What, No Load !!! What, No Load ??? - Simple Equation

What, No Load !!! What, No Load ???

Harish Rao - Sunday, June 21, 2009 5:08 PM

SEBI has just decreed that Mutual Funds in India will not charge a load. And many Financial Advisors have concluded that the epitaph in their tombstone has just been carved in granite by SEBI.

Having keenly observed and been an enthusiastic participant in the Investment Advisory business for more than a decade, there are two truths I firmly believe in.

  • 1. The Mutual Fund is the greatest financial product in India today. It has the ability to create and preserve the wealth of millions of Indians. It is truly egalitarian, convenient and has a tremendous sense of integrity in its design. It is also fortunate in having SEBI as its regulator. And SEBI has done a terrific job.
  • 2. The Mutual Fund Agent / Advisor has rendered maximum service and exerted the greatest of efforts in evangelizing mutual funds, despite the vagaries of the stock and money markets. The Mutual Fund Agent / Advisor - be it individual or institutional - has often received compensation that is a fraction of what their insurance counterparts have received.

So what is the fuss all about ? It's about the collision between the regulator and the distributor. For those not aware of what has happened, here is a three sentence gist : The regulator has abolished the entry load in Mutual Funds. This entry load (usually around 2.25%) was used to compensate the distributor. So now, investors get to enter for free, but will have to compensate their distributor with a separate cheque, at a rate of their discretion.

(Click Here for an earlier article on Variable Loads).

SEBI has clearly disrupted a perfectly well oiled business model. My sympathies with the distribution fraternity. This is a HUGE change. But SEBI must be having valid reasons for that. You bet. Foremost amongst them : Churning. Misselling. Skewed compensation to various distributors.

Do all distributors fall in this unsavoury category. Never. Just an unscrupulous few.

The Road Ahead

At this point in time, the path ahead seems unclear. Distributors have to shift to a fee based model and will have to make clients aware of their value. The clients on their part will have to realize that there is no such thing as a free lunch.

As I had said earlier, Mutual Funds are one of the finest financial products. I only hope that the best distributors continue their relentless pursuit of giving the finest advice and service. I also hope that some clients get over their mentality of discounting financial advice or trying to extract information for free. Every advisor should be adequately compensated for the energy and effort expended as well as education and counsel imparted. Not compensating an advisor satisfactorily would be the most unfair thing. But the moot point : Just what is fair? 1%, 3%, 5% or 0.1%

Knee-jerk Reactions

Some distributors I have met have predictably announced the death of the mutual fund industry. That is not going to happen. The destination remains the same. The routes have changed. All industries have to keep re-working the dynamics. Just ask Shah Rukh and Aamir. They have had to kiss and make-up so that Bollywood could do business with the Multiplexes.

What should the AMC do ?

The Asset Management Companies must recognize that this is a game changer. And not all distributors are equipped to handle the change. AMCs must initiate a dialogue with distributors and also inform their clients about SEBIs new rule. Clients must be made aware about the services they can expect from advisors and the necessity of engaging good advisors to achieve financial objectives.

AMCs also realize that they cannot afford disintermediation and that a robust channel is necessary to grow AUMs. Hopefully SEBI realizes this too.

As a strong votary of the Mutual Fund business, I hope SEBI, AMCs and Distributors work together to build a fantastic Asset Management industry in India. All the very best, everyone.

 

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33 Comment

From periyar selvam

June 21, 2009 6:17 PM
hi harish, i feel this move is more justified on SEBI side because they are to keep the MF industry more investor friendly and not advisor friendly.this change will make a positive impact on financial advisory services in india with the need of more CFP certificants.so the investor community can be served by more informed and skillful advisors than those who sell only NFO's in c class cities. lets face it

From Srikanth

June 21, 2009 9:52 PM
We at FundsIndia.com are very happy with this move. We provide an online transaction platform for mutual funds and provide value added services to the investor community in India. This move by SEBI is done with the investor's interest in mind, and we are delighted about it. Of course, I wish the insurance industry were as well regulated as well!! Oh well...

From Harish Rao

June 21, 2009 10:59 PM
@Periyar : I agree with the NFO viewpoint. I have one question for you : Will getting a CFP certification enable a fee based structure? @ Srikanth : I think online platforms as well as the touch and feel advisory model will co-exist for quite some more time. Yes, the Insurance regulator needs to address the huge fee disparity with mutual funds and a gargantuan one with the NPS.

From manoj shenoy

June 22, 2009 9:23 AM
This is a fallout of the excesses committed by certain private banks / distributors in good times. I feel its better to get into fee based structure as long as the advisor can justify knowledge based advise and value addition ( this will separate the men from boys ). However this decision will be hard on retail distribution houses who will be forced to get into financial planning module than just selling products.

From SEBI’s decision to abolish entry load to mutual funds in India « Planning With Passion

June 22, 2009 12:04 PM

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From kannan.k.v.

June 22, 2009 1:22 PM
Hi Harish,this move I feel is premature.Mfs are investment management products /services which offer market related returns.It is only appropriate that loads,commissions and charges levied should also be market driven and not in any other manner.In 1994 we had entry load of 6% and brokerage paid was 4%.However as the market expanded for MFs and competition increased in earnest both,load and brokerage , came down sharply.Similarly, from curent levels load&brokerage would have found their "correct destination" with cahnging market dynamics,hence, this move ,in my opinion is quite premature. Regards,Kannan.

From Harish Rao

June 22, 2009 4:14 PM
@ Manoj : The point about the excesses of the past causing all this is true. Red flags were raised even then, but people chose to ignore it. @ Kannan : Maybe this is SEBI's method of getting a 'market determined' pricing system going. I feel that Multiple Share class would have been a bridge between the old system and the new.

From Vikram J

June 22, 2009 4:56 PM
I think the insurance regulator should also make a move where the commission paid to agents and the addminstrative costs are clearly shown to the client. Bravo SEBI!! Is IRDA listening ?

From Balaji.K

June 22, 2009 9:33 PM
Hi Harish : Though this move will impact the distribution community in the short term, there would not be any long term impact. Bcoz : 1.The distributor will understand the situation and work for lower revenue. 2. The AMCs will try to compensate the distributor by either increasing the trail fee or giving volume based upfront. ( ranging from 0.25 to 1% ) ( There is a likely chance that AMC's bottomline will be affected ) 3. AMCs with big ambition of increasing their AUM( both small and large AMCs ), will certainly get more business going forward. Before I sign off, I would like to quote what has happened in the stock broking Industry over the last 2 decade. When I was working for a share broking company in late 80s' - early 90s' : They used to charge 2 to 3% for buying of a share and again 2 - 3% for selling the share. Now, stock brokers are charging 0.20 to 0.30% for delivery based buying / selling. The same situation will come to Mutual Fund too. Advisors should be prepared to charge a very reasonable fee in the range of 0.25 to 0.50% and try to negotiate with the AMCs for volume based upfront. ( as I mentioned in point # 2 ).

From Devang Badiyani

June 23, 2009 11:05 AM
Dear All, I am a distributor and let me assure you its hard to sell these products as compared to insurance ones through it is best for the clients. Now imagine if I have the option to choose A.Better for the clients but even the client does not understand its better for him. B.Client is not willing to give me a fee C.An insurance product easy to sell better remuneration to me Which one will i sell???? Thankfully I will still make an attempt to put the pros and cons to the client and let him take a call It's unfortunate that the same does not apply to other financial products in the personal finance sector Do you think some company will ask the deposit agent to collect the commission from the client ?? Just because an industry is transparent & regulated that does not mean that it should be screwed more,,, regards Devang Badiyani Regards Devang Badiyai

From Sumeet Vaid Ffreedom financial Planners

June 23, 2009 3:16 PM
Hi Harish I am in complete sync with you that this is market defining move in more than one ways. In my view we need to differentiate between Investment advisor and Financial advisor as in Investment advisor my core area should be Investment planning and hence I am servicing A need of my client where as Financial advisor my core area should be Financial planning and I am offering complete solution to clients financial freedom .As soon as we get this equation clear to me current Sebi regulations on load becomes a great opportunity as it legitimizes the Fee concept and that precisely is my experience with families that[ charging fee is ok if you are adding value by giving solutions not problems].

From nishikant rotkar

June 23, 2009 4:01 PM
Nishikant Rotkar: "Instead of finding the remedy for the disease SEBI is trying to kill the patient" I am really surprised why SEBI is so bothered about the 2.25 per cent brokerage paid to distributors (I am talking only about individual and small distributors). After deducting service tax & education cess it is 2 per cent in most schemes. NO ENTRY LOAD decision assumes: 1] The whole Indian population is highly educated , fully aware of financial markets and has an in-depth knowledge of MFs; 2] Mutual fund (MFs) industry has reached to every corner of the country, just like post offices; 3] MF. has country wide network in every city & smallest of the town as the banks in India have 4] MF offices are is easily accessible in every part of the country; 5] Almost 60 years since independence, insurance penetration in India is one of the lowest in the world, but the same population is highly intelligent and fully aware when it comes to MFs; 6] Because of high penetration of MFs, there is no need to pay even 2 per cent to distributor; 7] Investors can approach MF offices, there they get very IMPARTIAL advise -- that their funds’ performance is not so good, so kindly approach ‘XYZ’ AMC and invest in their products; Because of all these reasons there is no need of any DISTRIBUTOR to work. In my opinion no entry load decision will help only 3-to-5 per cent of investor community which is well educated, well informed and lives in big cities, but totally KILLS the product and the DISTRIBUTOR too in small cities and towns. This decision is like a sword given to investors. Only 5 per cent of the financially aware investors’ community will use it properly, while rest 95 per cent of the people, who are totally financially illiterate will misuse it and harm the distributors. On one side SEBI says that small investors should be the focus of MF industry, but on other side it is trying eliminate individual distributors who are their only representatives in small cities and towns where there is no MF office. Just by opening offices in selected big cities, you cannot reach out to the common people. MFs have zero presence in most part of the country. The only representative they have there are individual distributors working against all odds. If you are not ready to pay even 2 per cent commission, then this tiny presence will also vanish. No entry load decision is taken only for the benefit of high networth individuals (HNI) and corporate clients. It will benefit high profile investors but it is against the small investors because no individual distributor will work aggressively as there is no proper commission and future prospects are bleak. If SEBI has a problem that funds are not sold with transparency and distributors unnecessarily churn the funds, then it can start investor education programmes/seminars or give advertisement in media to avoid mis-selling by distributors. Lock-in periods can be made more stringent and exit loads can be made more restrictive to avoid early redemptions. Instead of finding the remedy for the disease SEBI is trying to kill the patient. Everybody knows that MFs have the least expenses, still small investors are opting for ULIPS to invest in, which carries expenses/allocation charges up to 80 per cent in some cases. If that small investor is still not aware/caring/bothered about the vast difference between 30-to-80 per cent load in ULIPs and just 2.25 per cent in MFs, then what is going to change even if there no entry load. In last 5-to-7 years, private insurance companies have reached into every district and tehsil, but AMCs are limited only to certain cities. Distributors from small cities have to face huge problems in processing the purchases, redemptions, or any transactions. They have to bear courier charges for every transaction to send the documents to AMCs. Every transaction gets delayed by 2 – 3 days because of this. If you want to grow the mutual fund industry, the focus should be on investor awareness, expansion and penetration of the industry in small cities, which can not be done without the help of distributor.

From Neelesh

June 24, 2009 9:33 PM
No load funds, sounds like a lot of simple stuff to a few in the advisory community. I really wish that everything in our lives had a no load / 2 cheque concept. For the bread that one buys, the cars that lot of us drive and the fruits that we consume...... Try talking to the manufacturers / wholesalers / growers to give you the product that you want at zero or no cost and try to compensate the shop guy with a margin of profit arrived at, by mutual consent. While we talk about all these products, we may feel that they are not at all similar to the financial products in any which way. Please understand, SERIOUS, financial planners / advisors are people who keenly follow business developments of all over the world irrespective of the industry. There is a good amount of time that is spent in reading, deciphering, understanding and simplyfying the entire gamut of business for the benefit of the investors and the public at large. No entry load for an industry which is about Rs.5.00 lac crore and only a decade and a half old. Developed markets have this concept of variable / no load after 50-60 years of the markets being in existence. In the developed markets more than 50% of the citizens invest in mutual fund schemes. In our country, we have 3-5% of people who invest in the stock market or related instruments like mutual funds, ULIP's etc. With every bear market this number fluctuates downward and picks up with every bull market. This number is not increasing in spite of having the biggest bull run from a 3000 sensex through 21000!!!! I think SEBI with the no load scheme is on its way to stifle the growth of this industry, in support of a few vested interests. If the interest of the general public at large is the real concern, then this step is going 2 steps back. Just a final thought. Financial advisors / intermediaries / planners etc are reducing the headache of the government to a very great extent. Being in the business they are self employed, generate business, pay lots of taxes like service tax, income tax, sales tax, road tax and so on. If SEBI wants all the people in this industry to work for free, then this proposal is in the right direction.

From rk

June 25, 2009 9:24 AM
What the fuss is all about!!! When the system changes, there is bound to be some reservations from one side or the other.Now the question is whether we have an alternative.The answer is yes , the AMC must be prepared for shedding some of its gains to the distributors and remember that this is not a small amount. As market matures , more and more people will be learned enough to make their own decisions and may not require anybody's help.what will happen at that time? So this is the time to move from the existing system to the new one and moreover SEBI is there to protect investors money from the financial goondas ( read as highly educated so called financial experts who make money from hard earned investors money)

From Harish Rao

June 25, 2009 10:08 AM
@ Vikram : Absolutely. IRDA must bring about parity. While it may seem all to 'clever' now; in the long run, Insurance Industry will be better off with complete transparency and lower charges. @ Balaji : Brilliant observations. Great assessment of how even AMCs may respond.

From Harish Rao

June 25, 2009 10:22 AM
@ Devang : Spot on. As Damodaran, former SEBI Chairman said, 'Sunlight is the best disinfectant', SEBI's insistence on transaprency cannot be questioned. @ Sumeet : Nice point. But honestly, how many differentiate a Financial Planner / Investment Advisor / Counsellor in the manner you have prescribed. A few Advisors / Planners have thoroughly abused their title.

From Harish Rao

June 25, 2009 11:09 AM

Nishikant : Agree with most points. But I don't think SEBI is wanting to deprive distributors of commission. You are technically free to charge wht the market can bear. Also I think ULIPs are popular NOT ONLY because customers want it, but ALSO because many distributors chose to push it. And how. No denying that. If distributors do not agree to this, then it is a case of Denial. And Denial can only lead to dismay and disappointment.  

From Harish Rao

June 25, 2009 11:22 AM

@ Neelesh : Persuasively put.However, the reality is that the rules have changed a bit. I am sure many Advisors will re-boot and be as effective in a fee based model as well.

@ RK : Yes. AMCs will have to step in. I am sure many have already drawn plans to help the intermediaries. 'Financial Goondas'. Nice term.

From nishikant rotkar

June 25, 2009 6:13 PM
even in fixed income/ guranteed return products like PPF,NSC,RBI BONDS there is a commission upto 1% to agents. in these products there is no need to advise anybody as the structure of the product & returns are fixed. MF is a risky product very few investors are self motivated & informed to invest in such product. so it is the role of the distributor to reach to such people.no product can survive for long without aggressive maketing push. no matter how best is your product. best example NPS ( new pension scheme). it is the latest example of what can happen to 'THE BEST'product in absence of proper marketing. those who do not need any advise & service are free to go by direct mode. u can not generalised any decesion for all. it may be good for particular class of people who are well educated, well informed people in big cities but it may very harmful for investor in small cities. the term 'Financial Goondas' i also like that term. but remember u can find such Goondas in each & every profession & sector. noble profession of doctor is also not the exception. for less than 10% of such Gondas, dont harm to other sincere people. the system to take fees by cheque/ cash from investor is highly impossible particularly in small cities. as investors are totally fianancially illitrate they will not understand that system. instead they can ask us, why we need any fees when they are giving business to us. MF industry is stll not matured to adopt advisory system. may be there is some class in metro cities who dont need our services then they are free to invest through direct mode. no small investor is worried about 2.25% load. i have yet not questioned by any investor regarding entry load. they appreciate us when we give comparison betn MF load and other high load products.

From nishikant rotkar

June 25, 2009 6:23 PM
mr. harsha rao has said that distributors are technically free to charge wht the market can bear. he use word technically. yes it is possible technically,but not practically for majority of the distributors.

From Harish Rao

June 26, 2009 9:02 AM

Nishikant : Point on Technical vs Practical is well taken. I agree, it may be practically very difficult. However, as can be seen some advisors don't see any problem in charging fees. Also, the Direct threat is in my opinion overblown. Less than  5% of applications is Direct.

From Dipankar Pattnaik

June 27, 2009 9:51 AM
What happens when you deal with small investors e.g. Rs.10,000/- - Rs.20,000/- annually. The advisor either shuns them or charge heavily. There are many in that segment who probably need equity exposure more than anyone else but have very limited or no knowledge of the markets at all. A businessman will always find a way to be in business, you call him a Goonda or find another word even more derogatory. Of course now on the financial advisors have to start understanding and evaluating their services and elevate themselves in value.

From nikhil

June 27, 2009 8:56 PM
Just want to know whats the plan for the future. How will mutual funds industry cope with this sudden loss of man power. What strategy will the fund house's adopt to bring in new investors and to serve the existing once. Perusing CFP.

From Harish Rao

June 28, 2009 12:51 PM
@Dipankar : Yes, there could be a problem of intermediation for the small ticket investor. But don't be surprised if the retail oriented mass distributor comes up with something innovative. @ Nikhil : Where is the loss of manpower? The men are there, but the power seems a bit weak, for now. It will bounce back, I am sure.

From Shanoj

July 1, 2009 11:45 AM
Mr. Rao, The SEBI directives might be a matured one but do you think our markets have the kind of bandwidth to obsorb such a move.SEBI is much ahead of times. What would AMFI/CFP certification mean anymore? Why are we ignoring the retail aspect of MF business, with penetration of household savings in equity being so low as compared to devoloped economy, it completely discourages retail participation. The percentage of investor community who would pay for advise consciously is a minority( It would pain the investor when he cuts a cheque of 2.5 lacs while making an investment of 1 crore everytime and neither will a retail SIP investor). All those who have commented above would have dealt with the menace of payouts in their careers, Imagine turning the tables. Yeah I agree, we need to move on and show will continue but the thin margins and high cost of operation would take its toll. Financial goondas is a frankenstein created by AMC's, now they want the monkey off their back. Thanks to recklessness of the so called private bankers (I am not sure if RK was referring them:))

From Harish Rao

July 1, 2009 12:38 PM

Shanoj : Yes, the penetration of equity is dismal. But I wonder whether re-imposing the load will improve it. Equity penetration was low because the cost-effort-reward ratio was always unfavourable. This improved drastically with ULIPs and look at insurance penetration.

From Dipankar Pattnaik

July 1, 2009 5:11 PM
The insurance penetration is high, much better than a mutual fund. Shouldn't SEBI be looking at making the banking convenient in rural areas. That would increase the participation in mutual fund much faster than the current No Load regime.

From VikasK

July 3, 2009 11:20 AM
I have been a private banker at a large Indian Bank and a customer of MFs for nearly 7 years. I feel the point no 2 in your post highlights the unholy nexus between Fund Houses and Agents and is actually a bane for customers. a) Most agents in the MF game offer bad advise. The employees themselves know no better than their customers b) They have no shame in churning portfolios or advising clients without trying to understand their needs and situation in life. Banks and Organized Agents are the biggest culprits. In an ideal world such a move should force the intermediaries to use their brains to 'earn' their fees. I am sure, however, that Fund Houses will find a way of robbing customers and compensating agents, SEBI or no SEBI.

From Bingo

July 4, 2009 12:41 PM
The distributors say that: 1. Investors in India never want to pay for advice. 2. After the no-load for direct investment route was established, 5% investments happened direct and 95% still through distributors. If these 2 are correct, we can safely conclude that the investors were not aware of the entry load. The mechanism of investment was such that 2.25 was "secretly" deducted from investors' money and the rest was invested. This is nothing but theft. If they were aware of this charge, investors would have definitely invested direct because, as distributors say, investors never want to pay for advice. Also, distributors being given a percentage of the total investment seems too much. Effort of the distributor are same whether the investment is of 500 monthly SIP, or 50000 monthly SIP. In both cases, someone is entrusting the distributor with, say, 20% of their monthly income. Why then should payment be so different. Because of this, distributors currently only chase rich people and poor people are shunned. I think investment should also move to the fee structure of doctors: fixed fees for an appointment.

From nishikant

July 4, 2009 2:24 PM
to bingo, how can u say that 2.25% entry load is secret/ hidden. if u see a account statement, it clearly mentions current NAV, then % of entry load, then comes applicable NAV ie current NAV + load. after that no. of units alloted against invested amount. also in every statement of account,there is line which mentions entry load 2.25 for amount below 1 cr/ 2cr etc, no entry load for direct investments. how much more transparency u need. can u show me recepit of any insurance company/ ppf/nsc which clearly mentions how much amount is deducted to pay the agent. majority of the investors have no problem with 2.25% load. if they secretly charged then it is in ULIPS not in MF.

From Harish Rao

July 4, 2009 4:49 PM

@Vikas : I am afraid you are generalising too much. Having been in the industry for a decade, there is certainly no 'unholy nexus' between Fund Houses and Agents. Also, many of the Agents and distributors I have met are fine people whose advice and counsel are terrific.

@ Bingo :  Nothing is secret in this business. The client just has to ask and he can get all the information. The Asset Management business is certainly more transparent than Banking, Insurance, Real Estate or Stock Broking.

@ Nishikant : Well said.

@ All : The AMC industry may be down, but certainly not out. I wish such activism is shown in say, the Real Estate industry. Fat chance.

From Anoop

August 7, 2009 4:51 PM
But one should also understand that what is the service being provided. In India there is nothing called service. If people are filling forms for you - thats your service. There is so much information available online on each fund .. one can choose and decide. Theory and gut feeling. Compare this with absolutely unqualified (some loser) charging you for your lazyness. Once this entry loads has been banned all banks are shutting down their mutual fund distribution business. Cause they know, their staff doing the advisory are just CLERKS filling up forms with ABSOLUTELY NO CLUE of which fund will do well and WHY. BET THEY WOULDNT EVEN KNOW THE FUND MANAGER, Portfolio etc. WHY SHOULD I PAY FOR A COURIER GUY. I can transfer funds online. WAY TO GO. just need to ensure these websites dont crash .. cheques going to wrong address/ acs which i think in service industry in india is ACCEPTABLE.

From R.Lakshman

August 10, 2009 1:01 PM
Dear Mr. Harish Rao, I congratulate you on your eloquent advocacy as a devil’s advocate for SEBI on the issue of entry load abolition and transition to a fee based model. As a senior investment advisor in the field for more than 27 years, I am not against introduction of a fee based model. But my reservations are over the manner in which SEBI has gone about it. It has essentially unbundled the role of a distributor into two – one as an advisor for which a negotiated fee model will arise and the other as a distributor where he will be compensated by the fund - house as a distributor for his services. To my mind, distributor is a businessman who acts in his own interest for a profit. Whereas an advisor is one who acts in his client’s interest for a fee. In the first role as an investment advisor, he has to align his interests with the interests of his clients and fulfill his role responsibly in the best interest of his clients. As a distributor he has to sell the products of the fund house in terms of the expectations of the fund - house as per his distribution contract with them. These two roles are essentially adversorial in character and it is very difficult to perform the two roles with fairness and equity. In the earlier scenatio, it was possible for the distributor if he so wished, to waive the fee for the advisory role on informing the client that he was not charging any fee for his advice since he was compensated by the fund house for his services. He also had the opportunity to sell the products of the fund houses he rated high both in terms of service and performance. Some advisors even earlier charged fee to their clients when they believed that they were providing value added services. In my opinion, SEBI could have transitioned to a fee based model in an altogelner different manner. It could have mandated that licensed advisors fulfilling some prescribed criteria will only be permitted to act as mutual fund advisors for a fee. They need not be empanelled with any fund house but could offer advise on which fund and which fund product to invest in, complete the investment formalities and direct the client application to the fund house. The system of licensing suggested is something similar to the Bar Council and Medical Council licensing Lawyers and Doctors respectively. This is akin to a Doctor licensed by the Medical Council practicing on a fee based model subject to a code of conduct prescribed by the Council. He advises patients with due care and diligence for a fee and is no pharmaceutical salesman. There could be another category of empanelled distributors who will sell mutual fund products for a commission paid by the fund - house and they should be prohibited from charging any fee and the cost of distribution will have been prized into the product. This system will have avoided conflict of interest as well as met SEBI’s objectives of transparency and investor empowerment.

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