Nominee directors of a bank or financial institution sharing information to their bank or financial institution for legitimate purpose, will it be covered as communication of UPSI?

 The nominee directors on an entity, falling under the list of designated persons or as an
insider, sharing UPSI with the Bank/FIs, for the legitimate purpose of the entity, would be considered as communication of UPSI. Accordingly, the same would need to be recorded in
the SDD of the company

If the directors fall under the list of designated persons or as an insider, then sharing of UPSI by them for legitimate purpose with the Bank/FIs, would be considered as communication of UPSI. Accordingly, the same would be recorded in the SDD of the company