Cut-Off Time: The Deadline That Decides Your NAV
A cut-off is the line that sorts each application into the dealing day whose struck figure it will be considered against. The struck figure is the scheme's net asset value (NAV) for that day. The line has to exist because a figure computed from what the scheme held and owed on one day cannot swallow an arrival that came after the computation without being wrong for everyone else in the pool. The Securities and Exchange Board of India (SEBI) sets the conditions and revises them.
The word is doing the damage, so begin there. The phrase cut-off time makes a reader look for a reading on a clock, and holding it that way is exactly what makes the whole subject feel arbitrary and faintly unfair. A far more useful picture is a line painted on the floor. Applications walk towards that line all through a working day. When the scheme closes its sorting for that dealing day, some applications are standing on one side of the line and some are standing on the other, and which side an application is standing on decides which day's figure it will be measured against. The line is the mechanism. Where somebody chose to paint it is a condition, and that condition is not the scheme's to invent.
One scheme runs through everything below. Girnar Asset Management Limited, an invented asset manager, operates the Girnar Large Cap Equity Fund, an open ended equity scheme with net assets of Rs 4,200 crore and 120.00 crore units in issue. Rs 4,200 crore across 120.00 crore units leaves Rs 35.00 sitting behind each unit, so one unit is worth Rs 35.00 exactly. The scheme is held across 3,80,000 folios. Kalyani Bhagat manages the portfolio and Sohail Merchant heads operations.
Three things are settled elsewhere and taken as given here. An application is matched to one of the scheme's daily figures rather than quoted a price by anybody. The scheme strikes one figure for each dealing day, after the day is finished, out of its own books. And the figure is what the scheme held less what it owed, divided by the units in issue. The line that sorts applications between those daily figures is the subject here, along with what turns on which side of it an arrival falls.
Times, periods, thresholds and amounts are conditions rather than mechanisms. SEBI sets them and revises them, and a section below sets out why a condition of that kind can only be read at the place that sets it.
What is a cut-off, and what does it actually decide?
A cut-offThe line a scheme draws between one dealing day and the next for the purpose of sorting applications. Where that line falls is a condition set by the regulator, not a property of the scheme. decides one thing and one thing only: which day's figure an application is considered against. It does not decide whether the application is accepted. Nobody knows what the figure will be yet, on either side of the line, so a cut-off cannot decide that either. It does not price anything, negotiate anything or reward anybody for arriving at a clever moment. It sorts.
Sorting is necessary because of the shape of the thing being sorted into. The Girnar Large Cap Equity Fund produces exactly one figure for each dealing dayA day on which the scheme is open for applications and strikes a figure. A calendar date that is not a dealing day produces no figure at all., and that figure is a struck valueThe single figure a scheme computes for one dealing day, worked out after that day is finished rather than quoted while it is running. for the whole pool. There is no continuous stream of prices to land in the middle of. There are discrete buckets, one for each dealing day, and every application has to end up in exactly one of them. A line between the buckets is not an optional refinement of that arrangement. The line is the only way the arrangement can work at all.
Here is the everyday version. A wedding caterer takes orders for a fixed price per plate, and works out that price for a day after the day's market buying is done. Orders that arrive while the counter is still taking them go into one day's costing. Orders that arrive once the counter has been closed for the day go into the next day's. The costing was going to be whatever it was going to be regardless of who turned up, so nobody is punished by the second arrangement and nobody is rewarded by the first. The counter closing is a sorting device, not a price.
Notice what this makes of the word time. Time is how the line is expressed, in the same way a queue in a bank is expressed as a rope. The rope is not the queue. The mechanism is the sorting. The reading on the clock is only the current administrative expression of it, and that expression has been changed more than once without changing the mechanism at all.
Why does a line have to exist at all?
The rest of the reasoning rests on one block. The figure for a dealing day is not an opinion and not a quotation. The figure is a computation, and every input to it belongs to that particular day: the value of what the scheme held, the amount of what it owed, the charges accrued for the day, and the number of units in issue while all of that was true. Rs 4,200 crore of net assets across 120.00 crore units gives Rs 35.00 a unit because those two quantities described the same instant.
Now try to fold in an arrival that reached the scheme after that computation was made. The money joins the assets, but the units for it were never in issue while the assets were being valued. The division no longer describes anything real. The line is not administrative tidiness and not a convenience for the back office: without one, the holders already in the pool would be absorbing the arithmetic consequences of somebody else's timing. That is the whole justification, and it is a justification about fairness between holders rather than about paperwork.
The household version is a shared vessel of milk. Four households have each put in a measured quantity and the vessel has been divided into four shares. A fifth household arrives after the division and adds its quantity. If the division is not redone from scratch, either the fifth household has bought into a share it did not fund, or the first four have quietly funded part of it. Neither outcome is acceptable, and the only clean answer is that the fifth household is measured into the next division rather than retro-fitted into the one already made.
How large would the distortion be in rupees on this scheme? The size is not computable from the figures given, and a plausible figure would be an invention. Sizing it would need flow data, and one day's figures for the Girnar Large Cap Equity Fund carry none: no subscriptions received, no redemptions paid, no day by day series. The principle does not depend on the size, and its independence from the size is what makes it a principle.
Why can a scheme not simply include a late application in the figure it has already computed for that day?
Which arrival settles it, the paperwork or the money?
Most readers are tracking one event when there are two. The application reaches the scheme. The money reaches the scheme. The two arrivals are separate events, they travel by different routes, and they need not land together or in any fixed order. The second of them has a name worth knowing: realisation of fundsThe money reaching the scheme in a form it can actually use, which is a different event from the instruction or the paperwork arriving., meaning the amount is genuinely with the scheme rather than merely promised or in transit somewhere between two institutions.
A reader who watches only the form being accepted is watching one of two events, and the one they are not watching is invisible to them from outside. Nothing on an acknowledgement shows where the money is. The acknowledgement is a record that a request was received. A record that the scheme has the amount is a completely different statement.
Both arrivals bear on which day's figure attaches. Which of them is decisive in a given case, whether the answer differs by the kind of scheme or the kind of application, and what happens when the two land on opposite sides of the line: all of that is condition rather than mechanism. SEBI sets them, they differ across cases, and they have been revised. Both arrivals matter, and the ranking between them is read in the current text at sebi.gov.in. A condition that moves cannot be fixed in an explanation written earlier.
Think about a school fee paid by cheque. The office stamps the counterfoil the moment it is handed over, and the household walks out with a stamped acknowledgement in hand. The fee is not settled. The fee is settled when the amount is actually with the school, and the stamped counterfoil says nothing whatever about that. Two events, one visible, one not.
The form went in and the acknowledgement came back stamped. Is it now settled which day's figure attaches?
Why is the deadline itself not stated here?
Because a deadline is a rule, and a rule is a different kind of object from a mechanism. Everything in the two sections above can be reasoned out from first principles. Why a line must exist, why the figure belongs to its own day, why two arrivals exist, why the result cannot be proportionate: all of that follows from how a pooled scheme is built, and it would still follow if every condition in the country changed tomorrow. A mechanism can be explained from understanding, and a rule can only be read at the place that sets it. That distinction runs through the whole subject, and cut-off is the clearest case of it.
The consequence is sharper than it first sounds. An explanation that prints a condition and then the condition changes does not become dated. The explanation becomes wrong. A stale explanation is merely old, but a superseded condition is an instruction to act incorrectly, and a reader who trusted it would arrange their affairs around a line that is no longer where the explanation places it. The cost of that falls on a real household, whose transaction lands in the wrong bucket.
The conditions for cut-off have been revised more than once. Revision is not a criticism of anybody. An operational rule has to keep pace with how money actually moves between institutions, and a printed copy of such a rule ages badly. SEBI is the authority. The current text sits at sebi.gov.in. The scheme's own offer documentThe scheme's own published document setting out its terms, restated and reissued as those terms change. restates what applies to that particular scheme.
There is a second reason, smaller but worth naming. Conditions of this kind are not one condition. The conditions differ by the kind of scheme and by the kind of application, so a single stated number could be the wrong answer for a given reader even on the day it was written. That the conditions differ is itself the useful fact; how they differ is read where they are set.
Why is SEBI named instead of the deadline itself?
How Cut-Off Times Can Affect Mutual Fund Transactions: what actually changes?
Everything above has been about the line. The consequence works out in rupees and units on the Girnar Large Cap Equity Fund. Rs 4,200 crore of net assets divided by 120.00 crore units in issue gives the scheme's struck figure for one dealing day, Rs 35.00 a unit.
To show what changes, a second figure is needed, and this record holds only one. So assume, purely as an arithmetic device, a figure of Rs 35.35 for the following dealing day, one per cent above Rs 35.00. Nobody can know a following dealing day's figure before that day has finished, which is exactly why the Rs 35.35 is an assumption made to give a comparison two ends rather than a value for this scheme or any other. A figure that fell would produce the mirror of everything below, and the mechanism would be identical.
Money going in: the rupees are fixed and the unit count moves
Rs 1,00,000/- is handed over. The investor decided on that amount, so it does not change according to which day's figure attaches. The unit count it buys is what changes. At Rs 35.00, the arithmetic is 1,00,000 divided by 35.00. The quotient is 2,857.142857 and so on without ending, recorded as 2,857.143 units on the scheme's three decimal convention. At the assumed Rs 35.35, the same Rs 1,00,000/- divided by 35.35 gives 2,828.854314, recorded as 2,828.854 units. The difference is 28.288543 units, or 28.289 units when the two recorded counts are subtracted from one another.
Here is a check worth doing, and it is the kind that catches an error rather than repeating one. The 28.288543 units, valued at the assumed Rs 35.35, come to exactly Rs 1,000/-, or one per cent of the Rs 1,00,000/- that went in. The two routes agree, so the unit gap is confirmed rather than merely plausible.
Money is going in, and a different day's figure attaches from the one expected. What moves, the rupees or the units?
Predict before reading on. Now units are going out instead of money going in. Which quantity is the fixed one this time?
Units going out: the units are fixed and the rupees move
Reverse the direction and the two roles swap places. A count of units is what is handed over now, and that count does not change according to which day's figure attaches. The amount that comes back is what changes. Take the 2,857.143 units from above. At Rs 35.00 they come to Rs 1,00,000.005. At the assumed Rs 35.35 they come to Rs 1,01,000.00505. The difference is about Rs 1,000/-, and it is exactly Rs 1,000/- if the unit count is carried unrounded instead of at three decimals.
The trailing digits are worth one honest sentence rather than a tidy rounding. An unrounded 2,857.142857 units at Rs 35.00 is exactly Rs 1,00,000/-. The recorded 2,857.143 units at Rs 35.00 is Rs 1,00,000.005. The scheme would carry that to the paisa as Rs 1,00,000.01. The two are not the same number. The half paisa between them is the three decimal unit convention showing itself rather than a real gain to anybody, and 2,857.143 is very slightly more than the true quotient. An approximation allowed to stand as an equality is how a reconciliation quietly stops tying, so where two routes differ by a rounding step, name both figures and say which one is the artefact.
Now put the two directions side by side. The whole practical consequence fits in one line. Going in, the rupees are fixed and the unit count moves; coming out, the units are fixed and the rupees move, and the two are exact mirror images of one another. Knowing which of the two quantities is the fixed one shows immediately where to look for the difference, and it is the only thing about this subject worth being able to recall without a document to hand.
| Step | The arithmetic | Result |
|---|---|---|
| The struck figure | Rs 4,200 crore of net assets over 120.00 crore units | Rs 35.00 a unit |
| Money in | Rs 1,00,000/- divided by Rs 35.00 | 2,857.143 units |
| Money in | Rs 1,00,000/- divided by an assumed Rs 35.35 | 2,828.854 units |
| The gap | 2,857.143 less 2,828.854 | 28.289 units |
| Units out | 2,857.143 units at Rs 35.00 | Rs 1,00,000.005 |
| Units out | 2,857.143 units at an assumed Rs 35.35 | Rs 1,01,000.00505 |
| The gap | Rs 1,01,000.00505 less Rs 1,00,000.005 | about Rs 1,000/- |
| Check | 28.288543 units valued at the assumed Rs 35.35 | Rs 1,000/- exactly |
Why is the result a step rather than a slide?
An arrival lands a moment on the far side of the line instead of a moment on the near side. How much difference should that make?
Human beings expect proportionality, and they expect it so strongly that it feels like a law of nature. A bus missed by a minute costs a short wait. A payment missed by a day carries a small charge. Being slightly late feels as though it ought to cost slightly. Sorting into dealing days does not work that way at all, and the mismatch between what people expect and what actually happens is the source of almost every complaint on the subject.
The line produces a step changeA jump straight from one value to another with nothing reachable in between, as opposed to a gradual slide from one to the other.. On the near side, the applicable figure is one day's figure. On the far side, it is another day's. The scheme does not compute a figure for very slightly late, so there is no third figure a very slightly late arrival gets instead. The scheme computes one figure per dealing day, and the sorting has exactly two outcomes.
Run that through the arithmetic already done. For a fixed Rs 1,00,000/-, the unit count on one side is 2,857.143 and on the other it is 2,828.854. There is no arrival anywhere that produces 2,850 units, or 2,840, or 2,829.9. Unit counts between the two do not exist, not because anybody forbade them but because nothing computes them. The 28.289 units between the two outcomes is not a penalty scaled to lateness, it is simply the distance between two figures that were always going to be different from each other.
The everyday version most people already know is a train. A passenger who reaches the platform as the doors close does not travel slightly less far than one who boarded. The passenger takes the next train. Trains are discrete and so are dealing days, so there is nothing between the two trains, and no amount of arguing about how nearly a passenger made it produces an intermediate outcome.
Drag the later arrival across the line and watch the result jump
One control: where the later of the two arrivals sits along an axis that carries no scale, no numbers and no clock, with a single marker on it standing for the line. Two things redraw. The highlighted block shows which day's struck figure is the applicable one, and the bar shows the outcome. Switch the direction to see the mirror: money going in moves the unit count, units going out move the rupees. The third control draws in what proportionality would have predicted. Almost everybody expects that answer, and it never occurs.
The assumed figure is exactly one per cent higher, Rs 35.00 becoming Rs 35.35. By how much does the unit count for a fixed Rs 1,00,000/- fall?
What is a cut-off not?
Four things get mistaken for it, and each substitution is made confidently by people who are otherwise careful. The first is the close of the market. Trading ending and applications being sorted are two different events serving two different purposes, and treating one as the other is the commonest error of the four. The second is the bank's own processing schedule. A bank's schedule governs when an amount leaves one institution and lands in another, and has nothing to do with how the scheme sorts what it has received.
The third is the distributor's own working schedule. A counter that is open or closed shows when a form can be handed over, not when the scheme has it. The fourth is subtler and costs more: the belief that there is one condition covering every kind of scheme and every kind of application. Each of these four is a real deadline for something, and being real is exactly what makes it convincing. Treating any of them as the cut-off is a common and expensive substitution.
The actual differences, and how they run across kinds of scheme and kinds of application, are set by SEBI and read at sebi.gov.in. The shape of the error is what matters: the reasoning runs from a schedule that belongs to somebody else's process, and the schedule being real is what makes the mistake so hard to notice.
Is the cut-off the same event as the close of the market?
Where are the conditions that actually apply read?
Two documents, and both of them are reissued in a way that no explanation can be. The first is the scheme's own offer documents, restating the conditions as they apply to that scheme and updated by the asset manager as things change. The second is the source itself: SEBI publishes what applies across schemes, and sebi.gov.in is where the current text sits.
Both of those are current documents, and an explanation written earlier is not. An explanation written earlier can teach what a line is for and what turns on which side of it an arrival falls. Such an explanation cannot say where the line is today, and one that claims to is making a promise about the future it has no way of keeping.
There is a habit worth building here, and it is small. When the answer to a question is a condition rather than a mechanism, the source is consulted before acting rather than after. The whole cost of doing that is a few minutes. The cost of not doing it is a transaction sorted into an unexpected bucket, discovered afterwards, when nothing can be changed.
Where are the conditions that apply to a particular scheme read?
Who actually reaches for this on a working day?
Sohail Merchant, who heads operations at Girnar Asset Management, reaches for it every single working day, and for him it is not a concept at all but a sorting job with a deadline attached. Every application received has to be placed in exactly one dealing day, and the placement has to survive being checked later. If a batch is sorted into the wrong day, the units allotted are computed against the wrong figure, the folio record and the scheme's record stop agreeing, and the reconciliationMatching one record against another until the two agree, and finding the reason wherever they do not. has to be unwound application by application rather than in bulk.
The registrar and transfer agent holds the folio records and processes what has been sorted, so that party reaches for it from the other side of the same joint. Between the two of them the sorting is checked twice. A genuine sorting error is therefore rare, and a misunderstood one is common. Kalyani Bhagat, who manages the portfolio, does not touch this at all, and that is worth saying: which day an application is sorted into has nothing to do with what the scheme holds.
A household reaches for it exactly twice. Once, to understand that the figure they will be measured against is not the figure they can see. And once more, whenever a transaction matters enough that they want to know which conditions govern it, at which point they go to the scheme's documents rather than to an explanation. Where the line falls is a condition, read at sebi.gov.in rather than reasoned out from anything above, and none of these three can work it out.
There is one more reader worth naming: whoever handles a complaint. A complaint on this subject is almost never about arithmetic that went wrong. A complaint is about arithmetic that went right against a figure the holder was not expecting, and the only thing that resolves it is showing which dealing day the application was sorted into and why. The answer is a record, not an argument.
The error that gets made, and what it costs
A holder submits an application towards the end of a working day. The paperwork is accepted, an acknowledgement comes back, and everything looks complete. The holder looks up the scheme's published figure for that day, works out the unit count they expect, and puts the number in a notebook. The money reaches the scheme afterwards. A different day's figure attaches and the unit count that appears is not the one in the notebook. A statement records the outcome rather than the reasoning behind it, so nothing on it explains the difference.
Nobody in that sequence was careless. The paperwork being accepted looks exactly like the transaction being done, and there is no reason for anybody to assume otherwise. The two arrivals are invisible from outside, no receipt shows where money is between institutions, and the conditions themselves have been revised more than once, so even a reader who once looked them up may be working from a version that has moved. The cost is a reconciliation that will not tie, a complaint raised against arithmetic that was in fact correct, and a lasting and entirely reasonable suspicion that the scheme moved the figure.
The fix is in three parts and none of them requires vigilance. Treat the applicable figure as unknown until it is confirmed, rather than writing down an expected unit count from a figure already visible. The money is a separate arrival from the paperwork, so track it as one. And read the conditions where they are set, at sebi.gov.in and in the scheme's own documents, rather than from any explanation written earlier.
Who sets the conditions that decide which day's figure attaches?
SEBI sets the conditions that decide which day's figure attaches to an application, including how the arrival of the application and the arrival of the money bear on it, and how those conditions differ by the kind of scheme and the kind of application. The conditions have been revised more than once. The current text is read at sebi.gov.in on the day it is needed, and what applies to a particular scheme is read in that scheme's own offer documents.
References
| Source | Document | Where |
|---|---|---|
| Securities and Exchange Board of India | The master circular for mutual funds, for the conditions governing cut-off and the receipt of funds, and for how those conditions differ across kinds of scheme and kinds of application | sebi.gov.in |
| The scheme's own offer documents | The document in which a scheme restates the conditions as they apply to that scheme in particular, reissued by the asset manager as terms change | published by the asset manager |
Girnar Asset Management Limited, the Girnar Large Cap Equity Fund, Kalyani Bhagat and Sohail Merchant are invented.
Educational material. Not advice on any investment, tax, budget or market position.
