The Senior Management Arrangements, Systems and Controls sourcebook contains high-level record keeping requirements – see the Senior Management, Systems and Controls chapter of this manual for further information.

There are no detailed record-keeping requirements in ICOBS. 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, however, bear in mind that to deal with requests for information from the FCA and their own customers, they may require evidence such as:

  • the reasons for a personal recommendation;
  • documentation provided to a customer; and/or
  • how claims have been settled and why.

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