Nature of obligation Type of record Summary of content Legislative reference

Client assessment

Information to clients Content as provided for under Article 24(4) of Directive 2014/65/EU and Articles 44 to 51 of this Regulation Article 24(4) of Directive 2014/65/EU Articles 44 to 51 of this Regulation

Client agreements Records as provided for under Article 25(5) of Directive 2014/65/EU Article 25(5) Directive 2014/65/EU Article 58 of this Regulation

Assessment of suitability and appropriateness Content as provided for under paragraphs 2 and 3 of Article 25 of Directive 2014/65/EU and Articles 54, 55 and 60 of this Regulation Article 25(2) and (3) of Directive 2014/65/EU Articles 54, 55 and 56 of this Regulation

Order handling

Client order-handling – Aggregated transactions Records as provided for under Articles 67 to 70 of this Regulation Articles 24(1) and 28(1) of Directive 2014/65/EU Articles 67 to 70 of this Regulation

Aggregation and allocation of trans-actions for own account Records as provided for under Article 69 of this Regulation Articles 24(1) and 28(1) of Directive 2014/65/EU Article 69 of this Regulation

Client Orders and transactions

Record keeping of client orders or decision to deal Records as provided for under Article 74 of this Regulation Article 16(6) of Directive 2014/65/EU Article 74 of this Regulation

Record keeping of transactions and order processing Records as provided for under Article 75 of this Regulation Article 16(6) of Directive 2014/65/EU Article 75 of this Regulation

Reporting to clients

Obligation in respect of services provided to clients Contents as provided for under Articles 59 to 63 of this Regulation Paragraphs 1 and 6 of Article 24 and paragraphs 1 and 6 of Article 25 of Directive 2014/65/EU Articles 59 to 63 of this Regulation

Safeguarding of client assets

Client financial instruments held by an investment firm Records as provided for under Article 16(8) of Directive 2014/65/EU and under Article 2 of Commission Delegated Directive (EU) 2017/593 Article 16(8) of Directive 2014/65/EU Article 2 of Delegated Directive (EU) 2017/593

Client funds held by an investment firm Records as provided for under Article 16(9) of Directive 2014/65/EU and under Article 2 of Delegated Directive (EU) 2017/593 Article 16(9) of Directive 2014/65/EU Article 2 of Delegated Directive (EU) 2017/593

Use of client financial instruments Records provided for under Article 5 of Delegated Directive (EU) 2017/593 Paragraphs 8, 9 and 10 of Article 16 of Directive 2014/65/EU Article 5 of Delegated Directive (EU) 2017/593

Communication with clients

Information about Costs and associated charges Contents as provided for under Article 50 of this Regulation Article 24(4), point (c) of Directive 2014/65/EU Article 50 of this Regulation

Information about the investment firm and its services, financial instruments and safe-guarding of client assets Content as provided for under Articles 47, 48 and 49 of this Regulation Article 24(4) of Directive 2014/65/EU Articles 47, 48 and 49 of this Regulation

Information to clients Records of communication Article 24(3) of Directive 2014/65/EU Article 46 of this Regulation

Marketing communications (except in oral form) Each marketing communication issued by the investment firm (except in oral form) as provided under Articles 44 and 46 of this Regulation Article 24(3) of Directive 2014/65/EU Articles 44 and 46 of this Regulation

Investment advice to retail clients (i) The fact, time and date that investment advice was rendered and (ii) the financial instrument that was recommended (iii) the suitability report provided to the client Article 25(6) of Directive 2014/65/EU Article 54 of this Regulation

Investment research Each item of investment research issued by the investment firm in a durable medium Article 24(3) of Directive 2014/65/EU Articles 36 and 37 of this Regulation

Organisational requirements

The firm’s business and internal organisation Records as provided for under Article 21(1), point (f) of this Regulation Paragraphs 2 to 10 of Article 16 of Directive 2014/65/EU Article 21(1), point (f) of this Regulation

Compliance reports Each compliance report to management body Article 16(2) of Directive 2014/65/EU Article 22(2), point (c) and Article 25(2) of this Regulation

Conflict of Interest record Records as provided for under Article 35 of this Regulation Article 16(3) of Directive 2014/65/EU Article 35 of this Regulation

Inducements The information disclosed to clients under Article 24(9) of Directive 2014/65/EU Article 24(9) of Directive 2014/65/EU Article 11, 12 and 13 of Delegated Directive (EU) 2017/593

Risk management reports Each risk management report to senior management Article 16(5) of Directive 2014/65/EU Article 23(1), point (b) and Article 25(2) of this Regulation

Internal audit reports Each internal audit report to senior management Article 16(5) of Directive 2014/65/EU Article 24 and Article 25(2) of this Regulation

Complaints-handling records Each complaint and the complaint handling measures taken to address the complaint Article 16(2) of Directive 2014/65/EU Article 26 of this Regulation