Home FCA Handbook COBS COBS 9A COBS 9A.4 Record keeping and retention periods for suitability records
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COBS 9A.4 Record keeping and retention periods for suitability records

Record keeping: MiFID business and insurance-based investment products

01/10/2018G

A firm to which SYSC 9 applies is required to keep orderly records of its business and internal organisation (see SYSC 9 (General rules on record-keeping)). The records may be expected to reflect the different effect of the requirements in this chapter depending on whether the client is a retail client or a professional client; for example, in respect of information about the client which the firm must obtain and whether the firm is required to provide a suitability report.

01/10/2018G

A firm should refer to SYSC 3.2 and SYSC 3.3 (for insurers and managing agents) and SYSC 9 (for other firms) for its obligations in relation to record keeping.

[Note: article 16(7) of MiFID]

Record keeping: MiFID business

23/10/2025R

  1. In complying with the requirements in SYSC 9, a firm to which those rules apply must keep a record of:

  2. (1) its compliance with the rules in COBS 9A.2 and COBS 9A.3 applicable to MiFID, equivalent third country or optional exemption business in respect of each assessment of suitability it undertakes;

  3. (2) its compliance with COBS 9A.3.6R in informing each client to which it provides investment advice whether it will provide a periodic assessment of suitability; and

  4. (3) in respect of investment advice provided to a retail client:

    1. (a) the time and date on which the investment advice was provided;

    2. (b) the financial instrument that was recommended; and

    3. (c) the suitability report provided to the client.

Retention of records: insurance-based investment products

05/04/2024R
  1. (1)

    Without prejudice to the application of the General data protection regulation, a firm must maintain records of the assessment of suitability in relation to insurance-based investment products undertaken in accordance with COBS 9A.2.1R and COBS 9A.2.16R.

  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 must be retained for at least the duration of the relationship between the firm and the client.

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

Record-keeping obligations for the assessment of suitability: insurance-based investment products

05/04/2024R

In the case of an assessment of suitability undertaken in accordance with COBS 9A.2.1R and COBS 9A.2.16R in relation to insurance-based investment products, the record maintained under COBS 9A.4.3R must include the following:

  1. (1)

    the result of the suitability assessment;

  2. (2)

    the recommendation made to the client and the statement provided in accordance with COBS 9A.3.3AR;

  3. (3)

    any changes made by the firm with regard to the suitability assessment, in particular any change to the client’s risk tolerance;

  4. (4)

    any changes to the underlying investment assets.

[Note: article 19(2) of the IDD Regulation]