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COBS 9.5 Record keeping and retention periods for suitability records


A3 firm to which SYSC 9 applies 3is required to keep orderly records of its business and internal organisation (see SYSC 9, General rules on record-keeping). Other firms are 3 required to take reasonable care to establish and maintain such systems and controls as are appropriate to their 3business (see SYSC 3, Systems and controls). The records may be expected to reflect the different effect of the rules in this chapter depending on whether the client is a retail client or a professional client: for example, in respect of the information about the client which the firm must obtain and whether the firm is required to provide a suitability report.


A1 firm must retain its records relating to suitability for a minimum of the following periods:

  1. (1)

    if relating to a pension transfer, pension opt-out or FSAVC, indefinitely;

  2. (2)

    if relating to a life policy,2 personal pension scheme 2or stakeholder pension scheme, five years;

  3. (3)

    if relating to MiFID or equivalent third country business, five years; and

  4. (4)

    in any other case, three years.


A firm need not retain its records relating to suitability if:

  1. (1)

    the client does not proceed with the recommendation; and

  2. (2)

    they do not relate to MiFID or equivalent third country business.