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. |
Handbook reference |
Subject of record |
Contents of record |
When record must be made |
Retention period |
Disclosable commission |
Each payment |
Date of payment |
6 years |
|
Indirect benefits given to an independent intermediary |
Each benefit |
Date from which benefit was conferred |
6 years |
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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 |
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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 |
|
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 |
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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 |
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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) |
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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) |
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Terms of business for: Pension transfer Pension opt-out FSAVC |
Each term of business provided and any amendments |
As soon as in force |
Indefinitely |
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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) |
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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) |
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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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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 |
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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 |
|
When the range changes |
6 years from the date on which the record is superseded by a more up-to-date record |
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Private customer's details for a pension transfer, pension opt-out, FSAVC |
Personal and financial circumstances |
On giving advice |
Indefinitely |
|
Private customer's details for a life policy, pension contract or stakeholder pension scheme |
Personal and financial circumstances |
On giving advice |
6 years |
|
Private customers details for any other case |
Personal and financial circumstances |
On giving advice |
3 years3 |
|
Private customer: Opt out or transfer from an OPS on an execution only basis |
Execution only transaction, no investment advice given |
Upon execution |
Indefinitely4 |
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Private customer: Suitability relating to a pension opt-out or transfer, or FSAVC |
Suitability letter |
After letter sent |
Indefinitely |
|
Private customer: Suitability relating to a life policy, pension contract, or stakeholder pension scheme |
Suitability letter |
After letter sent |
6 years |
|
Private customer:Suitability relating to any other case |
Suitability letter |
After letter sent |
3 years4 |
|
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 |
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Statistics of pension opt-out, pension transfer or FSAVC transactions involving private customers |
Separate records per customer |
On arranging the transaction |
Indefinitely |
|
Direct offer personal pension scheme |
Record of justification for promotion |
On making the promotion |
6 years4 |
|
The scope of basic advice which a firm'sappointed representative is permitted to give (including the range of stakeholder products on which each appointed representative advises.)11 |
The scope of basic advice each appointed representative is permitted to advise11 |
At the time an appointed representative is permitted to provide basic advice.11 |
6 years from the date on which the record is superseded by a more up-to-date record11 |
|
When a firm commences providing basic advice11 |
6 years from the date on which the record is superseded by a more up-to-date record11 |
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The range of stakeholder products on which a firm'sbasic advice to a private customer is based11 |
The range of stakeholder products on which a firm'sbasic advice to a private customer is based11 |
When a firm commences providing basic advice11 |
6 years from the date on which the advice is given11 |
|
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 |
|
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 |
|
Projections relating to a pension transfer or pension opt-out |
A projection provided to a customer |
As soon as proposal proceeds |
Indefinitely |
|
Projections relating to any other case |
A projection provided to a customer |
As soon as proposal proceeds |
3 years4 |
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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 |
|
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) |
|
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) |
|
Firm effecting or carrying out pure protection contracts which are life policies9 |
Adequate details of information provided |
After information provided |
6 years |
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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 |
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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 |
|
Firm aggregating a number of client orders that include a customer order |
Intended basis of allocation |
As soon as is practicable |
3 years |
|
Aggregation of one or more customer orders and an own account order |
Intended basis of allocation |
Before the transaction is executed |
3 years |
|
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 |
|
Re-allocation |
Basis and reason for any re-allocation |
At the time of the re-allocation |
3 years |
|
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) |
|
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 |
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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) |
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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) |
|
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) |
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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) |
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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) |
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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) |
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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 |
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Substantiation of a research recommendation |
The basis of substantiation of a research recommendation |
When producing the research recommendation |
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Periodic disclosure of arrangements entered into |
Details of the receipt of appropriate execution or research goods and services |
Date of provision of disclosure |
5 years (from when the disclosure is provided) |
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Confirmation of transaction |
Information provided |
On dispatch of confirmation |
3 years |
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Periodic statements |
Copy of any periodic statement |
On date on which it is provided |
3 years |
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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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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 |
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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 |
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Aggregated customer orders on behalf of a number of schemes |
The intended basis of allocation |
As soon as is practicable |
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Aggregated orders of schemes under its management and own account orders |
The intended basis of allocation |
Before the transaction is executed |
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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 |
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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) |
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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 |