Three years, one year, and the whole term of the loan

There is no single period. MCOB Schedule 1 gives each record-keeping rule its own row and its own clock, and the longest one runs for the whole term of the mortgage.

Read in the FCA Handbook on 24 August 2026, the rows a mortgage intermediary actually creates records under:

• Advice files — the customer information you obtained, and why you concluded the recommendation was suitable: “a minimum of three years from the date on which the advice or explanation was given” (MCOB 4.7A.25R).
• Execution-only sales — the information and confirmations the customer gave, plus any advice from you they rejected: a minimum of three years from the date the contract was entered into or arranged (MCOB 4.8A.18R).
• Illustrations — an illustration issued to a customer who then applies for that contract: one year (MCOB 5.4.19R). If you issue an ESIS rather than an illustration, check MCOB 5A separately.
• Customer categorisation — evidence that someone is a high net worth or professional customer: three years from when it was obtained or, if later, used (MCOB 1.2.9CR).

The row that breaks the single-number habit

MCOB 11.6.60R covers the affordability assessment — income, committed expenditure, the interest rate assumed, the calculation itself. That record must be kept “for the term of the regulated mortgage contract or home purchase plan”, and where the lending policy changes, the superseded policy is retained “for so long as any regulated mortgage contract or home purchase plan to which it was applicable remains outstanding”.

That row belongs to lenders and home purchase providers, not intermediaries. Which is why one number fails in both directions: borrow a lender’s schedule and you hold advice files for the life of a loan you never made, and a firm that both advises and lends will apply three years to records the rule ties to the term.

Open Schedule 1, list the record types your firm creates, and put the rule reference beside every line of your retention policy. Any line without one is a guess. The periods are floors, not ceilings — but a floor you haven’t identified isn’t a policy.