Thumbprint Signature Program
NOTE: The NBA administers this program for Nebraska financial institutions and businesses only. If you are located outside of Nebraska, please contact the bankers association in your state for more information or to place an order.
The Thumbprint Signature Program may be the answer to your business' check fraud problems. The Thumbprint Signature Program began as a pilot program in Nevada and Arizona. With an impressive decrease in check fraud of up to 75 percent, state bankers associations across the country have endorsed the program.
The Nebraska Bankers Association has joined this effort because we believe the Thumbprint Signature Program can substantially reduce check fraud losses for your organization. Participating Nebraska financial institutions require fingerprinting of all non-account holders (customers who do not have a depository relationship with the institution) seeking to cash checks.
The Thumbprint Signature can be used by law enforcement agencies in the investigation of fraud claims made by account holders. Use of the program is a natural deterrent. Participants will not retain the Thumbprint Signature in their files and the signatures will be shared with law enforcement officials only in cases of suspected fraud. We may ask you to fill out a report from time to time to help determine the effectiveness of the program. These reports will remain confidential.
The Thumbprint Signature Program is simple and easy to implement. The touch pad is a 2 x 1/2-inch fingerprinting device that leaves no residue on the thumb. Although the touch pad looks similar to an ink pad, it will not leave ink on a user’s thumb or clothing. The presenter of the check presses the thumb of his or her right hand on the pad and places the impression of the thumb on the face of the check between the memo and signature lines.
The NBA has negotiated a special purchase price for the inkless fingerprinting pads that are used in the program. The pads have a shelf life of 18 months or a minimum of 400 impressions. In addition, we are offering distinctive Thumbprint Signature Program door decals, statement stuffers, and teller window display tents.
Q: When can I join the program?
A: Banks can join the program any time by simply contacting the NBA. Your orders will be filled right away. Door decals and other materials are also readily available. Please allow time for shipping.
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 no longer recommend this. Banks that have sent the pads through the pneumatic tubes have not experienced favorable results. One Nebraska police department reported an increased number of forged checks coming from financial institutions as a result of using the pads in drive-throughs. If your bank lobby is open, the NBA 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. If the bank is a depository for state or local funds, they may not fingerprint or charge as a condition of cashing the state warrant. There is no requirement to cash either federal or state checks for non-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.
- 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 thumbprint. 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 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:
- When a policy is discriminatory on its face;
- When a policy is not discriminatory on its face, but is applied in a discriminatory manner; and
- 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.
On December 1, 1996, participating Nebraska financial institutions began using a new security device referred to as the Thumbprint Signature touch pad. The touch pad is intended to deter counterfeit and stolen check fraud by obtaining a Thumbprint Signature (thumbprint) from non-customers (customers who do not have a depository relationship with the institution) when cashing “on-us” and “not-on-us” checks. The Thumbprint Signature can be used by law enforcement agencies in the investigation of fraud claims made by account holders, and financial institution’s usage of the program is a natural deterrent. Participants will not retain the Thumbprint Signature in their files and the signature will be shared with law enforcement officials only in cases of suspected fraud.
Pilot programs in Arizona and Nevada were found to be helpful in decreasing check fraud. Early reports indicate decreases in check fraud of up to 75 percent since implementation of these pilot programs. In addition, less than 1 percent of presenters refused to provide the requested thumbprint. Neither Arizona nor Nevada experienced public criticism of their programs. Since that time, more than 35 state bankers associations have endorsed the program, or one similar to it, and are actively promoting the Thumbprint Signature Program.
Touch Pad Description
The touch pad is a round, plastic, inkless thumbprinting device approximately 2" in diameter and 1/2" in depth that leaves no residue on the thumb. Users simply rub their fingers together and any remaining ink disappears. The touch pad is not the same as an ink pad and will not leave ink on a user’s thumb or clothing.
How the Touch Pad Works
The presenter of the check presses the thumb of his or her right hand on the pad and places the impression of the thumb on the face of the check between the memo and signature lines. If the presenter is disabled and cannot use his or her right thumb, an impression of the left thumb is placed on the check and noted “left hand” on the check next to the thumbprint. Should both thumbs be disabled, an impression of the right index finger is taken and “right index finger” is noted next to the print.
NOTE: The Thumbprint Signature is not used as identification, but is recorded in addition to a customary ID.
When to ObtainaA Thumbprint Signature
A Thumbprint Signature should be obtained when:
- a non-customer presents an “on-us” or “not-on-us” check for encashment. This includes employees of commercial or business account customers who present payroll checks drawn on the participating institution.
- a non-customer presents an “on-us” check for exchange to a cashier’s check.
- a non-customer presents a government check for encashment.
NOTE: To comply with all applicable federal laws and regulations, a Thumbprint Signature should be obtained from every non-customer every time a check is presented for payment. Distinctions should not be based on appearance or suspicious vs. non-suspicious circumstances. Financial institutions in rural markets may want to develop a specific policy requiring a Thumbprint Signature only from non-residents of the community or county, but it is important to apply equal treatment to all non-customers once a policy is adopted.
Steps to Use in Obtaining a Thumbprint Signature
Tellers and other personnel should use the following procedures to obtain a presenter’s Thumbprint Signature:
Step 1: Obtain required identification from the presenter.
Step 2: Explain the following to the presenter:
“In order to protect the bank’s depositors, we require a Thumbprint Signature on the face of the check. The touch pad is not like an ink pad and will not stain hands or clothes. Our bank has joined other Nebraska financial institutions in implementing this program to eliminate check fraud.”
If necessary, demonstrate use of the pad by obtaining your own thumbprint. Rub your index finger with your thumb to show that the material quickly disappears. If the presenter refuses to provide the Thumbprint Signature, return the check to the presenter and explain that the bank will not cash the check.
Step 3: Request the Thumbprint Signature by stating the following:
“Please press your right thumb on this pad and then press the thumb onto the check here (pointing to the area of the check between the memo and signature lines).”
Obtain the presenter’s Thumbprint Signature between the memo line and signature line. If this is not possible, select a clear place on the face of the check away from all writing and printed information. If the presenter “drags” their thumb, request the Thumbprint Signature again and instruct the presenter to place the signature in a clear spot on the check.
Step 4: Record the identification information on the check and return the identification to the presenter.
Step 5: Process the transaction utilizing normal operating procedures.
If the presenter leaves the branch abruptly and leaves the identification or the check, immediately contact a supervisor or your security personnel. Tellers should document the time and date of the transaction and the presenter’s description. Tellers and officers should follow established documentation and reporting procedures regarding known or suspected fraudulent transactions.
Use of the Program at Drive-In Facilities
It is recommended that non-customers seeking to cash checks be required to enter the premises to complete their transaction and to affix their Thumbprint Signature to the face of the check. Some participants may elect to adopt policies providing for the use of Thumbprint Signature pads in drive-in facilities and others may elect to permit non-customers to cash checks through drive-in facilities only after normal banking hours.
How to Obtain Thumbprint Signature Pads
The Nebraska Bankers Association has arranged for a group purchase of Thumbprint Signature pads. All participating Nebraska financial institutions must place their orders through the NBA. Orders will be filled promptly.
Care of Touch Pads
Touch pads should be closed when they are not being used to prevent the pads from drying out. The pads, when cared for properly, will last up to 18 months or will produce 400 to 600 impressions before having to be replaced.
Reaction of Law Enforcement Authorities & Bank Regulators
Details of the Thumbprint Signature Program have been shared with the FBI, many local law enforcement authorities, and the bank regulatory agencies. The program receives widespread support from these and other groups.
Program Identification, Customer Awareness & Collateral Materials
A Thumbprint Signature logo has been developed and generic customer information materials are available for use in making customers and non-customers aware of an institution’s participation in the program. It is recommended that participants use a Thumbprint Signature decal on all entrances to banking facilities. Security professionals believe this early visibility of the program will act as a significant deterrent. Generic materials may be purchased from the Nebraska Bankers Association.
Notification to Business/Commercial Customers
It is recommended that all participating financial institutions write to their business/commercial customers at least two weeks prior to implementing the Thumbprint Signature Program. Letters and/or follow-up telephone calls should encourage these customers to notify their employees that a Thumbprint Signature will be required if the employees are not depository customers of the institution. Notification of the program is a courtesy to business/commercial customers and will assist in the process of making the policy known to larger numbers of non-customers who may seek to cash checks.
>>TopFor More Information Contact:
Senior Vice President
Nebraska Bankers Association / 233 South 13th Street, Suite 700 / PO Box 80008 / Lincoln, NE 68501-0008