NISM Series XIX-B · Chapter 6: Fees Structure, Fund Performance and Benchmarking
L1 · FoundationFoundation — The fee structure, hurdle, high-water mark and catch-up
Management fees at 1 to 2.5 per cent of Gross NAV, why they are not charged on committed capital, and the 14-day payment rule; incentive fees and how they are computed; set-up costs amortised over 36 months or the fund life, operating expenses, transaction expenses and trusteeship fees, and which of these investors should cap; the hurdle rate and why manager and investor pull in opposite directions on it, with Indian rates of 10 to 12 per cent against international 7 to 8 per cent; the high-water mark and the minimum NAV eligible for incentives; the catch-up clause with the XYZ Fund worked example showing Rs 69 lakh against Rs 3.45 crore; the comparison of fee structures against mutual funds and PMS; gross and net returns before and after incentives; and the impact of GST.
25 min read · Worth 15% of the paper · Written from pages 169–239 of the official NISM workbook · Updated 18 September 2026
What the fund charges, and what is left for the investor
1. Management Fees
⚠️ "In return of such services, the Manager charges an investment management fee to the Category III AIF, known as MANAGEMENT FEES, WHICH IS ALLOCATED TO EVERY INVESTOR ON A PRO-RATA BASIS, BASED ON THEIR VALUE OF INVESTMENT IN THE FUND."
⚠️ Three points to memorise:
- ⚠️ "Management Fee IS PAID TO THE MANAGER, IRRESPECTIVE OF ANY FUTURE GAINS OR LOSSES MADE BY THE FUND. Management Fees are paid FOR THE FUND MANAGEMENT SERVICES PROVIDED BY THE MANAGER AND NOT FOR PROFIT-GENERATION."
- ⚠️ "Paid on a periodic basis, GENERALLY QUARTERLY, SEMI-ANNUALLY OR YEARLY... GENERALLY PAID IN ARREARS, WITHIN 14 DAYS AFTER THE RELEVANT VALUATION DAY, WHEN THE GROSS NET ASSET VALUE (GNAV) IS COMPUTED."
- ⚠️ "Fees MAY VARY DEPENDING ON THE AMOUNT THE INVESTOR COMMITS AND TIMELINES OF COMMITMENT; these are usually captured as FEES IN DIFFERENT CLASSES OF UNITS."
1.1 Worked example — Fund ABC
Capital contributions Rs 50 crore · Gross NAV Year 1 Rs 58 crore · Gross NAV Year 2 Rs 65 crore · Management fee 1.5 per cent excluding GST at 18 per cent.
| ⚠️ Year 1 | ⚠️ Year 2 | |
|---|---|---|
| ⚠️ 1.5% of Gross NAV | ⚠️ 1.5% × 58 crore = Rs 87 lakh | ⚠️ 1.5% × 65 crore = Rs 97.50 lakh |
| ⚠️ Add GST at 18% | ⚠️ Rs 15.66 lakh | ⚠️ Rs 17.55 lakh |
| ⚠️ Total payable | ⚠️ Rs 102.66 lakh | ⚠️ Rs 115.05 lakh |
2. Incentive Fees
⚠️ "If the Category III AIF earns a profit in any particular year, the Manager IS ENTITLED TO A FEE FOR PROFIT-SHARING, KNOWN AS INCENTIVE FEES OR PERFORMANCE FEES."
⚠️ "Incentive Fees are COMPUTED AND PAYABLE TO MANAGER, AFTER COMPLETION OF THE STATED FUND TENURE, IN CASE OF CLOSED-ENDED FUNDS."
⚠️ "This helps to ALIGN THE INTEREST OF THE MANAGER WITH THE INTEREST OF THE FUND and encourages the Manager to seek best execution."
3. The other costs
| Cost | ⚠️ Detail |
|---|---|
| ⚠️ SET-UP COSTS / ORGANIZATIONAL EXPENSES | ⚠️ "A ONE-TIME cost from unit-holders AS A PERCENTAGE OF THEIR TOTAL CAPITAL COMMITMENTS, WHICH CAN GO UP TO 1.5 PERCENT OR 2 PERCENT of total capital commitments." Covers OFFERING COSTS, DRAFTING OF THE PPM, REGISTRATION AND COMPLIANCE COSTS, FEES AND COMMISSIONS TO INTERMEDIARIES, plus GST. "Can be AMORTIZED OVER THE FIRST 36 MONTHS, OR THE ENTIRE LIFE OF THE CATEGORY III AIF, COMMENCING FROM THE DATE OF FIRST CLOSING." Allocated pro-rata on TOTAL CAPITAL COMMITMENTS |
| ⚠️ OPERATING EXPENSES | ⚠️ Statutory, legal, tax, accounting, audit, consulting and other professional fees · banking, broken-deal, registration, qualification and finders fees · expenses of investor meetings (investors bear their own travel and accommodation) · cost of collecting capital contributions · INTEREST ON BORROWINGS · financial statements and reports · communications and travel · books of account · administration, advertising and promotional expenses including bank charges · fees to banks, merchant bankers and consultants · REASONABLE INSURANCE PREMIUMS for directors, partners, key personnel and officers of the Trustee and Manager · taxes and duties on acquiring, holding and selling assets · PROPORTIONATE LIQUIDATION EXPENSES |
| ⚠️ TRANSACTION EXPENSES | ⚠️ "Borne by the Fund and ALLOCATED ON A PRO-RATA BASIS, ACROSS ALL CLASSES OF UNITS, BASED ON CAPITAL CONTRIBUTIONS OR NAV" — BROKERAGE CHARGES · DEPOSITORY CHARGES · CUSTODIAN TRANSACTION CHARGES · SECURITIES TRANSACTION TAXES · COSTS AND CHARGES IMPOSED BY STOCK EXCHANGES |
| ⚠️ TRUSTEESHIP FEES | ⚠️ "To be in accordance with the terms agreed with the Trustee in the offer letter" |
⚠️ "The BEST-CASE SCENARIO FOR INVESTORS WOULD BE TO NEGOTIATE WITH THE INVESTMENT MANAGER TO NET-OFF SUCH EXPENSES AGAINST THE MANAGEMENT FEES, ALREADY BEING PAID."
4. Hurdle Rate
⚠️ "The Preferred Return WILL NOT BE TAKEN INTO ACCOUNT DIRECTLY, FOR THE PURPOSE OF COMPUTATION OF INCENTIVE FEES. Incentive Fees is paid to the Investment Manager ON THE RETURN GENERATED OVER AND ABOVE SUCH PREFERRED RETURN."
⚠️ "Deciding on the appropriate hurdle rate IS CRITICAL AND INVOLVES SERIOUS NEGOTIATIONS." ⚠️ Its purpose is "TO BENCHMARK THE EXPECTATIONS OF THE INVESTORS RATHER THAN TO PROVIDE A GUARANTEED RETURN (WHICH IS NEITHER PERMISSIBLE NOR POSSIBLE)."
4.1 The Fund ABC hurdle computation
Committed capital Rs 50 crore · 5,00,000 units at Rs 1,000 · hurdle 10 per cent · incentive fee 15 per cent · set-up cost Rs 1.25 crore amortised over 5 years · yearly expenses Rs 30 lakh.
| Particulars | ⚠️ Year 1 | ⚠️ Year 2 |
|---|---|---|
| ⚠️ Gross Asset Value | ⚠️ Rs 58,00,00,000 (Rs 1,160.000/unit) | ⚠️ Rs 65,00,00,000 (Rs 1,300.000/unit) |
| ⚠️ Less: Set-up cost amortised (1.25 cr ÷ 5) | ⚠️ (Rs 25,00,000) | ⚠️ (Rs 25,00,000) |
| ⚠️ Less: Fund expenses | ⚠️ (Rs 30,00,000) | ⚠️ (Rs 30,00,000) |
| ⚠️ Less: Management fees incl. GST | ⚠️ (Rs 1,02,66,000) | ⚠️ (Rs 1,15,05,000) |
| ⚠️ NAV (Pre-incentives) [A] | ⚠️ Rs 56,42,34,000 (Rs 1,128.468) | ⚠️ Rs 63,29,95,000 (Rs 1,265.990) |
| ⚠️ Reference Hurdle [B] | ⚠️ 50 cr × 1.1 = Rs 55,00,00,000 (Rs 1,100.000) | ⚠️ 55 cr × 1.1 = Rs 60,50,00,000 (Rs 1,210.000) |
| ⚠️ Amount for incentive fee [C = A – B] | ⚠️ Rs 1,42,34,000 | ⚠️ Rs 2,79,95,000 |
| ⚠️ Incentive fees at 15% of C | ⚠️ Rs 21,35,100 | ⚠️ Rs 41,99,250 |
⚠️ And the sensitivity: raising the hurdle from 10 per cent to 12 per cent drops the incentive fees to "YEAR 1 – Rs 6,35,100" and "YEAR 2 – Rs 8,69,250."
5. High-Water Mark
⚠️ Why it exists: "NO INCENTIVE FEES SHOULD BE PAID ON LOSSES MADE IN ANY YEAR, THROUGH-OUT THE LIFE CYCLE OF THE FUND."
⚠️ "If the High-Water Mark IS CONSISTENTLY RISING ABOVE THE PREVIOUS HIGH-WATER MARK, IT DENOTES SUPERIOR PAST AND PRESENT PERFORMANCE... However, IF THE HIGH-WATER MARK REMAINS UNCHANGED IN PREVIOUS YEARS, IT IS AN INDICATOR OF POOR PERFORMANCE."
5.1 The rule that decides eligibility
⚠️ Best case (Fund ABC): Year 1 HWM Rs 50,00,00,000 (initial subscription), Reference Hurdle Rs 55,00,00,000, so the higher is Rs 55 crore; NAV pre-incentives Rs 56,42,34,000 exceeds it, giving incentive fees of Rs 21,35,100. Year 2 HWM rises to Rs 56,42,34,000 but the Reference Hurdle of Rs 60,50,00,000 is still higher, giving Rs 41,99,250.
⚠️ Worst case: Gross NAV Rs 55 crore then Rs 54 crore. Year 1 NAV pre-incentives Rs 53,47,65,000 against a minimum of Rs 55 crore — ⚠️ NOT ELIGIBLE. Year 2 NAV pre-incentives Rs 52,49,42,000 against Rs 60,50,00,000 — ⚠️ NOT ELIGIBLE.
⚠️ Total incentive fees over two years: "Rs 63,34,350 in the best-case scenario, AS COMPARED TO ZERO INCENTIVE FEES IN THE WORST-CASE SCENARIO."
⚠️ "If investors HAVE NOT NEGOTIATED A HURDLE RATE at the time of subscription, THE HIGH-WATER MARK PREVENTS UNDUE INCENTIVES FEES BEING PAYABLE TO INVESTMENT MANAGER AND SERVES AS AN ADDITIONAL THRESHOLD."
6. Catch-up — the XYZ Fund example
XYZ Fund: committed capital Rs 50 crore · tenure 3 years · NAV at end of Year 3 Rs 70 crore · hurdle 10 per cent · incentive fees 20 per cent of total profits.
| Step | ⚠️ Computation |
|---|---|
| ⚠️ Total profit | ⚠️ Rs 70 crore – Rs 50 crore = Rs 20 crore |
| ⚠️ Manager's pre-determined share | ⚠️ 20% × Rs 20 crore = Rs 4 crore |
| ⚠️ Hurdle return for 3 years | ⚠️ [Rs 50 crore × (1.10)³] – Rs 50 crore = Rs 16.55 crore |
| ⚠️ Residual profit | ⚠️ Rs 20 crore – Rs 16.55 crore = Rs 3.45 crore |
⚠️ Scenario (a) — NO CATCH-UP CLAUSE
| ⚠️ Amount | |
|---|---|
| ⚠️ Investors: capital Rs 50 crore + hurdle Rs 16.55 crore | ⚠️ Rs 66.55 crore |
| ⚠️ Manager: 20% × Rs 3.45 crore | ⚠️ Rs 0.69 crore |
| ⚠️ Investors: 80% × Rs 3.45 crore | ⚠️ Rs 2.76 crore |
| ⚠️ Total to Manager | ⚠️ Rs 0.69 crore |
| ⚠️ Total to Investors | ⚠️ Rs 69.31 crore |
⚠️ Scenario (b) — CATCH-UP RATE OF 100%
⚠️ "Manager will receive 100% OF THE RESIDUAL PROFIT OF Rs 3.45 CRORE, TILL THE MANAGER IS PAID THE TOTAL PRE-DETERMINED PROFIT SHARE... i.e. Rs 4 CRORE. SINCE RESIDUAL PROFITS IN FUND XYZ ARE INSUFFICIENT to provide for profit share of the manager, THE ENTIRE RESIDUAL PROFIT OF Rs 3.45 CRORE WILL BE DISTRIBUTED TO THE MANAGER."
| ⚠️ Amount | |
|---|---|
| ⚠️ Manager | ⚠️ Rs 3.45 crore |
| ⚠️ Investors | ⚠️ Rs 66.55 crore |
⚠️ "Similarly, IF THE CATCH-UP RATE IS 40%, THEN 40% OF THE RESIDUAL PROFITS... WILL BE DISTRIBUTED TO THE MANAGER till the manager receives the pre-determined share."
7. Comparing fee structures
7.1 Mutual Funds versus Category III AIFs
⚠️ "The Fee Structure for Mutual Funds is calculated using the TOTAL EXPENSE RATIO (TER)... EFFECTIVE FROM APRIL 1, 2026, TER will represent the total cost borne by the investors" and consists of (a) BASE EXPENSE RATIO (BER), the AMC-controlled expenses, and (b) EXTERNAL CHARGES including brokerage, exchange and regulatory fees and statutory levies such as GST, STT, CTT and stamp duty.
| Fee component | ⚠️ Mutual Fund | ⚠️ Category III AIF |
|---|---|---|
| ⚠️ Management fees | ⚠️ BER limits restrict the fee; BER is a percentage of ASSETS UNDER MANAGEMENT | ⚠️ At the Manager's discretion, "USUALLY UP TO 2.5% OF THE TOTAL ASSETS... WITHOUT RESTRICTIONS FROM SEBI", computed on TOTAL ASSETS, "WHICH IS BEFORE THE DEDUCTION OF ALL FUND LIABILITIES AND EXPENSES" |
| ⚠️ Incentive fees | ⚠️ "INVESTMENT MANAGERS ARE NOT PERMITTED TO CHARGE INCENTIVE FEES" | ⚠️ Permitted, "USUALLY UP TO 20% OF INCREMENTAL RETURNS... WITHOUT RESTRICTIONS FROM SEBI" |
| ⚠️ Other operating expenses | ⚠️ "All operating expenses and transaction costs ARE COVERED IN THE BER LIMIT" | ⚠️ "Charged IN ADDITION to management fees... usually CAPPED BY THE CATEGORY III AIF, UP TO 0.5% OF AUM... charged BASED ON ACTUALS, UP TO THE CAPPED LIMIT" |
⚠️ Why the mutual fund is restricted: "to LIMIT THE RISK AND LEVERAGE TAKEN BY THE INVESTMENT MANAGER... AS WELL AS SAFEGUARD THE INTERESTS OF RETAIL INVESTORS WITH A LIMITED RISK APPETITE." ⚠️ And a consequence: "As a result of the reduction in the BER limit, MANY MUTUAL FUND MANAGERS HAVE NOW LAUNCHED THEIR OWN ALTERNATIVE INVESTMENT FUNDS."
7.2 PMS versus Category III AIFs
⚠️ "There is NO LIMIT ON FEES OR BENCHMARK RATES SET BY THE REGULATOR" for a PMS. ⚠️ "All investors are provided THE FLEXIBILITY TO CHOOSE THE FEE STRUCTURE OF THEIR PMS ACCOUNT, UNLIKE INVESTORS IN A CATEGORY III AIF, WHEREIN ONE CLASS OF INVESTORS ARE CHARGED THE SAME FEE STRUCTURE."
⚠️ The workbook's example: a Portfolio Manager may offer "a choice between a 'FIXED FEE' AND 'FIXED PLUS VARIABLE FEE'" — say 2.5 per cent management fee for one class, or 1 per cent plus 15 per cent incentive fee for another.
⚠️ Where SEBI restricts PMS MORE than AIFs:
| Restriction | ⚠️ Rule under the SEBI (Portfolio Managers) Regulations, 2020 |
|---|---|
| ⚠️ Upfront fees | ⚠️ "A Portfolio Manager is BANNED FROM CHARGING UPFRONT FEES, SUCH AS REGISTRATION FEES OR SUBSCRIPTION FEES, directly or indirectly" |
| ⚠️ Operating expenses | ⚠️ "Other than brokerage, SHALL NOT EXCEED 0.5 PERCENT EVERY YEAR, ON THE INVESTOR'S AVERAGE DAILY AUM. BROKERAGE FEES SHOULD BE CHARGED AT ACTUALS" |
| ⚠️ Exit load | ⚠️ "MAXIMUM 3 PERCENT if redeemed in the FIRST YEAR, MAXIMUM 2 PERCENT in the SECOND YEAR and MAXIMUM 1 PERCENT in the THIRD YEAR. NO EXIT LOAD CAN BE CHARGED SUBSEQUENTLY, AFTER THE END OF THIRD YEAR" |
| ⚠️ Distribution fees | ⚠️ "FULL-TRAIL COMMISSION METHOD... commission SHALL NOT BE PAID AT THE TIME OF INVESTOR'S INVESTMENT, BUT PAID SUBSEQUENTLY EVERY QUARTER OR OTHER PERIODIC TIME FRAME TILL THE INVESTOR EXITS" |
Note this well — the workbook's sample question asks whether exit load can be charged in an AIF but not in a PMS. It can be charged in a PMS, on the 3-2-1 scale.
8. Gross and Net Returns
| Measure | ⚠️ Basis |
|---|---|
| ⚠️ PRE-EXPENSE RETURN (GROSS) | ⚠️ "Calculated using the GROSS ASSET VALUE... BEFORE DEDUCTING THE FUND EXPENSES, COSTS, MANAGEMENT FEES AND INCENTIVE FEES" |
| ⚠️ NET RETURN (PRE-INCENTIVES) | ⚠️ "Using the NET ASSET VALUE... AFTER DEDUCTING THE FUND EXPENSES, COSTS AND MANAGEMENT FEES, BUT BEFORE DEDUCTING THE INCENTIVE FEES" |
| ⚠️ NET RETURN (POST-INCENTIVES) | ⚠️ "After deducting the fund expenses, costs, management fees AS WELL AS THE INCENTIVE FEES" |
⚠️ Fund ABC, Year 1 — best case: gross 16.00% · pre-incentives 12.85% · post-incentives 12.42%. Worst case: gross 10.00% · pre-incentives 6.95% · post-incentives 6.95%.
⚠️ Year 2 on a CAGR basis — best case: gross 14.02% · pre-incentives 12.52% · post-incentives 12.14%. Worst case: gross 3.92% · pre-incentives 2.46% · post-incentives 2.46%.
⚠️ The crystallization point: "There is a concept of PERFORMANCE FEES CRYSTALLIZATION DATE in Category III AIFs, which essentially means that they WOULD ACCRUE PERFORMANCE FEES ON A DAILY BASIS TO GET ACCURATE RETURN, HOWEVER THE PAYMENT OF THE SAID FEES TO MANAGER WOULD HAPPEN ONLY AT THE END OF THE TERM OF THE FUND."
9. GST on fees — the Fund N example
Fund N: corpus Rs 98 crore · 9,80,000 units at Rs 1,000 · management fee 2 per cent of Gross NAV.
| Fee | ⚠️ Amount | ⚠️ GST at 18% |
|---|---|---|
| ⚠️ Management Fees (2% of Rs 98 crore) | ⚠️ Rs 1,96,00,000 | ⚠️ Rs 35,28,000 |
| ⚠️ Trusteeship Fees | ⚠️ Rs 73,50,000 | ⚠️ Rs 13,23,000 |
| ⚠️ Fund Administrator Fees | ⚠️ Rs 42,70,000 | ⚠️ Rs 7,68,600 |
| ⚠️ Custodian Fees | ⚠️ Rs 51,10,000 | ⚠️ Rs 9,19,800 |
| ⚠️ Auditor Fees | ⚠️ Rs 44,80,000 | ⚠️ Rs 8,06,400 |
| ⚠️ Legal Advisor Fees | ⚠️ Rs 22,40,000 | ⚠️ Rs 4,03,200 |
| ⚠️ Investment Advisor Fees | ⚠️ Rs 11,90,000 | ⚠️ Rs 2,14,200 |
| ⚠️ TOTAL GST | ⚠️ Rs 79,63,200 | |
| ⚠️ As a percentage of the Rs 98 crore NAV | ⚠️ 0.81% |
Think of it like this
The tailor paid for stitching, not for the wedding
A tailor in Surat is paid for stitching the outfit. Whether the wedding goes well, whether the guests admire the clothes, whether the marriage lasts — none of that changes his bill.
Management fee is that bill. It is "PAID TO THE MANAGER, IRRESPECTIVE OF ANY FUTURE GAINS OR LOSSES MADE BY THE FUND", and is "PAID FOR THE FUND MANAGEMENT SERVICES PROVIDED BY THE MANAGER AND NOT FOR PROFIT-GENERATION."
The incentive fee is a different thing entirely — closer to a bonus the family gives the caterer because the food was genuinely better than promised. It exists "AS AN INCENTIVE TO THE MANAGER TO GENERATE PROFITS", and it appears only if there is something to be paid on.
And notice what the tailor bills on. Not on what you promised to have stitched, but on what he actually stitched. "MANAGEMENT FEES ARE NOT CHARGED ON THE COMMITTED CAPITAL AND CAPITAL CONTRIBUTIONS. MANAGEMENT FEES ARE COMPUTED ON THE GNAV OF THE FUND."
The flood mark on the temple wall
Old temples on the Godavari carry painted lines showing the highest the river ever rose. The line does not move down when the water recedes. It moves only when a new flood beats the old one.
That is the high-water mark — "THE HIGHEST NET ASSET VALUE, NET OF OPERATING EXPENSES, TRANSACTION EXPENSES AND MANAGEMENT FEES, ACHIEVED BY THE CATEGORY III AIF AT THE END OF THE YEAR."
A fund that falls 20 per cent and then rises 20 per cent has not reached a new flood mark; it has come back to where it was. Without the line on the wall, the manager would charge a performance fee for a recovery that left the investor exactly where he started.
And when the river has never risen at all since the temple was built, the mark stays at the foundation: "IF THE NET ASSET VALUE HAS ONLY DECREASED SINCE INCEPTION, HIGH-WATER MARK IS TAKEN AS THE INITIAL SUBSCRIPTION PRICE OF UNITS."
Two hurdles at the same school sports day
At a school race there are two bars to clear. One is the qualifying height the organisers set at the start of the season — clear it and you are in the finals. The other is your own personal best — beat it and you get the medal.
A Category III AIF manager faces both. The Reference Hurdle is the qualifying height. The High-Water Mark is the personal best. And the rule for incentive fees takes whichever bar is higher: "the MINIMUM NAV ELIGIBLE FOR AN INCENTIVE FEE... IS HIGHER OF REFERENCE HURDLE AND THE HIGH-WATER MARK."
In Fund ABC's worst case, the manager beat his personal best — NAV of Rs 53.48 crore against a high-water mark of Rs 50 crore — but did not clear the qualifying height of Rs 55 crore. No medal. "SINCE THE NAV HAS NOT CROSSED THE REFERENCE HURDLE, THE INVESTMENT MANAGER IS NOT ELIGIBLE FOR ANY INCENTIVE FEES."
The contractor who is paid last but paid fully
A contractor agrees to take 20 per cent of the total profit on a building project. The owners take their capital and their agreed 10 per cent return first — that is settled. What is argued over is the order and speed of what comes after.
With a 100 per cent catch-up, everything left over goes to the contractor until his 20 per cent of total profit is made up. On XYZ Fund the residue was Rs 3.45 crore and his full share would have been Rs 4 crore — so he took all Rs 3.45 crore and still fell short.
With no catch-up, he takes only 20 per cent of the leftover: Rs 0.69 crore.
Same fund, same profit, same agreed percentage. "THIS DIFFERENCE IN THE AMOUNT DISTRIBUTED TO THE MANAGER IS SOLELY ON ACCOUNT OF THE INCLUSION OF A CATCH-UP CLAUSE IN THE CONTRIBUTION AGREEMENT."
That is a five-fold difference decided by one paragraph in an agreement.
The autorickshaw fare and the meter reading
The meter says Rs 200. But there is a night charge, a luggage charge and a return-fare charge, and you hand over Rs 260.
A fund quotes 16 per cent gross. Then come the amortised set-up cost, the yearly fund expenses, the management fee with GST on top — and the net return before incentives falls to 12.85 per cent. Then the incentive fee takes it to 12.42 per cent.
The meter reading was never wrong. It simply was not the fare.
And the fixed charges hurt most on the shortest ride. In Fund ABC's worst case, a 10 per cent gross return became 6.95 per cent — the same fixed costs eating a far bigger share of a smaller number.
The GST on every professional bill in a family business
A trading family in Rajkot pays a chartered accountant, a lawyer, a company secretary and a valuer. Each bill carries GST. Because the family business sells goods and collects GST on sales, it sets that input tax off against what it collects.
A Category III AIF cannot always do so. It pays GST on management fees, trusteeship fees, fund administrator, custodian, auditor, legal advisor and investment advisor fees — in Fund N's case Rs 79.63 lakh, which is 0.81 per cent of the fund's Gross NAV.
And the sting: this "MAY NOT BE RECOVERABLE IN FORM OF INPUT CREDITS AS AIFs DO NOT NECESSARILY COLLECT GST ON OUTPUT SERVICES, THEREBY INCREASING THE INDIRECT COST FOR INVESTORS."
Eighty-one basis points, gone before a single investment decision is judged.
Key terms in this chapter
- Absolute-return Strategy
- A strategy aiming to make returns independent of broad market movements, benchmarked against a fixed pre-determined rate such as 10 per cent per annum rather than a market index.
- Alpha
- The excess return generated by a Category III AIF over the benchmark return for the same period, computed as the actual return less the CAPM expected return.
- Base Expense Ratio (BER)
- The AMC-controlled portion of a mutual fund's TER, subject to a mandatory upper cap that effectively restricts a mutual fund manager's income to approximately 1.5 per cent, against up to 2.5 per cent for a Category III AIF.
- Benchmark
- The comparable fund or index having similar risk-return characteristics to the fund being monitored. A valid benchmark is specified in advance, relevant, measurable, unambiguous, representative, accountable, investable and complete.
- Benchmarking Agency
- An agency notified by an AIF association representing at least 33 per cent of AIFs, which collects performance, cash-flow and valuation data and creates industry benchmarks. IVCA has appointed CRISIL, NSE and Preqin.
- Benchmark Report
- The standard report generated on SEBI's mandate by a benchmarking agency, as distinct from a customised, fee-based Performance Report prepared at an AIF's specific request with the express consent of the AIFs whose data is used.
- CAGR
- Compounded Annual Growth Rate — the ending value divided by the beginning value, raised to the power of one over the number of years, minus one. It expresses growth after accounting for compounding.
- Catch-up Rate
- The rate at which residual profits after returning capital and hurdle flow to the manager until he reaches his pre-determined share of total profits. In the XYZ Fund example a 100 per cent catch-up gave the manager Rs 3.45 crore against Rs 0.69 crore with no catch-up.
- Composite
- Under GIPS, a grouping in which an AIF reports consolidated performance of its schemes, defined by the investment strategy or investment objective those schemes follow.
- DPI
- Distributions to Paid-in Capital — total distributions divided by total capital contributions, measuring the amount distributed per rupee invested. Also called the realisation multiple.
- Excess Kurtosis
- Kurtosis minus three. A positive value indicates fatter tails and higher risk; a negative value indicates consistent frequencies around the mean.
- GIPS
- Global Investment Performance Standards — the global standard for calculating and presenting investment performance, requiring composites, prescribed methodologies, and annual performance for a minimum of five years building to ten.
- Gross IRR
- IRR computed on fund-level cash flows before deducting management fees, incentive fees, fund expenses and taxes paid.
- Gross Net Asset Value (GNAV)
- The value on which management fees are computed, before deduction of fund liabilities and expenses. Management fees are not charged on committed capital or capital contributions.
- High-Water Mark
- The highest net asset value, net of operating expenses, transaction expenses and management fees, achieved by the fund at the end of any year. If NAV has only decreased since inception, it is the initial subscription price of units.
- Hurdle Rate
- The minimum rate of return to be accrued to fund investors each year or shorter period, generating the preferred return. Managers prefer it low and investors prefer it high; Indian rates run 10 to 12 per cent against international 7 to 8 per cent.
- Incentive Fees
- Also called performance fees — a percentage of the incremental return earned by the fund, generally between 0 and 20 per cent, computed as per the PPM and, for closed-ended funds, payable after completion of the stated fund tenure.
- Kurtosis
- The degree to which a distribution is more or less peaked than a normal distribution, which has a kurtosis of three. Above three is leptokurtic and riskier; below three is platykurtic.
- Management Fees
- The fee paid to the manager for fund management services, charged as a fixed percentage of Gross NAV ranging from 1 to 2.5 per cent, accruing from first close to dissolution, generally paid in arrears within 14 days of the valuation day, and payable irrespective of gains or losses.
- Market Risk Premium
- The excess return of the benchmark or broad-based index over the risk-free rate, the term multiplied by beta in the CAPM expected return formula.
- Maximum Drawdown
- The peak-to-trough decline in a fund's AUM over a reporting period, quoted as a percentage of the peak. It does not show how often large losses occur or how long recovery takes.
- Minimum NAV Eligible for Incentives
- The higher of the reference hurdle and the high-water mark. Incentive fees are earned only on the amount by which NAV before incentives exceeds this figure, and not at all if the difference is negative.
- MOIC
- Multiple on Invested Capital — total realised and unrealised returns divided by total invested capital. Once all capital calls are met it equals TVPI, and a consistently large MOIC to RVPI ratio is a red flag on valuations.
- Net IRR
- IRR computed on investor-level cash flows, treating fund expenses, management fees and incentive fees as investor outflows and distributions after tax as inflows. It is always lower than gross IRR.
- Over-commitment Strategy
- The practice by which institutional investors let forecast capital calls on outstanding commitments exceed current cash balances, to avoid diluting returns by holding idle cash against uncertain calls.
- Performance Fees Crystallization Date
- The concept under which performance fees accrue daily so that reported returns are accurate, while actual payment to the manager happens only at the end of the fund term.
- PIC Multiple
- Paid-in capital divided by capital commitments, measuring how invested the fund is. A high PIC means the fund is near the end of its drawdown phase.
- Preferred Return
- The portion of total fund return generated by the hurdle rate that accrues to investors only, allocated pro-rata. It is not taken into account directly when computing incentive fees, which are paid only on returns above it.
- Reference Hurdle
- The absolute amount computed by applying the hurdle rate to the called-up capital at the beginning of the year, against which the NAV before incentives is compared.
- Risk of Adverse Selection
- The investor-level risk of choosing the wrong fund manager, since PPMs may make forward-looking statements or show track records that do not assure future performance, leading to sub-optimal returns or moral hazard.
- RVPI
- Residual Value to Paid-in Capital — assets under management divided by total capital contributions, representing the unrealised value still at market risk.
- Set-up Costs
- One-time organizational expenses charged as a percentage of total capital commitments, up to 1.5 or 2 per cent, covering offering costs, PPM drafting, registration and compliance, and intermediary commissions, amortisable over the first 36 months or the entire fund life from first closing.
- Sharpe Ratio
- Expected portfolio return less the risk-free return, divided by portfolio standard deviation — the excess return per unit of total risk. Ratios greater than one are preferable, and it is preferred over Treynor for undiversified portfolios.
- Since-inception IRR
- IRR calculated on all cash flows from the launch date of the fund to the reporting date. Where computed for a fund already liquidated, it is also called life-time IRR.
- Skewness
- The extent to which a distribution is not symmetrical across the mean, arising from outliers. A normal distribution has skewness of zero; positive skew puts the mean above the mode with a long right tail, negative skew puts the mean below the mode with a long left tail.
- Standard Deviation
- The square root of the average squared deviation of returns from the mean, measuring the volatility of returns and hence the historical risk of the fund.
- Total Expense Ratio (TER)
- The mutual fund measure representing the total cost borne by investors, effective from 1 April 2026, consisting of the Base Expense Ratio and external charges including brokerage, exchange and regulatory fees and statutory levies.
- Transaction Expenses
- Brokerage, depository charges, custodian transaction charges, securities transaction taxes and exchange charges, borne by the fund and allocated pro-rata across all classes of units based on capital contributions or NAV.
- Treynor Ratio
- Expected portfolio return less the risk-free return, divided by portfolio beta — the excess return per unit of systematic, non-diversifiable risk.
- TVPI
- Total Value to Paid-in Capital — cumulative distributions plus residual value divided by paid-in capital, equal to DPI plus RVPI. Commonly called the net multiple; it fluctuates until the fund is fully realised.
- Value at Risk (VaR)
- The maximum expected loss over a given time frame at a pre-defined confidence level. It quantifies the maximum potential loss but fails to indicate the size of losses beyond that confidence level.
Check you have understood it
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