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046

Case 046Compliance, risk limits and conductWarm up

A draft mutual fund advertisement says Our fund returned 42% last year, with no benchmark, no standard periods and no risk statement. Rewrite it within the rules on performance advertising and explain each change.

1The situation

Chaturang Mutual Fund's marketing team sends compliance a draft newspaper and social media advertisement for its flexi cap fund. The headline reads Our fund returned 42% last year! with a line inviting readers to start an SIP. It shows no benchmark, no other periods, no date, no plan and no risk statement.

The fund's data, as of the last quarter end, regular plan: 1 year 42.0% (scheme benchmark 38.5%, broad market index 31.2%); 3 years 16.2% a year (17.1%, 14.0%); 5 years 13.8% a year (14.4%, 12.6%); since launch ten years ago 12.9% a year (13.2%, 11.8%). You work in compliance.

2Your task

Rewrite the performance section within the rules on mutual fund performance advertising and explain each change. Confirm the current SEBI format before relying on any detail.

Quick check

Why do the rules require standard periods rather than letting the AMC pick one?

Worked solution

Try it on paper, then open one step at a time.

30-second answerThe answer to give first

Replace the single 42% with returns for 1, 3 and 5 years and since launch, each beside the scheme benchmark and a broad market index, as compound annual rates and as the value of Rs 10,000, dated and for a named plan, with the standard risk statement and riskometer. The rewrite shows the fund ahead of its benchmark over one year but behind it over three, five and ten. That less flattering picture is exactly what the rules exist to show.

Step 1What is wrong with the draft, item by item?

A restaurant that advertises one perfect review from one night, out of three years of meals, is not lying about that night, but it is misleading you about the restaurant. A single good year shown alone misleads, which is why performance advertising rules require standard periods, a benchmark and a risk statement. The draft has five problems: no benchmark, so 42% has nothing to be judged against; one period chosen because it flatters; no date or plan; no compound annual growth rates or rupee values over the standard periods; and no risk statement or riskometer.

A single good year shown alone misleadsChaturang Flexi Cap Fund42%Our fund returned 42% last year!Invest today and grow your wealthStart an SIP nowChaturang Mutual Fund11No benchmark: 42% against what?22One period, picked because it flatters33No date, no plan (regular or direct)44No CAGR or Rs 10,000 over 1, 3, 5 years, launch55No risk statement, no riskometerRewritten: fund behind benchmark over 3, 5, 10 yrs
The draft headline of 42% fails on five counts, no benchmark, a single chosen period, no date or plan, no standard-period returns and no risk statement, and once rewritten it shows the fund behind its benchmark over three, five and ten years.
Step 2What does the rewritten performance section show?

Show each standard period as a compound annual growth rate for the fund, its scheme benchmark and an additional broad market benchmark, and as the value today of Rs 10,000 invested at the start. Name the plan, since regular and direct plans have different returns, and state the as-of date. SEBI's advertising code and its performance disclosure format set these requirements; confirm the current version, including whether the performance of other schemes run by the same manager must also be shown.

Regular plan, as of quarter endFundScheme benchmarkBroad market indexRs 10,000 became (fund / benchmark)
1 year42.0%38.5%31.2%14,200 / 13,850
3 years16.2%17.1%14.0%15,690 / 16,057
5 years13.8%14.4%12.6%19,086 / 19,594
Since launch, 10 years12.9%13.2%11.8%33,646 / 34,551
The fund beat its benchmark by 3.5 points over one year but trailed it over three, five and ten years, so Rs 10,000 invested at launch grew to about Rs 33,646 against Rs 34,551 in the benchmark.

Read honestly, the fund had one excellent year inside a decade of slightly lagging its benchmark: since launch, Rs 10,000 grew to about Rs 33,646 against Rs 34,551, about Rs 905 less. It still beat the broad market index over every period, which is a fair point to make, so the rewrite does not need to bury the fund; it needs to stop hiding the comparison.

Step 3What else changes, beyond the numbers?

Add the standard mutual fund risk statement in the prescribed size and wording, the scheme's riskometer, and a line that past performance may or may not be sustained in future. Remove grow your wealth, which implies a return, and keep the call to start an SIP neutral. Keep a file note of why each change was made, because the ad will be reviewed again when the next quarter's numbers arrive and the one-year figure looks different.

Where candidates lose it

The common loss is adding a benchmark to the one-year figure and stopping. 42% against 38.5% looks even better, and the candidate has improved the misleading ad rather than fixed it; the standard periods are what reveal the lag.

The second miss is quoting a specific SEBI clause or font size from memory. The safe answer names the framework, standard periods, benchmarks, Rs 10,000 values, risk statement and riskometer, and says the current format must be checked.

What the interviewer asks next

  • Marketing wants to show the direct plan's returns because they are higher. Is that allowed, and what must go with it?
  • How would you handle a fund that is less than one year old?
  • The fund manager also runs two weaker schemes. Should their performance appear in this ad?
← Case 045A dynamic bond fund expects rate cuts and must choose between a 10-year callable bond with modified duration 7.1 and effective duration 4.2, and a 7-year bullet with duration 5.6, at similar yields. Which gains more from a 100 basis point fall, and what allocation would you run today?Case 047 →A client holds four equity funds of Rs 5 lakh each; pairwise overlap by weight runs from 41% to 62%, and together they hold 212 stocks but the top 40 make up 71% of his money. How many funds is he really holding, and what would you consolidate?

Company names and figures are illustrative.

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