It is a common experience in rural areas that by using pass-backs big distributors and NDs steal the business of smaller IFAs or apply pressure on fund houses to stop giving empanelment to IFAs so that IFAs stay only as sub-brokers. Pass back will be a license kill smaller IFAs. We opposit it

Bagariaji you are absolutely right.

It is getting quite clear now on why the so called associations never asked for a ban upfront commissions. All this while some of these associations heads, it seems , are practicing pass-back and usurping the business of smaller IFAs. No wonder that the number of IFAs is decreasing day by day. If pass back is made legal, can anybody compete with bank distributors whose parent fund houses give them much higher commissions Vs smaller IFAs? Had these associations asked for a ban on upfront commissions, probably SEBI would never have asked for commission disclosure. A transact only distributor and advisor should be segregated at remuneration in Mutual Funds. Trail + Fee should be the remuneration of advisor where as only a small upfront(Rs.150/- as per law) should be given to Transact only distributors.

If you can not kill IFAs by competition, kill them by manipulating the law seems to be the motto. The big distributors want to kill smaller IFAs by legalising pass-backs. If it were not for SEBI intervention, up-front commissions would never have been decreased and trail would never have been increased. Without SEBI intervention these big distributors would not have let smaller IFAs survive this long. Hope SEBI bans upfront completely and segregates what need to be paid to the advisor from expense(we don’t have to pay the service tax then,which is unfairly thrust on us, as service tax will be charged to scheme as with asset management charge etc.,).

Im totally agreeing with the logic Mr Raghuramam posted. Its totally killer suggestions for IFAs. Although I welcome Mr Bagarias suggestion of implementing only trail model and stop all upfront payouts, these 2 suggestions posted by him which are mentioned below are going to Finish IFAs if implemented. 1. Reduce commissions for big tickets:- Response:As we all know survival of most IFAs depend on the big ticket businesses that we occasionally get. These big ticket businesses cross subsidise small ticket businesses which otherwise would not have been viable. 2. Legalise Passback:- Response: If legalise pass-back, it will surely open a door for the Big distributors like banks, NDs and online platforms to kill IFAs . With the kind of commissions that these big distributors get, most IFAs will not to be able to compete on the basis of pass-backs. It will surely increase mis selling which increase SEBIs wrath on IFAs. Then why should we support pass-back? Is it ethical?

Probably these big IFAs are licking their lips assuming that by getting the pass-back legalised they can easily steal the business of small IFAs. Greed is blinding them to see the threat of AMAZON. If pass-back is legalised can anybody survive the attack of amazon with its discounts? The suggestions mainly seems to be aimed increasing the profits of fund houses and online platforms and are harmful for IFAs and investors.

What is being paid to a transaction only distributor(like banks, NDs, online platforms etc.,) is way higher than their quality and effort. At the same time what is being paid to an advisor ( mostly IFAs) is way lower to even survive. This is the reason that IFAs are unable to survive while commissions and profits of big distributors are increasing multiple times. Even if a trail of 1% is paid to IFAs, they still need to take fee to survive given the time and effort they put in to educate clients and sustain their investments.Upfront will go anyway. By not asking for segregation of transaction only distributors and advisors as per circular http://www.sebi.gov.in/cms/sebi_data/attachdocs/1314009686727.pdf and asking for these structured percentage slabs, there is a deliberate effort to help big distributors and to kill small IFAs.

Dear Mr. Bagaria, The article is really well thought of . I do wish that you arrange to transmit to AMFI and SEBI for their considered view on the matter. I am sure they would appreciate it. As you rightly pointed out, we should present a professional image of ourselves. Regards, Murali

Contd... One TER can never happen in presence of existing model of paying 80%-100% of distributable TER, to big distributors & to big ticket business. So actually speaking small Investors & small IFAs are subsidizing big ticket business & big distributors. So it is urgently & highly necessary to reduce difference between highest & lowest payouts & also increase the payout for small & new IFAs. Mr. Bagaria is our Respectable Industry Veteran. He has showed the way forward after his detailed study. I think it is high time for SEBI to regulate the commission structures. If commission payment to RIAs, is allowed, it will also serve the purpose. Bagariaji’s ideas will also increase Retail penetration. Big distributors will also start increasing retail business. Average TER of equity fund is 2.5-2.75%. So Proposed revenue sharing model is very attractive to encourage retail business & penetration.

IFA community is facing many problems like Disclosures, Direct Plan, E Commerce etc.. We should try to understand reasons of birth of such problems. Country is facing lack of penetration in MF Industry. Why it is So, in spite of huge alpha Creation? It is Sure that Because of Lack of Distributors any push product cannot penetrate.. Mr. Satya has correctly written that we need 5 Lakh active distributors. But number of ARNs is not increasing fast. IFAs are not assured of consistency of their business model. So Existing ARNs are also not active. Why new youngsters will spoil their own career? Payout level is also very very low for small & new IFAs. And surprisingly for well established & big distributors Payout is very very high. It is quite possible that, difference between highest average payout & lowest average payout is 300%-400%. Direct Plan, Disclosures & many other problems has taken birth due to this huge difference in payouts…Contd...

Nicely express the difference between distributor from another industry where job done after sale with IFA whose job start when investor buy the fund and also why trail is important and must protected . IF trail will remove and no commission or earning remain on Mutual fund , then by default Ifa have to move towards Big tickets where there working can by justify by fees , and retail or small ticket size clients left without service or care .

When % of Expenses are set by SEBI only, Why it insisted on disclosure of Commission in Absolute Terms ?

Worth considering. SEBIs endless meddling in the issue at hand is not solving any problem, but creating unwanted ambiguities. Almost always decisions are favourable to large institutional entities, A sharing within the TER with no regard for who brings in business, is most welcome. Registration as RIA when mandated will create another layer of hassle and another set of compliance norms,not of much use, as always there will pop up circumventing ideas and practices.

Very good said.But how can is implement?

Strongly oppose the suggestion of legalising pass-backs. Believe it is the easiest way to kill IFAs and hence some lobby seems to be working overtime on this.

I completely agree with Mr. Raghuramam. In the guise of helping IFAs, it seems, some big distributors are trying to propagate their own interest and want to harm IFAs in the process. As long as the SEBI Circular http://www.sebi.gov.in/cms/sebi_data/attachdocs/1314009686727.pdf is not implemented in letter and spirit i.e. a transaction only distributor (those who just submit applications and do nothing else afterwards like banks, NDs etc.,) and advisor(which most IFAs are - give continuous service and advice) in mutual funds are not separated at remuneration, these manipulations will keep on happening to kill IFAs.

Perfectly said Bagaria ji.

In the name of helping IFAs some of the above suggestions are aimed at killing IFAs completely. 1. As we all know survival of most IFAs depend on the big ticket businesses that we occasionally get. These big ticket businesses cross subsidise small ticket businesses which otherwise would not have been viable. By trying to reduce commissions on the big ticket businesses, effectively they want to kill IFAs out of this business. 2.By asking to legalise pass-back, they are trying to open a door for the Big distributors like banks, NDs and online platforms to kill IFAs in a single go. With the kind of commissions that these big distributors get, will we ever be able to compete on the basis of pass-backs? Then why are these Big IFAs supporting pass-back? Is it ethical?

Taking this forward is the key now. I think few points shared above should be implemented as soon as possible. Rest a process should begin to work on - one by one.

It seems to be the most logical and ideal choice. Why cant we take this idea forward and submit it to SEBI as our proposals for regulating TER and elimination of upfront commission.

Sensible ideas from an Industry veteran,An all trail model which rewards the distributor more when the investor stays longer is the need of the hour. For the investor to stay on the hand holding of the IFA is needed and the ifaneeds to be compensated proportionately. Ifas who have the skills can upgrade to the RIA model however forcing all distributors to become fee based advisors is far fetched, impratical and impossible. Even in countries where this model has been enforced there are studies which show that the retail investor is the most neglected thus defeating the very purpose of RIA model. Lets hope all the industry participants the regulator, The Amcs, the distributors sit together everyone brain storms and find a solution otherwise unregulated advice from finance writers in media print and digital with limited knowledge of how the industry works will continue to influence the decision makers and not those who really matter.

IFA"s are ready for all regulations,but SEBI has decided to totally vanish and curb the IFA fraternity.every move seems to be against IFA"s.Recent move has asked AMC"s to agressively market and advertise direct plans.Also RIA model will totally finish all future trail which every IFA has built up with very hard work.SEBI is following Canada and Austrilia models of regulation.Perhaps it is 10 to 15 years of Indian scenerio.What can be done to remove this negative perception of regulator towards IFA.Many times i think why we are not thinking moving to court of law against this biased attitude.This seems to be violation fundamental rights.Earning money thru legitimate and business is not crime.Already different channels of distribution have been launched.Now why further hurry to wash out IFA"s?In the due course of time market will itself eliminate the weaker models and only those channels which are beneficial to investors will only sustain.

TER based Revenue sharing model looks good as you shared above, SEBI is not utilizing the real potential of Distributors if it give some relief with a positive attitude towards us the Market will get unprecedented support in terms of Investment from pan india. Commission Discloser is a serious blunder from SEBI and not at all in favor of any one, neither on Investor nor on MF Industry ... We should always oppose it on every platform..

Everyone knows that if investor stayed in Diversified Equity MF for long time, say 10 years, chances of loosing money is close to NIL and also IFA numbers are not growing for the last 8 years. If IFAs are paid the best, why IFAs are not growing. SEBI will do the best to protect the investor and the industry. RIA is the best, if it is introduced where the investors are loosing money by trading in stocks at DEALER level. SEBI knows this well and trust it will do its BEST. India needs 500000 IFAs to serve the 1.2 billion population. MF is well regulated and transparent, but it is not reaching those who need it. PLEASE THINK AND ACT

A very detailed study has been made by you. A solution is always better arguing and wasting everybodys time. It will allow us to do business and giving good service to our customers.