Allocation record redaction is the removal of personal identifiers from an underwriting allocation log. The log exists because FCA COBS 11A and the retained MiFID Organisational Regulation (Regulation (EU) 2017/565) require a firm to record and justify how an offering was allocated, and because the resulting trades are reported under UK MiFIR Art. 26. anonym.plus marks each buyer field on your machine, so the log stays usable while individuals are shielded.
When this applies
The log ties each allocated lot to a person's name, account and settlement details. You strip those before an extract reaches an auditor, a co-manager or the issuer.
How anonym.plus handles it
- Open the log in anonym.plus on your device.
- Local OCR reads a printed or scanned extract.
- The tool flags recipient names and account fields.
- Keep the lot sizes, prices, and timestamps.
- Mask or swap each confirmed field.
- Save the clean extract locally.
What you need to provide
- The log (CSV export, PDF, DOCX, or scan).
- An operator (Mask suits structured fields).
- Optional batch for several deals.
PII & financial identifiers detected
| Category | anonym.plus entity type | Example |
|---|---|---|
| Names | PERSON | buyer R. Pennington → [BUYER] |
| Identifiers | NATIONAL_ID | buyer LEI/ref → [ID] |
| Financial | UK_BANK_NUMBER | settle acct → [ACCOUNT] |
| Money | MONEY | lot £2m → [SIZE] |
| Contact | EMAIL_ADDRESS | buyer@example.co.uk → [EMAIL] |
| Dates | DATE_TIME | alloc 03/2025 → [DATE] |
Compliance achieved
- The record exists because FCA COBS 11A and the retained MiFID Organisational Regulation (Reg. (EU) 2017/565) require allocation decisions to be recorded and justified.
- Conflicts between issuer and investor clients sit under FCA SYSC 10.1, so the master record must stay complete for review.
- Retention follows FCA SYSC 9.1 — redact the extract you share, never the master.
- Allocated trades are reported onward under UK MiFIR Art. 26, so keep the reportable fields intact in your own copy.
- Offline work keeps every recipient's data on your machine.
Anonymise allocation records offline — see plans & start free →
Limitations & cautions
The conduct rules require a complete, contemporaneous record, so redact only a shared extract. A rare lot size at a known price can still identify a recipient. Review distinctive rows before sharing, and band outliers where you can.
Frequently asked questions
Should I redact the master allocation log?
No. FCA COBS 11A and SYSC 9.1 require the complete record to be kept and available for review. Redact only a shared extract.
Will lot sizes and prices survive?
Yes. Allow-list those columns. Only personal identifiers are flagged for removal.
Does the log leave my machine?
No. Work runs offline, so each client's data stays on your device.