COB Sch 1 Record keeping requirements

The aim of the guidance in the following table is to give the reader a quick overall view of the relevant record keeping requirements.

It is not a complete statement of those requirements and should not be relied on as if it were.

COB 2.2.20 R (1)

Periodic reports

Details of soft commission agreements

Date of periodic statement

3 years (from termination of relevant soft commission agreement)

COB 2.2.20 R (2)

Disclosable commission

Each payment

Date of payment

6 years

COB 2.2.20 R (3)

Indirect benefits given to an independent intermediary

Each benefit

Date from which benefit was conferred

6 years

COB 3.7.1 R

Non-real time financial promotion - each: Pension transfer Pension opt-out FSAVC

Name of individual who confirmed compliance or approved the financial promotion. See COB 3.7.2 G (1) for other contents

Date of confirmation or approval

Indefinitely

COB 3.7.1 R

Non-real time financial promotion - each: Life policy Pension contract Stakeholder pension scheme

Name of individual who confirmed compliance or approved the financial promotion. See COB 3.7.2 G (1) for other contents

Date of confirmation or approval

6 years

COB 3.7.1 R

Non-real time financial promotion - any other case

Name of individual who confirmed compliance or approved the financial promotion. See COB 3.7.2 G (1) for other contents

Date of confirmation or approval

3 years

COB 4.1.16 R

Classification of each client - if relevant to: Pension transfers Pension opt-outs FSAVCs

Sufficient information to support classification

When the client relationship begins or upon re-classification , to include annual review where necessary

Indefinitely

COB 4.1.16 R

Classification of each client - if relevant to: Life policies Pension contracts

Sufficient information to support classification

When the client relationship begins or upon re-classification , to include annual review where necessary

6 years (from end of client relationship)

COB 4.1.16 R

Classification of each client - any other case

Sufficient information to support classification

When the client relationship begins or upon re-classification , to include annual review where necessary

3 years (from end of client relationship)

COB 4.2.14 R

Terms of business for: Pension transfer Pension opt-out FSAVC

Each term of business provided and any amendments

As soon as in force

Indefinitely

COB 4.2.14 R

Terms of business for: Life policy Pension contract Stakeholder pension scheme

Each term of business provided and any amendments

As soon as in force

6 years (from the date on which the customer ceases to be a customer)

COB 4.2.14 R

Terms of business: any other case

Each term of business provided and any amendments

As soon as in force

3 years (from the date on which the customer ceases to be a customer)

COB 4.3.11 R10

Fees and commission statement10

Fees and commission statement10

At the time a firm sets its fees and commission statements10

6 years from the date on which the record is superseded by a more up-to-date record10

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COB 5.1.6C R10

The scope and range (or ranges) of advice each of the firm'sappointed representatives is permitted to give10

The scope of advice and range (or ranges) of packaged products in respect of which an appointed representative is permitted to advise.10

At the time the appointed representative is appointed and on each change to the permitted scope and range (or ranges) of advice10

6 years from the date on which the record is superseded by a more up-to-date record10

COB 5.1.6E R10

The scope of the advice on investments a firm provides and its range of packaged products10

The scope of the advice on investments a firm provides and its range of packaged products10

At the time the record changes10

6 years from the date on which the record is superseded by a more up-to-date record10

COB 5.1.6F R

Range of packaged products

Range of packaged products

When the range changes

6 years from the date on which the record is superseded by a more up-to-date record

COB 5.2.9 R

Private customer's details for a pension transfer, pension opt-out, FSAVC

Personal and financial circumstances

On giving advice

Indefinitely

COB 5.2.9 R

Private customer's details for a life policy, pension contract or stakeholder pension scheme

Personal and financial circumstances

On giving advice

6 years

COB 5.2.9 R

Private customers details for any other case

Personal and financial circumstances

On giving advice

3 years3

COB 5.2.10 R

Private customer: Opt out or transfer from an OPS on an execution only basis

Execution only transaction, no investment advice given

Upon execution

Indefinitely4

COB 5.3.19A R

Private customer: Suitability relating to a pension opt-out or transfer, or FSAVC

Suitability letter

After letter sent

Indefinitely

COB 5.3.19A R

Private customer:

Suitability relating to a life policy, pension contract, or stakeholder pension scheme

Suitability letter

After letter sent

6 years

COB 5.3.19A R

Private customer:Suitability relating to any other case

Suitability letter

After letter sent

3 years4

COB 5.3.25 R

Private customer instructs a pension opt-out or transfer contrary to advice of firm

Firm's advice to customer and customer instructions to firm to proceed

Upon execution

Indefinitely

COB 5.3.26 R (2)

Statistics of pension opt-out or pension transfer transactions

Details of the notification required by COB 5.3.26 R (1) and COB 5.3.26 R (1A)

On making the notification

Indefinitely

COB 5.3.27 R

Statistics of pension opt-out, pension transfer or FSAVC transactions involving private customers

Separate records per customer

On arranging the transaction

Indefinitely

COB 5.3.28 R

Direct offer personal pension scheme

Record of justification for promotion

On making the promotion

6 years4

COB 6.5.52

Non-tradable life policy

Sufficient information to support classification that own policies are not tradable

Upon assessment of the firm's position and every 6 months thereafter

Indefinitely2

COB 6.6.19

Projections relating to a life policy, pension contract or stakeholder pension scheme

A projection provided to a customer

As soon as proposal proceeds

6 years

COB 6.6.19

Projections relating to a pension transfer or pension opt-out

A projection provided to a customer

As soon as proposal proceeds

Indefinitely

COB 6.6.19

Projections relating to any other case

A projection provided to a customer

As soon as proposal proceeds

3 years4

COB 6.7.47

Cancellation or withdrawal:

Pension transfer, opt-out or FSAVC

To include a copy of any receipt of notice issued to the customer and the customer's original notice instructions

Upon notice of cancellation or withdrawal being served to firm, its appointed representative or agent

Indefinitely

COB 6.7.47

Cancellation or withdrawal:

Life policy, pension contract or stakeholder pension scheme

To include a copy of any receipt of notice issued to the customer and the customer's original notice instructions

Upon notice of cancellation or withdrawal being served to firm, its appointed representative or agent

6 years (from the date when the firm became aware that notice of cancellation had been served)

COB 6.7.47

Cancellation or withdrawal:

Any other case

To include a copy of any receipt of notice issued to the customer and the customer's original notice instructions

Upon notice of cancellation or withdrawal being served to firm, its appointed representative or agent

3 years (from the date when the firm became aware that notice of cancellation had been served)

COB 6.8.18 (1)

Firm effecting or carrying out pure protection contracts

which are life policies9

Adequate details of information provided

After information provided

6 years

COB 7.7.6 E (4)

Allocation of aggregated transactions in a series of transactions all executed within one business day

The time each transaction is made

On executing an aggregated transaction

COB 7.7.14 R (1)

An aggregated transaction that includes a customer order

Identity of each customer; whether transaction is in whole or in part for discretionary managed investment portfolio and any relevant proportions

On executing an aggregated transaction

3 years

COB 7.7.14 R (2)

Firm aggregating a number of client orders that include a customer order

Intended basis of allocation

As soon as is practicable

3 years

COB 7.7.14 R (3)

Aggregation of one or more customer orders and an own account order

Intended basis of allocation

Before the transaction is executed

3 years

COB 7.7.16 R

Allocation of an aggregated transaction that includes the execution of a customer order

Date and time of allocation; relevant designated investment; identity of each customer and market counterparty and the amount allocated to each customer and market counterparty; agreement to extend allocation period for intermediate customers under COB 7.7.6 E (2)(b)

Date on which the order is allocated

3 years

COB 7.7.17 R

Re-allocation

Basis and reason for any re-allocation

At the time of the re-allocation

3 years

COB 7.9.7 R

Lending to private customers

Assessment of a private customer's financial standing and the date when the information was last updated/checked

Upon assessment

3 years (from the date on which the credit arrangement ceased)

COB 7.12.3 R and COB 7.12.6 E

Customer orders

Customer's name (or other designation)/account number; date and time of receipt or decision by the firm to deal; who received the order or made the decision to deal; the designated investment; the number of/total value of the designated investment including any price limit; whether sale or purchase; any other instructions received.

When the order arises

3 years (after the date of completion of the transaction)31

COB 7.12.3 R and COB 7.12.6 E

Execution of a transaction by a firm

Name/other designation of client (if any); name of counterparty (if known); date and time of execution; who executed the transaction; the designated investment; number of/total value of the designated investment; price and other significant terms; whether sale or purchase

When the firm executes a transaction

3 years (after the date of completion of the transaction)

COB 7.12.3 R and COB 7.12.6 E

The firm instructs another person to deal

Name of the person instructed; terms of instruction and date and time of instruction

When the firm instructs another person to deal

3 years (after the date of completion of the transaction)

COB 7.13.11 R (1)(a)

Personal account dealing

The restrictions upon pa dealing and the basis upon which any permission to deal is made

Whenever the restrictions are placed and from the date of consent

3 years (from the date that the restrictions or basis were communicated to the employee)

COB 7.13.11 R (1)(b)

Personal account dealing

Each permission to deal given by the firm

From the date of consent

3 years (from the date that the permission was given)

COB 7.13.11 R (1)(c)

Personal account dealing

Each notification of the transaction made by the employee to the firm

From the date of notification

3 years (from the date that the notification was made)

COB 7.13.11 R (1)(d)

Personal account dealing

The basis upon which the firm has determined that an employee will not be involved in, or have access to information about, the firm's designated investment business

On determining the basis

3 years (from the date on which the individual ceases to be an employee)

COB 7.16.5 R (2)(b)

Policy for managing conflicts of interest arising as a result of publication or distribution of investment research

Details of the policy

When adopted

Until three years after the policy ceases to have effect

Information provided

On dispatch of confirmation

3 years

COB 8.2.9 R

Periodic statements

Copy of any periodic statement

On date on which it is provided

3 years

COB 8A.5.1 R8

Claim under a long-term care insurance contract8

Details of the claim; a record of each communication with the policyholder, including the date it was made; the date the claim was settled or rejected.8

As soon as practicable8

The duration of the claim and 6 years after the insurer's obligations to the policyholder under the long-term care insurance contract have ceased 8

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COB 10.3.3 E (3)

Allocation of aggregated transactions in a series of transactions all executed within one business day

The time each transaction is made

On executing an aggregated transaction

COB 10.3.5 R (1)

Aggregated transaction on behalf of a number of schemes

Identity of schemes concerned, whether transaction was effected proportionally or if a stated proportion was effected for some schemes under its management

On executing an aggregated transaction

COB 10.3.5 R (2)

Aggregated customer orders on behalf of a number of schemes

The intended basis of allocation

As soon as is practicable

COB 10.3.5 R (3)

Aggregated orders of schemes under its management and own account orders

The intended basis of allocation

Before the transaction is executed

COB 10.7.6 R

Periodic statements in relation to unregulated collective investment scheme

Operator to retain copy of any periodic statement it has provided to participants in the scheme

On providing the periodic statement

3 years

COB 11.7.1 R

PTP appointment

Details of the written delegation to a PTP, PTP's undertaking under COB 11.6.1 R (3) and of any variation in the documentation

On the PTP's appointment

3 years (from date of end of the PTP's appointment)

Trustee firm following (or rejecting) proper advice in relation to exercise of power of investment

Evidence of compliance with COB 11.8.5 R

Date on which proper advice is received

3 years7