ICOBS 2.4 Record-keeping

The Senior Management Arrangements, Systems and Controls sourcebook contains high-level record-keeping requirements (see SYSC 3.2.20 R). These require firms to take reasonable care to make and retain adequate records of matters and dealings which are the subject of requirements and standards under the regulatory system, which includes this sourcebook.

This sourcebook does not generally have detailed record-keeping requirements: firms will need to decide what records they need to keep in line with the high-level record-keeping requirements and their own business needs.

Firms should bear in mind the need to deal with requests for information from the FSA as well as queries and complaints from customers which may require evidence of matters such as:

1. (a)

   the reasons for personal recommendations;

2. (b)

   what documentation has been provided to a customer; and

3. (c)

   how claims have been settled and why.