Level III Core · Guidance for Standard V: Investment Analysis, Recommendations, and Actions

Standard V(C) Record Retention for CFA Level III

Updated 9 October 2026 · Fact-checked

Standard V(C) requires members and candidates to develop and maintain appropriate records that support their investment analyses, recommendations, actions and other investment-related communications with clients and prospective clients. The Handbook recommends keeping records for at least seven years, absent a regulatory requirement. Records belong to the firm.

Understand Standard V(C) Record Retention

Standard V(C) is about proof. If a client, regulator or your employer questions an action you took, your records show what you did and why. Without records, you cannot show that your work had a reasonable basis or that you communicated fairly.

The standard covers more than research reports. It covers the analysis behind a recommendation, the recommendation itself, the action taken, and communications with clients and prospects. This includes notes, models, emails, messages and meeting notes that support those items.

The Standards of Practice Handbook recommends keeping records for at least seven years where no regulation requires a period. Treat seven years as a minimum recommended period, not a ceiling. If local law requires a longer period, follow the law. If local law sets a shorter period, the seven-year recommendation still applies as the stricter practice, in the spirit of Standard I(A), which requires you to follow the stricter of law and the Code and Standards.

Records are the property of the firm, not the individual. When you leave a firm, you do not take original records with you without permission. You may keep copies only if the firm allows it, and you must still respect client confidentiality. Your new firm cannot rely on old records you took unless your former employer agreed.

Electronic communications are a growing issue. Emails, texts and social media posts that relate to investment advice or actions are records. The firm should have a policy on which channels are acceptable and how messages are captured and stored. Members should use approved channels and keep business communication within them.

Key rules to remember

Core duty: Develop and maintain appropriate records that support analyses, recommendations, actions and client communications; Applies to both firm-created and member-created records relating to investment work.
Recommended retention period: At least 7 years in the absence of a regulatory requirement (longer if local law requires); The Handbook recommends this period. Where law requires a longer period, follow the law.
Record ownership: Records created as part of employment = property of the firm; A departing member does not take originals without the employer's permission.
Electronic communications: Business-related emails, texts and social posts = records to be retained; Use firm-approved channels and follow the firm's capture and storage policy.
Law link: Longer local law period: follow the law. Shorter local law period: keep at least 7 years as the stricter practice; Standard I(A) requires following the stricter of law and the Code and Standards. A shorter local period does not remove the seven-year recommendation.

How to solve Standard V(C) Record Retention questions

Use this method on any Standard V(C) vignette or constructed-response question.

1Identify what the item is: analysis, recommendation, action, client communication, or supporting data.
2Ask whether it relates to investment work. If yes, it should be kept as a record.
3Check who created or owns the record. Work done for the firm is firm property.
4Check the retention period: the Handbook recommends at least seven years, or longer if local law requires it.
5Check the format. Electronic messages, notes and models count, not just formal reports.
6Decide whether the member complied. Look for missing records, deleted messages, or taken files.
7State the action needed in the fewest words: keep records, use approved channels, return or seek permission for files.
8Link your answer to the Standard by name, V(C), and give the reason in one line.

Quickest way: Four-question check

When to use it: Use this when you have about a minute for an item set question on record keeping.

Is it investment-related? If yes, it must be kept.
Is the retention at least the recommended seven years, or the longer legal period?
Is the record held by the firm, not taken personally?
Was the communication on an approved, captured channel?
The violation is usually the answer that fails one of these four checks.

Common mistakes in Standard V(C) Record Retention

Saying records need to be kept for exactly seven years.
Students memorise the number without the wording.
Fix: Say the Handbook recommends at least seven years, and longer if local law requires it.
Thinking a departing member may take their research files.
The work feels personal because the member wrote it.
Fix: Records belong to the firm. Take copies only with employer permission and respect confidentiality.
Treating only formal reports as records.
Students think of published research.
Fix: Include models, notes, emails, texts and messages that support analysis, advice or actions.
Ignoring informal electronic messages.
Texts and chats feel casual.
Fix: If a message relates to investment advice or action, it is a record and should be captured through approved channels.
Confusing V(C) with V(A) or V(B).
All three sit in Standard V.
Fix: V(A) is about diligence and reasonable basis, V(B) is about communication, V(C) is about keeping the evidence.
Treating a shorter local retention period as a reason to keep records for less than seven years.
Students forget that Standard I(A) points to the stricter of the law and the Code and Standards.
Fix: Say the Handbook recommends at least seven years where no regulation requires a period. Follow a longer legal period. If the law is shorter, keep seven years as the stricter practice.

Worked examples

Example 1

An analyst at a global asset manager is leaving to join a competitor. Before leaving, she copies her valuation models and client recommendation files to a personal drive. Local law requires records to be kept for five years. Does her action comply with Standard V(C)? What should she do about retention, and which other Standard is also involved?

Show the solution

The models and recommendation files support investment analyses and actions. They are records under V(C).
Records created in the course of employment are the property of the firm.
Copying them to a personal drive without the employer's permission removes them from the firm's control. This is inconsistent with V(C), which expects records to be maintained and kept by the firm. The copying also risks client confidentiality, which implicates Standard III(E), Preservation of Confidentiality.
On retention, local law requires five years, but the Handbook recommends at least seven years. Seven years is the stricter period, so it should be kept, in the spirit of Standard I(A).
The firm, not the departing analyst, holds the records. She should leave the originals with the firm, which keeps them for at least seven years.

Answer: No. Copying the files breaches V(C) and also III(E) on confidentiality. The firm, not the departing analyst, holds the records. It should keep them for at least seven years, the stricter of the Handbook recommendation and the five-year local law.

Example 2

A portfolio manager sends buy recommendations to clients through a personal messaging app. The firm's policy requires all client communication to use its archived email system. Three years later, a client disputes a recommendation and the manager cannot produce the messages. Which statement is most consistent with Standard V(C)?

Show the solution

Messages recommending purchases are client communications and support actions, so they are records.
The firm requires an archived channel. The manager used a personal app outside it.
Because the messages were not captured, the manager cannot show what was communicated.
The fix is to use approved channels, or to ensure business messages are captured and retained, with the Handbook recommending at least seven years.

Answer: The manager failed to maintain appropriate records. Business communications must go through the firm's approved, archived channels and be retained, with the Handbook recommending at least seven years.

Exam tips

Use the phrase the Handbook recommends at least seven years, with longer if local law requires it.
Remember that records belong to the firm, so departing employees need permission.
Treat electronic messages as records. Expect vignettes with texts or social media.
In an essay, name the Standard, state the breach, and give one corrective action.
If the options differ only on the period, choose the one that says at least seven years.

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 should records be kept under Standard V(C)?

The Handbook recommends at least seven years where no regulation requires a period. If local law requires a longer period, follow the law. Treat seven years as the recommended minimum, not an exact figure.

Who owns records when a member leaves a firm?

The firm owns records created as part of employment. A departing member should not take originals, and may keep copies only with the employer's permission and while respecting client confidentiality.

Do emails and text messages count as records?

Yes, if they relate to investment analysis, recommendations, actions or client communications. Members should use firm-approved channels so that these messages are captured and stored.

What if local law has a shorter retention period?

Keep records for at least seven years. Standard I(A) requires you to follow the stricter of the law and the Code and Standards, so the Handbook's seven-year recommendation still applies as the stricter practice. If local law requires a longer period, follow the law.