Scheme auditor
The auditor appointed by the trustees to audit a mutual fund scheme's accounts, independently of the separate auditor the AMC appoints for its own corporate accounts.
In plain language
A mutual fund scheme's money and an AMC's own corporate money are kept strictly apart, and so are the auditors who check each set of books.
The scheme auditor checks the scheme's accounts. The AMC auditor checks the AMC's own accounts, as a company. They are never the same person or firm, and they answer to different masters — the scheme auditor to the trustees, the AMC auditor to the AMC itself.
How it works
Chapter 3, section 3.4.3, states the rule directly: scheme accounts must be maintained independently of the AMC's own accounts, and the auditor appointed to audit the mutual fund scheme accounts needs to be different from the auditor of the AMC.
Who appoints whom is equally specific: the scheme auditor is appointed by the Trustees, while the AMC auditor is appointed by the AMC. The separation exists because the AMC manages the scheme's money on the investors' behalf, and an auditor answerable only to the AMC would have every incentive problem that separation is designed to avoid.
A worked example
An asset management company runs 18 schemes across equity, debt and hybrid categories — an illustrative count; the workbook gives no figure of its own here. Its own Board of Directors appoints Auditor A to audit the AMC's corporate accounts — salaries, office expenses, the AMC's own profit and loss.
The Board of Trustees, a separate body overseeing the schemes on investors' behalf, appoints Auditor B — a different firm entirely — to audit the accounts of each of the 18 schemes: the NAV computations, the portfolio valuations, the income and expenses charged to each scheme.
If Auditor A also audited the schemes, the AMC would effectively be marking its own homework on how it manages investors' money. Keeping Auditor B separate, and answerable to the trustees rather than the AMC, is exactly what the independence rule is built to prevent.
Why NISM asks about it
Chapter 3 (Legal Structure of Mutual Funds in India), section 3.4.3 ("Auditors"), states the independence requirement and the two separate appointing authorities in a single short passage. Expect a direct recall question on who appoints the scheme auditor (the trustees, not the AMC).
Common exam traps
- The scheme auditor is appointed by the Trustees; the AMC auditor is appointed by the AMC — reversing the two is the obvious trap.
- They must be different auditors, not merely different engagement teams within the same firm, in the workbook's framing.
- This is about audit independence for investor protection, not a general accounting formality — the whole point is that the AMC does not choose who checks how it has handled investors' money.
Check yourself
1.Which statement about auditors and the compliance officer is correct?
- a)The same auditor may audit both the scheme accounts and the AMC accounts, for consistency
- b)Scheme accounts are maintained independently of AMC accounts, the scheme auditor must differ from the AMC auditor and is appointed by the trustees, while the compliance officer reports directly to the head of the AMC and reports non-compliance immediately to the trustees
- c)The compliance officer reports to the fund management team to ensure investment decisions are compliant
- d)The AMC auditor is appointed by the trustees and the scheme auditor by the AMC
Show the answer
Answer: (b) Scheme accounts are maintained independently of AMC accounts, the scheme auditor must differ from the AMC auditor and is appointed by the trustees, while the compliance officer reports directly to the head of the AMC and reports non-compliance immediately to the trustees
On auditors: "Accounts of the mutual fund schemes need to be MAINTAINED INDEPENDENTLY of the accounts of the AMC. The auditor appointed to audit the mutual fund SCHEME accounts needs to be DIFFERENT FROM THE AUDITOR OF THE AMC. While the SCHEME AUDITOR IS APPOINTED BY THE TRUSTEES, the AMC AUDITOR IS APPOINTED BY THE AMC." Option (d) reverses the appointing bodies. On compliance: "To ensure INDEPENDENCE, the Compliance Officer REPORTS DIRECTLY TO THE HEAD OF THE AMC. The Compliance Officer works closely with the Trustees on various compliance and regulatory issues. It is the responsibility of the compliance officer to REPORT ANY ISSUE OF NON-COMPLIANCE DIRECTLY AND IMMEDIATELY TO THE TRUSTEES." The officer also "signs a DUE-DILIGENCE CERTIFICATE" in the scheme documents of new issues, confirming that all regulations have been complied with and that the intermediaries named hold "the requisite statutory registrations and approvals."