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MUTUAL FUND ROUNDTABLE
WAY FORWARD:
EVOLVED ENTRY
In the second roundtable on 'Balancing Regulation with Development', mutual funds experts
discussed how the industry is in the process of a significant transition with the Securities and
Exchange Board of India (Sebi) scrapping entry loads. In the course of the detailed talk, they laid
out a roadmap for the three affected parties - the investor, the distributor and the MF house.Experts
Kayezad E. Adajania:
By banning entry loads,Sebi seems to think that the investor
is in a better position than the MF to decide the quantum of fees he needs to pay
the distributor. Do you think it's good for the investor?
Vikramaaditya: We should account for, one, the long-term approach and two, how to
manage that in the short term? Nobody can dispute the transparency of this model,
but implementing this is a challenge. The question is how much financial literacy
is there and to what extent the investors will be in a position to make a rational
decision with respect to the services that they receive from a distributor. It is
critical for both the MFs and the distributors to ensure that investors are educated
so that they can make a meaningful decision. However, I don't think, Sebi is saying
that MFs and distributors cannot have a mutually acceptable commercial arrangement.
If that's the way business can move forward and markets can be penetrated, there
is no restriction on that.
Kayezad E. Adajania:
Is transparency coming at the cost of financial literacy? Has
financial literacy gone up recently?
Jaydeep Kashikar: Financial literacy has surely gone up, but is still at a nascent
stage because many investors still depend on their advisors. So, an advisor's job
is to first educate the investor and then do a proper financial plan as per the
investor's needs.
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The new regulations will surely further this cause. The competition among distributors
has historically depended on who gives the highest payback (rebating). In future,
the competition should be on the quality of advice. As the remuneration from the
manufacturer would come down and that from the investor will go up, the advisory
level and financial literacy will go up.
Kayezad E. Adajania:
Ajit, you have always banked on financial literacy you have
avoided the distributor route and preferred to reach out to your investors directly.Do
you think investors are ready for this?
Ajit Dayal: There is a huge effort required in terms of educating investors. It is
great that investors are empowered to decide how much distributors should get and
how much money should finally be invested. But, there has been 15 years of complete
nonsense in the MF industry. Products have been mis-sold, products that should never
have entered the MF space have entered, and have hurt investors in the long run.
So there is complete relearning that needs to happen. I am told that, globally,
regulators and agencies are spending a lot on investor education. Just as a well-informed
voter chooses the right government, a well-informed investor will pay the right
price to his financial planner. But, it's a long way to go in terms of investor
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Kayezad E. Adajania:Rajesh, your online platform is advisory-based rather than commission-based,
so it encourages decision-making from the investor’s end. Has the investor’s life
become more complicated with increased choices?
Rajesh Krishnamoorthy:True, but the investor has to not only decide what he needs
to pay to the agent, but also has to choose the type of service his financial planner
would offer, based on his fee structure.. To convince the investor that the financial
planner is adding value, he has to put in a lot of effort—he needs to educate clients
about options on offer. People at the lower end of the spectrum may not understand
a financial advisor’s value. The advisor’s challenge would be to ensure the investor
graduates to a higher level.
Kayezad E. Adajania:
Jaydeep,we Indians have a mentality of looking for discounts
and hard-bargaining even when we recognise a product’s value. How big is this challenge?
Jaydeep Kashikar: When we stopped rebating long back, at a time when Sebi officially
banned the practice, we lost 20-25 per cent of our investors. Those who believed
that we can deliver returns in excess of the gains that they make on rebates stuck
with us. Similarly, right now, some people compare our rates with what other financial
planners charge. But, we are firm on our capabilities. I am sure investors would
realise that the advisor who is able to deliver higher risk-adjusted returns would
be more important than the one who charges lower fees.
Kayezad E. Adajania:
Would this regulation work for small investors who could get
perplexed by so many choices?
Rajesh Krishnamoorthy: There
are operational concerns. If you are talking of investing
Rs 5,000 and you are talking of a 2 per cent commission, are investors used to paying
a separate cheque for this Rs 100 fee? Is there an effective collection mechanism?
Many foreign markets have a mandate to mention clearly the amount of fees the investor
wants to give to the agent on the form itself. The investor gives a consolidated
cheque and is made aware of the charge. The MF then passes the negotiated charges
to the agent. There are no economies of scale for collecting cheques of Rs 25 or
Rs 100 or Rs 50 and it is worth the effort, Administratively, the new regime coule
be a nightmare.
Ajit Dayal: It is unknown for people to make two
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separate payments; it is unknown
in our industry so I don't think it is a bad regulation as such. Just the mindset
needs to change. It is something like a patient going to a doctor for treatment.
There is one bill paid to the doctor for diagnosis and the other for medicines to
the chemist or for an X-ray.
Kayezad E. Adajania:
What is the way ahead for the investor?
Jaydeep Kashikar: If it’s an equity fund, check whether the fund that your agent
has recommended comes in the top two quartiles, consistently. Ensure your agent
does not recommend you high-momentum funds when markets are high. Many infrastructure
funds were sold in the last quarter of 2007. A good advisor would not have recommended
them at a time when equity shares of infrastructure companies were already overvalued.
Some kind of an advisory should be available in overheated markets, too, to soothe
the nerves of investors.

Kayezad E. Adajania:
Some distributors claim they will now focus on selling uni-linked
insurance plans. Are you worried?
Jaydeep Kashikar: There are distributors who treat this as a business and not a profession.
Such distributors will shift to selling insurance products realising that income
from MFs will drop. Maybe the regulator should have curtailed the transition period
required to shift to the new-cost regime to six months, down from one-and-a-half
years. Clearly, in the next 18 months, distributors who are just looking at their
upfront revenues will have a major advantage in selling insurance products. In the
current scenario, there is a good chance that more than 50 per cent distributors
will focus on insurance.
Ajit Dayal: But that’s good for people like you (pointing towards Jaydeep Kashikar).
Those who are here to do business as opposed to treating it as their profession
would move out to the next business opportunity. That will leave serious guys like
you here, offering serious advice and genuinely adding value.
Rajesh Krishnamoorthy: Distributors
will have to show the value they add. I see distribution
turning into a value-added product. It would be nice if the distributor’s interests
are also aligned with that of the investors. The Financial Services Authority (FSA;
regulator) of the UK has given three years for the new on-load commission regime
to roll out. Sebi gave 30 days. An association
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in UK came out with an impact analysis that said that every advisor in UK is expected
to incur at least £6,000 of investment to move to the new model prescribed by the
FSA. It also says that 18 per cent of their community is investing between 6-10
hours every week to work on this implementation and more than 50 per cent of the
IFA community is investing five hours for planning this out, over a period of three
weeks, to move towards the new model. In India, distributors are not regulated.
You don’t have a financial advisor’s regulation.
Kayezad E. Adajania:
So, should the distribution community be a part of decision-making
for such regulations?
Rajesh Krishnamoorthy:
It is desirable to have a body of financial advisors. Sebi
had even put up draft regulations some time back. This panel can take advisors’
feedback from the ground level and present the impact at the distribution level.
It would ensure that distribution becomes commercially viable and gives value-added
services to the investor. It’s important that the new scenario is favourable to
advisors, too.
Kayezad E. Adajania:
Won’t the drop in commission nudge the distributor to upgrade
himself?
Jaydeep Kashikar: For agents who are into this purely because it made business sense
[merely distribution, little or no advise offered], it is time to change. For the
next one-anda- half years, they could, perhaps, switch to insurance. But, what after
that? Kayezad E. Adajania:Is this the end of the transactionbased fee model? Jaydeep
Kashikar:It should be because till the time it is a transaction-based fee regime,
there is scope of churning. Entry loads may be zero, but there is an upfront fee
ranging from 0.25 per cent to 0.5 per cent, at times slightly more. Till the time
money comes from the manufacturer, there would be scope of wrong advice. Ideally,
the fees should be on the wealth managed.
Kayezad E. Adajania:
Ajit, your fund house does not believe in trail commission.
What about investors who need no advice, but a distributor who can do the running
around? What about distributors who do not have skills beyond collection?
Ajit Dayal: A distibutor can offer a menu of services, which could include just
a pick-up service. They [distributors with limited skills] will go out of business
or sell something else.

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Kayezad E. Adajania:
Then the investor will lose out,isn’t it?
Ajit Dayal: No, I think there are enough people who will happily pick up a cheque
from my place and drop it somewhere else for a fee. I don’t think that’s an issue.
Kayezad E. Adajania:
What are the key lessons to be learnt to ensure a smooth transition
to the new scenario?
Jaydeep Kashikar: Investors
should look at valued-added services rather than cheaper
services. Also, I think until misselling stops, it is better that theMF industry
doesn’t expand. If we go into villages and sell wrong products at the wrong time
and erode wealth, it is better we don’t penetrate. Let us have the right regulation
in place, let us have the right advisors in place and then think of penetration.
Asuper regulator overseeing all financial products, including MFs and insurance,
would bode well because the distributors won’t find an escape route to sell other
products if one is regulated and the other isn’t. It will bea win-win situation—MFs
and insurance companies could disclose their commission structure, financial advisors
charge what they feel they deserve, and the investors get the best kind of advice.
Ajit Dayal: I agree that you should not be selling bad products in rural India. I
am happy that penetration levels in India are very low because we have horrible
products to be sold. Implement KYC not just in terms of knowing your investor's
details, but also the investor’s mindset. Also, financial advisors should ask every
fund how much money can it manage without changing the fund's mandate to suit higher
inflows. The MF industry has reduced to being an asset-under-management game. The
real question is how much a fund manager can take so that the returns are not compromised.
I recognise the huge obstacles and resistance, but the regulatory environment looks
like it is willing to fight and convince the practitioners to protect investors'
interest.
Vikramaaditya: The financial advisor would need to engage the investor and convince
him that the fees that he will charge is for the value addition he will make. It
is incumbent on all the industry players to spread awareness with the regulator’s
help.
Rajesh Krishnamoorthy: The
distributor has to stop expecting money from the manufacturer
and start asking fees from the client in return of a service. Investors will need
to change, too, as they will need to find out the value addition that the advisors
have on offer rather than the quantum of rebate. This change in behaviour would
lead to a healthier financial relationship. |
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