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1Fund Structure
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2NAV and Units
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11Fund Distribution and Investor Service
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Portfolio Disclosure and Factsheet: What Each Gives

A portfolio disclosure and a factsheet answer different questions about one scheme. One is a dated list of holdings in a set format, so its rows can be added and checked. The other is a periodic summary in panels, so it describes the scheme and prints its headline figures. A list can be summarised. A summary can never be turned back into a list.

Both of these arrive from the same asset manager, about the same scheme, often in the same week. The overlap is exactly why readers reach for whichever one is nearest and expect it to answer whatever they walked in with. It will not. A disclosure and a factsheet are not a long version and a short version of one another; they are two different kinds of object, and a question that suits one of them will get a confident, useless answer out of the other.

Girnar Asset Management Limited, an invented asset manager, runs the Girnar Large Cap Equity Fund, an open ended equity scheme whose recorded net assets are Rs 4,200 crore against 120.00 crore units outstanding. Kalyani Bhagat manages the portfolio and Sohail Merchant heads operations. A trustee company, a custodian, a registrar and transfer agent, an auditor and a distributor all sit around the scheme, each doing one defined job.

Two conventions run through the comparison. Not one holding of the Girnar Large Cap Equity Fund is stated anywhere below: no security, no weight, no cash position, not one line item, and a cell that would need such a figure stands empty and is labelled empty. The second convention concerns the rules. What each of these two documents must contain, how often each must appear, and the shape each must take are set by the Securities and Exchange Board of India (SEBI). Requirements of that kind get revised. A statement that prints one of them today is not merely out of date the morning it changes; it is untrue. So every row of that kind stands blank with the source named inside it, to be filled from sebi.gov.in on the day the question actually matters.

What is each of these two documents, in one line?

A portfolio disclosureA scheme's holdings as they stood on one named date, put out in public. is a dated list of what one scheme held, set out in a standard shape. The standard shape is what makes the same scheme in two different periods, and two different schemes in the same period, all look alike. A factsheetThe manager's own periodic summary of one scheme, laid out in panels. is the manager's own periodic summary of one scheme, laid out in panels, each panel answering a different sort of question about the scheme as a whole.

The nature of a dated list, how it reaches a reader and what its stated date does to everything on it are covered under portfolio disclosure. The arrangement of a factsheet's panels, the order to read them in and what the performance panel means on which basis are covered under factsheet structure. One property separates the two documents, and every other difference a reader will ever meet descends from it.

One of these documents is a list and the other is a summary, and every other difference between them is a consequence of that one. A list has rows, and a row is an item with a size attached. A summary has statements, and a statement is a description somebody wrote after looking at rows the reader cannot see. A household coming back from the wholesale market shows the difference. The bill in the bag is a list: every item, every quantity, every amount, and the bottom of the bill has to match what left the purse. The sentence somebody says at the door, that it was mostly grains and a bit of oil, is a summary. Both are true. Only one of them can be added up, and only one of them tells at a glance how the trip went.

Try it out

What single structural difference generates every other difference between these two documents?

Try it out

One of these two documents can be added up to a figure that can be checked against something else. Which one, and what does it check against?

Which five tests separate a list from a summary?

Five tests, applied to both sides in the same order, and four of the five fall out of the first one. GranularityHow finely a document reports what it reports. comes first: the list names every holding and puts a size beside each. The summary shows groupingsMany holdings collapsed into a category that somebody chose. that somebody at the manager decided on, with the individual rows folded away inside them. Purpose comes second: one exists to disclose what was actually held on a stated date, the other exists to describe the scheme and print its headline figures for a stated period.

Producer is the third test. The answer is the same on both sides, and that is what surprises people. Girnar Asset Management produces both. The freedom Girnar has differs between the two. On the list side it works to a shape it did not design. On the summary side the shape is largely its own, within whatever limits apply. Most readers reach first for who wrote them, and asking that separates nothing at all.

The fourth test is cycle, and the row stands blank on both sides. Both documents appear on a schedule, and both schedules have rules behind them. A printed frequency of that kind becomes a false statement the moment the rule behind it moves, and it moves without telling anybody who copied it.

The fifth test is the one almost nobody thinks to apply, and it is the test that decides which questions each document can answer: what does it add up to? The list adds up to a total, and that total has to agree with the scheme's net assets. The agreement between the list total and the net assets is a reconciliationThe check that a list's total agrees with the scheme's own net assets., and a reconciliation is the reason a list can be trusted to be complete rather than merely representative. The summary adds up to nothing that can be checked. Its groupings were formed by somebody else's choices, and there is no independent figure sitting outside the document to test them against.

Five tests, both documents, same order. Watch four of them fall out of the first. THE TEST PORTFOLIO DISCLOSURE, A LIST FACTSHEET, A SUMMARY Granularity Every holding named, and each one sized. Nothing is folded into anything else. Groupings that somebody chose, with the individual rows folded away inside them. Purpose To disclose what the scheme actually held on one stated date. To describe the scheme and print its headline figures for a stated period. Producer Girnar Asset Management, working to a shape it did not design. Girnar Asset Management, working to a shape largely of its own choosing. Cycle how often it comes NOT STATED HERE SEBI, sebi.gov.in NOT STATED HERE SEBI, sebi.gov.in What it adds up to the deciding row A total that has to agree with the scheme's net assets, Rs 4,200 crore. THE AGREEMENT IS THE CHECK. CANNOT BE FORMED No total here can be checked from outside. ONE DIFFERENCE GENERATES THE OTHER FOUR: ONE DOCUMENT IS A LIST, THE OTHER IS A SUMMARY. The cycle row stays empty on both sides. How often either one appears is SEBI's to set, and it is read at sebi.gov.in.
Five tests applied to both documents in the same order show that granularity, purpose, cycle and checkability all descend from the single fact that one is a list and the other a summary.

The last row of that grid does more work than it appears to. The list side carries a figure. The summary side carries an empty box that says the total cannot be formed, and that emptiness is not the drawing falling short, it is the finding. When a document is described as comprehensive, the useful question is not how long it runs; it is whether anything in it can be added up and set against a number that came from somewhere else.

One of these two totals has something outside the document to agree with. The other has nothing. THE DATED LIST THE SUMMARY PANEL Row one NO FIGURE RECORDED Row two NO FIGURE RECORDED Row three NO FIGURE RECORDED Row four NO FIGURE RECORDED and every remaining row, to the end of the list TOTAL OF EVERY ROW Rs 4,200 crore MUST AGREE WITH THE SCHEME'S NET ASSETS Rs 42,00,00,00,000/-, and here it does Grouping one NO FIGURE RECORDED Grouping two NO FIGURE RECORDED Grouping three NO FIGURE RECORDED and whatever other groupings the panel carries TOTAL OF EVERY GROUPING CANNOT BE FORMED THERE IS NOTHING OUTSIDE THIS PANEL for a reader to check it against This record holds no holdings for either scheme, so every row above is drawn empty rather than filled with a plausible figure. THE CLAIM IS STRUCTURAL: A LIST HAS A TOTAL THAT MUST AGREE. A SUMMARY HAS NO TOTAL AT ALL.
The list totals to a figure that has to agree with the scheme's net assets, while the summary's groupings add up to nothing a reader can test from outside the document.

What can each document settle by itself?

Take the list first. On its stated date the list settles composition, meaning simply what was there, and it settles concentrationThe share of a scheme carried by its biggest few positions., meaning what share of the whole sat in the biggest few positions. Both of those are settled computably, without taking anybody's word for it. Adding the rows and taking the largest few as a share of the total gives an answer that is arithmetic performed rather than a description accepted. Arithmetic performed rather than description accepted is the whole reason the list exists in a set format: a format that is the same everywhere is a format that can be computed across.

Now the summary. The summary settles the scheme's stated aim, its size, its value per unit, its charge, and its reported performance beside whatever yardstick the manager prints, each of those as at the as-at dateThe point in time that a document's figures were actually true of. printed on it. The load is real and useful. A reader who wants the scheme's purpose, its size, the worth of one unit and its record over a stated period is holding exactly the right document, and holding the list instead would leave them worse off.

Neither of these is the richer document in general, and a reader who has a favourite will eventually carry a question to the wrong one. Richness is not a property of a document. Richness is a property of the pairing of a document and a question. The list is enormously rich about composition and completely silent about aim, cost and return. The summary is the reverse. The moment one of them is settled on as the serious document and the other dismissed as marketing, the question actually in hand has stopped being asked.

Try it out

Which of the two is the richer document?

What can neither document settle?

Four things, and the shape of the four is more instructive than the list itself. Neither document says why anything is held: a holding appears with a size, not with a reason, and a summary's commentary describes rather than justifies. Neither says what will be held next. Neither states what an investor's own transaction will be priced at. The price that applies to a purchase or a redemption turns on rules about the point at which the application and the money actually reach the scheme, and those rules are SEBI's. And neither states whether the scheme suits any particular investor.

Three of those four are about the future, and no report of any kind carries the future; the fourth is about the individual investor, and no publication has ever met one. That is the whole explanation for why these four sit outside both documents, and it is why no third document would fix it either. A document is a record of a state that has already happened, addressed to nobody in particular. Asking it what comes next is like asking last month's electricity bill what this month's will be. The bill has the meter reading. The bill does not have July.

Four questions sit outside both documents, and three of the four share one reason. ABOUT THE FUTURE, WHICH NO REPORT CARRIES Why anything is held at all a size, not a reason What will be held next no document has July What an investor's own transaction will price at SEBI rules, sebi.gov.in ABOUT THE INVESTOR Whether the scheme suits the investor no publication met the investor A DOCUMENT IS A RECORD OF A STATE THAT HAS ALREADY HAPPENED. It is addressed to nobody in particular, which is why it can settle what was and never what will be, and never what fits a particular investor. NO THIRD DOCUMENT FIXES THIS. THE LIMIT IS IN WHAT A DOCUMENT IS. Looking harder at either one of the two, or at both together, does not move any of these four questions inside.
Three of the four questions neither document settles are about the future and the fourth is about the reader, which is why no third document would close the gap.
Try it out

Three of the four things neither document settles have something in common. What is it?

Try it out

The question is how much the scheme traded over a period. Which document answers it?

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Which reader question goes to which document?

Six real questions go to the Girnar Large Cap Equity Fund's two documents, in the order somebody actually asks them. The refusals are what make the answers worth having, so watch how many come back with nothing.

The first question is what the scheme was worth per unit at the stated date. The worth question goes to the summary, and the division is done by the reader rather than read off the document: net assets of Rs 4,200 crore divided by 120.00 crore units outstanding. In whole rupees that is Rs 42,00,00,00,000/- divided by 1,20,00,00,000 units. The answer is Rs 35.00 per unit exactly, and the division leaves no remainder at all. Run backwards as a check, Rs 35.00 across 1,20,00,00,000 units comes to Rs 42,00,00,00,000/- again. Neither direction needed any rounding, so no rounding decision had to be made here at all.

DirectionThe arithmetic, in whole rupeesResult
ForwardRs 42,00,00,00,000/- divided by 1,20,00,00,000 unitsRs 35.00 a unit
RemainderWhat is left over after that divisionNil, it is exact
BackwardsRs 35.00 a unit across 1,20,00,00,000 unitsRs 42,00,00,00,000/-

The second question is what the scheme returned for the stated year and against what. The return question also goes to the summary, and it is the one routing where the answer is worthless unless two labels travel with it. The scheme's recorded figure for the stated year is 13.4 per cent, and that is a net returnA figure worked out from values that had the charge taken out of them first, so nothing comes off it later., worked out from values that had already given the charge up. Printed beside it is the stated benchmark for the same year at 12.1 per cent, and that figure sits on a costless basisA figure that never had a charge taken out of it, since holding an index is not something anybody is billed for.. An index is a calculation rather than something anybody buys, so nobody is ever billed for holding it. The difference printed on the document is 1.3 points, and that difference subtracts a figure that has borne a charge from a figure that never could. Putting both onto one basis moves the honest reading to somewhere near three points, more than twice what the document appears to show. Levelling two bases onto one is covered under performance reporting. One year, one scheme, and this record carries no second year to set beside it.

The third question is how concentrated the scheme was at the stated date. Concentration goes to the list, and only to the list. A summary panel shows groupings, and a grouping was formed by somebody's choice about where to draw a boundary; how much sat in the largest single holding cannot be recovered from it. The fourth question is what the scheme held on a date falling between two published lists. A date between two published lists goes to neither. A list exists at its stated dates and nowhere else, and reading across from the nearest one is precisely the assumption ruled out under portfolio disclosure.

The fifth question is how much the scheme traded over the period. Neither, and the reason is worth being blunt about: no holding of this scheme is stated anywhere in the comparison, so even a document that did report trading would have no line to report it against. The sixth question is what the scheme will hold next month. Neither, and nothing published anywhere carries it. A routing that always produces an answer quietly teaches a reader that every question has a document waiting behind it. The lesson is false, and a false lesson is worse than no routing at all.

Six questions, three destinations. The connectors show which document answers each one. 1. What was it worth per unit at the stated date? 2. What did it return for the stated year, and against what? 3. How concentrated was it at the stated date? 4. What did it hold on a date between two published lists? 5. How much did it trade over the period? 6. What will it hold next month? THE DATED LIST and only the dated list THE SUMMARY with both bases named NEITHER DOCUMENT Three of the six come back with nothing at all, and the routing says so rather than sending the reader somewhere. HALF THE VALUE OF A ROUTING IS THE HALF THAT REFUSES TO SEND THE READER ANYWHERE. Spacing between the six shows order of asking, not any interval of time between them.
Concentration routes to the dated list and the two headline figures route to the periodic summary, while three of the six route nowhere and are told so plainly.

Set out as rows, the same six routings look like this, with the thing to be checked independently named in the last column. The last column is empty for exactly the three that route nowhere. An honest routing table looks exactly like that.

The question askedWhere it goesWhat the reader checks
Worth per unit at the stated dateThe summaryThe division, Rs 4,200 crore over 120.00 crore units
Return for the stated year, and against whatThe summaryThat both figures carry a period and a basis
How concentrated at the stated dateThe dated listThe largest rows as a share of the total
Held on a date between two listsNeither
How much it traded over the periodNeither
What it will hold next monthNeither
Total that can be formed across the sixCannot be formedThree answers and three refusals do not add
Try it out

Suppose the question is what the scheme held on a date that falls between two published lists. Which document carries it?

Try it out

A summary prints net assets of Rs 4,200 crore and 120.00 crore units outstanding. How much is one unit worth, and why is doing the division yourself worth the ten seconds?

Comparing Funds Without Being Fooled teaches you to compare on the right basis and to know what a returns table hides.

Why can a summary never be turned back into a list?

Because grouping throws information away, and no amount of care at the reading end puts it back. When four rows are folded into one grouping, what survives is the grouping. Which rows went in, and how much of each, is gone from the document. An hour spent looking at that grouping will not recover it, not because the manager hid anything but because the operation itself does not keep a record of its own inputs.

The other direction works every time. Given the full list, somebody can build any summary at all: group it by whatever categories are named, total each group, print the panel. The list contains the summary. Summarising is a one way operationSomething that can be done and can never be undone., and the direction it runs in is the whole reason the two documents are not substitutes for each other.

Household version. A shopping bill goes into the bag and somebody writes in the diary that Tuesday cost about eleven hundred rupees on groceries. From the bill, that diary line can be produced in a moment. From the diary line, nobody in the house can ever again say what the rice cost, or whether it was the oil or the pulses that made the trip expensive. The diary is not a worse document than the bill. The diary is a different document, and it was made by destroying something.

The practical consequence for anybody short of time is direct. Where exactly one of the two is kept for a date that genuinely matters, it should be the list. The summary can always be regenerated from it. The other direction is never available, and the day the composition is needed and only the panel is at hand is the day that becomes clear.

The operation runs in one direction. Going back the other way is not hard, it is impossible. A LIST Every row present and separately sized. Drawn empty: this record holds no holdings at all. SUMMARISE always possible REBUILD THE LIST never possible A SUMMARY Grouping one Grouping two Grouping three Three groupings somebody chose, each one holding rows that can no longer be seen. WHAT THE FOLD THREW AWAY, AND CANNOT PUT BACK Which row sat inside which grouping, and how much of each. The grouping keeps no record of its own inputs, so the fold cannot be undone by anybody, at any level of effort, however carefully the panel is read.
A summary can always be built from a list while a list can never be rebuilt from a summary, which is why keeping the list keeps the option.
Try it out

Only one of the two documents can be kept for a date that matters. Which, and why?

What do the two cards look like with the rule rows left empty?

Here are both documents drawn as cards, side by side, with two kinds of row on each. What a list is and what a summary is do not change when a requirement changes, so the structural rows are filled in. The rows that describe a requirement are drawn empty, with the source printed inside them.

A reader trusts a filled row and has no way of knowing when it stopped being true. A card with those rows completed from somebody's recollection is therefore worse than a blank one. A form printed with the rule rows empty, filled from the source on the day the answer is needed, never goes stale.

Two cards. Structure filled in, requirements left blank with the source inside them. PORTFOLIO DISCLOSURE WHAT IT IS A dated list of what one scheme held. AS AT One stated date, and no other date. WHAT IT TOTALS TO The scheme's net assets, Rs 4,200 crore. ROWS BELOW ARE SET BY THE REGULATOR AND STAY EMPTY WHAT IT MUST CONTAIN SEBI, sebi.gov.in to be filled in on the day it is needed HOW OFTEN IT MUST BE PUBLISHED SEBI, sebi.gov.in to be filled in on the day it is needed THE FORMAT IT MUST FOLLOW SEBI, sebi.gov.in to be filled in on the day it is needed FACTSHEET WHAT IT IS A periodic summary of one scheme, in panels. AS AT A stated date printed on the document. WHAT IT TOTALS TO CANNOT BE FORMED ROWS BELOW ARE SET BY THE REGULATOR AND STAY EMPTY WHAT IT MUST CONTAIN SEBI, sebi.gov.in to be filled in on the day it is needed HOW OFTEN IT MUST BE PUBLISHED SEBI, sebi.gov.in to be filled in on the day it is needed WHICH PERFORMANCE PERIODS IT MUST SHOW SEBI, sebi.gov.in to be filled in on the day it is needed ACROSS BOTH: WHAT THE MANAGER MUST PUBLISH ON ITS OWN SITE, AND HOW LONG IT STAYS THERE SEBI, sebi.gov.in. The industry level route to a scheme's published documents sits with AMFI at amfiindia.com. ILLUSTRATION. THE SCHEME AND EVERY FIGURE ON IT ARE INVENTED. NO REAL DOCUMENT IS REPRODUCED HERE.
Both cards carry their structural rows filled in and every requirement row drawn empty with the source printed inside, so the form stays correct when a requirement moves.

Who actually reaches for which of these on a working day?

Three people, and they reach differently. Somebody tracking how concentrated a scheme has been over time pulls the dated lists and nothing else, one for each stated date, and computes the same measure on each of them. The summary would give them a different set of groupings to compare and no way to check either set, so it never gets opened for that work. The list is the working document not because it carries more detail, but because the same computation runs on every one of them.

Somebody sitting with a household deciding what to do next reaches for the summary, and correctly. The scheme's stated aim, its cost, its size, the worth of one unit and its reported figures for a stated period are all in there, laid out to be read rather than processed. The one habit worth building is to redo the value per unit from the two printed figures instead of reading the third one off the document. Ten seconds of arithmetic catches a typesetting slip that no amount of reading would.

And Sohail Merchant's operations desk sits on the other side of both, producing them. From that side the difference is obvious in a way it is not from the reading side: one of the two has to reconcile before it goes out, and the other has to read well. Neither person on the reading side should conclude from any of this that one document is the better one. The two documents were built for different jobs.

Where this goes wrong, and what the wrong reading costs

Somebody wants to know whether a scheme is concentrated. The factsheet turned up in the inbox and it is pleasant to read, so the factsheet is the one they open. The portfolio panel shows holdings spread across several groupings, none of them looking dominant, and they close the file satisfied that the scheme is well spread.

The panel could not have told them that. The groupings were drawn by somebody at the manager, and a grouping can contain one large position or twenty small ones without the panel looking any different. A spread across groupings is therefore entirely consistent with heavy concentration inside one of them. Nothing in the panel adds up to anything checkable, so what has happened is that a description was accepted in place of a computation that was sitting three clicks away in the published dated list.

Concentration is precisely the property that decides how much a scheme's value moves when one holding moves, so the cost of reading it wrong is not small. A wrong reading of it produces a wrong expectation about how the whole scheme behaves, and that wrong expectation will not be discovered on the day it is formed. The discovery comes later, when something moves and the movement is a different size than the reader was braced for.

The reason the mistake is so natural is structural rather than careless: the factsheet is designed to be read and the list is designed to be filed, so the document that arrives in front of the reader is the one that cannot answer the question brought. The fix is one line long. A question that has to be added up goes to the document that can be added up.

One panel, two completely different schemes underneath it, and no way to tell which. A SUMMARY PANEL, AS IT ARRIVES Grouping one NO FIGURE RECORDED Grouping two NO FIGURE RECORDED Grouping three NO FIGURE RECORDED Nothing in this panel totals to a figure a reader can form. CONSISTENT WITH an even spread of holdings inside each of the groupings shown. THE PANEL READS THE SAME. EQUALLY CONSISTENT WITH one holding dominating a grouping while everything else is tiny. THE PANEL READS THE SAME. THE PANEL CANNOT SEPARATE THE TWO. A SPREAD OF LABELS IS NOT A SPREAD OF MONEY. Neither arrangement is drawn with figures, because this record holds no holdings for the scheme and a plausible invented weight would read on the screen exactly like a disclosed one. The dated list is what separates them.
A spread of groupings on a summary panel is equally consistent with an even spread and with one holding dominating, so the panel cannot settle the question at all.
No scale on either axis. Position shows order only, never any measured distance. ADDS UP to a check DOES NOT ADD UP designed to be filed designed to be read THE DATED LIST answers it, rarely opened THE FACTSHEET opened first, cannot answer it THE DOCUMENT THAT ARRIVES SITS OPPOSITE THE DOCUMENT THAT ANSWERS A COMPOSITION QUESTION. That is why the wrong one gets used, and why the mistake feels natural rather than careless.
The document designed to be read sits opposite the document that can be added up, which is why the wrong one so often gets used.
Try it out

A factsheet's portfolio panel shows holdings spread across several groupings. Is the scheme well spread?

India

Who decides what each of these two documents must carry?

SEBI decides it, and every row below stands blank. Requirements of this kind are revised, and a copy of one that has moved is not merely dated, it is misleading. Each row is filled from sebi.gov.in on the day the answer matters.

The required contents of a portfolio disclosure: SEBI, sebi.gov.in. How often a portfolio disclosure must be published: SEBI, sebi.gov.in. The format a portfolio disclosure must follow: SEBI, sebi.gov.in. The required contents of a factsheet: SEBI, sebi.gov.in. How often a factsheet must be published: SEBI, sebi.gov.in. Which performance periods a scheme must show: SEBI, sebi.gov.in. Everything an asset manager must publish on its own site, and how long it must stay there: SEBI, sebi.gov.in.

Finding where a scheme's published documents actually sit, at the industry level, belongs to the Association of Mutual Funds in India (AMFI), at amfiindia.com. The association names where something is published rather than what it has to say, and it makes none of the rules above. Read against a market other than India, the mechanism still holds. The argument about lists and summaries does not depend on any requirement at all, so what changes is the set of addresses, and it changes by adding rows rather than by rewriting the argument.

What a dated holdings list is and how it reaches a reader, and what a factsheet is and how its panels are arranged, are both covered separately. The offering documents are covered separately as well, and the exchange traded version of the summary is covered separately after it. How a portfolio gets built in the first place, and how concentration is measured as a discipline rather than read off a document, are both covered under portfolio material. What either document must contain, how often either appears, the format of the list and the periods the summary must show belong to SEBI, the body that writes them and later revises them. Two addresses stand in place of any figure of that kind: sebi.gov.in for the requirement itself, amfiindia.com for where a scheme's published documents actually sit. Two documents, two jobs, and the routing card is the whole output.
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References

SourceDocumentWhere
Securities and Exchange Board of IndiaThe rules setting what a portfolio disclosure and a factsheet must each contain, how often each must be published, the format each must follow, which performance periods a scheme must show, and what an asset manager must keep published on its own site and for how long.sebi.gov.in
Association of Mutual Funds in IndiaThe industry level route to where a scheme's published documents can be found. This source makes none of the rules above.amfiindia.com

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.

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