Why are there almost no record-keeping requirements in the new ICOBS?
The only detailed requirement we have kept is for you to keep a record of whether you have chosen to sell pure protection contracts under our Conduct of Business Sourcebook (COBS) or ICOBS. We have deleted the other requirements because we think Principle 3 and SYSC 3.2.20R in our Senior Management Arrangements, Systems and Controls sourcebook are enough – these require you to take reasonable care to make and keep adequate records. Guidance in ICOBS 2.4 says you should bear in mind the need to deal with requests for information from us and also customers’ queries and complaints, which may require evidence of the reasons for advice given to a particular customer, what documents they have been given and how claims have been settled and why.
