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Speaking Notes of Shri Amarjeet Singh, WTM, SEBI at the FICCI Financial
Products Distribution Summit
Theme: Reimagining Financial Distribution: Scale, Trust and Sustainability
May 13, 2026
A. Introduction
1. Good morning. It is a pleasure to be here. I thank FICCI for inviting me.
2. Financial distribution is sometimes viewed as the ‘last mile’ of finance. To my mind,
it is much more central. Distribution determines whether finance remains
concentrated in a few hands or whether it truly becomes a vehicle for broad-based
economic participation. I therefore compliment the organizers for choosing a very
relevant theme of Reimagining Financial Distribution.
3. Over the past decade, we have seen a remarkable expansion in the financial
distribution space. Digital channels have grown rapidly. Technology has widened
access. Social media has transformed the way financial products are accessed and
discussed.
4. The conversation today is therefore no longer only about enhancing the scale of
distribution. It is about how distribution can scale responsibly, how trust can be
strengthened in an increasingly digital environment, and how the ecosystem can
remain sustainable for investors, intermediaries, and markets alike.
5. My remarks today are in three parts. First, I will briefly touch upon the distribution
landscape in India. Then, I will briefly mention some of the emerging risks and issues
in the distribution ecosystem. Finally, I will share a few thoughts on some of the
expectations from distributors.B. Context – distribution landscape
6. Over the past decade, India has witnessed significant financialization, with
household savings increasingly channelled into capital markets. This is reflected in
the rapid growth of demat accounts and the fund management industry — assets
managed across Mutual Funds, PMS1, and AIFs2 has grown at a CAGR of over
19%, reaching INR 91 lakh crore as of March 2026.
7. Mutual funds have been central to this transformation. Nearly 54% of industry’s AUM
as on March 31, 2026 is mobilized through regular plans. This underscores the
importance of distributors in deepening investor participation. For many retail
investors, particularly first-time investors, distributors remain the first point of
engagement with financial markets.
8. The broader distribution ecosystem has expanded in parallel: AMFI-registered active
distributors have grown from 2.4 lakh to 3.4 lakh over five years3, Business
Correspondents from 5.4 lakh to over 16 lakh4, and insurance agents (associated
with life, general and health insurance) from 34 lakh to over 54 lakh5 — reflecting
the growing scale of India's financial distribution architecture.
9. Yet significant headroom remains. A recent SEBI investor survey provides some
interesting insights in the mutual fund space. While 53% of households are aware of
mutual funds or ETFs, only about 6.7% actually invest. In rural India, awareness falls
to 45%, and participation to around 4%. Participation remains closely linked to
education, income and occupation.
10. The industry’s future growth will therefore depend on reaching investors, across
geographies, income segments, and demographic groups. Recognizing these
1 Excluding EPFO / PF AUM
2 Funds raised by AIFs
3 Source: AMFI, period – March 2021 to March 2026
4 Source: media reports, period – 2020 to 2025
5 Source: IRDAI Annual report of FY 2019 - 2020 and FY 2024 - 2025structural realities, SEBI has accordingly adopted calibrated incentive frameworks
- including Beyond-30 (B-30) location incentives, additional incentives for
onboarding new women investors, and the introduction of the Chhoti SIP framework
- to support responsible expansion.
11. Similar to the successful model of mutual fund distribution, SEBI is examining a
proposal to introduce a specialized category of distributors to increase the reach of
debt securities, expand the investor base and promote the retail-isation of bonds.
Much like mutual fund distributors, it is envisaged they will simplify the investment
process for retail investors by assisting with KYC formalities, documentation, and
initiating transactions.
C. Emerging Risks and Issues
12. Increasing complexity
a. Financial products are becoming more sophisticated, from passive products and
factor investing to alternatives, private credit and other wealth management
solutions. SEBI's recently introduced Specialized Investment Fund (SIF)
framework reflects this evolution, offering investors regulated products with greater
flexibility and risk-taking capability.
b. Complexity in itself is not a problem. But complexity without adequate
understanding can be problematic.
c. Investors often grasp the upside narrative far better than the downside. This makes
the role of distributors critical in helping investors understand risk, navigate
uncertainty, maintain discipline, and make decisions aligned with their long-term
financial goals.13. Rise of Social media and mis-information
a. Financial distribution today operates amid information abundance, viral narratives,
and intense competition for investor attention. While digital channels improve
awareness and outreach, they can equally amplify misinformation, speculative
behavior, and short-termism.
b. Market participation should be driven by informed decision-making and long-term
planning — not momentum or social-media trends. Distributors have a key role
here, and I urge the industry to ensure that all digital communication — like offline
communication — reflects the same standards of suitability and transparency.
14. Technology and AI
a. Digital onboarding, mobile platforms, and AI-enabled tools are transforming how
financial products are accessed, distributed, and monitored — creating significant
opportunities for financial inclusion while simultaneously raising new challenges.
b. The growing use of AI in financial intermediation raises important questions around
accountability, transparency, and suitability, with rising risks of "AI washing" where
technology claims outpace actual capabilities.
c. The core principles of transparency, suitability, accountability, and investor
protection cannot become secondary merely because interactions are digital. The
challenge before the industry is therefore how digital distribution can scale
responsibly without eroding investor trust.
15. Conduct risks
a. Another important challenge relates to incentives within the ecosystem. Excessive
focus on short-term performance, rapid customer acquisition, or distributionvolumes can create risks of mis-selling, unsuitable recommendations or product
churn.
b. These concerns have directly informed our regulatory approach. SEBI’s shift
towards a trail-based commission framework in the mutual fund industry, seeks to
better align distribution incentives with long-term investor outcomes.
D. Expectations – towards building a responsible distribution ecosystem
16. Financial products are fundamentally different from most other products. Investors
commit their long-term savings based on confidence in the institutions and trust in
those who guide them.
17. This places distributors in a uniquely important position. Distributors are not merely
facilitators of transactions; you are stewards of the investor journey.
18. Ethical distribution
a. The distribution landscape is evolving rapidly. Competition is intense. Pressure to
grow assets and acquire customers has become more pronounced, even as
regulatory expectations have strengthened over the years.
b. This environment can sometimes tempt firms to prioritise growth over suitability
and short-term acquisition over long-term investor outcomes. However, growth not
built on investor trust will ultimately become difficult to sustain. Ethical distribution
is therefore essential.
c. Conflicts of interest are inherent to financial intermediation and cannot be
eliminated entirely. The endeavour should therefore be to ensure that suchconflicts are recognised, disclosed, and managed transparently, with investor
interest remaining paramount.
d. As the ecosystem evolves, we may also need to reflect more on what success in
the distribution industry truly means. Assets under management alone cannot
become the sole measure of success. Equally important are metrics such as
investor persistence, investor behaviour across market cycles and periods of
volatility, quality of service, and grievance redressal.
e. Entities involved in financial distribution should also pay close attention to their
internal incentive and remuneration structures. If compensation frameworks are
driven excessively by short-term asset gathering or sales velocity, they can
weaken judgment even in the presence of detailed rules.
f. Ultimately, culture is what sustains Ethical conduct - not compliance manuals.
Leaders must set the tone at the top, embedding integrity, transparency, and into
organisational decision-making. A culture of integrity and accountability is perhaps
the strongest competitive advantage any distributor can build over the long term.
g. AMFI has constituted an ethics committee which is a very welcome step. SEBI,
through NISM, would be glad to partner with the industry on ethics capacity-
building for key participants, including distributors and AMC professionals. Initial
discussions on this have already begun.
19. A few key principles
Responsible distribution rests on a few practical principles:
Full and fair disclosure to investors, without any explicit or implied assurance
of returns,
Suitability of product with investor needs. Apply the family test – would you say
and do exactly the same if the investor were a family member? Ongoing engagement - Distribution does not end at the point of sales.
Continued servicing is central to the role of a distributor requiring a shift from a
sales centric to relationship-centric approach
As products, technologies, and investor behaviour evolve, distributors must
deepen their understanding of suitability frameworks, behavioural aspects of
investing, technology and cyber risks, liquidity risks, and portfolio construction.
E. Concluding Remarks
20. Let me conclude by reiterating that India’s financial markets are entering a phase
of unprecedented expansion and transformation. As we reflect on the future of
financial distribution, it is also useful to recognize that scale, trust, and sustainability
are not independent objectives, but reinforce one another. Scale without trust
becomes fragile. Trust without sustainability becomes difficult to preserve. And
sustainability without scale limits broader economic participation.
21. The task before all stakeholders - regulators, intermediaries, distribution
community, platforms and industry bodies is therefore to build a distribution
ecosystem where these three pillars strengthen each other.
Thank You !