Why and How MF Advisors Can Charge Fees to Clients
There is a lot of confusion around this matter amongst the financial advisory fraternity. I wanted to share some of my personal views on this topic based on simple logics, interactions with other advisors and precedencies observed.
After the SEBI Investment Advisor Regulations, 2013 came into effect, many of the Mutual Fund advisors came to a conclusion that only RIAs can charge fees and not MF Advisors. Please make note of the word advisor used not the word distributor. MF Advisors are the ones who are adding value beyond pure transaction facilitation. This article is more relevant for the MF advisors who are creating real value to their clients by exhibiting professionalism.
MF Advisors Can Charge Fees
Two very important points can be referred to say that MF Advisors can charge fees. First, when SEBI banned entry load in 2009, it allowed the MF Advisors to charge fees in lieu of entry load. After all, a lot of time and efforts goes into educating/ acquiring clients and value added is much beyond transaction facilitation.
Second, SEBI has included MF Distributors under the list of people who are exempted from registering as an Investment Advisors. The exact wordings under Exemption from registration read;
“Any distributor of mutual funds, who is a member of a self-regulatory organization recognized by the Board or is registered with an association of asset management companies of mutual funds, providing any investment advice to its clients incidental to its primary activity”.
Hence, MF Advisors can charge fees but with certain restrictions and by creating real value. And this can be done within the overall regulatory framework.
Why Charging Fees is Important for MF Advisors
After the entry load ban, upfront commission ban and now talks are on about reducing overall TER, MF Advisorsincome has been hit drastically and a majority of them are finding it increasingly difficult to survive and grow. Here are some reasons why MF Advisors should charge fees to increase their income and overcome this challenge.
(1) It is economically not feasible to onboard and service the small retail investors say with an ability invest Rs. 10,000 or less a month. Hence now most of the MF Advisors are focusing only on bigger ticket size clients and ignoring the small investors. Back of the envelope calculation will show that; a good quality advisor with a boutique firm set-up should be earning no less than Rs. 10,000 per client/family per annum.
(2) There is a high entry barrier for aspiring MF Advisors, as there is hardly any income from commissions in the first 3-5 years of setting up. There is hardly any incentive for the majority of career seekers to take this as a profession of choice, because of poor income stream only with commission based model.
(3) Now with Direct Plans & Online Investing gaining popularity day by day if your existing clients or prospects want to just get your advice but would like to invest directly online. It’s better to have an alternative fee-based model than to say ‘NO’ and shoo them away.
(4) With commission disclosure coming soon from October (next month), those MF Advisors having clients with lower ticket size should be easily able to communicate the gap between how much they are earning and how much value they are adding. And charge fee.
(5) Charging fees also help ensure your clients and prospects perceive you as an “advisor/professional/consultant” and not as an “agent/distributor/broker”
There are many more reasons why MF Advisors should charge fees based on advisor specific situation and client-specific situations. These were just the top 5.
Anyone doing Rs. 5000 SIP has the ability to pay Rs. 5000 Fees. But why should they pay?
A person doing a Rs. 5000 SIP would typically have a minimum income of around Rs. 50,000 p.m. i.e. Rs. 6 lakhs p.a. And I think a person earning that much would easily have the ability to pay Rs. 5000 as professional fees. Now it’s the duty of MF Advisor to convert that “ability” into “willingness” by creating a strong value proposition and learning the art of communicating that value.
There are certain things investors will value and be willing to pay for it. Some of them are;
Create a Written Goal based Investment Plan – covering all goals of family
Help them create/track their Networth Statement and Income Expenditure Statement
Proper Risk Profiling to understand investor beyond the time horizon of investments
Properly written process showing how your shortlist and recommend MF Schemes
Quarterly, Half Yearly or Annual Review Meetings to track progress
Your qualifications, testimonials, personal branding, and other credibility builders
Good communication & relationship skills – nobody explicitly asks, but is expected by all
Do’s and Don’ts while charging Fees
I think MF Advisors should respect the SEBI Investment Advisors regulations and follow the law of land. And appreciate the fact that RIAs are making an extra effort to build new practice models and taking the pain to comply with the regulations. There are certain things to take care of while charging fee being only a MF Advisor. Here they are, based on my interpretation of regulations;
Avoid calling your services as “Investment Advisory” or “Financial Planning”. Both terms/services come under the gambit of RIA regulations. Call your services as Personal Financial Advisory, Goal-based Investment Recommendations, MF Suitability Analysis Report, Wealth Management etc.
Avoid doing Comprehensive Financial Plans – Data Collection, Analysis, and Recommendation of multi-asset/product classes in one report. This falls under RIA. MF Advisors should stick to Data Collection and Analysis of what is required to give Mutual Fund Investment recommendations.
Create and Maintain documentation of risk profiling, reports generated, recommendation of MF advice, MF Selection process, communication with clients etc. This also helps you in justifying your value add and fees.
Sample of a Report which MF Advisors can Generate for charging Fees
I think SEBI should encourage MF advisors to charge fees and increase income to ensure good talent is attracted to industry and existing ones survive & grow. Existing MF advisors also should take interest in acquiring small investors instead of chasing Mass Affluent and HNIs. And AMFI should come out with a circular / notification giving clarity on this matter so that MF advisors can follow this approach more confidently. This is absolutely in client interest and nobody is a loser in this approach.
On the mid to long term basis say in about 3-5 years, MF advisors should figure out a way become RIAs wherein they can do comprehensive financial planning and get higher wallet share of clients. One has to aim to evolve beyond being just a MF Advisor.
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