FRE2 AC7.2: Records, AML, data protection, complaints, the FOS and the FSCS
1,723 words · checked 2026-10-30 · Pro
Assessment criterion 7.2 asks you to understand and apply the main rules of the regulatory framework: record keeping, reporting and notifications; anti-money laundering and proceeds of crime; data protection; complaint handling; the Financial Ombudsman Service; the Financial Services Compensation Scheme; and treating customers fairly and conduct risk. This is the most number-heavy part of FRE2, so this note gathers the time limits and limits you need. Figures are those in force on 30 October 2026. CeMAP® questions here often hinge on which date a clock starts from.
Record keeping, reporting and notification
Record keeping
A firm must keep orderly records of its business and internal organisation, sufficient for the FCA to check compliance (SYSC 9.1.1R).
| Record | Minimum period | Source |
|---|---|---|
| Mortgage advice: customer information and why advice is suitable | 3 years from the advice | MCOB 4.7A.25R |
| Complaints | 3 years from receipt | DISP 1.9.1R |
| Customer due diligence and transaction records | 5 years from the end of the business relationship; not beyond 10 years | MLR 2017 reg 40 |
| Mortgage arrears handling | 3 years | MCOB 13.3.9R |
Reporting and notifications
- Regular returns. Firms submit periodic regulatory returns. Mortgage and insurance intermediaries use the Retail Mediation Activities Return (RMAR).
- Complaints data. Firms report complaints from eligible complainants to the FCA twice a year (DISP 1.10).
- Notifications. Under Principle 11, firms must disclose anything the FCA would reasonably expect notice of. SUP 15 lists events such as significant rule breaches, fraud and matters with a serious regulatory impact.
- Change in control. Anyone proposing to acquire control of an authorised firm needs the regulator's approval first.
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Official sources
- Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017
- Proceeds of Crime Act 2002, sections 333A and 334
- UK GDPR, Article 5 (principles)
- FCA Handbook DISP 1.6 - Complaints time limit rules
- FCA Handbook DISP 3.7 - Awards by the Ombudsman
- FSCS - What we cover