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    <title>Specification of the terms and conditions for Debenture Trustees for carrying out activities outside the purview of SEBI</title>
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    <description>DTs may undertake activities outside SEBI regulation only if they are fee based, non fund based financial services carried out at arms&#039; 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.</description>
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