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    International Journal of Trade andCommerce-IIARTC January-June 2012,Volume 1, No. 1, pp. 4-!

    I""N-22##-$11

    % "&"R.'(((.)* )r+o urnal ).comAll ri*t re)ered.

    Role of Securities & Exchange Board of India(SEBI) in Regulating Mutual Funds

    Rajiv KumarSingh*

    /epartment of u)ine)) Admini)tration, ana Racna Internationalnier)ity, 3arida4ad, 5mail Id6 r a+i l# 7 re d i8m a il.c om

    ABSTRACT

    utual fund) are financial intermediarie) (ic collect te)ain*) of ine)tor) and ine)t tem in a lar*e and(ell dier)ified portfolio of )ecuritie). Te adanta*e) forte ine)tor) are reduction in ri)9, e:pert profe))ionalmana*ement, dier)ified portfolio, li;uidity ofine)tment and ta: ene.4 lac)crore). "ince te mutual fund) inole a u*e amount ofretail ine)tor), terefore, ti) paper attempt) to analy)e(eter "5I i) ale to re*ulate te actiitie) in utual3und ar9et and (eter it) re*ulatory role i) capale toprotect te intere)t of u*e ine)tor). Ti) )tudy al)oattempt) to analy)e te )ortcomin*) 'if any in tere*ulatory re*ime and )u**e)t )ome mea)ure to increa)eit) effectiene)).

    Keywords6 "5I, utual 3und, Retail Ine)tor),Re*ulatory Re*ime

    PAPER/ARTICLE INFO

    RECEIE! "#$%/'/'%ACCEPE! "#$ */'+/'%

    Reference to this ,a,ershould -e .ade as

    follos$ "in*, Ra+i?umar '2012 @Role of"ecuritie) 5:can*eoard of India'"5I in re*ulatin*

    utual 3und)BInt. J. of Trade andCommerce-IIARTC,Vol. 1, No. 1, pp. 4-!.

    *Corresponding Author

    http://www.sgsrjournals.com/http://www.sgsrjournals.com/http://www.sgsrjournals.com/mailto:[email protected]:[email protected]:[email protected]:[email protected]://www.sgsrjournals.com/
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    Role of "ecuritie) 5:can*e oard of India '"5I in re*ulatin*

    -46-

    Ra+i ?umar"in*

    %0I#R"!1CI"#

    %0% SEBI2sBac3groundCapital market was growing at a very fast pace in India particularly after

    liberaliation in

    Industrial !olicy in "##". Controller of Capital Issues $CCI% was looking after newissues. &epartment of company a'airs was also looking after some aspects. (owever)need was felt to have a single authority to regulate and administer the securities law.ith this in mind) S+,I $Securities and +-change ,oard of India%) which was earlierestablished as an administrative body in pril "#//) was given a statutory statusunder section 0 of Securities are +-change ,oard of India ct) "##1 on 02 th3anuary

    "##1. Controller of Capital Issue $CCI% was abolished with a view to have S+,I as asingle agency to look after over capital market.

    %0 MutualFunds4utual funds are financial intermediaries which collect the savings of investors and

    invest them

    in a large and well diversi5ed portfolio of securities. 6he major advantages for theinvestors are reduction in risk) e-pert professional management) diversifiedportfolio and ta- benefit. ,y pooling of their assets through 4utual 7unds) Investorsachieve economies of scale.4utual 7unds are to be established in the form of 6rust under Indian 6rust ct) and

    are to be

    operated by sset 4anagement Company $4C%. 4utual 7unds dealing e-clusively

    with 4oney 4arket Instruments are to be regulated by R,I. 4utual 7unds dealingprimarily with capital market and also partly in 4oney 4arket Instruments are to beregulated by S+,I. ll schemes floated by 4utual 7unds are to be registered withS+,I.

    %04 SEBI Regulation on MutualFunds$Securities 8 +-change ,oard of India had issued a set of regulations and code ofconduct as S+,I $4utual 7und% Regulations) "##9 on #th &ecember "##9 for thesmooth conduct and regulation of mutual funds. Recently) S+,I has issued updatedregulations as S+,I $4utual fund% Regulations12"" on 2: 3an 12"1 covering all amendments up to &ec 12"". 6hese guidelines lay

    down certain

    criteria for investment) disclosure) accountability and distribution of profits to itsmembers. 6he salient features of these regulations include various aspects relatingto Registration of 4utual 7und) Constitution and management of mutual fund 8 rightsand obligations of trustees) Constitution and management of sset 4anagementCompany and custodian) Restrictions on business activities of 4C and itsobligations) Schemes of mutual fund) Investment objectives and valuation policies)dvertisement code) Code of conduct) Restrictions on investments) Investment

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    Role of "ecuritie) 5:can*e oard of India '"5I in re*ulatin*

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    valuation norms) ccounts and ;ffer documents.

    0 5IERA1RE

    REIE66here are some Indian studies which viewed

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    Role of "ecuritie) 5:can*e oard of India '"5I in re*ulatin*

    Ra+i ?umar "in*

    i) number of academics) professionals) and journalists have written articlese-plaining the basic concept of mutual funds) their characteristics and reviewedthe trends in the growth of mutual funds. 6hey also emphasised the importanceof mutual funds in the development of the capital market in India. few underthis category are> Sudee, 7hosh) Madan 7o,al8 id9ashan3er8 Batra8Sunil 7arodia8 Sar3ar8 Agraal8 and Sadha38 er.a2s book on mutualfunds covers the conceptual and regulatory aspects to the Indian 4utual 7undwith some informational data and guidelines to the investors in selection ofmutual funds.7u,ta made a (ousehold investor Survey in pril "##1. 6he main objective of

    the survey is

    to provide data on the investor preferences on mutual funds and other financialassets. 6he findings are more appropriate to the policy makers who design the

    financial products $7und Schemes%See.a aid2s study covers conceptual and the regulatory framework) review of

    the growth

    of mutual funds) and primary information about mutual fund schemes.:ulashreshta o'ers certain guidelines to the investors in selecting the mutualfund schemes.

    ii) few articles highlighted the importance and issues for the regulation of

    mutual funds.

    mong them the notable are> Barua) #ara9an Bhatt) Bhanu) and Bhatt.7inally) in "##9) S+,Iframed regulations for mutual

    funds.

    iii) few articles touched upon certain aspect of portfolio management andother issues involved in the management of mutual funds. 6he notable amongthem are Sengu,ta) 5al and Shar.a) and Saha and Murth9.Barua and other $"##"%) made a pioneering attempt to evaluate the

    performance of ?a)ter

    "are scheme of

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    Role of "ecuritie) 5:can*e oard of India '"5I in re*ulatin*S1!?6oday there are around @2 mutual funds and over 022 schemes with total assets ofaround Rs.

    9.9@ lacs crores. 6his fast grown industry is regulated by the Securities and+-change ,oard of

    India $S+,I%. 6oday the investor is being o'ered service standard $daily D)reduced transaction time) on the Euery answering etc.% comparable to that of westerncountries. nd has a choice of a diverse range of products) with Internet beingwidely used) mutual funds minimise the costs and improve turnaround time intransactions in future. Since the mutual funds involve a huge amount of investors)therefore) it has been tried and analysed whether S+,I regulatory role is up to themark or have some shortcomings.

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    Role of "ecuritie) 5:can*e oard of India '"5I in re*ulatin*

    Ra+i ?umar"in*

    6he main objectives of this study are asunder> A

    6o appraise different rules and regulation laid down in India to regulate the

    4utual 7unds. 6o analye the working of S+,I in regulating 4utual 7und

    4arkets.

    6o e-amine the e'ectiveness of S+,IFs functioning in this regard and to

    suggest suitable

    measures for the e'ective regulation of 4utual7unds.

    6o study the difficulties e-perienced by the 4utual

    7unds.

    6o study the role 8 e'ectiveness of S+,I in protection of Investors in4utual 7unds.

    @0>?P">ESISIn this research the following hypothesis have been

    tested=

    ". Tere i) no )i*nificant effect of "5I re*ulation) in facilitatin* te utual 3und)to canneli)in* te )ain*) of Ine)tor).

    1. o)t of te Ine)tor) are not a(are aout te "5I 'utual 3und re*ulation).Tere i) no )i*ni

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    Role of "ecuritie) 5:can*e oard of India '"5I in re*ulatin*test) tAtestGetc are used. !eriod under this study have taken from the year 1222and onwards. suitable Euestionnaire is prepared for collecting primary data fromprofessionals and investors. 6he areas covered for sampling are &elhi) oida)

    Hhaiabad) 7aridabad) and Hurgaon) five leading cities of three states of India.

    0 SEBI2S R"5E " RE715AE M11A5F1#!S6he role of S+,I can be understood from the followingpoints>

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    Role of "ecuritie) 5:can*e oard of India '"5I in re*ulatin*

    0% Securities Mar3et Aareness Ca.,aignS+,I believes that An Educated In=estor is aProtected In=estor02

    Ra+i ?umar"in*

    comprehensive Securities 4arket wareness Campaign was launched on 3anuary":) 1220. 6he campaign includes workshops) audioAvisual clippings) distribution ofeducative materials in +nglish) (indi and local languages) a dedicated investorwebsite with inventory of bookletspamphlets7JFs and periodic advertisements inll India Radio $IR% and print media. 6ill 4arF"1) 01": workshops were conductedcovering around @#0 citiestowns in India.0 Recognition to In=estorAssociations$

    S+,I recognises investor associations) e-tends financial support for conductinginvestor education programmes) and also addresses various issues raised by them to

    protect the interest of the investors. S+,I has so far recognised "2 InvestorsFssociations.

    04 Portfolio!isclosure6ransparency is essential for corporate governance and portfolio disclosure is animportant means of keeping the investors informed about the way their moneys arebeing used to create financial assets. 6herefore) S+,I has made it mandatory formutual funds to disclose the entire portfolio of any scheme.

    0@ rans,arenc9 in In=est.ent!ecisionsS+,I has taken a farAreaching step towards ensuring due diligence and

    transparency in all

    investment decisions by advising all mutual funds ?to maintain records insupport of each investment decision which will indicate the date) facts and opinionleading to that decisionF.

    0+ Screening of .utual funds at theentr9 le=el$+very mutual fund shall be registered with S+,I and the registration is granted on theful5llment of certain conditions laid down in the regulations for ?e'icient and orderlyconduct of the a'airs of a mutual fundF.

    0 SEBI has outlined thead=ertise.ent code too$ll mutual funds are bound to publish a schemeAwise annual report or an abridgedsummary through an advertisement within si- months of the closure of the financialyear. 6he trustees of a mutual fund are bound to convey to the investors any

    information that has an adverse impact. mutual fund is also to publish halfAyearlyunaudited financial results through an advertisement.

    0 Prescri-ed #or.s forIn=est.entS+,I has prescribed norms for investment management with a view to

    minimisingreducing

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    Role of "ecuritie) 5:can*e oard of India '"5I in re*ulatin*undue investment risks. 6here are also certain restrictions) which are aimed atensuring transparency and prohibiting mutual funds from e-cessive risk e-posure.6hese restrictions and limitations have strong similarities with those imposed in the

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    Ra+i ?umar"in*

    0* s financial journalists play a critical role for investorsF education) S+,I decidedto conduct aoneAday workshop on capital market for the financial journalists atdifferent centers.

    0 A#A5?SIS &FI#!I#7S;n the basis of the data collected and analysed) the followings are the findingsof the study>

    0% Aareness of SEBI regulations & its role tochannelise the sa=ings;ut of the investors responded) only 0/ of the investors are aware about the S+,I

    regulations while #/.@ of the professionals associated with 47 Industry areaware about the updated regulations and appreciate the regulations in buildingthe investorsF confidence to invest in 4utual 7unds. Investors do not acknowledgethe role of S+,I regulations.

    a-leD%$ Awareness about SEBI regulationsand its role

    Res,ondents ?es #o otal

    !rofessionals associated #2 21 #1

    Investors $47 unit holders% :: "1: 12@

    0%0% #ull>9,othesisTere i) no )i*nificant e8ect of "5I re*ulation) in canneli)in* te )ain*) ofIne)tor) to utual fund.

    6he results of the test show that at B level of significance) null hypothesis is

    rejected. $

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    o)t of te Ine)tor) are not a(are aout te "5I 'utual 3und re*ulation).Tere i) no )i*nificant

    e8ect of te)e re*ulation) in protection ofIne)tor) intere)t.6he results of the test at B level of signi5cance accept the null hypothesis. $

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    Ra+i ?umar "in*

    taking any decision regarding investment. 6hese often demotivate the fund managersto innovate the investment strategies that may optimie the unit holderFs wealth.4ost of fund managers are reluctant to innovate new strategies on account of strictinvestment norms speci5ed by S+,I.

    )a-le $ Eect of SEBI regulations on investmentdecision making and innovativeinvestment strategies

    Effect

    Investment

    decision making

    Innovation of investment

    strategies

    as hurdles 63 58

    as facilitator 12 21

    o effect 17 23

    00% #ull>9,othesisTere i) no )i*ni

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    Ra+i ?umar "in*

    a-leD4$ Eect of SEBI regulations onMutual Fund

    )a-le @$ SEBIRegulations

    Res,ondents Strict

    Control

    #o

    Contro

    o

    so.eProacti=e

    Reacti=e #eutral

    !rofessionals 9" 19 B 0@ B" :

    Investors $unit B/ #@ B1 B/ #@ B1

    6otal ""# "1B B: #1 "@B B#

    040% #ull>9,othesisTere i) no )i*nificant e8ect of te)e re*ulation) inre*ulatin* utual fund).

    6he results of the test show that at B level of significance) null hypothesis isrejected. $

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    be very e'ective.

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    Table 6: SEI !rievance Redressal "ec#anism

    !ffecti"e #$effecti "e Ca$%t sa&

    u'(er of

    res)o$de$ts39 09 156

    Ra+i ?umar "in*

    Ta(le 5* Familiarit$ of SEI A%areness Cam&aign

    o+ of Res)o$de$ts ,a'iliarot

    fa'iliar

    -i'ited

    #$for'atio$

    #$"estors ./, u$it

    holders24 116 64

    0 SEBI2s Functioning$ A CriticalRe=ieSince 4arch "##") S+,I has supervised all the 4utual 7unds $e-cluding N6he committee regrets to note that Some 4utual 7und has violated almost all the

    guidelines and

    regulations of the 4inistry of 7inance) R,I and S+,I. In many cases) the

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    sponsor and itssubsidiary have derived benefit through the operations of fund at the cost of

    investors.O

    N6he manner in which 4utual funds had invested the funds indicates that it had note-ercised sufficient care) prudence and diligence in the interest of investorsand in several instances e-posed the investors to high degree of risks withoutdisclosure of it to the investors. 6his is in the view of the committee is a seriousbreach of trustO

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    Ra+i ?umar"in*

    6he committee regrets to note that several funds indulged in seriousmalpracticesirregularities detrimental to the interest of investors. 7ailure to e-erciseadeEuate control by the authorities concerned resulted in recurrence of the sameand regrettably) the irregularities came to be regarded as market practice. It issystematic failure of this order that set the stage for the scam. 6he system is asmuch in need of rectification as culpable individuals are in need of punishmentO. Inugust 1220) S+,I barred Samir rora) the famed fund manager of lliance Capital4utual 7und) and the 7IIsubAaccounts of ERRE715AI"#n analytical view of crucial issues for further regulations is

    presented here.

    0% oting Right to MutualFunds$s per Companies ct) trust cannot e-ercise any voting power) but it can be

    e-ercised by a publictrustee who is a government o'icial) which is as good as not e-ercising at all. 6herecently formed 47I has urged for voting rights to mutual funds so as to have a sayin decisionAmaking. 4utual 7unds sponsors like bank and 7inancial Institutions) in theirrole as merchant bankers and lenders have access to inside information whichcoupled with voting rights encourage the fund managers to indulge in unscrupulouspractices) such as insider trading where regulations are weak.

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    04 Ca,italAdeHuac9$Safety of the principal amount can be achieved by guarantee o'ered by theHovernment) like postAo'ice saving deposits. lternatively) safety can be assuredthrough capital adeEuacy) which is presently applicable to bank deposits)debentures and eEuity shares. 4utual 7unds) whose main activity is to invest inmarketable securities) are put to risk of default. 6he collapse of market may a'ect theinterest of investors and safety of depression) the investor) and the 4Cs shouldhave capital adeEuacy norms. 6he norms are to be formulated after a though study ofthe issue.

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    0@ Borroing,oers$

    Ra+i ?umar"in*

    S+,I regulations have not speci5ed about borrowing powers. 6he basic feature ofopenA ended 4utual 7unds is to provide liEuidity by continuous repurchase andresale. ;n repurchase reEuisition) the fund will sell some of its securities and meetthe investor reEuirement. ,ut if the fund invests in securitiesAwhich are not liEuidableat optimumfair price or the encashment may be delayed because of various reasons.In this conte-t) S+,I regulations may have to permit openA ended fund to borrow inorder to accommodate the liEuidity interest of the investor.

    0+ Insurance co=erage for Mutual FundIn=estors$&eposit Insurance Corporation of India provides an insurance coverage to somee-tent to deposit holders of banks. Similarly) 4utual 7und investors should also have

    such coverage against the risks associated. In the

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    regulation in 12"".6here is an e-pansion of the derivatives segment) the Corporatisation anddemutualiation of the bourses) the central listing authority) sweat eEuity norms)delisting norms etc. It has already amended the takeover code and modi5ed theportfolio management service guidelines. &isclosure standards have beenimproved= initial public o'er documents have become more streamlined with moreinformation on business and revenue models.

    %'0 S177ESI"#S F"R EFFECIERE715AI"#S6he following suggestions can be given on the basis ofthis study>

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    Ra+i ?umar"in*

    %'0% o e.,oer in=estor to .a3e infor.ed decisions &achie=e fair deals$S+,I should ensure that the checks and balances in the surveillance system workwell to curb manipulations) which should be backed by prompt scrutiny)investigations and punitive actions. S+,I has to e-ercise due diligence to ensuretimely crackdown on price manipulation) and impose stringent penal action and havea close tab on fund flows to protect investor interests.

    %'0 Suggestions for consu.ers and ,artici,ants to thin3 that .ar3ets areeicient8 orderl9 and clean$

    S+,I can encourage more market players. It can reconsider the participation of ;C,s

    by making it mandatory for them to announce their beneficiaries rather than

    completely banning them.

    It should proactively e-amine issues of contentious nature. In most cases) It hastaken action only when there is a referral from a court or investor forum or thegovernment $e.*.)

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    %'0+ Suggestion Regarding Co.,lianceCertificate

    6he compliance certi5cate to be submitted by the 4C on a halfAyearly basis shouldcontain speci5c comments on the followings>

    If the 4C is carrying on other activities) whether as per the regulations) and

    whether it continues to meet the capital adeEuacy reEuirements for each of the

    activities.

    If the investments have been made in accordance with the regulations)

    trust deed and investment objectives of the scheme.

    If the utiliation of the services of the sponsor or any of the 4CFs associates)

    employees or their relatives for any securities transaction is in accordance withthe o'er document and the brokerage and commission paid to such a'iliates.

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    Ra+i ?umar "in*

    &etails of any changes in the interests of the directors on the 4CFs boardof directors.

    InvestmentsRedemption by the 4C or sponsor in any of the schemes and

    interAscheme investments) giving details) date) price) value and charges levied.

    6ransactions in securities by the key personnel of the 4C) whether in their own

    name or on behalf of the 4C) giving details of the names of the personnel) nameof the security) and purchasesale details like the Euantity) rate) value and nameof the broker= whether the transaction is on personal account or conducted by theimmediate family or fiduciary.

    6he identi5cation and appropriation of e-penses to individual schemes and

    whether the e-penses are in conformity with the limits laid down by S+,I.

    &eficiencyarning letters) if any) received from S+,I and the corrective

    action taken.%'0 Suggestions Regarding rans,arenc9 inIn=est.ent !ecisionsS+,I has taken a farAreaching step towards ensuring due diligence and

    transparency in all

    investment decisions. hile the 4C boards can prescribe the broad parameters ofinvestment) it is important that the basis for the decision to invest in individualsecurityAeEuity or debtshould be recorded. 6he 4C should report on the matter ofcompliance to the trustees and the trustees shall report to the S+,I in their biAannualreport.

    %'0 Suggestions to Pro=ide More Poer to SelfRegulator9 (SR")ssociation of 4utual 7und Industry $47I% needs to be given the status of SR;

    through

    legislative measures) and to be declared a ?juridicalpersonF.

    %'00% S+,I should delegate certain supervisory powers to 47I so that it canfunction as the firstAline supervisor such as Screening of applications for licenses andthe ?5t and proper testF for 4C) intermediaries) registrars and transfer agents) fundmanagers..etc) routine audit matters) investigation relating to investorsF complaints)implementation of the advertisement code) etc..) valuation of the portfolio) routinedisclosure of portfolio assets= and !eriodic investigations to uncover any possibility ofmoral haards) fraud) etc.

    %'00 47I must set up an appellate body) which could act as an arbitrator

    between members and 4Cs) between investors and 4Cs) between 47I and 4Cs.

    %'0 Suggestions Regarding Ris3Manage.ent FunctionIt is recommended that all funds should have an independent risk

    management function

    responsible for identifying) evaluating or measuring all risks inherent in a mutualfund organisation) as well as establishing controls to mitigate such risks. 6his

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    function should be separate from fund management. Risk 4anagement 7rameworkmanual detailing the policies8 procedures) systems) organisation controls and specific risk managementmeasures for the above risks should be mandated by S+,I) with an implementationtime frame.

    %'0* Suggestion to Pro=ideInsurance Co=erIt is recommended that funds should be reEuired to buy insurance cover against third

    party losses

    arising from errors and omissions. 6he level and type of cover should be determinedby the 6rustees) subject to a minimum level of Rs. B crores. (owever) 4utual 7undswith assets of less than Rs. "22 crores may take insurance cover for an amount ofless than Rs. B crore as determined by their trustees. 6he premium for this covermay be paid for in accordance with Chapter DII)

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    Ra+i ?umar "in*

    Section B1 $@% $b% $-% of the S+,I $4utual 7und% Regulations) "##9. R86 agents andcustodians should also be reEuired to take separate cover for errors and omissions.

    REFERE#CESL"M. garwal) H.&. $"##1%. 4utual 7und and InvestorsF Interest. Chartered

    Secretary) Dol. II) o.") pp."@A1:.L1M. nnual Reports and ;ffer &ocuments of 4utual 7unds) Currency and

    7inance) Reserve ,ank of India) "#/:A// to 122BA29. H.S. !atel CommitteeRecommendations) Centre for 4onitoring India

    L0M. ,ansal) Q.K. $"##B%. Signals from nnual Reports of 4utual 7und. CharteredSecretary) Dol.

    D) o.#) $September%.

    L@M. ,arua) Samir K.) and Darma) 3ayant R. $"##2%. 4aster Shares> +nigmatic!erformance.

    orking !aper o. #29) Indian Institute of 4anagement) hmedabad) &ecember.LBM. ,arua) Samir K.) Darma) 3ayant R.) Denkiteswaran) . $"##"%. Regulatory7ramework for

    4utual 7unds. +conomic and !olitical eekly) 4ay 1B.

    L9M. ,hatt) R.S. $"##1%. 4utual 7undsStepping

    Investment !olicy and Investment Company !erformance.Reprinted in (siuA Kwangwer) lan 3akon $ed.% op. cit.

    L"@M. Harodia) Sunil. $"##"%. 4utual 7unds and ;verview. 7inancial +-press) 3anuary

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    12.L"BM. Hraham) &odd &.Q) Cottle) C. $"#91%. Security nalysis> !rinciples and

    6echniEues) ew

    Tork> 4cHrawA(ill.L"9M. (aslem) 3ohn. $"#//%. Investors Huide to 4utual 7unds) ew 3ersey>

    !rentice (all)

    +nglewood Cliff.L":M. (aard) 3ohn .) and Christie) 4ilon. 6he Investment ,usiness $ Condensation

    of the S+C

    report%) ew Tork> (arper and Row !ublishers.L"/M. Ippolito) Richard . $"###%. +'iciency with Costly Information> Study of

    4utual 7und

    !erformance "#9BA"##@. 6he Juarterly 3ournal of +conomics) Dol. CID Isset)7ebruary.

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    Ra+i ?umar "in*

    L"#M. I4R; Rule ,ook> n ;verview) Investment 4anagement Regulatory;rganisation) Qondon) ov 122"L12M. 3ames) ng S.) 3ess) Chau (. $"##1%. 4utual 7unds> &i'erent Strokes for

    &i'erent 7olksO

    3ournal of !ortfolio 4anagement) /) inter.L1"M. 3ayadev) 4. $122B%. Daluation of 4utual 7und n +valuation. 6he IC7I 3ournal of pplied 7inance) Dol. ") o. ")

    $3anuary%.L1@M. Qall C.) Sharma) S. 4utual 7unds(ow to Keep 6hem on Right 6rack.

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