48 Felix Johnson, CFA, is a portfolio manager for Claros Securities. Johnson maintains all records only in hard copy for a period of three years. He maintains all records that support decisions to buy or sell securities. He also maintains records on reviews undertaken which do not lead to a change in investment positions. Claros Securities has no policy regarding record retention. In contrast, regulatory guidance states that firms must maintain records for at least three years.

Are Johnson's actions consistent with the Standard relating to record retention?