Chapter 3 NISM V-A Notes: Legal Structure of Mutual Funds in India

Structure Of Mutual Funds In India : 

  • Definition: A mutual fund is a trust-based investment vehicle defined by SEBI regulations to raise money via sale of units for investing in securities, gold/silver-related instruments, or real estate. 
  • Key Characteristics
  • Established as a trust. 
  • Raises public money through schemes. 
  • Investments span multiple financial and physical asset categories. 
  • Legal Framework
  • Governed by SEBI (Mutual Fund) Regulations, 1996 and the Indian Trusts Act, 1882. 
  • Trust Components
  • Sponsors create the trust. 
  • Investors (unit-holders) are the beneficiaries. 
  • Trust Deed governs operations and trustee appointment/change. 
  • Trustees’ Role
  • Protect investor interests. 
  • May be individuals (Board of Trustees) or a trustee company (Board of Directors). 
  • Asset Management Company (AMC)
  • Appointed by sponsors/trustees to manage schemes. 
  • Operates under an investment management agreement. 
  • Custodian & RTA
  • Custodian holds scheme assets. 
  • Registrar & Transfer Agent (RTA) or AMC maintains investor records. 

Key Constituents Of Mutual Funds : 

  • Sponsors
  • Apply to SEBI for mutual fund registration and invest in AMC. 
  • Must have at least 5 years in financial services with positive net worth and profits. 
  • Required to have ₹10 crore average net profit over the last 5 years. 
  • Must be “fit and proper” as per SEBI norms. 
  • Board of Trustees
  • Appointed by sponsors; must be reputable and not involved in economic/securities violations. 
  • At least 4 trustees required; 2/3 should be independent. 
  • Responsible for legal compliance, investor protection, and overseeing AMC operations. 
  • Must conduct regular reviews, file SEBI reports, and perform due diligence. 
  • Mutual Fund Trust
  • Formed via a registered trust deed under the Indian Registration Act, 1908. 
  • Asset Management Company (AMC)
  • Handles day-to-day operations and investments. 
  • Must have ₹50 crore net worth (from Jan 2024) and independent directors. 
  • SEBI/trustee approval needed for director changes or control shifts. 
  • Responsible for due diligence, investor communication, and regulatory compliance. 
  • Custodian
  • Manages fund assets, settles transactions, and monitors corporate actions. 
  • Must be SEBI-registered; appointed via agreement with trustees. 
  • Must be independent if sponsor controls 50%+ of its voting rights. 

Organization Structure Of Asset Management Company : 

  • Compliance Function
  • Ensures regulatory compliance and legal formalities. 
  • Compliance Officer signs due-diligence certificates and reports directly to AMC head and trustees. 
  • Fund Management
  • Core function involving investment decisions. 
  • Divided into analysts (identify opportunities), fund managers (make investment decisions), and dealers (execute trades). 
  • Operations and Customer Service
  • Includes front and back office, customer service, RTA (handles transactions and investor records), custody, fund accounting (calculates NAV), and cash management. 
  • Sales and Marketing
  • Responsible for branding, advertising, and managing distributor relationships. 
  • Drives investor outreach and supports distributor network development. 
  • Other Support Functions
  • Include Finance/Accounts (AMC finances), Administration (infrastructure), HRD (talent management), and IT (technical infrastructure and online services). 

Role & Support Functions Of Service Providers : 

  • Fund Accountant: Calculates Net Asset Value (NAV) using scheme asset and liability data; may be in-house or outsourced; SEBI registration not required. 
  • Registrars and Transfer Agents (RTAs): Maintain investor records, process transactions, and update investment details; SEBI registration required; optional for AMCs to appoint. 
  • Auditors: Audit scheme accounts separately from AMC accounts; appointed respectively by trustees (for schemes) and AMCs (for themselves). 
  • Distributors: Sell mutual fund schemes; require NISM certification and AMFI registration; SEBI permits a simplified distributor category with limited product range. 
  • Collecting Bankers/Payment Aggregators: Handle fund inflow/outflow; include traditional banks and digital platforms like wallets and payment gateways. 
  • KYC Registration Agencies (KRAs): Centralize investor KYC process to avoid repetition; SEBI-registered, must maintain data security and interconnectivity. 
  • Valuation Agencies: Provide fair value matrices for non-traded debt securities; AMCs must use these; CRISIL and ICRA appointed by AMFI. 
  • Credit Rating Agencies: Assess credit risk of securities; vital for investment decisions in debt funds and schemes like FMPs and capital protection-oriented funds. 
  • Depositories and DPs: Hold mutual fund units in demat form; NSDL and CDSL are key players; ETFs must be held in demat. 
  • Stock Exchanges & Platforms: Facilitate mutual fund transactions (e.g., BSE-Star MF, NSE NMF-II, MF Utilities); Execution Only Platforms (EOPs) enable digital transactions in direct plans, needing SEBI or AMFI registration. 

Role & Function of AMFI : 

  • AMFI (Association of Mutual Funds in India) is an association of all registered Asset Management Companies (AMCs) in India. 
  • Objectives include promoting ethical standards, best practices, and a code of conduct in the mutual fund industry. 
  • Acts as a representative to SEBI, the government, RBI, and other authorities on matters related to mutual funds. 
  • Conducts investor awareness programs and promotes understanding of mutual fund operations. 
  • Disseminates information and undertakes research related to the mutual fund industry. 
  • Regulates mutual fund distributors, including registration via AMFI Registration Number (ARN) and disciplinary actions. 
  • AMFI is not a regulatory body or SRO, but plays a key advisory and facilitative role. 

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