Case 076Bank economics, fees and riskCore
A review of one adviser's last 50 client switches finds 70% went into the product paying 1.2% against alternatives paying 0.4%, on Rs 40 crore moved. What is the extra annual cost to clients, and which switches need a suitability check?
1The situation
A private bank's supervision team pulls the last 50 switches made by one adviser. Together they moved Rs 40 crore of client money. 35 of the 50 switches, Rs 28 crore, went into the bank's in-house multi-asset fund, which pays the desk a trail of 1.2% a year out of its expense ratio. The comparable funds the clients were in, or could have been put into, pay 0.4%. Assume the difference in trail is the whole difference in the clients' annual cost.
Across the whole desk, 35% of switches go into the 1.2% product. The file notes give three facts about the 35 switches: 9 of them, Rs 8 crore, moved clients out of a similar fund they had held for under a year, paying a 1% exit load; 10, Rs 7.5 crore, moved clients over 65 or rated conservative into the fund, which holds about 60% equity; the other 16, Rs 12.5 crore, carry no flag.
2Your task
What does the pattern cost clients each year, is it a pattern or chance, and which switches do you review first?
Quick check
What is the extra annual cost to clients of the switches into the 1.2% product?
Worked solution
Try it on paper, then open one step at a time.
30-second answerThe answer to give first
The pattern costs clients about Rs 22.4 lakh a year, and it is almost certainly not chance. Rs 28 crore sits in a product costing 0.8 points more than the alternatives. Against the desk's own 35% habit, 35 of 50 switches has well under a one in a million chance of happening at random. Review first the 9 switches that paid exit loads to leave a similar fund, then the 10 older or conservative clients moved into 60% equity.
Step 1How do you put a rupee figure on a conflict of interest?
Price the gap, not the product. Think of a pharmacist who hands out the branded medicine when a generic does the same job: the harm is the price difference on the prescriptions he steered, not the price of every medicine he sold. The client cost of steering is the fee gap multiplied by the money that was steered, Rs 28 crore times 0.8 points, which is Rs 22.4 lakh a year. Left alone for five years that is about Rs 1.12 crore before any compounding, paid by clients for no difference in what they own. The fee here sits inside the expense ratioThe annual cost of a fund, deducted from its assets every day, so the investor sees it only as a lower return., so no client ever sees a bill for it.
Step 2Is 35 out of 50 a pattern, or could it be chance?
Use the desk as the benchmark. If this adviser chose like everyone else, you would expect 35% of 50, about 17 or 18 switches, into the product. He made 35. If each switch had a 35% chance of landing in the product, the chance of 35 or more out of 50 is about 5 in ten million. That does not prove misconduct. A book of clients who genuinely suit a multi-asset fund would also skew the numbers, which is why the next step is to read the files rather than to conclude.
| 28 crore | money switched into the product paying 1.2% |
| 1.2% - 0.4% | the fee gap the client bears each year |
| 22.4 lakh | annual extra cost across those clients |
Step 3Which switches do you check first, and why in that order?
Rank by harm that has already happened, then by harm that could happen. Group A comes first because those clients paid a 1% exit load, about Rs 8 lakh, and possibly capital gains tax, to move from one multi-asset fund to another that costs more. That switch is hard to defend on any suitability ground. Group B comes second: moving a conservative or older client into a fund that is 60% equity is a risk mismatch whatever the fee. Group C is sampled, a quarter of the files, to test whether the documented reasons hold up.
| Group | What the file shows | Switches | Rs crore | Extra cost, Rs lakh a year |
|---|---|---|---|---|
| A | Left a similar fund held under 12 months, 1% exit load paid | 9 | 8.0 | 6.4 |
| B | Client over 65 or rated conservative, moved into a 60% equity fund | 10 | 7.5 | 6.0 |
| C | No flag on file | 16 | 12.5 | 10.0 |
| Total | 35 | 28.0 | 22.4 |
Close with what the bank does next, not a verdict. Contact the Group A clients, refund loads where the switch fails a suitability test, and move the adviser's future switches into the product onto a second sign-off for a period. A strong answer adds the structural point: while the product pays three times the alternative, the next adviser faces the same pull.
Where candidates lose it
Most candidates multiply the fee gap by all Rs 40 crore and get Rs 32 lakh. The Rs 12 crore that went into cheaper funds did not cost anyone extra; applying the gap to it overstates the harm and tells the interviewer you did not think about which money was steered.
The second miss is calling it misconduct from the number alone. The flow pattern justifies a file review; the files decide. Say that, and name the group you would open first.
What the interviewer asks next
- The adviser says his clients asked for a single fund that does everything. What evidence in the file would support him?
- How would you redesign the desk's pay so the 1.2% product stops pulling flows?
- What refund would you offer a Group A client, and how do you compute it?
Company names and figures are illustrative.
