the bank, just as any check would. The checks are not segregated and no database is maintained. The thumb printed checks are used by law enforcement agencies only in the case of check fraud.
What should I do if I suspect check fraud?
- Tellers and officers should follow established reporting procedures regarding known or suspected fraudulent transactions, including contacting local law enforcement personnel, as well as the FBI.
What about the angry non-customer?
- The program has been met with very minimal public criticism (less than 1% of non-customers refused to provide thumbprints in the pilot program). If a non-customer objects to providing a thumbprint, you have two options: invite him/her to open an account, or refer the person to another institution. Not all banks are participating in the program at this time. Although it is best if bank personnel avoid engaging in a discussion of the legalities of the program, you should be assured that the request for a thumbprint of a non-customer is not a violation of either federal or state laws.
Must a bank obtain a fingerprint on every non-customer?
- 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:
- 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.
- A bank can establish a dollar threshold below which it will not require a fingerprint. Again, the policy must be applied consistently. Tellers and other bank personnel should not be authorized to waive or modify the policy.
- 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.
- A small town bank can choose to fingerprint 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 has the effect of discriminating against a protected class.
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