CONC 5B.5 Record keeping

1RTO firms are reminded of their obligations in SYSC 9.1.1R to keep orderly records, which must be sufficient to enable the FCA to monitor the firm’s compliance with the requirements of the regulatory system. Records which the FCA would consider to be sufficient to show compliance with the benchmarking requirements in CONC 5B include:

1. (1)

   point-in-time evidence of other benchmarking cash prices such as screengrabs or outputs of third party benchmarking data, together with evidence establishing the point in time to which it relates;

2. (2)

   evidence to show how the RTO firm took reasonable steps to ascertain whether the same item of goods or bundle of goods was available for sale by other retailers; and

3. (3)

   evidence to show how the RTO firm established that goods benchmarked against were comparable to those supplied by the RTO firm.