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Module: | Specialized Audits, Tech & ESG Disclosures

Q96: Consider the following statements regarding the intimation of events to Debenture Trustees under Regulation 56 of the SEBI LODR, updated in late 2025:

1. Listed entities are mandated to forward critical information regarding their non-convertible securities to the debenture trustee within a maximum of 24 hours from the occurrence of the event.
2. Prior to this specific October 2025 amendment, the regulation only contained the vague requirement to forward information "promptly" without a strict numerical hour limit.
3. The 24-hour timeline ensures that debenture trustees have immediate visibility into corporate actions or defaults that could jeopardize the financial interests of bondholders.

Which of the above statements is/are correct?
A
Only 1 and 2
B
Only 2 and 3
C
Only 1 and 3
D
1, 2, and 3
✅ Correct Answer: D
🎯 Quick Answer:
D. All statements 1, 2, and 3 are correct.
Concept Definition: A Debenture Trustee is a specialized financial intermediary appointed to safeguard the interests of individuals and institutions who lend money to a listed company by purchasing its debt securities (bonds/debentures). Structural Breakdown: Statement 1 is correct; the SEBI LODR (Fourth Amendment) Regulations, 2025 explicitly hardcoded the "24 hours" rule into Regulation 56.
Statement 2 is correct; the word "promptly" was legally substituted out because companies were exploiting its vagueness.
Statement 3 is correct; instantaneous reporting is critical for trustees to take preemptive legal action (like freezing assets) before a defaulting company can strip its balance sheet.
Historical/Related Context: In several massive NBFC defaults (like DHFL or Reliance Capital), the listed entities delayed informing their debenture trustees about severe liquidity crunches for weeks, claiming they were "promptly" assessing the situation.
By the time the trustees found out, the cash reserves were entirely gone.
Causal Reasoning: Legal terms like "promptly" or "as soon as possible" are subjective and impossible to enforce in a court of law.
Hardcoding an absolute "24-hour" deadline removes all interpretative ambiguity, allowing SEBI to immediately penalize companies that attempt to hide bad news from their lenders.