CFA Level I Exam · Guidance for Standard V: Investment Analysis, Recommendations, and Actions

CFA Standard V(C) Record Retention Explained

Updated 7 October 2026 · Fact-checked

Standard V(C) requires members and candidates to develop and maintain appropriate records to support their investment analyses, recommendations, actions and other investment-related communications with clients and prospects. The Handbook recommends keeping them at least seven years, longer if local rules require. Records generally belong to the firm, not the individual.

Understand Standard V(C): Record Retention

Standard V(C) is the last of the three Standard V rules. V(A) covers diligence and a reasonable basis. V(B) covers communication with clients. V(C) covers the paper trail that proves you did V(A) and V(B).

The official wording says members and candidates must develop and maintain appropriate records to support their investment analyses, recommendations, actions, and other investment-related communications with clients and prospective clients. Records let a firm show regulators, clients and employers what was recommended, why, and what was said.

The records can be paper or electronic. Examples include research notes, models, spreadsheets, client communications, emails, trade tickets, and the data that supported a recommendation. If the firm keeps records electronically, you should make sure they are kept in a form that can be retrieved.

The Handbook's guidance is to keep records for at least seven years. This is a recommended minimum in the Handbook. If local law or regulation requires a longer period, follow the longer period. Also, records are generally the property of the firm, not the individual analyst.

That ownership point matters when you change jobs. You cannot take original records with you. You may keep copies only if the firm permits it and doing so does not breach confidentiality. When you join a new firm, you may recreate your analysis from public information and non-confidential knowledge or memory. You should not use confidential client information from the old firm, and you should not rely on the old firm's records.

Key formulas to remember

Standard V(C) core duty: Develop and maintain appropriate records to support investment analyses, recommendations, actions and other investment-related communications with clients and prospects; Applies to all of these, not only written research reports.
Retention period: Keep records for at least 7 years (longer if local law requires); The Handbook recommends at least seven years; if local law requires a longer period, follow the longer one.
Ownership rule: Records are generally the property of the firm; Departing employees should not take originals; copies need firm permission.
Recordkeeping responsibility: Firm usually holds the records; where there is no firm, the member must retain them; Independent practitioners and those without firm systems must retain records themselves.

How to solve Standard V(C): Record Retention questions

Use this method for any Standard V(C) question.

1Identify what was created or communicated: research, model, recommendation, trade rationale, or client communication.
2Ask whether the item supports an analysis, recommendation, action or client communication. If yes, it needs a record.
3Check who holds the records. Under a firm, the firm owns them. For an independent practitioner, the member must keep them.
4Check the retention period: at least seven years, or longer if local law demands. If local law requires longer, follow the longer period.
5If the member is leaving a firm, decide whether they are taking originals (violation) or copies without permission (violation), or rebuilding work from public information and non-confidential knowledge or memory (acceptable). Confidential client information from the old firm should not be used.
6Check the form: paper or electronic is fine if the records are retrievable.
7Pick the option that creates or preserves records and meets the retention period. Reject options that discard records early or move them without permission.

Quickest way: Three-check shortcut for V(C)

When to use it: Use when you have about 90 seconds and the question is about records, retention, or changing firms.

Check 1: Is a record being created or kept? Maintaining records is the correct direction.
Check 2: Is the period at least seven years, or longer if local law says so?
Check 3: Whose records are they? Firm-owned means do not take them without permission.
Eliminate any option that destroys records before seven years without a reason, ignores a longer local requirement, or takes originals to a new firm.

Common mistakes in Standard V(C): Record Retention

Treating seven years as a legal requirement everywhere.
Students remember the number and forget it is a Handbook recommendation.
Fix: Say 'at least seven years recommended; follow longer local requirements'.
Thinking an analyst owns the models and notes they built.
Personal effort feels like personal ownership.
Fix: Remember that records are generally firm property. Leaving analysts need permission to take copies.
Taking client files or originals to a new employer.
Students want continuity for clients and research.
Fix: Do not take originals. Rebuild from public information and non-confidential knowledge, and respect confidentiality.
Assuming only formal research reports need records.
Reports feel more important than emails or notes.
Fix: Remember that all investment-related communications with clients and prospects, and the support for actions, are covered.
Confusing V(C) with V(A) or V(B).
All three are in Standard V.
Fix: V(A) is about the work behind a recommendation, V(B) is about telling clients, and V(C) is about keeping the evidence.

Worked examples

Example 1

An analyst works at a firm in a country whose rules require records to be kept for at least five years. The analyst's recommendation records are now six years old. Under Standard V(C) and the Handbook's guidance, what should the analyst do? A. Give the records to the client and keep no copy. B. Keep the records, as the Handbook recommends at least seven years. C. Discard the records immediately.

Show the solution

The records support past recommendations, so Standard V(C) applies.
The Handbook recommends keeping records for at least seven years. This is a recommendation, not a fixed legal rule. If local law requires a longer period, the longer period governs.
The local requirement is five years, which is shorter than the recommended seven years. Where two periods apply, the longer one governs, so the shorter local requirement does not permit disposal.
The records are six years old, which is under seven, so they should still be kept.
Option A leaves the firm without records. Option C discards the records early.

Answer: B

Example 2

A portfolio manager leaves Firm X for Firm Y. She wants her old research files and models so she can continue covering the same companies. Which action is most appropriate under the Standards? A. Copy the files on her last day without asking. B. Take the original files and tell Firm X later. C. Leave the originals, and at Firm Y rebuild her analysis from public information and non-confidential knowledge.

Show the solution

This scenario is mainly about Standard V(C), but it also draws on confidentiality (Standard III(E)) and loyalty to the employer (Standard IV(A)).
Under V(C), records are generally the property of Firm X.
Taking originals, or copying them without permission, treats firm property as personal property. Copies are acceptable only if Firm X permits it and confidentiality is respected.
Option A is copying without permission, which is not acceptable.
Option B takes the originals, which leaves Firm X without its required records.
Option C leaves the records in place and uses public information and non-confidential knowledge to build new records at Firm Y.

Answer: C

Exam tips

Expect questions on departing employees. The safe answer leaves originals with the old firm and rebuilds from public information and non-confidential knowledge.
Remember 'at least seven years' and 'longer if local law requires'. If law requires longer, follow the longer period.
Records can be electronic. A question will not penalize electronic storage if the records are retrievable.
Spot the V(C) trigger: someone is discarding, moving or failing to create records.
With three options and no penalty for wrong answers, always answer. Eliminate the option that breaks ownership or retention first.

Practice questions from Guidance for Standard V: Investment Analysis, Recommendations, and Actions

Standard V(C): Record Retention in other exams

The same ground in other exams, if you are preparing for more than one or want another angle on it.

Standard V(C): Record Retention: frequently asked questions

How long must records be kept under CFA Standard V(C)?

The Handbook recommends at least seven years. If local law or regulation requires a longer period, follow that longer period.

Who owns the records under Standard V(C)?

Records are generally the property of the firm, not the individual analyst. Where a member has no firm, the member must retain the records personally.

What can I take when I change firms?

Do not take original records. You may keep copies only if the firm permits it and confidentiality is respected. At the new firm, build your work from public information and non-confidential knowledge, not confidential client information.

What records does Standard V(C) cover?

It covers records supporting investment analyses, recommendations, actions and other investment-related communications with clients and prospective clients. This includes models, notes and emails, in paper or electronic form.