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079

Case 079Compliance, risk limits and conductCore

An analyst has high conviction in a stock and wants the fund to hold 7% of NAV against an internal limit of 5%. The position would be Rs 350 crore in a stock that trades Rs 8 crore a day. What would make the investment committee comfortable, and what should it refuse?

NUNuveenNew York · 2021

1The situation

A mid-cap equity fund with net assets of Rs 5,000 crore has an internal rule that no single stock may exceed 5% of NAV. Its analyst covering industrials has high conviction in Jalvahini Pumps, an invented maker of agricultural and industrial pumps, and asks the investment committee for an exception to hold 7%, Rs 350 crore.

Jalvahini has a market value of Rs 4,000 crore and trades about Rs 8 crore a day. The fund's desk assumes it can trade 20% of daily volume without moving the price badly. Two other schemes of the same fund house already hold 1.5% of Jalvahini's shares between them. The fund house also has a liquidity guideline: no position should need more than 60 trading days to exit at that pace.

2Your task

What measures would make the committee comfortable with the idea, and which parts of the request should it refuse?

Quick check

At 20% of daily volume, roughly how long would it take to sell Rs 350 crore of Jalvahini?

Worked solution

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

30-second answerThe answer to give first

The committee can get comfortable with the idea but should refuse the size. At 20% of volume the 7% position takes about 219 trading days to exit, and even the 5% limit takes 156, against a 60-day guideline that caps the stock near 1.9% of NAV. It would also take the fund house to about 10.2% of the company. Comfort comes from a written thesis, an independent review and pre-set exit triggers, not from an exception.

Step 1What is the committee actually being asked to accept?

Two separate risks, and conviction speaks to only one of them. A shopkeeper can be right that a product will sell and still ruin himself by stocking a year's worth of it in a shop that sells a week's worth at a time. Conviction is a view on whether the stock goes up; the limit exists for the day the view is wrong and the fund needs to get out. The committee's job is to test the first and protect the second. Size is where they meet, and it is the one thing the analyst's enthusiasm cannot change.

Step 2How long would an exit take?

Convert the position into days. At 20% of Rs 8 crore, the desk can sell Rs 1.6 crore a day. Rs 350 crore takes about 219 trading days, and the 5% limit, Rs 250 crore, still takes 156. The fund house's own 60-day guideline allows only Rs 96 crore, 1.92% of NAV. So the request is not a small stretch of a comfortable rule: the stock's liquidity says the current limit is already too large for it. And the exit would be slowest exactly when it is needed, because volume in a stock with bad news dries up and every other holder is selling too.

Days to sell each position at 20% of daily volume2% of NAVRs 100 crore62 days5%, the internal limitRs 250 crore156 days7%, the analyst's askRs 350 crore219 days60-day guideline050100150200Trading days at Rs 1.6 crore a day, 20% of Rs 8 crore volumeConviction changes none of these bars. Only size and volume do.
At Rs 1.6 crore a day, 20% of volume, a 2% position takes 62.5 trading days to sell, the 5% limit 156 days and the requested 7% about 219 days, all but the smallest far beyond the fund house's 60-day guideline.
Step 3What else does the size run into?

Ownership of the company. Rs 350 crore of a Rs 4,000 crore company is 8.75%. Add the 1.5% the fund house's other schemes hold and the house would own about 10.2% of Jalvahini, above the 10% ceiling that SEBI places on a fund house's combined holding in one company's voting shares; confirm the current rule and how it is measured. That line is regulatory, not internal, and no committee can waive it. Even below it, owning a tenth of a company's float makes the fund the market in that stock.

Test7% request5% limitWhat passes
Single-stock limitBreaches 5%At the limit5% or below
Days to exit at 20% of volume21915660 days, Rs 96 crore
Fund house ownership of the company10.25%7.75%Below the regulatory ceiling
The 7% request fails all three tests; even the 5% limit fails the liquidity test, which on its own caps Jalvahini at about Rs 96 crore, 1.92% of NAV.
Step 4What would make the committee comfortable, and what should it refuse?

Comfort comes from evidence about the idea and controls around the position. Ask for a written thesis with a bear case and the specific facts that would make the analyst sell, an independent review by a second analyst, a staged build with a check-in at each step, and exit triggers agreed before the first purchase. A liquidity-adjusted size, here nearer 2% than 7%, lets the fund express the conviction without making the exit a year-long problem. Refuse three things: the breach of the limit itself, any temporary exception that is meant to be regularised later, and any argument that conviction is a reason to relax a risk rule. The rule exists for the case where the conviction turns out to be wrong.

Where candidates lose it

Candidates spend the answer on the stock's merits, the order book, the margins, the management, as if the committee's problem were whether the analyst is right. The question is about the measures around a position, and the one number that settles it is days to exit.

The second miss is treating the 5% limit as safe. Run the same arithmetic on the limit and it already takes 156 days, which tells the committee the limit, not just the request, needs a liquidity overlay.

What the interviewer asks next

  • The analyst offers to build the position over six months so the entry does not move the price. Does that solve the committee's problem?
  • How would a 10% redemption from the fund change Jalvahini's weight if the manager sells only liquid stocks to meet it?
  • What would you put in the exit triggers, and who should be able to pull them?

Asked at Nuveen, Real Estate, New York, 2021 (Wall Street Oasis): What are the measures you would take to get an investment or credit committee more comfortable with a potential deal

← Case 078After a 150 basis point hiking cycle, a short duration fund yields 7.8% against 6.1% a year ago, with a duration of 2.5. What one-year return should an investor expect if rates stay flat, fall 50 or rise 50, and why is the starting yield the best single guide?Case 080 →A fund compares a 5-year AAA(SO) bond rated on a parent guarantee at 7.9% with a plain AA plus bond of an unrelated manufacturer at 8.1%. What does the structured obligation actually protect, and which would you own?

Company names and figures are illustrative.

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