Our response to your comments on our Axis fund call

We upset a few of you with our call on some of the Axis funds last week ๐Ÿ˜Š Some of you commented on the blog and others raised tickets. We thought it would be better for us to respond through an article for the benefit of others as well. 

Here are a couple of sample comments from folks who seemed pretty disturbed.

โ€œFrankly, Iโ€™m little appalled by your call โ€œexit on Axis Smallcapโ€. You are not a weathercock, are you? You are an analyst. There has to be some gravity in your analysis. Yes, as an analyst you run risk of being told โ€œwhy you did not warn usโ€, so warn if you need to. An exit call now is so premature as to promote flip-flopping. If anything, the Franklin debacle has proved that investors got fair returns on investments, albeit with protracted wait. I think you must have qualified who needs to exit and who does not rather than promote a scare among concerned investors. Do your job and your job is not scare mongering.โ€

โ€œI am afraid that your analysis is half-hearted. It seems you want to stay aloof when it comes to riskโ€.

***

Franklin was an incident that was unfortunate to happen to debt funds in the MF industry. Prime Investor panicked and told investors to redeem even from equity funds. Are the equity funds not performing well? The funds in question with Axis MF is between 0.01% and 0.04% of the industry assets. We have seen issues with banks, corporates, etc. and the same will continue in future. Will there not be any problem with other AMCs in future? Can the regulator guarantee that all issues with AMCs be monitored stringently to ensure that no issues would arise in future? If we are scared of such risks, then retail investors should not be investing in Mutual Funds.

Please post crisp articles and give a clear message that is helpful to investors at large instead of scaring them.โ€

We had this and several other comments and queries. We thought we could list our responses here together.

Our response to your comments on our Axis fund call

#1 Comparing with the Franklin episode

Comparing the current Axis issue with the Franklin event, in our view, is not quite right. The governance issue involved was significantly different. Franklin was a case of an AMC reneging on the promise of liquidity that is given by any open-ended fund to a retail investor. It closed its funds without any warning or approval. It did this at a time when other AMCs were also facing the liquidity issue in the debt market.

It did this because it took credit risk across its funds, irrespective of the duration of the fund. It did this knowing liquidity can be a big risk in the Indian debt market. Yes, liquidity is a big risk that investors take in bonds. But not in mutual funds. 

Next, our first call on Franklin debt funds dated back 2 months before the Franklin fiasco happened. We gave our call based on some of their fundsโ€™ exposure to Vodafone papers. It was a proactive call. Second, some of the Franklin equity funds were already a sell in our tool. 

The reason we stopped rating the fund house post the event was a qualitative call, given the way the fund house had handled the issue. We did not think the fund house would close down but we did mention management change as a risk. The fund house has also lost equity fund managers since. 

We had no reason to panic. We were simply using the stick we could, batting for the small investor, for what we considered as an unfair practice by an AMC โ€“ that of punishing retail investors, many of whom had their income portfolios in those schemes. 

But yes, the Franklin AMC issue is indeed a good example of why exit is a good course when governance issues are flagged. Yes, people received their principal back – after a 2 year wait with marginal 3% returns after losing their liquidity! We certainly want our subscribers to have a better experience!

Axis AMCโ€™s allegations are of a far different kind โ€“ squarely based on unethical and illegal business activity by individuals in the firm for frontrunning of stocks. A comment in our blog that said these are part of market risks is a wrong notion and should be dismissed.  Mutual funds are subject to market risks. Investors do not come in fully expecting risk of fund managers frontrunning stocks! 

Yes, there is a regulator to protect the investor from risk of fraudulent and unethical business practices, but no regulation is foolproof, and investors therefore end up facing risks outside of market risks. Our job as analysts is to reduce such risks post-event, where we have no way of identifying them pre-event (like we did with Franklin). 

The Axis issue is not one where your money will be locked and returned later like Franklinโ€™s. But it is one where you may lose money. You may see losses as flight of money in equity is swift in stocks where front-running is rumoured. Here, there is no question of the AMC returning such money or making good the losses – it becomes a market risk. So, the risk in Axis is that of real loss of money or loss of future returns.

#2 On our seemingly โ€˜hastyโ€™ call on Axis funds

Some of your reactions range from accusing us of scaremongering, giving half hearted calls and being weathercocks ๐Ÿ˜Š 

First, we acknowledge (and in our recent article on our call too) the superior performance of many Axis funds. We have not issued the calls as an immediate reaction – we have deliberated much before doing so. Many of you had been writing to us from the day the event was publicized on what you should be doing, but we decided to take our time to respond. 

We did this to understand outflow patterns, stock hits, performance etc. We studied the portfolios of the funds to weigh the risk in each of them as far as NAV hits from stock falls or stock liquidity issues were concerned. We considered performance in cases where performance was already showing concern. We did all this as our intention, much as you may think otherwise, is not to unnecessarily scare you or cause too much churn in your portfolio. 

Second, we clearly outlined 4 risks that may emerge due to market rumours and fear, even if this does not become a full-fledged corporate governance issue. Those risks (that we have detailed in our earlier article) are:

  • Redemption pressure
  • Impact cost on illiquid stocks
  • NAV hit from stock fall
  • Poor inflows

This apart, when a fund undergoes such allegations, future inflows also get impacted. We weighed the challenges arising from this against future performance, in relation to their peers. We considered only those categories where this risk was higher. Yes, none of these risks may materialise. But when risks are evident, why get stuck with these funds when you have other options? 

And therefore, our calls were to mitigate the risks in your funds. Our calls were also only on those funds where there was a higher risk of performance taking a hit. We have not made an AMC-wide call. We gave an exit call on just one fund. We moved two others to a hold. If we had half-hearted calls, we would not alert you in the first place๐Ÿ˜ŠIn fact, it would be half-hearted if we acknowledged the risks and then asked you to decide what to do for yourself โ€“ having issued the original investment recommendation!

Whether the risks transpire or not is not something we want to assign weights to, because there isnโ€™t enough information to do so. 

But when we take these calls, we gladly prefer to err on the side of caution. At PrimeInvestor our philosophy has been to deliver returns but by first cutting down risks. Churning a portfolio and paying nominal taxes (for equity funds) is a small price to pay and it does not hurt much at a time when some profit booking is a sane thing to do in the current market environment. 

We take our mission of protecting and growing investor portfolios seriously. Taking such difficult calls, when they are merited in our opinion, underscores the independence of our opinion and sincerity of our efforts.

#3 On our risk strategy and why we go against buy-and-hold

One of the questions we had was what risk management we had in place to identify such events. Honestly, we can try (not always) to identify risks in the portfolio. But frankly, to identify front-running activities is beyond our capacity as these are per se activities done without leaving much trace. 

Where we can identify risks is in portfolio quality. Credit risks, poor investment decisions, concentration risks and such are somewhat identifiable. We place weights to such risks in our ratings. We do have a mechanism of identifying credit downgrades of instruments in debt funds, AUM loss, checking for liquidity in stocks of equity funds and so on. We do watch performance change and portfolio change when fund manager changes happen. 

Next, on the buy-and-hold strategy – we urge you all to read what we think about this strategy here.  We are not sure why there is so much furore about exit calls. Most of you ask us about profit booking when funds perform well. But when we highlight possible risks, we are accused of churning or creating a scare! 

Folks, donโ€™t get too attached to funds. Get attached to your portfolio. Compounding rewards you, as long as you stay invested. It does not treat you any better for sticking to the same fund!

More like this

30 thoughts on “Our response to your comments on our Axis fund call”

  1. Hi, given the developments or lack of, in the past 3 months, would you revisit your recommendation on the Axis Small cap and Midcap funds? What would be your threshold to consider the risk as passed?

    1. Unlikely sir. There are enough options. We will wait to watch fund flows and performance. Vidya

  2. Hi Vidya,
    Thanks for the call and for responding again to explain the reasoning. My initial thoughts were the funds affected are different, so I shouldn’t bother. But then after going through this article, I thought I better be safe and should not be attached to the fund names. I haven’t exited from Axis Small Cap but stopped my SIP.
    In the email I got from Axis confirming my SIP stoppage, I see the below quote in their email Signature. I think I am being ‘responsible’ by stopping my SIP at least based on the news and not 100% transparency from the fund.
    “Markets don’t create Wealth, Responsible Investing does”

    Regards

  3. Everyone doesn’t understand the fine details of money matters and as a leader / guide its the responsibility of PI to raise a red flag at the correct time.

    If one feels that the call given is wrong then it’s their wish to follow or reject that call. Some of us redeemed all the money from all schemes, some – only from the red flagged scheme and some didn’t withdraw at all. It’s completely our own wish. No need to badmouth the guide.

    It is something like paying a doctor and then questioning the doctors instructions. If we have paid and come to doctor, then it means that we agree that the doctor knows better than us. And therefore its prudent that we follow the orders of that doctor.

    Kishan

  4. I fully appreciate your stands in both Franklin and Axis issues. After all a good investment strategy necessarily includes protecting one’s capital. Your role is to identify not just investment opportunities but also suggest timely exits. Some of your calls may look ill timed with the benefit of hindsight. But at the time they were made, I think all available information was taken into account and a stand taken.

  5. I agree with Prime speaking from a neutral position. I am sure you have nothing to gain, by giving a red alert . As Investors we are always paranoid when it comes to negative news , since we keep hoping that luck is always on our side. It is something like betting that CSK will always be the super winner!!!Beware all kings ( Kohili, Rohit, Dhonl, Jaddu fail one day )

  6. Ms. Vidya Bala, As on date, one year return of Axis Long Term Equity ELSS fund is negative 1.5% which is worst among 95% of all mutual funds scheme. Did you notice that on the day of this Axis saga broke out a month back, this ELSS scheme fall by 4.5% as against 1.0 – 1.6% all other schemes? What are your comments, as this scheme is in your recommended schemes for long time and has Rs.32000 crore AUM?

    1. Hello Sir, that fall is in line with market fall. Please see the table where we have given the fund fall along with market index fall and AUM fall. That will help clarify. AUM is not a concern for large-cap biased funds. thanks, Vidya

  7. Respected Madam,
    You only analyze the situation. Decision will be taken by paid subscribers. Your previous article is not panic creating one. If you have panic creation intension, we should not have trust on your channel. The situation is changed as and when required in stock market. There is no rule of stick to fund.

    SANDIP BOSE

  8. @kshah1984 Yes, not going to exit the best performing smallcap fund as well. One needs to think about various factors such as taxation against the perceived risk. In case of Franklin, except for the specific funds that were affected, I believe all other funds are still available in the market. It would be interesting to see how their performance got affected, if at all. Hope SEBI heavily penalizes the erring fund managers so that others dont even think about it.

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Refunds: There can be no cancellation and refund of subscription fee paid once the subscription is active, other than as stated in Clause 8 of these Terms. If the client is entitled to a refund as specified under Clause 8 of these Terms, the RA will credit that refund to the card or other payment method used by the client to submit payment, unless it has expired - in which case the RA will contact the client to proceed with the refund. If we do issue a refund or credit due to circumstances outside the obligations specified under Clause 8, we are under no obligation to issue the same or a similar refund in the future.

General disclaimers: The recommendations made herein in the Research Services are expression of views and/or opinions and should not be deemed or construed to be advice for the purpose of purchase or sale of any security, nor a solicitation or offering on any investment/ trading opportunity on behalf of the company, AMC, insurance company, or issuer of security referred to herein.

The content and research reports generated by the RA does not constitute or is not intended to constitute an offer to buy or sell, or a solicitation to an offer to buy or sell financial products, units or securities.

The information/ opinion/ views mentioned in research reports or by the RA are not meant to serve as a professional guide to the client or recipients of this Report. The research report, recommendation, or any other content published by the RA do not assure or guarantee any minimum or fixed returns to the client or recipients of the reports/ recommendations/ content.

Use of this information is at the clientโ€™s own risk. The client must make his/ her own investment decisions based on his/her specific investment objective and financial position and using such independent advisors as he/she believes necessary. The services rendered by the RA are on a best-effort basis. All information in the content or research report of the RA is provided on an as is basis. Information is believed to be reliable but the RA does not warrant its completeness or accuracy and expressly disclaim all warranties and conditions of any kind, whether express or implied.

While due care has been taken to ensure that the disclosures, information, and opinions given are fair and reasonable, PrimeInvestor Financial Research Pvt Ltd and/or none of its officers, directors, partners, employees, agents, subsidiaries, affiliates or business associates shall be liable for any direct, indirect, special, incidental, consequential, punitive or exemplary damages, including lost profits arising in any way whatsoever from the information/ opinions/ views contained in the research report and recommendations that form part of the Research Service, and/or mails, social media or notifications issued by PrimeInvestor Financial Research Pvt Ltd or any other agency appointed/authorised by PrimeInvestor Financial Research Pvt Ltd. Returns and performance figures mentioned in the research report represent past performance and should not be constituted to be future returns or guaranteed returns.

Any agreements, transactions or other arrangements made between the client and any third party named on (or linked to from) the Website are at your own responsibility and entered into at your own risk. Any information that you receive via the Website, whether or not it is classified as โ€œreal timeโ€, may have stopped being current by the time it reaches you. Market price information may be rounded up/down and therefore may not be entirely accurate.

The purpose of these disclosures is to provide essential information about the Research Services in a manner to assist and enable the prospective client/client in making an informed decision for engaging in Research Services before onboarding.

History, present business and background: PrimeInvestor Financial Research Private Limited is registered with SEBI as Research Analyst with registration no. INH200008653. The Research Analyst got its registration on August 19, 2021 and is engaged in offering research and recommendation services.

Disciplinary history: There are no pending material litigations or legal proceedings against the Research Analyst. As on date, no penalties / directions have been issued by SEBI under the SEBI Act or Regulations made thereunder against the Research Analyst relating to Research Analyst services.

Details of the RA's associates: No associates.

Usage of Website Content: This Website is controlled and operated by the RA. All material, including research reports, recommendations, portfolios, ratings, lists of financial products, illustrations, statements, opinions, views, photographs, products, images, artwork, designs, text, graphics, logos, button icons, images, audio and video clips and software (collectively, โ€œContentโ€) are protected by copyrights, trademarks and other intellectual property rights that are owned and controlled by the RA or by other parties that have licensed their material to us.

Except where otherwise agreed in writing with the RA, material on the Website is solely for the clientโ€™s personal, non-commercial use. Except as provided below, the client must not copy, reproduce, republish, upload, post, transmit or distribute such material in any way, including by e-mail or other electronic means and whether directly or indirectly and the client must not assist any other person to do so.

Without the prior written consent of the RA, modification of the materials, use of the materials on any other web site or networked computer environment or use of the materials for any purpose other than personal, non-commercial use is a violation of the copyrights, trademarks and other proprietary rights, and is prohibited. Any use for which the client receives any remuneration, whether in money or otherwise, is a commercial use for the purposes of these Terms.

The client may occasionally distribute a copy of a research report, or a portion of the same, from the Website in non-electronic form to a few individuals without charge, provided the client includes all copyright and other proprietary rights notices in the same form in which the notices appear, original source attribution, and the phrase โ€œUsed with permission from PrimeInvestor Financial Research Pvt. Ltd.โ€

While the client may occasionally download and store research reports or information from the Website for his/her personal use, he/she may not otherwise provide others with access to the same. The foregoing does not apply to any sharing functionality we provide through the Website that expressly allows the client to share Content or links to Content with others. In addition, the client may not use Content he/she has downloaded for personal use to develop or operate an automated trading system or for data or text mining.

The client agrees not to rearrange or modify the Content available through the Website. The client agrees not to display, post, frame, or scrape the Content for use on another website, app, blog, product or service, except as otherwise expressly permitted by these Terms. You agree not to create any derivative work based on or containing the research products and Content. The framing or scraping of or in-line linking to the Services or any Content contained thereon and/or the use of webcrawler, spidering or other automated means to access, copy, index, process and/or store any Content made available on or through the Services other than as expressly authorized by us is prohibited.

The client further agrees to abide by exclusionary protocols (e.g., Robots.txt, Automated Content Access Protocol (ACAP), etc.) that may be used in connection with the Research Services. The client may not access parts of the Research Services to which he/she is not authorized, or attempt to circumvent any restrictions imposed on your use or access of the Services.

As a general rule, the client may not use the Content, including without limitation, any Content made available through one of our RSS Feeds, in any commercial product or service, without our express written consent.

The client may not create apps, extensions, or other products and services that use our Content without our permission. The client may not aggregate or otherwise use our Content in a manner that could reasonably serve as a substitute for a subscription to the Website.

The client may not access or view the Services with the use of any scripts, extensions, or programs that alter the way the Services are displayed, rendered, or transmitted to you without our written consent.

The client agrees not to use the Services for any unlawful purpose. We reserve the right to terminate or restrict the client's access to the Website if, in our opinion, the client's use of the Services may violate any laws, regulations or rulings, infringe upon another person's rights or violate these Terms.

Prohibited content: The Website includes comments sections, blogs and other interactive features that allow interaction among clients and between clients and the RA. We call the information posted by or contributed by users โ€œContributed Content.โ€ In the course of availing of the Research Services or uploading any post or comment on the Website, the client shall not post any Contributed Content that (i) contains nude, semi-nude, sexually suggestive photos, (ii) tends or is likely to abuse, harass, threaten, impersonate or intimidate other users of the Website and/or Research Services, (iii) is lascivious or appeals to the prurient interest or if its effect is such as to tend to deprave and corrupt persons who are likely to use or have access to the Website and/or Services, or (iv) otherwise violates, is prohibited or restricted by applicable law, rule or regulation, is offensive or illegal or violates the rights of, harms or threatens the safety of other users of the Website and/or Services (collectively โ€œProhibited Contentโ€).

We reserve the right to cease to provide the client with the Research Services or access to the Website, or terminate your subscription, with immediate effect and without notice and liability, for violating these Terms, applicable law, rules or regulations and reserves the right to remove Prohibited Content which is in violation of these Terms, or is otherwise abusive, illegal or disruptive. The determination of whether any content constitutes Prohibited Content, violates these Terms, or is otherwise abusive illegal or disruptive, is subject to the sole determination of the Firm.

Changes to Research Services: We are constantly endeavouring to improve the quality of Research Services provided to our clients. Due to this, the form and nature of the Research Services provided may change from time to time without any prior notice to the client. We reserve the right to introduce and initiate new features, functionalities, components to the Website and/or Research Services and/or change, alter, modify, or discontinue existing ones without any prior notice to the client.

Warranty and liability disclaimer: The Website, Research Services, and all the materials and services, included on or otherwise made available to the client through this Website is provided by the RA on an โ€œas isโ€ and โ€œas availableโ€ basis without any representation or warranties, express or implied except otherwise specified in writing. Without prejudice to the foregoing paragraph, the RA does not warrant that:

  • This Website and/or Research Services will be constantly available, or available at all;
  • The information on this Website or provided through the Research Services is complete, true, accurate or not misleading; or
  • The quality of any products, services, information, or other material that you obtain through the Website or Services will meet your expectations.

The RA, to the fullest extent permitted by law, disclaims all warranties, whether express or implied, including the warranty of merchantability, fitness for particular purpose and non-infringement. The RA makes no warranties about the accuracy, reliability, completeness, or timeliness of the Website, Research Services, Content, Contributed Content, Services, software, text, graphics and links.

The RA does not warrant that this Website, Research Services, information, content, materials, or any other material included on or otherwise made available to you through this Website, their servers, or electronic communication sent by the RA are free of viruses or other harmful components.

Nothing on this Website constitutes, or is meant to constitute, advice of any kind.

Indemnification: The client:

  1. Represents, warrants and covenants that no materials of any kind provided by him/her will:
    1. Violate, plagiarise, or infringe upon the rights of any third party, including copyright, trademark, privacy or other personal or proprietary rights; or
    2. Contain libellous, Prohibited Content or other unlawful material;
  2. Hereby agree to indemnify, defend and hold harmless the RA and all of the RAโ€™s officers, directors, owners, agents, customers/clients, information providers, affiliates, licensors and licensees (collectively, the โ€œIndemnified Partiesโ€) from and against any and all liability and costs, including, without limitation, reasonable advocateโ€™s fees, incurred by the Indemnified Parties in connection with any claim arising out of any breach by the client of these Terms or the foregoing representations, warranties and covenants. The client shall cooperate as fully as reasonably required in the defence of any such claim. The RA reserves the right, at its own expense, to assume the exclusive defence and control of any matter subject to indemnification by the client.

Applicable law: This Website, including the Content and Contributed Content and information contained herein, and the provision of Research Services shall be governed by the Securities and Exchange Board of India, laws of the Republic of India and the courts of Chennai, India which shall retain exclusive jurisdiction to entertain any proceedings in relation to any disputes arising out of the same. As such, the laws of India shall govern any transaction completed using this Website.

Information gathered and tracked: Information submitted or collected on the Website or pursuant to the use of the Services is stored in a database. Specifically, we store the username, name, e-mail address, contact number, as submitted or collected on our Website or through the provision of the Research Services. We may use such information to send out occasional promotional materials, including alerts on new Services available, or other promotional and marketing material relating to our clients and customers.

In accordance with the Information Technology Act 2000, the name and the details of the Grievance Officer at PrimeInvestor is provided below:

Mr. Srikanth Meenakshi
PrimeInvestor Financial Research Pvt. Ltd., Registered office: 659, 4th Avenue, D-Sector, Anna Nagar Western Extension, Chennai 600 101.
Email: [email protected]

11. Mandatory notice:

Clients shall be requested to go through Doโ€™s and Donโ€™ts while dealing with RA as specified in SEBI master circular no. SEBI/HO/MIRSD-POD-1/P/CIR/2024/49 dated May 21, 2024 or as may be specified by SEBI from time to time.

12. Optional Centralised Fee Collection Mechanism:

SEBI has operationalized a centralized fee collection mechanism for IA and RA. Under this mechanism, clients shall pay fees to IAs/RAs through a designated platform/portal administered by a recognized Administration and Supervision body. This is an optional mechanism for the registered entities. At this time, PrimeInvestor has opted out of this fee collection mechanism. Therefore, all subscription payments for the Research Services will be through the modes as specified in Clause 5 of these Terms.

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