Tuesday, 27 January 2015

Will Offshore Funds Prove to be the Domestic Mutual Fund Investor’s Achilles’ heel?

Earlier this month, market regulator SEBI released a document titled “Consultative paper on managing/advising of Offshore Pooled Assets by Local Mutual Fund Managers”. The paper makes a case for removing certain restrictions existing under section 24(b) of the SEBI (Mutual Funds) Regulations Act.

At present, if an Indian asset management company (AMC) wants to manage or advise offshore pooled assets or funds, and for the purpose appoint a fund manager who is currently managing its domestic funds, the AMC can do so subject to: both domestic and offshore funds having the same investment objective and asset allocation. Furthermore, both portfolios must have a commonality in holdings of at least 70%; finally, the offshore fund must pass muster on the 20/25 rule applicable to domestic mutual funds. SEBI has proposed that for offshore assets classifying as Foreign Portfolio Investors (FPI) investments these restrictions be scrapped.

It’s not difficult to understand what’s driving SEBI. For a better part of the last five years, the domestic mutual fund industry has struggled to clock a healthy growth in terms of assets under management. With expectations of a strong economic revival and buoyant markets, India has resurfaced on global investors’ radar. The opportunity to freely manage/advice global funds can prove to be a significant opportunity for Indian AMCs.

To be fair, the present set of regulations though well-intended (more on that later) were restrictive for Indian AMCs. Let’s take an example to better understand this. Consider a global fund house which wants to launch an India-dedicated fund and hand its reins to a domestic AMC, which in turn has a skilled fund manager with a proven long-term track record. Expectedly, the global AMC would want it’s monies to be managed by the same fund manager. His track record and presence will be the new fund’s USP. However, the present set of restrictions (especially ones related to 70% commonality in holdings and the 20/25 rule) made it operationally difficult to have the Indian fund manager at the global fund’s helm.

Conflict of interest
If the aforementioned restrictions are done away with, life will become significantly easier for both Indian AMCs and fund managers. However, the flipside is that it could lead to a potential conflict of interest situation with domestic investors on one side and investors in global funds on the other. Global funds, by virtue of their asset size can prove to be lucrative for Indian AMCs, and the possibility of fund managers paying more attention to these funds at the cost of domestic funds cannot be ruled out.

Even SEBI recognizes this prospect and has provisions wherein AMCs are required to make a disclosure in the scheme information document (SID) that there exists no material conflict of interest across its activities and other like measures. Perhaps some of the restrictions which are now proposed to be scrapped had their origins in protecting domestic investors’ interests.

A quick glance at how AMCs reacted to these restrictions in the first place reveals a lot. There were cases of AMCs withdrawing their leading fund managers from domestic funds and instead utilising them to run/advice offshore funds. To placate distributors and investors in India, a standard (but off-the-record) refrain was that though the said managers no longer run domestic funds, they do ‘influence’ the local strategy. In 2011, when SEBI came up with the present set of regulations permitting managers to be named on both domestic and offshore funds, while some of the 'absent' managers returned, others yet chose not to do so. All in all, it isn’t difficult to see which piece of the pie Indian AMCs prefer.

Skin in the game
Admittedly, there is no foolproof method to ensure that domestic investors’ interests are not compromised. But what SEBI can do is institute a framework which prods AMCs and fund managers to act in a fair manner. To begin with, provisions requiring AMCs to invest its personal monies in new fund offers must be expanded to include all its domestic funds. Furthermore, SEBI should make it mandatory for fund managers to invest in every domestic fund helmed by them. Ensuring that AMCs and managers have their skin in the game, is perhaps the best way of ensuring that domestic funds aren’t neglected. Also, these investment must be periodically disclosed.

Another disclosure which will help is that of performance and portfolios of offshore funds being managed/advised by fund managers. This will help domestic investors track and compare the manager’s activities on offshore funds versus domestic funds. 

At their core, these measures can go a long way in revealing the true character of AMCs and fund managers. Using the former as inputs, the onus of making informed choices will rest with investors.

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