You are reading the 2026 curriculum (exams up to November 2026). Sitting in February 2027 or later? Go to the 2027 Ethical and Professional Standards guide.
Standard V(C): Record Retention
Develop and keep appropriate records that support your investment analysis, recommendations, actions and client communications, in any medium. Records belong to the firm, not to you. Follow local rules on how long to keep them. If none exist, CFA Institute recommends at least seven years.
Before this: Standard V(B): Communication with Clients and Prospective Clients
On the exam
- Demonstrate the application of the Code of Ethics and Standards of Professional Conduct to situations involving issues of professional integrity
- Recommend practices and procedures designed to prevent violations of the Code of Ethics and Standards of Professional Conduct
- Identify conduct that conforms to the Code and Standards and conduct that violates the Code and Standards
Demonstrate V(C). Expect how long, whose records, and do emails or social media count. The seven-year guideline and firm ownership are the two facts examined most.
How deeply to learn each part
- Know the idea
- Understand it in general. It frames other topics, but you will not calculate with it.
- Use it
- Understand it well enough to solve a question with it. Recognize when it applies.
- Memorize
- Learn it by heart. The exam will not give it to you.
You know this one. The full lesson is folded away. The takeaways, formulas and checkpoint below are your quick refresher, and the checkpoint is a fair test of whether you still do.
You tested strong here. The full lesson is folded away. The takeaways, formulas and checkpoint below are your quick refresher, and the checkpoint is a fair test of whether you still know it.
What does Standard V(C) require?
You must develop and maintain appropriate records (record retention ) to support your investment analyses, recommendations, actions and other investment-related communications with clients and prospects.
Memorize
The records must show the scope of your research and the reasons for your conclusions. That covers decisions to buy or sell and also reviews that ended with no change in position. Which records you need depends on your role in the decision process. Typical examples are meeting notes, company press releases, model inputs and outputs, risk analyses, selection criteria for outside advisers, notes from investment policy statement meetings with clients, and outside research. Hard copy and electronic form are both fine.
- Keep Memorize
- Research notes and models inputs and outputs
- Meeting notes and outside research
- Client communications email, texts, social media
- Reviews with no change in position
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- Ownership Memorize
- Property of the firm not the individual
- Leaving no copies without express consent; rebuild from public sources
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- Duration Memorize
- Local law or firm policy follow first
- No rule at least seven years
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Do emails and social media count?
Yes. New media records carry the same duty: emails, text messages, blog posts and social media posts that support your analysis or were sent to clients must be retained. Firm and regulator policies can lag behind new channels, which puts more weight on the individual to keep what is relevant.
Whose records are they?
Records are the property of the firm . Records you create as part of your work for your employer belong to the employer. When you leave, you cannot take originals or copies to a new employer without the previous employer’s express consent.
You also cannot reuse old recommendations or reports at the new firm, because their support is not available there. Rebuild the support from public sources or from the covered company directly, never from memory or from material obtained at the old firm. Taking the files can also breach Standard IV(A).
How long must you keep them?
Local requirements and firm policy come first. Meeting them satisfies Standard V(C). When neither sets a period, CFA Institute recommends keeping records for at least seven years: the seven-year guideline .
Where do the lines fall?
| Situation | Verdict |
|---|---|
| An analyst deletes working files after publishing a report | Violation (no support for the recommendation) |
| A manager keeps client text messages on the firm’s approved archive | Consistent |
| A departing analyst takes copies of her models to a new employer without consent | Violation of V(C), because the records are the firm’s (and of IV(A) Loyalty) |
| A firm in a country with no rule keeps records for eight years | Consistent (meets the seven-year guideline) |
| An analyst keeps notes on a stock she reviewed and decided not to buy | Consistent (reviews without a change count too) |
Exam tip “Whose?” the firm. “How long?” local rule first, then seven years. “Which kinds?” every kind.
Who is responsible for retention?
The firm usually carries the main responsibility through policy, a central archive and training. Even so, you must archive the research notes and other documents that support your current communications, in electronic or hard-copy form, which helps the firm meet its own duties.
Recommended procedures:
- a firm-level retention policy covering all media;
- a central archive so records are not scattered on personal devices;
- training on what must be kept;
- following local rules, or the seven-year guideline when there are none.
Go deeper Archiving electronic communications
Messaging apps and social media make it easy to discuss a trade outside the firm’s systems. If the firm’s archive does not capture those channels, either they should not be used for client business, or the individual must make sure the messages are saved. Supervisors under Standard IV(C) set up procedures so that this happens, and a missing record is hard to defend when a client later disputes what was recommended.
Memorize this
MemorizeStandard V(C): what to know cold
| Point | The rule |
|---|---|
| What | Records that support analysis, recommendations, actions and client communications, including reviews that led to no change |
| Which media | Any: paper, electronic, emails, texts, blog and social media posts |
| Who owns them | The firm. Leaving? No copies without express consent. Rebuild from public sources, not from memory |
| How long | Local rules or firm policy first. If none, at least seven years |
| Who keeps them | Usually the firm, but you must archive your own notes and documents supporting current communications |
Memory hook Keep it, it is theirs, seven years: keep what supports the work, the firm owns it, and seven years is the fallback when no rule applies.
Know it cold Law or firm policy beats the guideline. No rule = at least seven years. Records leave with the firm, never with you.
- Keep Memorize
- Research notes and models inputs and outputs
- Meeting notes and outside research
- Client communications email, texts, social media
- Reviews with no change in position
-
- Ownership Memorize
- Property of the firm not the individual
- Leaving no copies without express consent; rebuild from public sources
-
- Duration Memorize
- Local law or firm policy follow first
- No rule at least seven years
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How it is asked
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How long, with no local rule
A firm in a jurisdiction with no retention rule should keep research records for at least how long?
Seven years. Traps: three years, ten years, "permanently".
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Leaving for a new employer
An analyst wants to reuse the models she built at her old firm. What should she do?
Rebuild them from public information. Records belong to the old firm.
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Does this medium count?
Is a text message to a client about a trade recommendation covered?
Yes. Format does not matter. Trap: "only formal reports count".
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Deleting working files
An analyst deletes her working files after publishing a report. Violation?
Yes, V(C). No support remains for the recommendation.
Exam traps
- Thinking records belong to the analyst who created them. Work records are the firm's property.
- Picking three years or "permanently" when no rule applies. The guideline is at least seven years.
- Thinking only formal reports must be kept. Emails, texts and social media posts count.
- Applying the seven-year guideline when local law or firm policy sets a period. Those come first.
- Reusing old research at a new firm from memory or from copied files. Recreate it from public sources.
Checkpoint
4 exam-style questions. About 90 seconds each.
1A firm operates in a jurisdiction with no record-retention requirement and has no policy of its own. Under the Standards, it should keep records supporting its research for at least:
2After joining a new firm, an analyst wants to use the earnings models she built at her previous employer. She most appropriately:
3Which of the following is most likely subject to Standard V(C)?
4A firm's local regulator requires retention of client records for five years. The firm follows this rule and deletes records after five years. Under the Standards, the firm is:
Key takeaways
- Keep records that support analysis, recommendations, actions and client communications, in any medium.
- Records belong to the firm. Leaving analysts rebuild from public sources.
- Follow local law or firm policy. If none, keep at least seven years.
Questions about this lesson?
Where this comes back
- Standard VI(A): Avoid or Disclose Conflicts Guidance for Standards I–VII
Questions candidates ask
How long should records be kept under the CFA Standards?
Follow the period set by local regulators or your firm's policy. If neither exists, CFA Institute recommends keeping records for at least seven years.
Who owns research records when an analyst leaves?
The firm. An analyst cannot take original or copied records to a new employer without the previous firm's express consent. She must recreate her support from public sources or the covered company, not from memory or old files.
Do emails and social media count as records?
Yes. The format does not remove the duty. Emails, text messages, blog posts and social media posts that support analysis or client communications should be retained, even if firm or regulatory policies lag behind new channels.
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