Debenture trustees must run non SEBI activities via ring fenced separate business units with specific disclosure and compliance duties. DTs may undertake activities outside SEBI regulation only if they are fee based, non fund based financial services carried out at arms' length through one or more Separate Business Units (SBUs) ring fenced by a Chinese Wall. SBUs must have separate records, distinct staff (with board approved crossing procedures), separate grievance mechanisms and distinct marketing/web presence. DTs must disclose non SEBI activities and relevant financial sector regulator on their website, obtain stakeholder acknowledgements, submit disclosures and a compliance report for existing arrangements within six months, and include a board approved undertaking in half yearly compliance reports confirming adherence to regulation 9C and this circular.