Which of the Following Statements Is Incorrect

Which of the following statements is incorrect?
1) prepare a disclosure document before the proposed offer of debentures
2) appoint a trustee whose task is to monitor the borrower so as to safeguard the investors
3) keep a register of debenture holders

A) There is no specific format for a debenture
B) The term 'mortgage debenture' can only be used to describe a debenture that is secured by a first mortgage over real estate, where the loan does not represent more than 60% of the value of property under charge
C) The term 'debenture' can only be used to describe a debenture that is fully secured by charges over company assets
D) None of the above