On 18 October 2018, the Association for Financial Markets in Europe (AFME) published a guidance note for record-keeping under COBS 11A.1.4BR(3)(c), COBS 11A.1.4CR and COBS 11.A.1.4ER (the Guidance).

Specifically, the Guidance sets out its suggested approach for record-keeping in the IPO process relating to:

• a firm’s process for conducting an assessment and reaching an opinion under COBS 11A.1.4BR(3)(a) plus an explanation of the firm’s consideration of the number and expertise of the unconnected analysts included in the range (COBS 11A1.4BR(3)(c));
• any restrictions that would be imposed on each unconnected analyst that accepts the opportunity (COBS 11A.1.4BR(2)); and
• the sharing of information to connected and unconnected analysts (COBS 11A.1.4ER).

The Guidance is not intended to be prescriptive and a firm may adopt other approaches to record keeping that would also be sufficient to comply with its obligations.