In order to have a federal criminal background check fingerprints are required as they are used to scan the FBI database. The regulation also states that if you are an institution registered with the NMLS you will be obtaining the background checks through the NMLS (which requires fingerprints). And if you are not you will be obtaining them through law enforcement or a commercial servicer – but they will still need to e similar to the NMLS. So, yes, you will need to do fingerprinting.
p. 11378
The Bureau disagrees with some
commenters’ assertions that the
provisions would result in significantly
higher compliance burden compared
with existing requirements. For
example, as further discussed below, a
depository institution will not be
required to obtain multiple criminal
background reports or undertake
multiple reviews of a criminal
background report. Instead, the required
criminal background report is the same
report the institution already obtains
under Regulation G after submission of
the individual’s fingerprints to the
NMLSR (12 CFR 1007.103(d)(1)(ix) and
1007.104(h)).