Mooring for wealth and asset management
Client files that stand up to a file review
Wealth managers keep some of the longest-lived records in financial services, from suitability reports to pension transfer files kept indefinitely. Mooring checks your register, chases advisers to confirm their files, tests retrieval and certifies disposal, so you can prove it all when asked.
The rules
What you have to be able to prove
Where it goes wrong
The problems we see in wealth and asset management
Client files drift out of date
In 2013 the FCA fined J.P. Morgan International Bank £3.08m partly because some wealth client files weren't kept up to date and lacked key suitability information. Knowing a file exists isn't enough; firms need to know it's current and complete.
Advisers own the evidence
Files sit with individual advisers and teams, across a CRM, a platform, shared drives and email. Confirming each one by email every year takes weeks of chasing.
Some records must outlive everyone involved
Pension transfer advice files are kept indefinitely. Past-business reviews and redress exercises can depend on producing the original file many years later, long after the adviser has left.
Deleting is as risky as keeping
Keeping personal data too long breaches UK GDPR; deleting a record still under a complaint or legal hold is worse. Disposal needs a check and an audit trail, not a bulk delete.
Typical retention
Records you'll be asked about
Common starting points with their basis. Your own retention schedule always takes precedence; confirm periods with your compliance team.
| Record type | Typically kept | Basis |
|---|---|---|
| Pension transfer and opt-out advice files | Indefinitely | COBS 9.5 |
| Pension and life policy suitability records | 5 years | COBS 9.5 |
| MiFID suitability and transaction records | 5 years (up to 7 if the FCA asks) | MiFID II Art. 16(6), SYSC 9 |
| Recorded calls and messages | 5 years (up to 7 if the FCA asks) | COBS 11.8 |
| Customer due diligence (KYC/AML) | 5 years after the relationship ends | MLR 2017 reg. 40 |
| Complaints | 3 years, 5 for MiFID business | DISP 1.9 |
How Mooring helps
Four controls, evidenced automatically
Inventory attestation
Each adviser gets one email listing their client files and records. They confirm or correct each one, with no login, and every answer is time-stamped.
Location conformance
Records with web locations are checked nightly; anything missing is named, with the owner, before a reviewer finds it.
Retrieval testing
A risk-weighted sample, weighted toward regulatory records such as pension transfer files, is sent for retrieval within a deadline, and results are recorded.
Certified disposal
Records past retention are queued, legal holds, for example on open complaints, block disposal, and each approved disposal gets a certificate.
Example · Wealth and asset management
A discretionary manager with an advice arm
A wealth manager with two regulated entities and 22 advisers keeps a register of 1,400 records: client files, suitability reports, pension transfer files, recorded call archives and KYC packs.
The records manager imports the register from two spreadsheets. Mooring flags 38 records whose location no longer resolves, 26 of them client files that moved when the firm changed platform. The attestation campaign goes to all 22 advisers; they correct the locations and confirm the rest within ten days, with Mooring sending the reminders.
The quarterly retrieval test samples 20 records, with pension transfer files weighted in. All but one are produced on time, and the exception is recorded with the reason. The compliance director takes a conformance report by entity to the risk committee.
This is an illustrative example, not a customer story.
Questions
Does Mooring read our client files?
No. Mooring holds the register: record IDs, owners, locations and retention details. The files stay in your own systems.
Does it connect to our CRM or platform?
There's no integration to set up. Export the register or file list from your CRM or platform as Excel or CSV and import it. Web locations are checked automatically; others are confirmed by advisers.
Can it handle more than one regulated entity?
Yes. Each record carries its entity, and dashboards and the annual report break results down by entity.
Do you set our retention schedule?
No. You keep your schedule and Mooring applies it. The built-in library includes the periods on this page as a starting point to confirm with your compliance team.
See Mooring on your own register
A 30-minute walkthrough. Bring an anonymised extract and we'll load it live. Early-access firms get a free pilot.
Sources
- FCA Handbook, SYSC 9: record-keeping (opens in a new tab)
- FCA Handbook, COBS 9.5: suitability record keeping and retention (opens in a new tab)
- FCA Handbook, COBS 11.8: recording telephone conversations and electronic communications (opens in a new tab)
- Money Laundering Regulations 2017, regulation 40 (opens in a new tab)
- FCA Handbook, DISP 1.9: complaints record rule (opens in a new tab)
- ICO: storage limitation principle (opens in a new tab)
- FCA: J.P. Morgan International Bank fined for systems and controls failings in its wealth management business (2013) (opens in a new tab)
Examples are illustrative, not customer stories. This page summarises rules for general information and isn't legal advice.