| FINANCIAL PROMOTIONS |
|
|
|
|
| Communication or approval of a financial promotion (COBS 4.11). |
|
|
|
|
| A copy of any financial promotion communicated or approved, why it complies with the financial promotion rules and date of first issue. |
Date when financial promotion was communicated or approved. |
Five years from the date on which the financial promotion was communicated or approved. |
Professional clients. |
|
| CLIENTS |
|
|
|
|
| Categorisation of each client as specified in COBS 3.8.2(R). |
Notification sent to clients regarding client categorisation (including information to support the categorisation). |
From the date of categorisation. |
Five years (from end of client relationship). |
All. |
| Record of information provided to client regarding terms of client relationship (COBS 8.1.4(R)). |
Terms of business sent to clients (and any other agreement entered into with a client). |
On issue. |
For the longer of five years or the duration of the relationship with the client. |
Professional clients. |
| INDUCEMENTS |
|
|
|
|
| Inducements paid or received by TSMC (COBS 2.3). |
Any fee, commission or non-monetary benefit paid or received by TSMC. |
When inducement is paid or received. |
Five years. |
Professional clients. |
| PERSONAL TRANSACTIONS |
|
|
|
|
| Personal transactions entered into by any relevant person (COBS 11.7). |
Details of the personal transactions notified to TSMC, or identified by TSMC, of a personal transaction by TSMC, including any authorisation or prohibition in connection with a personal transaction. |
From the date of notification or identification of personal transaction. |
Five years. |
N/A. |
| CLIENT ORDERS AND EXECUTION |
|
|
|
|
| Client orders and decisions to deal (COBS 11.5). |
Details of client orders and decisions to trade and executed orders as listed in COBS 11.5. |
Immediately on receipt of the order, decision to trade or execution. |
Five years. |
N/A. |
| SYSTEMS AND CONTROLS |
|
|
|
|
| Records relating to the systems and controls implemented by TSMC (SYSC 9). |
Records of TSMC’s business and internal organisation, including all services and transactions undertaken. |
Ongoing. |
Five years. |
N/A. |
| CONFLICTS OF INTEREST |
|
|
|
|
| Records of both potential and actual conflicts of interest to be kept by Tiny. SYSC 10.1.6(R). |
Details of the kinds of services and activities carried out by TSMC in which a conflict of interest, entailing a material risk of damage to the interests of one or more clients, has arisen or may arise. |
Ongoing. |
Five years. |
All. |
| MONEY LAUNDERING |
|
|
|
|
| Client identification and verification of identity. |
Full details of evidence of identity. |
As soon as reasonably practicable after first contact. |
Five years from end of relationship with client. |
All. |
| Transactions. |
Full details of every transaction carried out for the client in the course of a regulated activity. |
On effecting the transaction. |
Five years from the date when the transaction was completed. |
All. |
| Internal and external reporting (to MLRO or NCA respectively). |
Full details of actions taken. |
Once actions have been taken. |
Five years from the obtaining of the information or the creation of the record. |
All. |
| Information not acted upon. |
Full details of information considered by the MLRO where no external report was made by the MLRO. |
Once decision not to report has been made by the MLRO. |
Five years from obtaining of the information. |
All. |
| EMPLOYEE OR DIRECTORS — COMPETENCE |
|
|
|
|
| Skills, knowledge and competence of personnel (SYSC 5.1.1 (R)). |
Assessment of suitability of employee or director with respect to skills, knowledge and expertise. |
When assessment is made (and on-going). |
Five years from the date of assessment (and on-going date). |
N/A. |
| PERIODIC STATEMENTS |
|
|
|
|
| Duty to keep copies of periodic statements provided to investors (COBS 18.5.14) |
Copies of periodic statements sent out. |
From the date of issue of the periodic statement. |
Three years. |
All. |