My latest blog on SEBI's recent directives on Mutual Funds is
here. The post follows:
Assume we are living at a time when we
still used boats to travel long distances. Imagine a large, leaky boat
about to set out on a stormy sea. Imagine that this boat is about to
make a journey that in the normal course will last over a year.
Additionally, the boat has had a history of capsizing a few times in the
past, often taking with it the passengers. However, each time, the
owners are able to pull the boat out from the sea put up a few patches
and declare it seaworthy. It would seem obvious that tickets for the
trip would be hard to sell especially to people staying in the vicinity
of the port of launch.
Now imagine that there is a
regulator whose job is to protect the passengers. The regulator is
charged with certifying the sea-worthiness of the boat so that the
passengers have a safe journey. Over the years, seeing that the boat has
not proven to be particularly safe, the regulator declares that all
passengers have to decide for themselves what the journey is worth to
them. Sellers of tickets are to be paid for their services directly by
the passengers not by the boat owners. Meanwhile, the seas become
stormier, and ticket sales fall.
The boat owners now
demand that the ticket prices should be raised (They obviously form a
cartel if you want to use the boats, you have to deal with them). This
extra money is to be used partially for rewarding those who sell tickets
to passengers. Importantly, more money is to be paid to those sellers
who sell tickets to unsuspecting passengers, who live far away, and are
therefore less likely to have heard of the experience of earlier
passengers. Even more intriguingly, passengers who have already bought
the tickets should be charged extra every time a "new" passenger from
afar agrees to board the leaky boat. What should the regulator do?
It
could of course ignore the lobbying of the boat owners, and insist that
they spend money building a more robust boat. It could insist that boat
owners pay more to cartographers who can help determine a less risky
path to the destination. It could insist that buyers have a right to
know that that besides the boat, there were other less dangerous paths
to the destination as well. It could mandate the creation of boats that
are safer. It could insist in fact, that their primary mandate was to
protect the passenger, and not the well being of the boat owners.
What
would you say of a regulator that instead, agrees whole heartedly with
the boat owners, caps the payment to the cartographers, increases the
price of the tickets and increases incentives for those getting
unsuspecting passengers to the boat even forcing existing passengers to
pay more. Who am I talking about replace "boat owners" with "Mutual
Funds" and you have your answer.
Undoing its own logic
In
2009, SEBI decided to ban entry loads for mutual funds the argument
then was that investors should determine for themselves what services of
"fund advisors" people who sold them funds was worth to them.
Investors could decide how much they would pay. A laudable objective.
This
change effectively killed a whole range of distributors where clearly,
the investor did not feel that enough value was being added to be worth
paying. Inflows into equity mutual funds fell as well.
The moot point is whether the inflows fell as a result of
poor market and fund performance or because of a lower distributor
base.
A look at the graph above shows that the
problem is not that the assets did not increase. Just that equity fund
assets did not grow. Most equity funds in the period post the ban of
entry load (August 2009) have delivered poor returns to investors
(category average for 3 years for equity large cap has been 4.5% per
annum while even liquid debt funds have delivered 7% per annum). Since
the equity markets have performed poorly, long-only funds too have
performed poorly some more so than others. Long-only refers to a
situation where fund managers are only allowed to buy before they can
sell. An alternative would be to sell first and then buy back at a lower
price if the market were falling. Almost all mutual funds are
"long-only". In such an environment, would it be expected that there
would be a rush of investors into equity funds? Not in the view of this
writer.
What therefore was the rationale to re-impose
the entry load which is what SEBI has mandated as per its latest
guidelines? Under the guise of increasing investor participation, SEBI
has made the following changes (a) entry load has been increased if
mutual funds were to raise money from centres other than the top 15.
Astonishingly, it has allowed mutual funds to charge the extra load to
other investors of the fund as well not only the far-away ones (b) it
has passed on the service tax that was earlier paid by the asset
management company to the investor (c) it has capped the brokerage that
can be paid to the broker who provides research and trade execution to
the fund house and incidentally provides the fund manager the inputs to
enable him or her to make investment decisions after considering
multiple view points.
The product is faulty, not the sales effort
First
and foremost, SEBI could have allowed mutual funds to have investment
styles which are not only "long-only". The market offers enough
instruments today to allow a skilful fund manager to trade both ways
and generate "alpha". By allowing manager to only buy, the ability to
sensibly exploit shorting opportunities is unavailable to managers. The
recent Alternative investment fund guideline is a step in direction of
allowing shorting as well, but the large ticket size per investor
(currently Rs 1 crore is the minimum per investor) is a big entry
barrier.
Another could have been the ability to
manage a multi-asset fund. Here of course the plethora of regulators
offers an impediment. So we have the strange conundrum that each
individual can be a "multi asset class hedge fund" by himself there is
no bar for an individual to trade in equity, commodity, currency, gold
or real-estate, but no investment professional or fund house can offer
such an investment vehicle to investors. A mutual fund cannot invest in
commodities for example an asset class that has done well in the same
years that equity has performed poorly. But if this is the problem,
should it not have been addressed?
Clearly this is a
case where the wrong question has been posed and answered. Many
representatives of mutual funds and distributors would have presented
their view points to SEBI. I wonder how many investor associations did.
The views expressed are the personal views of the author.