Every year, the Association of Mutual Funds in India publishes a document on its portal that most people read as a commission ranking. It runs to a few thousand rows. Financial media picks it up once a year to write the same story: who earned the most, which bank subsidiary crossed a hundred crore, how the pool grew. Then the file goes back to sitting quietly on the AMFI website, rarely opened again until the next edition lands.
What the leaderboard framing conceals is that commission is only one of several columns SEBI's Master Circular requires for this disclosure. The table also carries gross inflows, net inflows, and average assets under management for each distributor. These are not supplementary. They are mandated fields, and they exist for a reason that has nothing to do with ranking distributors by income.
The reason sits in the same chapter of the circular. A separate provision links excessive distributor turnover — defined as anything above two times the weighted industry average — to additional AMC due diligence. The columns that let you compute a distributor's turnover and the rule that specifies what should happen when that turnover is too high are neighbours in the regulation.
Only the first half of that arrangement is visible. Three years of this table sit on AMFI's website right now, covering FY2022-23 through FY2024-25, free to download. The due-diligence outcomes that should follow — what AMCs did when those numbers looked wrong, whether trustees were told, whether SEBI received a filing — are not in any public document.
The provision itself is straightforward. If a distributor's portfolio turnover exceeds two times the weighted industry average, the AMC is required to conduct additional due diligence. AMFI discloses the weighted industry benchmark in the same document that carries the distributor-level data. Dividing gross inflows by average AUM gives the distributor's turnover. Comparing that figure to twice the disclosed industry benchmark tells you whether the distributor's turnover crossed the public threshold.
That comparison gives you something resembling a public version of the screen the circular describes. Resembling, not replicating. What the public can build is a proxy, assembled from the same disclosed fields, imprecise in its mechanics but close enough to ask whether the internal process generates any review trail for the cases the public data surfaces.
The three disclosures cover FY2022-23 through FY2024-25. Across those years, 2,802 unique distributor names crossed the crore-club threshold — annual commissions of Rs 1 crore or more — at least once. The club itself nearly doubled in size, from 1,511 distributors in FY2022-23 to 2,631 in FY2024-25, as the industry's annual commission pool grew from Rs 11,878 crore to Rs 20,735 crore.
2,802
Distributors in crore-club · FY23–25 0
Public records of AMC due-diligence review found
In percentage terms, the picture has been improving. The share of crore-club distributors reporting negative net flows fell from 23.9% in FY2022-23 to 18% in FY2024-25. But even in the most recent year, 473 crore-club distributors still reported net outflows while collecting Rs 1,694 crore in commissions.
Adding the public turnover proxy on top of the negative-flow filter narrows the set considerably. Thirty names survive both screens. They are distributors who were aggregate net-negative across their disclosed high-commission years and crossed the public two-times benchmark in at least one year. Thirty out of 2,802; slightly over one percent of the crore-club universe.
Two names from the hardest subset illustrate the point. Tata Securities Limited earned Rs 10.2 crore in commissions and reported Rs 2,461 crore in net outflows. Its gross turnover reached 119 times its own asset base. The commission it earned amounted to 11 basis points on AUM. These are the numbers of a securities firm intermediating institutional and treasury money at enormous volume.
ASCENT FINANCIALS earned Rs 4.2 crore and reported Rs 143 crore in net outflows. Its turnover was 3.3 times average AUM. The commission it earned, at 65 basis points on AUM, sits firmly at the retail end of the fee spectrum. These numbers describe a boutique distributor earning retail-level margins on a relatively small book while its investors, on net, left for three consecutive years.
This piece does not claim to know what happened in either case. A due-diligence process exists precisely to make distinctions of this kind; the public record does not show whether that distinction was made.
There are at least two formal pathways through which due diligence should reach distributors like these. The first is the turnover-linked trigger in the Master Circular. The second is AMFI's own unified due diligence process for distributors receiving more than Rs 1 crore in annual commissions. AMFI appoints chartered accountancy firms to conduct the exercise on behalf of participating AMCs, producing Due Diligence Reports with observations rated on a severity scale of one to three.
The process is structured. It has institutional backing. It produces documents with risk ratings and formal observations. And none of it is visible to the public.
The broader accountability chain that SEBI's regulations describe is, on paper, complete. AMCs are required to monitor their distributors and report non-compliance to their own boards and to the trustees of the fund. Trustees submit half-yearly reports to SEBI. The Risk Management Framework adds further obligations. Every link in the chain connects one institution to another, and every connection runs entirely inside the system. The investing public, whose money flows through these distributors, sits on neither side of any of these exchanges.
These findings do not prove that AMCs failed to review those distributors; it is possible that some or all were examined internally. What the findings show is that a public signal mandated by the regulator exists without any corresponding public evidence of institutional response. The gap is not necessarily between action and inaction. It is between the public signal and any public record of what followed.
Closing this gap would not require a new disclosure regime. The table AMFI already publishes could carry one additional field: for each distributor whose disclosed data triggers a review signal, whether additional due diligence was conducted and whether observations were escalated. Not the substance of any finding — just the fact of the review.
The immediate objection is confidentiality. That concern is genuine. But the architecture as it currently stands does not balance confidentiality against accountability; it resolves the tension entirely in favour of opacity, leaving the same investors who are expected to read and act on the commission table unable to verify whether the system designed to protect them is functioning at all.
The mutual fund industry publishes enough data, every year, to let the public see where a due-diligence trail should exist. The missing disclosure is not another commission table. It is the trail itself.