Myths on Structured Digital Database
SDD Software – a path-breaking software tool to curb UPSI menace
Orion Legal Supplies has been pioneering in the space of software related to Structured Digital Database (“SDD”). In the below part, we take a moment to give you a brief idea of our Structured Digital Database Software (“SDD Software”) or Insider Trading Software (“PIT Software”)
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Myths & Myth Busters
Clearing common misconceptions around Structured Digital Database (SDD) compliance
1. We can maintain data required under SDD Compliance Regulation 3 (5) of SEBI PIT Regulations, 2015 in an Excel sheet!
As per Regulation 3(5) of the PIT Regulations, SDD must be maintained with adequate internal controls and checks such as time stamping and audit trails to ensure non-tampering of the database. These features are not possible in an Excel sheet...
2. I have to purchase Structured Digital Database Software (“SDD Software”) only through my Registrar and Transfer Agent (“RTA”).
No, RTA provides services related to share registry maintenance... Companies can evaluate software vendors.
3. SDD Compliance does not apply to our Company as we are listed on the Metropolitan Stock Exchange (“MSEI”) and Calcutta Stock Exchange (“CSE”).
Even though shares of the Company are listed on MSEI or CSE...
4. SDD Compliance does not apply as our shares are not traded on the Stock Exchanges.
Even if shares are not actively traded, the company is still defined as a listed company under the law...
5. SDD Compliance does not apply as our shares are suspended to trade.
Even suspended companies are still legally considered listed companies...
6. SDD Compliance applies only to listed companies, not fiduciaries.
No, all fiduciaries handling UPSI must maintain SDD Software.
7. SDD Compliance applies only to listed companies, not intermediaries.
No, intermediaries also must comply with SDD obligations.
8. We are fiduciaries and use the same software as the listed company.
Fiduciaries must maintain their own SDD database — it cannot be shared.
9. As a listed company also acting as an intermediary, I need only one SDD.
Separate SDD software is required for listed company and intermediary functions.
10. All UPSI-related emails must be stored or automated through email.
The regulation requires capturing nature of UPSI, not all communication. Bulk email storage is not compliant.
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