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Microlesson · 5-min read

Creation of Charge & Appointment of Deposit Trustee for Secured Deposits

## Secured Deposits — Creation of Charge

Where a company opts to issue secured deposits, it must:

1. Create a charge on tangible assets of the company (excluding intangible assets).

2. The value of charged assets must be sufficient to cover the deposit amount + interest.

3. The charge must be created in favour of a Deposit Trustee appointed for the depositors.

4. The charge must be filed with ROC in Form CHG-1.

## Appointment of Deposit Trustee

Before issuing the circular/advertisement, the company must:

  • Appoint one or more Deposit Trustees by the company;
  • Obtain written consent of the Trustee;
  • Execute a Deposit Trust Deed in Form DPT-2 at least 7 days before issuing the circular to members / advertisement to public;
  • Mention the name of the Deposit Trustee in the circular.

## Disqualifications of a Deposit Trustee (Rule 7)

A person CANNOT be appointed Deposit Trustee if:

DisqualificationExplanation
Director / KMP / Officer / Employee of the companyConflict of interest
Material guarantor for repayment of deposits / interestConflict — represents company side
Beneficially holds shares ≥ amount specifiedInsider stake
Indebted to the company / subsidiary / holding / associate of companyCannot impartially enforce
Has a material pecuniary relationship with the companyIndependence compromised
Relative of any promoter / director / KMP of the companyIndependence compromised
Engaged in any business with the companyIndependence compromised

## Removal of Deposit Trustee

A Deposit Trustee can be removed only with consent of all directors present at the Board Meeting, AND such meeting must include at least one Independent Director (where applicable). This high threshold protects depositors from arbitrary removal.

## Duties of Deposit Trustee — Calling Meetings of Depositors

The Trustee must call a meeting of all deposit holders:

1. On requisition — when depositors holding ≥ 1/10th (in value) of outstanding deposits so requisition; OR

2. Suo motu — on the happening of an event that, in the opinion of the Trustee, requires depositors' attention (e.g., default, downgrade, distress).

Worked example

### Example 1

Q. A company proposes to issue secured deposits worth ₹10 crore. Its tangible assets free of charge are valued at ₹8 crore; goodwill is ₹5 crore. Can it secure the deposits using all these assets?

A. No. The charge must be on tangible assets only. Goodwill (intangible) cannot be considered. Tangible coverage is ₹8 crore — short of the ₹10 crore + interest requirement. The company must either reduce the issue size, acquire more tangible assets, or issue unsecured deposits (with appropriate disclosures).

### Example 2

Q. Mr. X, a relative of the Managing Director of ABC Ltd., is proposed as Deposit Trustee. Is this valid?

A. No. A relative of any director / KMP of the company is disqualified under Rule 7. Appointment is void; the company must appoint an independent person.

### Example 3

Q. Depositors holding ₹5 crore of an outstanding deposit pool of ₹40 crore requisition a meeting. Must the Deposit Trustee call it?

A. Yes. ₹5 cr / ₹40 cr = 12.5%, which exceeds the 1/10th (10%) threshold. The Trustee is bound to convene the meeting of all deposit holders.

⚠️ Common exam mistakes

  • Allowing intangible assets (goodwill, patents) to be charged — only tangible assets qualify.
  • Executing the Trust Deed after issuing the circular — it must be at least 7 days before.
  • Writing 'requisition by ≥ 1/20th' (debenture-holders' threshold) — for deposit-holders it is 1/10th in value.
  • Believing the Trustee can be removed by a simple majority of directors — it requires consent of all directors at the meeting including at least one Independent Director.
  • Listing 'subsidiary of the trustee' as a disqualification — the disqualification flows from the trustee's nexus with the company, not vice versa.
Bare-Act text Rule 6 (Creation of Security) read with Rule 7 (Deposit Trustees) and Rule 8 (Duties of Trustees) · Companies (Acceptance of Deposits) Rules, 2014 · click to expand
Rule 6 of Companies (Acceptance of Deposits) Rules, 2014: Every company referred to in sub-section (2) of section 73 or any eligible company inviting secured deposits shall provide for security by way of a charge on its assets as referred to in Schedule III of the Act excluding intangible assets of the company for the due repayment of the amount of deposit and interest thereon for an amount which shall not be less than the amount remaining unsecured by the deposit insurance.
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