A registrar outage delays 1.8 lakh SIP instalments by one business day while the market rises 1.2%. Which NAV should investors get, what does making them whole cost, and who pays?

Investors whose money was realised before the cut-off on the 5th are entitled to the 5th's NAV, and the cost of honouring that, about Rs 64.8 lakh, should be paid into the scheme by the AMC and recovered from the registrar. Each Rs 3,000 instalment bought 59.29 units instead of 60.00, about Rs 36 short. Re-allotting without new money would move that loss onto existing unitholders, which is no fairer.

If a shop takes your money at 5 p.m. and the till breaks, you expect the 5 p.m. price, not tomorrow's. Mutual fund purchases are priced on the day the money is realised in the scheme's account before the cut-off, so investors whose instalments arrived on the 5th are owed the 5th's NAV. That is the framework SEBI applies to NAV applicability; confirm the current circular and cut-off times before quoting them. The registrar's failure does not move the investor's entitlement.

Measure the gap in units, then in rupees. At Rs 50.00, Rs 54 crore buys 108.00 lakh units; at Rs 50.60, it buys 106.7194 lakh. The missing 128,063 units, valued at today's NAV, are worth about Rs 64.8 lakh, which is exactly 1.2% of Rs 54 crore. Per investor it is small, about Rs 36; in total it is a real liability.

Because the cost is real and someone holds it. The Rs 54 crore was invested on the 6th at prices 1.2% higher, so issuing units at the 5th's NAV gives the SIP investors more value than their money bought, and the difference comes out of existing unitholders. On an Rs 18,000 crore scheme it is about 0.0036% of NAV, tiny per head, but the rule is that one group of investors never pays for a service provider's error. The right fix is to re-allot at the 5th's NAV and have the AMC pay Rs 64.8 lakh into the scheme at the same time.

The AMC pays first because it is responsible to investors for its service providers; it then recovers from Anuvrat under the service agreement, which should carry penalty and indemnity clauses for exactly this, and Anuvrat in turn may claim on its errors and omissions insurance. Had the market fallen 1.2% instead, investors would have gained units; the AMC still re-allots at the correct NAV, because the reference is always the NAV they should have had, not whichever is better for the firm.

One nuance matters: if the outage had stopped the bank debits themselves, the money would not have been realised on the 5th, and strictly the 6th's NAV would apply. Many AMCs would still compensate, because the investor did nothing wrong. Finish with the process fixes: a reconciliation that flags collection-account credits without matching transaction feeds by the cut-off, a tested fallback file route, and a disclosure note to affected investors explaining the correction.