Should funds ration your investments?

As the stock indices defy gravity to soar past earlier highs, AMCs are back to using a time-tested ploy to manage their flows – rationing your investments. 

ration inflows

Mirae Asset has just drastically slashed the monthly SIPs it will allow into its Mirae Asset Emerging Bluechip Fund from Rs 25000 to Rs 2500 from November 6. SIPs and STPs registered earlier will be allowed to continue, but new registrations will need to be capped at Rs 2500. The scheme had already put a stop to all lumpsum investments from October 2016 and capped its SIPs at Rs 25000 a month in November 2017. This is a rare instance of a large and mid-cap equity fund regulating inflows, but such rationing is a common practise with small-cap funds.

It was only on March 31 that SBI Mutual Fund decided to reopen its Smallcap Fund for lumpsum investments, after shutting them out for nearly five years. In September, barely five months later it decided to shut its doors to lumpsum investments again. It also decided to cap SIPs at Rs 5000 per investor.

DSP Smallcap Fund was among the first to gate flows into the scheme at Rs 2 lakh per investor in 2014. In 2017, it completely gated all inflows. In September 2018, it opened for limited SIPs. From April 1 2020, it has allowed lumpsum investments too.

Investor dilemma

While AMCs have many explanations for why such caps and quotas are for your own good, they trigger some valid queries from our readers. Here they are.

  1. A fund that I am regularly investing in, as a part of my child’s education goal, has restricted my SIPs. What I am supposed to do to meet that goal?
  2. A monthly SIP of Rs 2500 or Rs 5000 is too small to make a difference to my wealth, so what’s the point in continuing with this investment at all? Should I switch to my second-best or third-best choice? How will this help me?
  3. If the fund manager thinks that he can’t find attractive deployment opportunities in this market for my money, will my existing investments earn much lower returns? Should I redeem all my holdings in this fund?  

However much AMCs may insist that they are trying to deliver a good investor experience, this start-stop approach to accepting flows inconveniences investors. Folks working towards goal-based portfolios using SIPs are forced to interrupt their investments and scout around for alternatives. Asset allocation plans and fund choices made painstakingly get disrupted. Those who have lumpsums to invest are forced to make sub-optimal choices for deploying that money. 

Justifications

Fund houses come up with many convincing-sounding explanations on why rationing flows is for your own good.

A common one is that, as markets have soared, the fund manager is finding it difficult to unearth attractive deployment opportunities for the new money and would not like to dilute returns for existing investors.

A second is that the small-cap universe in India can only support a certain fund size, beyond which impact costs start to kick in and hurt fund performance.

A third is that, as the market as a whole or a specific market cap segment has become over-valued, the fund would like to warn off investors from chasing returns and risking capital losses.

But each of these arguments wears a little thin with repetition.

For one, it is not necessary for a fund manager to identify new stocks to buy every time his scheme receives new inflows. If he’s convinced about the merits of the stocks he already owns in his portfolio, all he needs to do is to add to existing positions without further ado.

If he believes that even this will be return-dilutive because they will not replicate their past returns, the ideal thing to do would be to communicate this clearly to investors so that they either tone down their expectations or book profits. Sending out subtle hints through restrictions on lumpsums or SIPs doesn’t really do the job.

But only problem is that this ‘ideal’ fund size seems to be a moving target and varies with AMCs. 

Building significant positions in smaller stocks in India does entail impact costs. Therefore, the argument on the small-cap universe in India being able to support only a certain fund size rings true. But only problem is that this ‘ideal’ fund size seems to be a moving target and varies with AMCs. Barely five years ago, a Rs 2000 crore small cap fund was considered too unwieldy and AMCs imposed restrictions on flows well below this size. Lately, this threshold has moved to Rs 5,000 crore. It is also difficult to grasp why some fund houses deem a Rs 5,000 crore small-cap fund too big to handle, while others peg the breaking point at Rs 8,000 crore. Yet others are happy to accept flows whatever their size.

Let’s also not forget that rationing SIPs or barring lumpsums does not really prevent a small-cap fund from growing beyond what the fund manager deems a nice size. Sheer momentum in returns can bloat a small-cap fund too.  

Impact costs for a small-cap fund are also a function of market conditions, while also being a structural issue that’s not going be resolved anytime soon. In a bull market, when dozens of long-ignored small-cap names come to miraculous life, liquidity picks up even in obscure names and impact costs fall. This however tends to be quite a bad time for long-term investors to enter small-cap funds. During a bearish spell, even high-quality small-cap names can face a sudden dearth of liquidity. Investing in such bearish spells can entail high impact costs but may prove favourable for long-term investors – which small-cap investors need to be.   

The truth is that, if an AMC really believes that there’s a specific fund size beyond which any new inflows or expansion will dilute scheme returns, it ought to be completely gating its flows at that size. It must reopen only when and if the scheme gets back to the ideal size. Merely refusing lumpsums or curtailing SIPs sends out very mixed signals, as the investor may not like to earn sub-par returns even on Rs 2500 or Rs 5000 of his monthly investments.  

Does timing work?

The third argument, about restricting flows because the market or a specific market-cap segment is over-valued, is the shakiest of the lot. Time and again, Indian AMC honchos tell investors that timing the market is a cardinal sin and that no one can second-guess market direction over the next week, next month or next year.

When AMCs try to tell investors when they should start or stop investments, they’re assuming that the investor doesn’t have an asset allocation plan or a financial goal in mind 

Reams of investor awareness material is devoted to educating the investor on the merits of goal-based investing and sticking to a disciplined asset allocation plan irrespective of market conditions. But when AMCs try to tell investors when they should start or stop investments, they’re assuming that the investor doesn’t have an asset allocation plan or a financial goal in mind and is simply making an opportunistic bet on equities.

Let’s not forget that AMCs can also go quite wrong in such market timing efforts. The last three-four years, during which some schemes have completely barred lumpsum investments, have actually turned out to be pretty good periods for the Indian investor to buy into equities.

Many small-cap funds were closed for lumpsums and had restricted SIPs until March this year and began to re-open from April. But the best time to invest in small cap companies was in early March when the small-cap index bottomed. Clearly, what’s a great time to invest and what’s a poor time, is often evident only with the benefit of hindsight.

Bottomline

Instead of rationing flows at the investor’s end, it would be good if AMCs simply used better communication policies to convey their views on valuations to investors. If fund size is the problem, the best bet would be to completely gate all flows, or better still, book profits on stocks and return hard cash to investors even in the growth plans.

Instead of rationing flows at the investor’s end, it would be good if AMCs simply used better communication policies to convey their views on valuations to investors.

SEBI on its part should do away with its one-scheme-per-category rule and allow AMCs to gate old schemes and launch new ones in categories where fund size can pose a challenge to returns.

 Until that happens, though, funds shuttering flows is a phenomenon that needs be lived with. So don’t read too much into such actions with respect to market levels or potential returns. The best you can do is to continue to stick to your planned asset-allocation and investing. If a fund you want to increase SIPs in won’t accept more flows, look for another alternative in the same risk-return frame that’s a good performer.

Also Read : SIP vs Lump sum

More like this

13 thoughts on “Should funds ration your investments?”

  1. “SEBI on its part should do away with its one-scheme-per-category rule and allow AMCs to gate old schemes and launch new ones in categories where fund size can pose a challenge to returns.”
    When you suggest that SEBI should allow more than 1 scheme in the same category, aren’t we going back to the time when AMCs had multiple schemes without real differences between those? Also, in the case of NFOs, it is not a good idea to invest without a track record, so how will it help investors?

    1. In categories like smallcaps multiple schemes are necessary so that schemes beyond a certain size don’t accept flows. No harm in multiple funds in a category as long as managers and styles are different.

  2. Dear Aartiji, Thank you for a good article. Can you clarify that if the fund has accepted a long term multi year SIP then would it able to stop it? I have started some SIPs recently across 5 to 15 years in some funds. Also, would request you to extend this article with action points/advice which Investors can do if they fall in such a situation as shared by you like stoppage of an existing SIP (Children’s Education) etc. Thank you!

    1. If they’ve accepted a sip for a specified period it is not subject to the restrictions. But most ppl gace limited period sips that they renew and renewal does get affected. In such cases best to look for another fund with similar ratings and mandate

  3. protyay91banerjee

    This could be one useful reason to move to a next50 index fund ? Or Index fund in general, right ?
    AMC doesn’t have much to say in case of index funds.

  4. madhav.vaidyanath

    Hello Aarthi – thanks for the detailed view on the recent changes. One question though is as an investor does it make sense to stop in progress SIPs in such funds and move to alternative one’s?

  5. The AMCs restricting fresh inflows and existing SIPs is not stopped -please correct me ?
    Goal based investment _if already in place- should not come in the way .

  6. Yes Madam, points – varying AUM sizes of SMALL CAPS by different AMCs well brought about. Second one, profit booking and distribute it to the existing investors, very well articulately argued upon. And the same small cap stocks are dealt with well in other nomenclature of the other segments say hypothetically Banking stocks, small banks stocks are heavily traded in the market, but the same in small cap segments, no trading take place.

  7. Even though i agree with most part of the article, i have a different opinion on going away with one fund per category rule for few categories. Knowing the greed of AMC’s, they will just launch many funds,as they are doing in thematic space, which effects investor decision making and proper comparison.

    For an investor, below are the things which can be beneficial IMO,

    1) Each fund should define its maximum capacity AUM – i know some of the intellects suggesting this from some time, i don’t know why SEBI doesn’t implement these instead of creating or fiddling with categories
    2) AMC should communicate atleast 2-3 months prior about their restriction on flows for investors to take action.

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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 “real time”, 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, “Content”) 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 client’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 “Used with permission from PrimeInvestor Financial Research Pvt. Ltd.”

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 “Contributed Content.” 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 “Prohibited Content”).

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 “as is” and “as available” 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 RA’s officers, directors, owners, agents, customers/clients, information providers, affiliates, licensors and licensees (collectively, the “Indemnified Parties”) from and against any and all liability and costs, including, without limitation, reasonable advocate’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 Do’s and Don’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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