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Corporate Laws Central Ministry of Finance Securities and Exchange Board of India Act, 1992

Advisory for SDD compliance by fiduciaries under the SEBI (PIT) Regulations, 2015

28-Feb-2024 | NA

ICSI has issued advisory for SDD compliance by fiduciaries under the SEBI (PIT) Regulations, 2015.

By virtue of this notification it has been clarified that the structured digital database should be maintained internally by fiduciary or intermediary, capturing information in accordance with Regulation 9A (2)(d) and as required under Schedule C of the Regulations :-

i. Details of the Unpublished Price Sensitive Information (UPSI);
ii. Details of persons with whom such UPSI is shared (along with their PANs/other unique identifier) and details of persons who have shared the information.

Fiduciaries include Professional firms such as auditors, accountancy firms, law firms, analysts, insolvency professional entities, consultants, banks etc., assisting or advising listed companies shall be collectively referred to as fiduciaries for the purpose of these Regulations

Accordingly, the Company Secretaries in Practice dealing with UPSI of listed entities and unlisted entities whose securities are proposed to be listed, by virtue of their position as Fiduciaries under the Regulations are required to ensure compliance with the requirement of maintaining a separate SDD internally.

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