NAV, TER and Pricing in Segregated Portfolios
Definition
A segregated portfolio (commonly known as side-pocketing) is a mechanism introduced by SEBI in December 2018 that allows mutual fund schemes to separate distressed or impaired debt securities from the main portfolio following a credit event such as a rating downgrade to below-investment grade or actual default. When a credit event occurs, the affected security is moved to a separate "segregated portfolio" with its own NAV, while the remaining "main portfolio" continues with its own NAV. Existing investors receive units in both portfolios in proportion to their holdings. The TER on the segregated portfolio cannot exceed the TER being charged on the main portfolio. This mechanism protects existing investors from panic redemptions and ensures that any future recovery on the distressed asset benefits the original investors, not new investors.
In Simple Words
Side-pocketing is one of the most important investor protection mechanisms in debt mutual funds, and the Franklin Templeton crisis of April 2020 brought it into the national spotlight. Understanding why it was needed and how it works is essential. Before SEBI introduced side-pocketing, the following would happen during a credit event: suppose a debt fund held 5% of its portfolio in Company X bonds. Company X defaults. The fund must immediately mark down the value of Company X bonds (MTM), causing a sharp NAV drop — say 5%. Panic-stricken investors start redeeming. The fund sells its good, liquid bonds to pay redemptions, leaving the remaining investors stuck with a portfolio that has a higher proportion of the bad Company X bonds. The first redeemers escape with relatively less damage, while loyal long-term investors suffer the most. This is deeply unfair. Side-pocketing solves this by separating the bad asset. The moment a credit event occurs, the fund creates two portfolios: (1) Main Portfolio — contains all good assets, gets its own NAV, and is open for subscriptions and redemptions as usual. (2) Segregated Portfolio — contains only the distressed security, gets its own NAV (which reflects the impaired value), and is locked — no new subscriptions or redemptions until recovery or write-off. All existing investors get units in both portfolios in proportion to their original holdings. New investors who come after the segregation can only invest in the main portfolio. If Company X eventually recovers (pays back some or all of the money), that recovery goes to the segregated portfolio investors — the unitholders who were holding when the crisis happened. This is fair and equitable.
Real-Life Scenario
The most prominent Indian example is the Vodafone Idea (Vi) exposure in several debt mutual funds. In late 2019, after the Supreme Court's AGR ruling, Vodafone Idea's creditworthiness deteriorated sharply. Several fund houses that held Vodafone Idea bonds used side-pocketing: Consider "Trustner Corporate Bond Fund" (hypothetical but based on real scenarios) with AUM of ₹2,000 crores and NAV of ₹25.00. • The fund held ₹100 crores in Vodafone Idea bonds (5% of portfolio) • After the credit event, CRISIL downgraded Vi bonds to D (default) • The fund invokes side-pocketing: Before side-pocketing: • NAV: ₹25.00 (includes Vi bonds at original value) • After MTM markdown of Vi bonds: NAV would have dropped to ₹23.75 (5% fall) After side-pocketing: • Main Portfolio NAV: ₹23.75 (reflecting the value of all good assets only) • Segregated Portfolio NAV: ₹1.25 per unit (reflecting the impaired Vi bonds valued at 25% of face value) Gopal, a retired banker from Nagpur, held 40,000 units. After side-pocketing: • He holds 40,000 units of the main portfolio at NAV ₹23.75 = ₹9,50,000 • He also holds 40,000 units of the segregated portfolio at NAV ₹1.25 = ₹50,000 • Total value = ₹10,00,000 (same as his original investment value before markdown) Gopal can continue to redeem from the main portfolio normally. The segregated portfolio is locked. If Vodafone Idea eventually recovers and pays 50% of its dues, Gopal's segregated portfolio NAV rises from ₹1.25 to ₹2.50, and he recovers an additional ₹50,000.
Key Points to Remember
Frequently Asked Questions
Test Your Knowledge
4 questions to check your understanding
Side-pocketing (segregated portfolio) in mutual funds was introduced by SEBI in:
Summary Notes
Side-pocketing (segregated portfolio) was introduced by SEBI in December 2018 to protect debt fund investors from unfair impact of credit events — the IL&FS crisis was the trigger
When invoked, the distressed security is separated into a segregated portfolio with its own NAV, while the main portfolio continues normally — existing investors get units in both
New investors can only invest in the main portfolio and have no claim on the segregated portfolio or its recovery proceeds
TER on the segregated portfolio cannot exceed the main portfolio TER — and SEBI allows AMCs to list segregated units on exchanges for investor liquidity
The Franklin Templeton crisis (April 2020) was a different event (scheme winding up, not side-pocketing) but highlighted the importance of credit risk management in debt funds
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What you’ll learn in NAV, Expenses & Pricing
Learn how NAV is calculated, understand Total Expense Ratio (TER) and the new BER framework under SEBI 2026 regulations, exit loads, cut-off timings, and pricing mechanisms. Key numerical concepts for the NISM VA exam.
Frequently asked questions
Does a fund with ₹10 NAV mean it is a new fund and therefore risky?
Not necessarily. A NAV of ₹10 usually indicates the fund is in its NFO stage or recently launched. However, NAV alone does not indicate risk — the risk depends on the underlying portfolio (equity, debt, hybrid), the fund manager's strategy, and market conditions. Always evaluate the scheme information document (SID), portfolio composition, and fund house track record before investing.
Why does NAV change every day?
NAV changes daily because the market value of the securities held by the fund changes every trading day. Equity prices fluctuate based on market forces, debt securities are revalued based on yield movements, and accrued income and expenses change. Since SEBI requires end-of-day NAV calculation, these changes are reflected in the updated NAV published after market hours.
Can NAV of a mutual fund go below zero?
No, NAV cannot go below zero. Since mutual funds invest in regulated securities traded on exchanges, even in extreme market crashes, asset values do not go to zero (unlike individual stocks of bankrupt companies). The lowest theoretical NAV would be close to zero if all holdings became worthless, but this has never happened in the history of Indian mutual funds.
Is NAV the same as the market price of an ETF?
No. For regular mutual funds, investors transact at NAV. But for ETFs (Exchange Traded Funds), there are two prices: the NAV (calculated end-of-day based on holdings) and the market price (the price at which ETF units trade on the exchange during market hours). The market price can be at a premium or discount to NAV depending on demand and supply.
When an investor receives dividends, does the NAV change?
Yes. When a mutual fund declares and pays a dividend (now called IDCW — Income Distribution cum Capital Withdrawal), the NAV drops by the dividend amount on the ex-dividend date. For example, if NAV is ₹50 and the fund declares ₹3 per unit as IDCW, the NAV will drop to approximately ₹47 on the record date. This is not a loss — the investor receives the ₹3 separately.
What happens if a security is not traded on a given day — how is it valued?
If an equity security is not traded on a particular day, it is valued at the last available closing price on the exchange. If it has not traded for more than 30 days, it is classified as a non-traded/thinly traded security and must be valued using fair valuation methods approved by the AMC's valuation committee. For debt securities, AMFI/CRISIL matrices provide daily valuations regardless of whether the security traded that day.
Why did SEBI introduce mark-to-market for debt funds?
Before MTM norms, some debt funds were valuing securities at "amortized cost" — essentially showing a smooth, straight-line return regardless of market conditions. This masked the true risk. When a credit event occurred (like IL&FS default in 2018), the sudden shift to market-based valuation caused sharp NAV drops. SEBI mandated MTM to ensure daily NAV transparency and prevent funds from hiding losses until a crisis erupted.
Does MTM apply to liquid funds as well?
Yes. From October 2019, SEBI mandated that liquid funds must value all securities with maturity above 30 days using MTM valuation. Earlier, liquid funds used amortization for securities up to 60 days maturity, which masked short-term volatility. Now, even liquid fund NAVs can show minor daily fluctuations due to MTM.
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