by Ms.
UMA SHASHIKANT, Centre for Investment Education and Learning
There is
one segment in the financial market which works on the premise that investors
need a diversified portfolio of market securities that professionals build and
manage for a reasonable annual fee.
This
segment--the mutual fund industry-is very competitive, transparent, efficient
and clever. It, however, consistently gets rapped on the knee for one thing or
/ the other.
The
latest is the SEBI circular that asks for more disclosures. Who will this help
or harm?
In most
regimes worldwide, with the sad exception of India, mutual funds manage large
corpuses of pension and insurance pools. The Indian mutual fund industry has
been bogged down for many years by a singular problem- lack of size.
There
are at least three reasons for this. First, many investors find the idea of
investing in the markets rather complex.
It takes
time, effort, education, and experience to figure out that funds make immense
investment sense for long-term investors.
Second, funds focus on selling to achieve size, so that the
fixed costs of employees, infrastructure and technology can be leveraged. To
sell is to push, to portray products in a favourable light, to persuade and
persist, and to be opportunistic. Not traits that endear them to the investor
or policy makers.
Third, mutual funds do not have reach. Their cost structure
makes it unviable to have too many branches and employees.The market for
distribution is skewed against them. It is far easier to sell insurance
products and earn much more as commission.
Mutual
fund distribution is a mixed but shrinking bag of good, bad and ugly players,
who struggle to differentiate themselves.
The
regulatory approach to the mutual fund business has rightly been that investors
should be protected from clever sellers who push unsuitable products for a
commission.
The
regulatory response to this global problem has been to ask that the investors
pay the commissions instead. This is easier said than done. Mutual funds were
also mandated to introduce direct plans which enable investors to buy a product
without paying any distribution charges.
The SEBI
circular of March 18, 2018 simply extends this idea further.It has asked that
the bi-annual account statements that investors receive show the cost incurred
on distribution.
They
should also disclose the cost structure of the direct plan, so that the investor
is able to compare and choose. The benevolent view is that investors would
choose the direct plan and pay the intermediary directly , using the
differential as a benchmark.However, there are many flaws in this assumption.
First, investors would now know how much their distributor is
earning. The clever ones would ask for a direct or indirect pass back.
Second, inferior distributors would grow insecure about this
disclosure and would be willing to forego a part of it to keep the investor
happy , creating an undesirable spiral to the bottom when it comes to
distributor earnings.
Third, quality distributors will struggle to differentiate
themselves and negotiate a fee from the investor that matches the loss of
commission.The net effect would be a reduction in income for distributors .Many
distributors will face a fresh round of uncertainty .
It is a
long-standing demand that the distributor who is a mere seller, and the adviser
who works in the client's interest, be differentiated. While everyone agrees
that this would be in the best interest of the investor, industry and
intermediaries, making it happen on the ground has been a challenge.
SEBI
notified the Investment Advisers Regulation in 2013, but the struggle is that a
distributor has to give up the sizeable annual commission income built up over
the years, to become an adviser who will depend on the unreliable fee income
that an investor may or / may not pay. Less than 400 advisers have found it
worthwhile to register.
Which of
the problems we just discussed does this new regulatory mandate solve? Fear of
lower and falling commission income means even fewer distributors will go out
there in search of business and talk about mutual funds. Investors may choose a
direct plan, and know what they have saved.
Funds
will continue to struggle with volumes and reach and wonder about the next big
idea to mobilise money .
The
solution may be simpler, if the regulator concedes that the annual trail
commission rightfully belongs to the adviser who holds expertise, registers and
complies with regulation, and wears the badge of investor interest.
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