Johnson's actions are consistent with the Standard relating to record retention because:

• He maintains all records that support decisions to buy or sell securities
• He maintains records on reviews undertaken which do not lead to a change in investment positions
• He maintains records for three years, which meets the regulatory guidance minimum
• There is no requirement that records must be maintained in electronic form
• The three-year retention period is adequate per regulatory guidance
• Claros Securities has no policy requiring longer retention, so Johnson is following the regulatory minimum

The Standard requires maintaining records that support investment recommendations and actions, which Johnson is doing. The format (hard copy vs electronic) is not specified in the Standard, and the three-year period meets regulatory requirements.