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COBS 10A.7 Record keeping and retention periods for appropriateness records

03/01/2018G

A firm is required to keep orderly records of its business and internal organisation, including all services and transactions undertaken by it. The records may be expected to include the client information a firm obtains to assess appropriateness and should be adequate to indicate what the assessment was.

Record keeping: MiFID business

23/10/2025R

(1) A firm must maintain records of the appropriateness assessments it undertakes.

  1. (2)

     The records maintains under (1) must include:

    1. (a)

       the result of the appropriateness assessment

    2. (b)

       any warning given to a client:

      1. (i)

         that an investment service or product had been assessed as potentially inappropriate for them; or

      2. (ii)

         that the client did not provide sufficient information to enable the firm to undertake an appropriateness assessment;

    3. (c)

       whether the client asked to proceed with a transaction despite being given a warning in (b); and

    4. (d)

       if applicable, whether the firm accepted the client's request to proceed with a transaction despite being given a warning in (b).

Record keeping: insurance-based investment products

05/04/2024R
  1. (1)

    Without prejudice to the application the General data protection regulation, a firm must maintain records of the assessment of appropriateness undertaken in accordance with COBS 10A.2.1R and COBS 10A.2.2R in relation to an insurance-based investment product.

  2. (2)

    The records maintained under (1) must include the information obtained from the client and any documents agreed with the client, including documents that set out the rights of the parties and the other terms on which the firm will provide services to the client.

  3. (3)

    The records in (1) must be retained for at least the duration of the relationship between the firm and the client.

  4. (4)

    The record in (1) must also include the following:

    1. (a)

      the result of the appropriateness assessment;

    2. (b)

      any warning given to the client where the insurance-based investment product was assessed as potentially inappropriate for the client, whether the client asked to proceed with concluding the policy despite the warning and, where applicable, whether the firm accepted the client’s request to proceed with concluding the policy;

    3. (c)

      any warning given to the client where the client did not provide sufficient information to enable the firm to assess the appropriateness of the insurance-based investment product, whether the client asked to proceed with concluding the policy despite the warning and, where applicable, whether the firm accepted the client’s request to proceed with concluding the policy.

[Note: article 19(1) and (3) of the IDD Regulation]

Record keeping: MiFID business and insurance-based investment products

01/10/2018G

A firm should refer to SYSC 3.3 (for insurers and managing agents) and SYSC 9 (for other firms) for its obligations in relation to record keeping. These provisions require records kept for the purposes of this chapter to be retained for a period of at least five years.