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Q. Can America sentence young non-violent people to military basic training and advanced skilled training instead of a prison sentence?A. Correctional boot camps were the rage in the US in the 1980’s and 1990′s. Meta-analysis conclusively showed no improvement in recidivism, or cost savings. Two papers included were reviews of US experience (vengeful justice) as models/cautionary tales for Australia and the United Kingdom.Correctional boot camps (United Kingdom)What is the focus of the intervention?Boot camps are programmes for juvenile or adult offenders as an alternative to punishments such as prison or probation. They are modelled on military boot camps and involve activities such as drills, ceremony and physical training. Strict daily schedules are followed, and punishments for misbehaviour often involve physical activities like push-ups.Programmes differ based on content and delivery of physical and therapeutic aspects, which could include education, substance abuse treatment and improvement of cognitive skills.This narrative summarises the findings of three systematic reviews. Review 1 was based on 32 studies, Review 2 was based on 44 studies and Review 3 was based on 16 studies.The conclusions on effect size are taken from Review 1 only.All boot camp studies included in the reviews were conducted in the USA.EFFECTHow effective is it?There is some evidence that the intervention has either increased or reduced crime, but overall the intervention has not had a statistically significant effect on crime.In Review 1, while individual studies found both statistically significant positive and negative effects on crime, the overall analysis showed that boot camps had no overall effect on rates of re-offending by participants. This result was consistent across all three reviews.How strong is the evidence?The overall evidence is taken from Review 1 (based on a meta-analysis of 32 studies).The review was sufficiently systematic that most forms of bias that could influence the study conclusions can be ruled out.It had a well-designed search strategy, included unpublished literature and risks of bias by the reviewers were minimised.However, biases remain within the primary studies, including the difficulties of comparing boot camps to one another due to differences in treatments, the use of different outcome measures by researchers, and the problem of drop-out rates and how to take these into consideration when calculating effect sizes.MECHANISMHow does it work?The authors of Review 2 provided the most comprehensive attempt at explaining how boot camps work to reduce reoffending.By ensuring strict discipline and demanding physical exercise and labour, participants are encouraged to behave respectfully and obediently, hopefully making them more likely to comply with rules or laws upon programme completion.Adherence to daily routines and interactions with camp staff should teach participants skills to help them control their behaviour.Prosocial behaviours such as respect are also taught and practiced, with close supervision allowing positive behaviours to be reinforced and negative behaviours punished immediately.Review 3 also mentioned increasing self-esteem and promoting physical fitness as life skills.MODERATORSIn which contexts does it work best?The reviews noted a number of potential moderators, including offender characteristics (age and gender), programme characteristics (focus on rehabilitative or physical elements), treatments (drug treatment, vocational education and aftercare components), whether the programme was voluntary or mandated, and the presence of counselling sessions as part of the programme.None of the three reviews explained why or how these contextual differences might influence the outcome.Review 1 found that participants in boot camps with a strong therapeutic component including treatments such as education, drug treatment and counselling had lower rates of reoffending than those in camps with a stronger focus on physical elements.They also found that juvenile boot camps without a counselling component had a statistically significant negative effect upon re-offending rates of participants.Review 2 found that participants in voluntary boot camps had reduced rates of recidivism compared to mandatory boot camps. Review 2 also discovered that voluntary boot camps for young people significantly reduced the participants’ odds of recidivism (based on only 3 primary studies).While no moderator analysis was conducted on race, review 3 noted that up to 80% of boot camp participants were ethnic minority youths, despite boot camps being originally designed for white, working class participants.IMPLEMENTATIONWhat can be said about implementing this initiative?Boot camps are structured programmes, which generally last between 90 and 180 days.There is a graduation ceremony attended by family and friends for those who successfully complete the programme.Participants are housed in dormitories resembling military barracks, are placed in squads or platoons, and wear uniforms. Programme staff function as drill instructors and are often addressed by military titles. Punishment for misbehaviour is immediate, and usually takes the form of physical activities such as push ups.All three reviews note that studies evaluating boot camps with a strong therapeutic element seemed to have a higher chance of a successful outcome than those with a weaker or no therapeutic focus. Review 3 noted that programmes vary widely in the application and duration of therapeutic elements. Review 2 suggested that aftercare services with therapeutic content are important, and therefore, should not be short term in duration.ECONOMIC CONSIDERATIONSHow much might it cost?While none of the reviews conducted a full cost benefit analysis, some mention of costs was reported in the primary studies.Review 2 cited one study, which found that in 1997, the cost per boot camp participant was $31,752 less per year in California, compared to the cost of incarceration. Another study reported a similar comparison and found that in 2001 boot camps were $78,700 cheaper than prison per participant per year. Review 3 stated that the Alabama boot camp cost a total of between $779,229 and $1,676,880 less than participants being in prison. Three studies within Review 3 found that boot camps were cheaper than prison, while four studies found no difference.General considerations• Boot camps differ substantially in content – some camps focus on physical training and hard labour, while others emphasise delivering therapeutic programming such as academic education, drug treatment or cognitive skills.• Boot camps with an evidence-based therapeutic focus see the largest reductions in recidivism amongst participants.SummaryThere is some evidence that the intervention has either increased or reduced crime, but overall the intervention has not had a statistically significant effect on crime. Those boot camps that have seen the greatest reduction in participant recidivism, especially with juvenile populations, have focused upon therapeutic elements within the programmes.Ratings for Individual ReviewsResourcesReview 1: Wilson, D.B., MacKenzie, D.L., Mitchell, F.N. (2003) 'Effects of correctional boot camps on offending' Campbell Systematic Reviews 2003:1, DOI:10.4073/ csr.2003.1Review 2: Meade, B. and Steiner, B. (2010) 'The total effects of boot camps that house juveniles: A systematic review of the evidence', Journal of Criminal Justice, 38, 841-853Review 3: Riphagen, R. C. (2010) 'Effectiveness of Male Juvenile Boot Camps in the United States: A Critical Review of the Literature', Doctoral Dissertation, Azusa Pacific University.Uploaded 04/06/15Boot camps a poor fit for juvenile justice (Australia)October 24, 2012 2.36pm AEDT Robyn Lincoln Assistant Professor, Criminology, Bond UniversityQueensland unveils tenders for two new boot camp programs for young offenders.The Queensland Attorney-General, Jarrod Bleijie, has authorised a tender process for the operation of two youth boot camps. The camps, aimed at 13 to 17 year olds, are to be trialled in Cairns and on the Gold Coast for a two-year period. The camp in the north of the state is an intensive diversion program for “sentenced” juveniles, while that in the south-east corner is an early intervention scheme for “at risk” youth.As with all matters of justice, Queensland is not alone in proffering boot camps as the “answer to youth crime”. The Brumby Government proposed school-based camps for Victoria in 2010, and both the Northern Territory and Western Australia have flirted with such programs as early as the 1980s.In the wake of calls for the operation of boot camps to solve problems of youth crime, it is instructive to examine what they are, what inspires them and what the research evidence reveals about their outcomes.The shape and size of boot campsThere was a proliferation of boot camps in the USA in the 1980s and 1990s, where millions of dollars were diverted to their operations.They come under the guise of wilderness, bush, work, motivational and challenge camps. Some are attached to schools or prisons and many are geared toward adult offenders, but a significant proportion are aimed at “recalcitrant youth”, some set up specifically for females.While the camp programs vary, the common features of these residential programs are that they are established on militaristic lines with an emphasis on deference to authority, conformity, intimidation, isolation, and concentrated physical training.The tender documents for the proposed Queensland camps appear no different. The program intends to instill “discipline and respect”, ensures “direct consequences for offending” and entails considerable “supervision”.Moral foundationsThe very concept of a boot camp is based on the notion of individual responsibility for crime and anti-social behaviour. It is about failure of parents or families and ultimately of the young people who find themselves in trouble with the law.The principles revolve around shock treatment, power and control, and disciplinarian techniques. To that end they exemplify the “get tough” politicisation of crime, a misplaced view that we have the capacity to correctly identify threat and risk. A misguided belief in the effectiveness of the punitive approaches of past centuries.This is what has been labelled by some as “vengeance justice”. For even though these programs purport to “address the causes of crime”, they are mean-spirited and sheet the blame for crime solely at the individual level.Queensland Attorney-General Jarrod Bleijie addresses the press. AAP/Dave HuntEvaluating boot campsDuring the 1990s in particular and in the USA specifically, a number of studies were conducted into the effectiveness of boot camps. Similar evidence emerged from the UK about a range of “short sharp shock” treatment regimes.All of this empirical work shows quite clearly that there is no benefit to boot camps. Whether the measures are re-offending rates or whether it is centred around cost-effectiveness — there is little to show that boot camps offer a beneficial alternative.Of course given the variety of boot camp philosophies and the practices of their daily regimes some caution needs to be exercised about the research evidence. In addition, trying to conduct any truly robust research is difficult and rarely are quasi-experimental designs used (that is, random allocation of youth to boot camp versus a range of other interventions that are then followed up in the long term).Yet even in studies where there were some differences in outcomes, they were marginal or negligible and could often be sheeted home to the backgrounds of the offenders (age, sex, previous convictions) rather than any militaristic-style intervention they had undergone.Of most significance is that some studies showed that there was potential for greater effectiveness when the boot camp included some kind of “treatment” option which flies in the face of the fundamental philosophy of such camps.In the last decade more sophisticated research has emerged including meta-analyses of multiples studies. However the findings remain, that there were no significant differences on re-offending measures between those who attend a correctional boot camp and those who did not.Even when the “softer” style of boot camps were evaluated there were no differences on recidivism. Similarly studies that have undertaken longer term follow-ups show no benefit. In research where a cost-saving has been identified this was only because offenders spent slightly less time in prison. Finally, one evaluation of a school-based camp again found no differences on re-offending but participants displayed “favourable” views of the program.Does the boot fit?Thus several decades of evaluations of boot camps has demonstrated quite conclusively that they are not effective in reducing recidivism and have marginal impact on cost-savings.The problem with these “shock and awe” tactics is that they are centred around individual responsibility. This shows a fundamental lack of appreciation of the “causes” of crime — demographic changes, deployment of police, reform to criminal codes, urban design, extended surveillance, tougher supervision orders.Most of all it signals a vengeful justice system. Let’s face it, boot camps are founded on fear and terror.Return to the Crime Reduction ToolkitJuvenile Boot Campshttps://www.ncjrs.gov/pdffiles1/nij/197018.pdfConclusions: Correctional practitioners and planners might learn from boot camps’ failure to reduce recidivism or prison populations by considering the following:■ Building reintegration into the community into an inmate’s individual program and reentry plans may improve the likelihood he or she will not commit a new offense.■ Programs that offered substantial discounts in time served to those who completed boot camps and that chose candidates sentenced to serve longer terms were the most successful in reducing prison populations.■ Chances of reducing recidivism increased when boot camp programs lasted longer and offered more intensive treatment and post release supervision, activities that may conflict with the goal of reducing population. Efforts to achieve multiple goals are likely the overall cause of boot camps’ conflicting results.Program designers are urged to determine which options are best for their jurisdictions; for example, they may consider whether to implement more treatment programs or move inmates out of the system more rapidly. These decisions affect costs, as prison bed-space savings go up or down. Other correctional programs are adopting some of the important elements of boot camps—for example, carefully structured programs that reduce idleness—to increase safety and improve conditions of confinement for younger offenders.20 However, in recent years, some jurisdictions facing rising costs have responded by cutting programs.One lesson for policymakers from 10 years of boot camp research is that curtailing programs may lead to increased violence, misconduct, and serious management problems.Boot Camp Justice for Juvenile OffendersAfter the crime rate for those under the age of 17 doubled in a five year period, Camp Stop, a military-style boot camp, was opened. This program aims to deal with juvenile offenders and steer them away from a life of crime. Fourteen-year-old Norton G. explains why he was incarcerated. Sgt. Major Richard Hurt believes boot camp can make a positive difference in kids’ lives. While life is harsh at Camp Stop, it cannot compare with life in Georgia prisons in the 1930s. Scenes from the movie I Am a Fugitive from a Chain Gang, based on a book about Georgia prisons, show how the mistreatment of prisoners led to prison reforms.Criminal Justice and the Juvenilehttp://file:///C:/Users/RAD/Downloads/1978-6398-2-PB%20(1).pdfhttps://www.fdle.state.fl.us/FCJEI/Programs/SLP/Documents/Full-Text/Bobbitt-thomas-paper.aspx

[Edited to add an answer to a comment that asked what, specifically, that Spenser Rapone did “wrong”. Why was being an avowed Communist not protected or allowed under freedom of expression. This follows below as an addendum to my original answer.]It was not a DD, which a commissioned officer cannot receive anyway (more on that later), but an OTH (Other than Honorable) which impinges on some VA benefits but not nearly as severely as Dismissal from the Service would, the officer version of a DD that is identical in all but name. Officers are not “discharged”, they resign, retire or are dismissed. In the case of Rapone, the US Army accepted a Qualified Resignation for the Good of the Service, which is OTH (when accepted), except it’s a resignation.While some would want a General Court-martial conviction with Dismissal, the Qualified Resignation is more expedient and IMHO appropriate. Dismissal requires a General Court-martial conviction which is time consuming for all involved, especially the panel which is drawn from officers in the convening authority’s command. A commissioned officer can only be tried by a General Court-martial which must be convened by a general and has the most formal and involved procedures of the four types (Summary, Special, Special-BCD, General).I’ve no doubt this was the sequence of events:Investigation initiated in 2017 regarding the Facebook and other social media photos. Investigation recommends Article 32 Proceedings for possible referral to a General Court-martial.General Court-martial convening authority (a general officer in command) initiated Article 32 Proceedings. An officer (in compliance with Article 32 requirements; almost always a judge advocate) is appointed to conduct the Article 32 hearing. This is the military equivalent of a preliminary hearing to determine if there is probable cause to proceed with trial and makes recommendation to the convening authority. Article 32 Proceedings recommended trial by General Court-martial.Commanding general (I would guess the 2-star commanding the 10th Division at Fort Drum) refers General Court-martial charges, most likely for UCMJ Article 133, Conduct Unbecoming an Officer and Gentleman. Other possible charges could be for things such as false official statements if he lied to investigators under oath, or signed a statement he wasn’t a communist for a clearance application which has a very long form in which one indicates whether or not they’ve had membership or association with a large number of subversive organizations. Simply signing something attesting to its veracity is sufficient; it need not be a sworn statement made “under penalty of perjury”. Commanding General calls in Rapone and formally reads him charges and specifications.Rapone consults with defense counsel provided by Staff Judge Advocate’s defense section and any other attorneys he might wish to hire on his own. The military has very hard partitions between defense, prosecution and judge advocate sections to protect them and their integrity. Defense counsels are not in or under the same command as the convening authority to prevent even the appearance of command influence. It was my experience the defense counsels are as aggressive as trial rules allow. Defense counsel advises Rapone to offer resignation to avoid court-martial which will assuredly convict and send him to the USDB at Fort Leavenworth for the maximum sentence allowed by the UCMJ.Rapone offers to tender unconditional resignation in lieu of court-martial. CG declines the offer with reply that he would consider a conditional resignation “for the Good of the Service”. Rapone submits conditional resignation and it’s accepted.Rapone is ignominiously heaved out of fhe US Army with an OTH (Other than Honorable) characterization of service. Note that he is not “discharged” but has resigned. The OTH is reflected on his DD214.Rapone flips bird at Fort Drum sign as he’s ignominiously escorted from the post as persona non grata on the installation and is no longer authorized to enter it.Attending the USMA incurs a five year minimum active service obligation. Failure to complete that incurs a debt to the US Government for the complete cost of the education received up to the point when the cadet departed or graduated. IRS sends him a bill for his entire USMA education, including pay received, prorated down for his months of active duty following graduation from the USMA. This would be 60 months (five years) minus about 12 months or so, or roughly 80% of the total cost. Rapone, by law, cannot absolve this debt with bankruptcy. Rapone may have not gotten the bill yet, but he most assuredly will.That is, without any doubt, how it all went down.Edit:As Bugs Bunny would have observed: What a maroon!—————————————————————————-Addendum: Had a comment that asked the following of me:“Can you clarify what his actual charge was - or more specifically, what he did wrong? I wasn’t aware that being a communist - or belonging to a communist political party in the US - was an offense at all. I would think it would be protected under free expression..Obviously, you’re more educated on the subject than I am, and I hope you can clarify it for me!”This will be a long reply to those questions . . .I majored in Political Science specializing in Public Administration for three years before changing my major to General Physics with an emphasis on Mathematics. Reading Karl Marx’s “The Communist Manifesto” to understand Communism was required in my Political Science studies. It was also required during the height of the Cold War in the late 1960’s was during my senior year HS Civics class. There was considerable class discussion regarding it, with emphasis on critical thinking, something I believe has gotten utterly lost in today’s primary, secondary and post-secondary education systems. If someone is going to espouse or decry Communism, they need to know what it is they’re supporting or opposing.Espousing Communism was the fundamental problem that got Spenser Rapone in serious trouble. Read “The Communist Manifesto” (Karl Marx & Friedrich Engels, 1848):https://www.marxists.org/archive...It is the fundamental basis for all flavors of Communism (e.g. Marxist, Leninist, Stalinist, Trotskyist, Maoist, etc.) and remains its touchstone 170 years later. Among its tenets is the need to violently overthrow not only the government, but the “class” society and underlying culture that supports it. Section IV, the last section of the Manifesto ends with:“The Communists disdain to conceal their views and aims. They openly declare that their ends can be attained only by the forcible overthrow of all existing social conditions. Let the ruling classes tremble at a Communistic revolution. The proletarians have nothing to lose but their chains. They have a world to win.Working Men of All Countries, Unite!”The Communist Anthem is the “Internationale”. Read its lyrics:The Internationale - WikipediaThe Communist Revolution is intended to ultimately create a global Communist society and “government” with no nations and no borders, just one big happy Commune (or communal) Proletariat. The title of their anthem is a major clue! The international global theme runs throughout the Manifesto. Everyone is reduced to being a worker. The proletarian is the “working man” versus the bourgeoisie middle class, landed “gentry” (landowners), titled, royalty and ruling class (as defined by the government being overthrown). The operative words here are “forcible overthrow”. After the revolution, only the Proletariat remain. Everyone else is either dead or in the process of being “reeducated” to make them “good” proletarians.The true meaning of “all existing social conditions” in terms of government, society and culture is becomes clear in reading the entire Manifesto. Karl Marx contrasts this with several different forms of “Socialism” in his Manifesto which require placing those forms of Socialism into the historical context of mid-19th Century Europe to fully understand it (i.e. some knowledge about those mid-19th Century Socialist movements helps).Stalin used the gulags and Siberian mines to work to death those who ran afoul of his Communist ideal, or posed a political threat (real or perceived). Sometimes I wonder if those that got the immediate bullet to the back of the head weren’t the luckier ones. Pol Pot of the Khmer Rouge that took over Cambodia from 1976–1979 (renaming it Kampuchea) was orders of magnitude more barbaric. Pol Pot and the Khmer Rouge were the epitome of the Proletarian revolution with unbridled vigor, executing all the educated, professionals, and intelligentsia they could get their hands on. The Khmer Rouge destroyed centuries of Cambodian cultural icons in the effort to destroy the culture in order to remake it into ideal Communes of nothing but uneducated agricultural peasants. See the movie “The Killing Fields” (1984). Cambodia still hasn’t recovered from his wanton destruction.Thus, Communism is a political dogma that seeks to achieve its ends with the proletariat becoming the “ruling class” with violent revolution, and to do so internationally. That inherently requires taking up arms against one’s government, which is the definition of sedition. This is why being a Communist or belonging to any one of many Communist organizations is part of the list of subversive beliefs and organizations on the application for a security clearance. To receive a commission, one must be able to hold a Secret clearance (three levels: Confidential, Secret, and Top Secret). This requires a background investigation and one must affirm they do not hold subversive beliefs or belong to a subversive organization that advocates violent overthrow of the government. Spenser Rapone would never have received a security clearance of any kind (not even Confidential) or a commission had his espousal of Communism been known.I do not know the specific charges and specifications Rapone was read for General Court proceedings as he was allowed to conditionally resign before a trial began. My citing UCMJ Article 133, Conduct Unbecoming an Officer and Gentleman, comes from knowledge of the UCMJ’s punitive articles (those that define crimes) and how they are generally applied. Given the above regarding signing documents for commissioning and for a Secret security clearance in which he must aver to not being a Communist or belonging to, among a huge list of subversive organizations, a long list of Communist organizations, some of which are in the US and others in other countries, UCMJ Article 107, False Official Statement, would also be applicable. Article 133 is a catch-all for behavior by a commissioned officer that reflects discredit upon the individual, the US Army and the Nation. There are various specifications under it for specific acts, but there is also a very general one for acts not specifically cited. Knowing what falls within that is similar to knowing what is and isn’t pornography: “you know it when you see it” (to paraphrase a Supreme Court Justice).UCMJ Article 134, General Article, could also have been used, but it would be seen as redundant with a charge under Article 133 and stacking charges isn’t allowed. I cite it as that is the UCMJ punitive article that applies to all personnel, including enlisted (which includes NCOs). Commissioned officers are held to a higher standard of conduct by the very nature of their position in the military’s leadership structure, to include command positions, with the absolute responsibilities and specific powers given Officers of the United States under Title 10, US Code. A major part of leadership is leading by example. The US places a special Trust in its commissioned officers who receive a commission from the President of the United States appointing them to their rank as an Officer of the United States.. Honor, Integrity and Honesty are essential to having and maintaining that Trust, and respect from one’s superiors and subordinates. It is earned. Easy to tarnish and destroy, and exceptionally difficult if not impossible to regain. Trust is paramount in battle: trust that one will do what they say they will do, trust that one will diligently do whatever they need to do without fail to accomplish assigned missions. Violating or failing that trust hazards units, other related missions, and costs lives. That is the fundamental reason for UCMJ Article 133 which only applies to officers. Rapone willfully violated the Trust the United States placed in him. There are many things civilians can do in their personal conduct that commissioned officers cannot do. One lives in somewhat a fishbowl and must set an example of conduct, personal and professional, that is beyond reproach. The higher the rank, the bigger the fishbowl becomes. The military is unique in that its personnel live together 24/7 when deployed. They don’t go home at Beer-Thirty and resume the battle at 9 AM the next weekday. Even in garrison the nature of military duties is much more comprehensive than in civilian life.The photos of Rapone with his cap and the Che Guevera T-shirt were the ones the media found most compelling for news stories. They weren’t the only ones. He Facebook and Twitter accounts were quickly shut down to public access, then deactivated and deleted. There were numerous statements and other photos. The US Government has means to recover content with the help of Facebook and Twitter via subpoenas. From what I was able to see before Rapone deleted his accounts, the evidence he is a Communist was more than compelling. The US Army’s investigation would have collected supporting evidence in the form of statements from the cadets he lived with and was in classes with at USMA (West Point) as well as interviews with his fellow officers and NCOs in the units he was assigned to after graduation, which would have included the Infantry Officer Basic Course at Fort Benning, his first assignment after graduation.I hope this gives some insight regarding Spenser Rapone, how the military dealt with him, and why. I saw the initial news article, was in an initial state of disbelief and then was aghast at what I read and saw. With 21 years of commissioned service I knew the wheels would not turn quickly, but in the end his military career was ending. It was a matter of how ignominious it would be. What the press hasn’t covered is the wider investigation I am certain is (or was) being conducted to determine how Spenser Rapone got through the USMA without his beliefs and conduct being discovered and brought to light before he graduated. It’s extremely difficult for me to fathom how someone close to him didn’t know what was going on. If so, they had a legal obligation to report it, another aspect of the military that isn’t necessarily applicable to civilians.

How to read the mutual fund offer documentsEvery mutual fund commercial ends with a few words of caution that read: Mutual Funds are subject to market risks - this bit is absolutely true and almost every investor knows this. However the latter part of the sentence - Please read the scheme related document carefully before investing - is easier said than done.The scheme related offer documents (ODs), can run in to tens of pages and carry legal and financial jargon that can put a retail investor off. That is why most of them rely on financial advisers and bank agents for recommending mutual fund schemes. However, with loads of information (sometimes contradictory) coming through various channels, it helps to be aware of what one should expect from the investment.When reading the ODs, do go through the following important aspects that will stand you in good stead:* Investment Objectives: Investment policies and objectives form the mainstay of the ODs. Scanning through these will enlighten the investor about the goals of the specific funds, their expected composition of the underlying portfolio. Investors can also get a fair idea of the strategies that the fund manager will use to achieve the said objectives. Match these objectives with your own expectations about income or long-term capital appreciation as well as your risk appetite.* Past Performance: Some of the important aspects to look at are the inception date of a scheme, the Assets Under Management (AUM) and its past performance. Investors should compare this with similar funds in the market as well as against the industry benchmark. Ideally, opt for schemes that have offered consistent returns over a long term. However, never use this information to predict future returns because - past performance is not an indicator of future returns.* Risk factors: The OD specifies the various types of risks that the scheme would be exposed to. Make an informed decision based on your own outlook and understanding of the markets. Study and understand these so that you can choose the right scheme as per your risk taking ability. A word of caution here - don't be overwhelmed by the various types of risks. Mutual fund companies are stipulated by law to highlight every type of financial risk you may be exposed to if you invest in a particular scheme.* Fees, Loads and Taxes: Read the ODs to learn about the minimum investments, charges applicable and services available to you. Some of the common charges applicable are Entry and Exit Loads, Transaction Charges, Security Transaction Tax (STT), various charges for managing the fund - together called the Total Expense Ratio (TER). It is important to know that all mutual funds do not have the same type of charges and that all these charges are regulated by the Securities and Exchange Board of India (SEBI).* Key Personnel/Fund Managers: The ODs also give you significant insights about the credentials of the fund managers, their experience and investment style.Let us now take a look at the various types of documents that makeup the ODs:1. SID [Scheme Information Document]: This is a compendium of all the scheme related information. It will list all the MF schemes available to the investor.2. SAI [Statement of Additional Information]: A supplementary document to a mutual fund's prospectus that contains additional information about the fund and includes further disclosure regarding its operations. This is also, known as "Part B" of the fund's registration statement.3. KIM [Key Information Memorandum]: The KIM sets forth the information, which a prospective investor ought to know before investing.4. Fund Fact Sheet: Self-explanatory, this document is a data mine. It provides a thorough analysis of the fund with comprehensive financials, graphs and other research which help investors gain insight into the fund's performance under varying market conditions.Source - How to read the mutual fund offer documentsOFFER DOCUMENTForm NS is the Standard Offer Document for schemes launched by Mutual Funds under the Securities and Exchange Board of India (Mutual Funds) Regulations, 1996. All Mutual Funds should use Form NS for filing an offer document pursuant to sub regulation (1) of Regulation 28 of the SEBI (Mutual Funds) Regulations, 1996, (Regulations) along with filing fees as specified in the Second Schedule to these Regulations.The purpose of a scheme offer document is to provide essential information about the scheme in a way that will assist investors in making informed decisions about whether to purchase the units being offered. Since investors who rely on the offer document may not be sophisticated in legal or financial matters, care should therefore be taken to present the information in the offer document in simple language and in a clear, concise and easily understandable manner.The Standard Offer Document enumerates the minimum disclosure requirements to be contained in the offer document of a scheme. A Mutual Fund is free to add any other disclosure, which in the opinion of the Trustees of the Mutual Fund (Trustees) or the Asset Management Company (AMC) is material for the investor, provided that such information is not presented in an incomplete, inaccurate or misleading manner. Care should be taken to ensure that inclusion of such information does not, by virtue of its nature, or manner of presentation, obscure or impede understanding of any information that is required to be included under the Standard Offer Document.The Standard Offer Document prescribes only the nature of the disclosures that should be contained under various heads in the offer document of a scheme, and is not intended to describe the layout or the language to be contained therein, with the exception of Items I, II and III, which must appear in the same numerical order in the offer document of a scheme. If the Mutual Fund desires, it may include Item III as a part of Item I in the offer document.The instructions for filling up the Standard Offer Document form are given under each head.1. THE COVER PAGEThe cover page is required to contain the following information: (a) The name of the Mutual Fund;(b) The name of the scheme;(c) The type of the scheme;(d) The name of the asset management company;(e) The classes of units offered for sale;The price of units;The name of the guarantor in case of an assured return scheme;(h) Opening, closing and earliest closing date (if any) for the offer; (i) A statement to the effect that (A) the offer document sets forth concisely; the information about the scheme that a prospective investor ought to know before investing; (B) the offer document should be retained for future reference;(j) A statement to the effect that the scheme particulars have been prepared in accordance with the Securities and Exchange Board of India (Mutual Funds) Regulations, 1996, as amended till date,and filed with SEBI, and the units being offered for public subscription have not been approved or disapproved by the Securities and Exchange Board of India nor has Securities and Exchange Board of India certified the accuracy or adequacy of the offer document.Instructions :The scheme shall not have a name or title which may be deceptive or misleading. If the scheme's name suggests a certain type of investment policy, its name should be consistent with its statement of investment policy.The type of the scheme would mean whether the scheme is a growth scheme, bond scheme, balanced scheme etc. and whether the scheme is open-ended, close-ended, an interval fund etc.In case of an open-ended scheme or a close-ended scheme with a reissue option, the currency of the offer document shall be clearly defined; for example, it should be stated that the offer document will remain effective till a ‘material change’ (other then a change in Fundamental Attributes and within the purview of the offer document) occurs and thereafter the changes shall be filed with SEBI and circulated to the unitholders along with the quarterly/half-yearly reports.(iv)Highlights of the scheme, irrespective of whether they appear on the Cover Page or not, shall make a specific disclosure in case of assured return schemes regarding the guarantee given either by the AMC or by the Sponsor to distribute income at the assured rate, and to redeem the capital invested, to the unitholder. This statement shall be in bold, legible fonts.DEFINITIONSAll terms used in the offer document shall be defined in this Section. Instructions :Language and terminology used in the offer document shall be as provided in the Regulations. Any new term if used shall be clearly defined.All terms shall be used uniformly throughout the text of the offer document e.g. the terms ‘sale price’ and ‘repurchase price’ shall be used uniformly to indicate ‘offer price’ and ‘bid price’ of units.The term ‘scheme’ shall be used uniformly to indicate the different schemes of a Mutual Fund.III. RISK FACTORSThis section shall describe the Risk Factors in the scheme.The scheme shall disclose the following risk factors in addition to scheme specific risk factors, if any, in legible fonts. These risks factors may be peculiar to the Mutual Fund as well as those attendant with specific investment policies and objectives of the scheme.The Standard Risk Factors :Mutual Funds and securities investments are subject to market risks and there is no assurance or guarantee that the objectives of the Mutual Fund will be achieved.As with any investment in securities, the NAV of the units issued under the scheme can go up or down depending on the factors and forces affecting the capital markets.Past performance of the sponsor/AMC/Mutual Fund does not indicate the future performance of the schemes of the Mutual Fund.'XYZ' is the name of the scheme and does not in any manner indicate either the quality of the scheme or its future prospects and returns.Scheme Specific Risk Factors:Scheme specific risk factors arising from the investment objective, the investment strategy and the asset allocation of the scheme;Risk arising from non-diversification, if any;Specific risk factors associated with investing in close-ended schemes (i.e. infrequent trading, possibility of market price of units being at a discount to NAV etc).In respect of assured return schemes, if assurance is till the maturity of the scheme, the risk factor must state that assurance is given on the basis of the guarantee provided by the sponsor/trustee/AMC. Further, the networth and the liquidity position of the guarantor and the source of the guarantee shall be disclosed. In case assurance is for a specific period, the risk factors shall stipulate the following: "These returns are assured only for a specific period by the guarantor. There is no guarantee that such returns may be generated for the remaining duration of the scheme, unless the Mutual Fund proposes to provide assured returns in the future."If the AMC has no previous experience in managing a Mutual Fund, a disclosure to the effect that this is the first scheme being launched under its management.IV. DUE DILIGENCE BY THE ASSET MANAGEMENT COMPANYThe Asset Management Company shall confirm that a Due Diligence Certificate duly signed by the Compliance Officer/Chief Executive Officer/Managing Director/Wholetime Director/Executive Director of the Asset Management Company has been submitted to SEBI, which reads as follows :It is confirmed that :(i) the draft offer document forwarded to SEBI is in accordance with the SEBI (Mutual Funds) Regulations, 1996 and the guidelines and directives issued by SEBI from time to time.(ii) all legal requirements connected with the launching of the scheme as also the guidelines, instructions, etc., issued by the Government and any other competent authority in this behalf, have been duly complied with.(iii) the disclosures made in the offer document are true, fair and adequate to enable the investors to make a well informed decision regarding investment in the proposed scheme.(iv) the intermediaries named in the offer document are registered with SEBI and till date such registration is valid.Instructions :With respect to Point (ii) , while submitting the due diligence certificate, the asset management company shall clarify the legal requirements which are yet to be complied with.V. EXPENSESThe description on expenses to be incurred under the scheme shall include a table, furnishing the following information, using the captions provided, in the format illustrated below :A. Unitholder Transaction Expenses or Sales Load :Maximum Sales Load imposed on purchases ______ %(as % of NAV)Sales Load, if any, on issue of units in lieu ______ %of dividends (as % of NAV)Contingent Deferred Sales Load Year 1 ______ %(give yearwise details as % of Year 2 ______ %NAV) Year 3 ______ %Year 4 ______ %Redemption / Repurchase Load ______ %(as % of NAV)Switchover/Exchange Fee ______ % (as % of NAV)Note : Wherever quantitative discounts are involved, this shall be disclosed. The Mutual Fund may charge the load within the stipulated limit of 7% and without any discrimination to any specific group of unitholders. However, any change at a later stage shall not affect the existing unitholders adversely.B. Initial Issue Expenses :(i) For the Present Scheme :Under this head, briefly describe the nature of initial issue expenses for launching the scheme such as Advertising Expenses, Commission to Agents/Brokers, Registrar's Expenses, Printing & Marketing Expenses and Postage & Miscellaneous Expenses. Other expenses, if any, may be specified. The offer document shall disclose that initial issue expenses would be approximately _____% of the resources raised.Estimate the amount that will be available to the scheme for every Rs.100 contributed by the investors.A statement to the effect that total Initial Issue Expenses shall not exceed 6% of the initial resources raised under the scheme, as prescribed in the Regulations, and any excess beyond 6% shall be borne by the Asset Management Company.(ii) Past Schemes : The Mutual Fund shall disclose total issue expenses at actuals for the schemes launched during the last one fiscal year. Expenses borne by the asset management company, if any, shall be disclosed. If no scheme has been launched during the last one fiscal year, the particulars may be provided in respect of the latest scheme launched by the Mutual Fund. Include a brief narration for the reasons for adverse variations if any, between the 'actual expenses' and 'estimated expenses'. C. Annual Scheme Recurring Expenses : (as a % of Average weekly Net Assets) Give a break-up of the recurring expenses chargeable to the scheme in the format illustrated below; however, certain items of expenditure may be clubbed together, if felt necessary by the Mutual Fund to give meaningful information to the investors :-Investment management & Advisory fees ________ %Additional Fees (if any) ________ %Trustee Fees ________ %Custodian Fees ________ %Registrar & Transfer Agent Fees ________ %Marketing & Selling Expenses includingAgents Commission ________ %Brokerage & Transaction Cost pertainingto the distribution of units ________ %Audit Fees ________ % Costs related to investor communications ________ %Costs of fund transfer from location to location________ %Cost of providing account statements anddividend redemption cheques and warrants ________ %Insurance premium paid by the Fund ________ %Winding up costs for terminating the Fund/scheme ________ %Costs of statutory advertisements ________ %Other expenses*TOTAL ANNUAL RECURRING EXPENSES ________ %(* To be specified as permitted under the Regulations)The regulatory limits on Annual Recurring Expenses and Investment Management & Advisory fees in terms of regulation 52 shall be disclosed.Instructions :Immediately after the table provide a brief narrative explaining that the purpose of the table is to assist the investor in understanding the various costs and expenses that an investor in the scheme will bear directly or indirectly. Include, where appropriate, cross-references to the relevant sections of the offer document for more complete descriptions of the various costs and expenses.If a particular caption is not applicable to the scheme of the Mutual Fund, the caption may be omitted from the table in the scheme offer document.Round all Rs. figures to the nearest lakh and all percentages to the nearest hundredth of one percent.List separately the data for schemes launched with two classes of units("load" and "no load") and also schemes launched on a "partial load" basis.Under Unitholder Transaction Expenses (Section V A), "Contingent Deferred Sales Load" includes the maximum contingent deferred sales load, expressed as a percentage of NAV. A tabular presentation, within the larger table, of the range of contingent deferred sales load over time may also be included.Switchover/Exchange Fee includes a maximum fee charged from any switchover of units between different schemes under the same AMC.Under Annual Scheme Recurring Expenses (Section V C), additional fee shall include fee charged, in case of a scheme launched on a 'no load' basis, in accordance with the Regulations.In case of a no-load scheme or where sales load is collected from investors, disclosure of marketing and selling expenses is not required.In case the scheme offers additional benefits by way of insurance, the premium paid and the manner in which the expenses will be met, shall be disclosed.VI. CONDENSED FINANCIAL INFORMATION(a)HISTORICAL PER UNIT STATISTICSSCHEME NAMEYR. 1YR. 2YR. 3NAV at the beginning of the yearNet Income per unitDividends :Transfer to reserves (if any)NAV at the end of the yearAnnualised returnNet Assets end of period (Rs. Crs.)Ratio of Recurring Expenses to net assetsThe information shall be presented schemewise for all the schemes launched by the Mutual Fund during the last three fiscal years (excluding redeemed schemes) in the above comparative columnar form for each of the last three fiscal years. In addition, upto date information for the current fiscal year such as half yearly unaudited results of the schemes shall also be furnished. The latest NAV and annualised return figures updated as of 30 days prior to the launch of the scheme shall be furnished.Instructions :In case a Mutual Fund has launched a scheme which has not completed a full year of operation nor has it been audited, the information shall be furnished upto a latest date and the offer document shall also include a statement to that effect.Per unit amounts shall be rounded off to two decimal places.Appropriate adjustments shall be made and indicated in a footnote to reflect rights/bonus issue, if any, during the period.Annualised returns in terms of rise/fall in NAV and dividends etc. paid to the unitholders of each scheme of the Mutual Fund from the date of allotment till the end of each financial year shall be disclosed. These returns shall be annualised and compounded. (For example, while giving figures for the thirdfiscal year, the comparison should be with the NAV prevailing at the time of allotment and not with that prevailing at the end of the second fiscal year.The NAV at the time of allotment should be taken at Rs.10 or face value i.e. the money that is given by the investor).(c) Furnish the following information as of the end of the last fiscal year for the Mutual Fund, schemewise.:Year Amount of Amt. as % of NAV Purpose of Time Period borrowing at the of borrowing(Rs. crs.) time of borrowing------ ----------------- ---------------------- ----------- ------------------------------VII. CONSTITUTION OF THE MUTUAL FUNDUnder this head, the following shall be discussed:(i) A brief description of the objectives of the Mutual Fund;(ii) Functions and responsibilities of the constituents of the Mutual Fund, viz. Sponsor, Asset Management Company, Trustees and Custodian;(iii) Note on the activities of the Sponsor and its financial performance for the last three fiscal years which shall include figures for turnover/total income, profit after tax, equity capital, free reserves, net worth, earnings per share, book value per share and percentage of dividend paid;(iv) Names and addresses of the Board of Trustees/Board of Directors of the Trustee Company and details of their principal occupations and current directorships. In case they are associates of the Sponsor or the Asset Management Company during the last three fiscal years, this shall be disclosed separately;(v) Summary of substantial provisions of the Trust Deed which may be of material interest to the unitholders;(vi) Trusteeship fees, if any.VIII. INVESTMENT OBJECTIVES AND POLICIESThe scheme's investment objective and policies (including the types of securities in which it will invest) shall be clearly and concisely stated in the offer document so that they may be readily understood by the unitholder. Because the circumstances of each scheme will vary, it may not be possible to define precisely the asset allocation pattern. But as a general rule, the level of disclosure regarding the asset allocation pattern shall be consistent with the objective of the scheme. The offer document shall emphasise the main types of investments the Mutual Fund proposes to make and the basic risks inherent in such investments. Accordingly, discussions of types of investments that will not constitute the scheme's principal portfolio shall be as brief as possible and may be limited to identifying the particular type of investments. Similar treatment shall be accorded to other types of practices such as borrowing money. In order to achieve the objective of clear and concise disclosure, the Mutual Fund shall avoid use of extensive legal and technical detail and need not discuss every possible contingency, such as remote risks;The disclosures under this head shall include the following:A short description of the types of securities in which the scheme will invest "principally" and if applicable, any special investment practice or technique that will be employed in connection with investing in such securities;Asset allocation pattern (as % of the assets) in tabular form in which indicative range of investments or the maximum investment in a certain class of instruments;The policy of diversification to be pursued by the scheme. If however, the scheme proposes to concentrate in a particular industry or a group of industries, the names of such industry or industries shall be disclosed. The policy on concentration should not be inconsistent with the scheme's name and objective.;If the scheme's name implies that it will invest primarily in a particular type of security, or in a certain industry or industries, the scheme shall have an investment policy that requires that, under normal circumstances, at least 65 percent of the value of its total assets be invested in the indicated type of security or industry. Further, the scheme's name may not be so similar to the name of an existing scheme of another Mutual Fund as to cause confusion in identifying the new scheme;Disclosure of the policy with respect to investment in non publicly offered debt securities (including convertible securities) as well as in unrated instruments ( of listed/unlisted companies) of any issuer;For open ended schemes, if the proposed aggregate holdings of assets considered "illiquid," including debt securities (for which there is no established market), is expected to be more than 10% of the value of net assets, then the offer document shall disclose the policy to be followed by the Mutual Fund with respect to illiquid investments, indicate such percentage and disclose the possible effect on the ability of the scheme to make payment within 10 days of the date its units are tendered for repurchase/redemption;If the scheme chooses to invest in another scheme managed by the same AMC or by the AMC of any other Mutual Fund, disclosure of the type of schemes with prudential limit as provided in the Seventh Schedule to the Regulations, as also the percentage of its assets which may be invested, and disclosure as to how such investment would enable the scheme to achieve its investment objective shall be made in the offer document. The offer document shall also disclose that no investment management fee shall be charged by the AMC on such investments;If the AMC chooses to invest in any of its schemes, full disclosure of its intention to invest, maximum extent of its investment, either in the initial issue or on an ongoing basis shall be disclosed. A statement that the AMC shall not charge any fees on its investment in that scheme, in accordance with sub clause (3) of regulation 24 of the Regulations shall also be included;In case of assured return schemes, the offer document shall disclose:how many schemes have assured returns, their number and corpus size;a justification as to how the networth and liquidity position of the guarantor would be adequate to meet the shortfall in these schemes;details of the schemes which did not pay assured returns in the past and how the shortfall was met.A concise description of those significant investment policies or techniques that are not described above but which the AMC of the Mutual Fund has the intention of employing in the foreseeable future;Discussion of types of investments that will not constitute the scheme’s principal portfolio emphasis, and of related policies or practices, shall generally receive less emphasis in the offer document and may be limited to the information necessary to identifying the type of investment policy or practice;In case a Mutual Fund is investing in debt securities, disclose briefly relevant regulations governing investments in debt securities and specific risks involved in such investments and the conditions under which such investments could be made. When the scheme chooses to use certain rating criteria in its offer document disclosure, the scheme shall also disclose what would be the minimal rating which that fund would find acceptable according to the rating criteria it has chosen.In case a Mutual Fund is investing in government securities issued by Central or State Government, the offer document shall disclose the extent to which the scheme intends to invest its assets in GOI/State Government securities. In addition, the following information should also be included whether such securities are:è supported by the ability to borrow from the Treasury.supported only by sovereign guarantee or of the State Government.supported by GOI/State Government in some other way.The Portfolio Turnover policy, particularly for equity-oriented schemes shall be disclosed separately under the head "Portfolio Turnover" under the section Investment Objectives". In discussing investment techniques, the scheme shall briefly discuss in the offer document the probable effect of such techniques on the rate of total portfolio turnover of the scheme, if such effects are significant and also other consequences which will result from the higher portfolio turnover rate e.g. higher brokerage and transaction costs.(vii) Fundamental AttributesThe following Fundamental Attributes of the scheme, in terms of sub-regulation (15) of regulation 18 of the Regulations, shall be disclosed in the offer document under the head "Investment Objectives" with a statement to the effect that the ‘Fundamental Attributes’ cannot be changed without the consent of less than 75% of the unitholders.:(a) Type of scheme.(b) Investment Objective (objective, investment strategy, investment pattern including the tentative Equity/Debt/Money Market portfolio break-up with minimum and maximum asset allocation, while retaining the option to alter the asset allocation for a short term period on defensive considerations).(c) Terms of the issue (provisions such as listing, repurchase/redemption, fees, expenses, guarantee/safety net).IX. MANAGEMENT OF THE FUNDThis section shall describe the manner in which the Mutual Fund is managed. The disclosure shall include -(i) Identification of Asset Management Company and the name of the Fund Manager(s) who would be responsible for managing the scheme along with his qualifications, experience and background;(ii) Name and address of the Investor Relations Officer;.(iii) Briefly state for the Asset Management Company of the Mutual Fund:(a) The name and the address of the Asset Management Company and the names and addresses of the Directors on the Board of the AMC with a brief description of the experience of the AMC;(b) Disclosure of the date of entering the Investment Management Agreement.(c) A brief description of the Asset Management Company's compensation. If the fee is paid in some manner other than on the basis of average weekly net assets, briefly describe the basis of payment.(iv) Name and business experience/exposure of the key personnel of the AMC;(v) The identity of any other person who provides significant administrative or business management services and a brief description of the services provided and the compensation to be paid therefore;.(vi) The identity of the Custodian and a brief description of the services provided and the compensation to be paid therefore;(vii) The name and principal business address of the Registrars, Transfer Agents and the dividend paying agent. A statement to the effect that the Board of the Trustees and the AMC have ensured that the Registrar has adequate capacity to discharge responsibilities with regard to processing of applications and despatching unit certificates to unitholders within the time limit prescribed in the Regulations and also has sufficient capacity to handle investor complaints;(viii) Identification and name and address of the statutory auditor for the scheme;(ix) State the Securities and Exchange Board of India's Registration Numbers of the Custodian, Registrar and Transfer Agents and Collecting Bankers for the Mutual Fund. It should be ensured that none of the intermediaries are prohibited by SEBI from carrying on their activities.X. UNITS AND OFFER.a) Describe concisely the nature and the most significant attributes of the units being offered, including : (i) The minimum amount to be raised as per sub regulation (1) of regulation 35 of the Regulations. In case of assured return schemes, the maximum target amount to be raised by the Mutual Fund and refund beyond this amount shall also be disclosed.(ii) The circumstances under which refund may take place and the period within which refunds must be carried out (in accordance with sub clause (2) and (3) of regulation 35).(iii)A calendar indicating opening, closing, earliest closing, allotment and despatch of certificates.(iv) The period within which allotment and despatch of certificates will be completed and relevant Regulations in this regard alongwith a statement to the effect that an advertisement will be published in a newspaper soon after completion of allotment procedure; provided that if allotment is assured to all applicants, such disclosure may not be required.(v) If listing of units is envisaged, the names of specific stock exchanges where the application for listing of the units of the scheme has been made/proposed to be made.(vi) The policy regarding reissue of repurchased units, including the maximum extent, the manner of reissue, the entity (the scheme or the AMC) involved in the same are to be disclosed. Where box trading is permitted and resorted to, the policy of the AMC on such trading including the policy on the cancellation of units in the box and reissue of such units including pricing of such units shall be disclosed.(vii) In case there is likely to be an option to convert the close ended scheme into open ended, this option, along with the option to unitholders to redeem their units in full, shall be disclosed in the offer document.The sale/redemption at fixed pre-determined intervals including the maximum/minimum amount of sale/ redemption of units and the periodicity, amount, restrictions, days etc.Restrictions, if any, on the right to freely retain or dispose of such units.(x) Maturity period of the scheme and the circumstances under which the duration of the scheme may be extended alongwith a statement that the extension shall be in accordance with the Regulations.(xi) The circumstances under which the scheme shall be wound up (in accordance with Regulations).(xii) Procedures to be followed for transfer and transmission of units.XI. SALE OF UNITSDescribe briefly the manner in which the units of the scheme being offered under the scheme offer document may be purchased by the prospective investor. The descriptions should emphasise the procedures to be followed. Include :(b) List any special purchase plans or methods such as letters of intent, accumulation plans, dividend reinvestment plans, withdrawal plans, exchange privileges, redemption reinvestment plans etc; and identify each class of individuals or transactions to which such plans apply.(c) Any minimum initial or subsequent investment.(d) If the scheme offers any additional facility to the investor such as insurance premium etc. pursuant to a plan adopted under a scheme:(i) a brief description of the plan(s);(ii) a listing of the principal types of activities for which payments will be made;(iii) a statement of claims pending i.e. claims filed by the Mutual Fund with the insurance company - the number of cases and the aggregate amounts involved shall be disclosed.(e) Details of who can invest, sales price fixation and nomination facilities may also be included here.XII. DIVIDENDS AND DISTRIBUTIONS.Describe briefly the scheme’s policy with respect to dividends and distributions, including any option that unitholders may have as to the receipt of such dividends and distributions.XIII. INTER-SCHEME TRANSFERSThis section shall disclose the policy that the Mutual Fund has been following or proposes to follow with respect to inter-scheme transfers.XIV. ASSOCIATE TRANSACTIONSThe following disclosures summarising historical information for the last three fiscal years of the schemes of the Mutual Fund under the management of the Asset Management Company reflecting associate transactions and the manner in which such transactions affected the performance of schemes of the Mutual Fund should be made. The disclosures shall include any underwriting obligations undertaken by the schemes of the Mutual Fund with respect to issues of associate companies, devolvement if any, of such commitments, subscription by the schemes in issues lead managed by associate companies, total business given to associate brokers and the percentage of brokerage commission paid to them and any distribution of units performed by associate companies.This section shall also disclose :(a) the policy for investing in group companies of the sponsor of a Mutual Fund that is followed/to be followed by the Mutual Fund, including(i) the aggregate market value of investments in group companies of the Sponsor and asset Management Company by all the schemes of the Mutual Fund and its percentage of the aggregate net asset value of the Mutual Fund,(ii) the maximum investments in those companies proposed by the scheme to be launched.(b) in case any scheme of the Mutual Fund has invested more than 25% of its net assets in group companies, this shall be disclosed.(c) names of associates of the Sponsor or the Asset Management Company with which the Mutual Fund proposes to have dealings, transactions and those whose services may be used for marketing and distributing the scheme and the commissions that may be paid to them.XV. BORROWING BY THE MUTUAL FUNDThis section shall disclose the borrowing policy of the Mutual Fund under the scheme including the intent and purpose of borrowing. Such disclosure will also include the circumstances under which borrowing will be resorted to, regulatory limits on borrowing, expected sources of borrowing, and possible collateral used if any. The potential risk of loss presented to the AMC and its unitholders by these transactions shall also be addressed.XVI. STOCK LENDING BY THE MUTUAL FUNDThis section shall disclose the policy that the Mutual Fund shall follow for stock lending.XVII. NAV AND VALUATION OF ASSETS OF THE SCHEMEDescribe briefly the policies of the Mutual Fund with regard to frequency of disclosure of NAV and Valuation of Assets and properties of the scheme in accordance with SEBI (Mutual Funds) Regulations, 1996. Briefly describe the evaluation norms with regard to non traded securities in accordance with clause 2 of Eighth Schedule of regulation 47.XVIII. REDEMPTION OR REPURCHASE(a) Describe briefly the basis and the manner of determination of redemption and repurchase price of the units in terms of the Regulations.(b) Describe briefly all procedures for determining the redeeming and/or repurchase price of the units, any restrictions thereon, and any charges that may be attendant upon redemption and for terminal redemptions.(c) Describe briefly the statutory restrictions governing the redemption and repurchase prices of units.(d) Disclose the names of the centres where redemption can be effected.XIX. ACCOUNTING POLICIESThis section shall briefly disclose the accounting policies to be followed by the Mutual Fund for the scheme.XX. TAX TREATMENT OF INVESTMENTS IN MUTUAL FUNDSThis section shall disclose the various tax benefits that are available and the taxes that are charged to the investors in the schemes of Mutual Funds.XXI. INVESTORS' RIGHTS AND SERVICES.This section shall include the following:- The rights of the investors under the scheme.- Documents available for Inspection. These documents include Trust Deed, Investment Management Agreement, Custodian Agreement, Agreement with Registrars & Share Transfer Agents, MOA and AOA of the Trustee Company and Asset Management Company, SEBI (Mutual Funds) Regulations, 1996, Indian Trusts Act, 1882 and Consent of the Auditors, Legal Advisors.- Access to information : Publication of NAV, its computation and unit price.- Investor friendly services including names, addresses and telephone number of the contact person/grievances officer who would take care of investor queries and complaints.XXII. INVESTOR GRIEVANCES REDRESSAL MECHANISMDescribe briefly the investors' complaints history for the last three fiscal years of existing schemes and the redressal mechanism thereof. The offer document should include data updated as of 30 days prior to the launch of the scheme on the number of complaints received, redressed and pending with the Mutual Fund.XXIII. PENALTIES, PENDING LITIGATION OR PROCEEDINGS, FINDINGS OF INSPECTIONS OR INVESTIGATIONS FOR WHICH ACTION MAY HAVE BEEN TAKEN OR IS IN THE PROCESS OF BEING TAKEN BY ANY REGULATORY AUTHORITY1. All cases of penalties awarded by SEBI under the SEBI Act or any of its regulations against the Sponsor of the Mutual Fund or any company associated with the Sponsor in any capacity including the Asset Management Company, Trustee Company/Board of Trustees, or any of the directors or key personnel (specifically the fund managers) of the Asset Management Company and Trustee Company. The nature of the penalty must be disclosed. For Sponsor and its associates, other than the penalties as mentioned above, the penalties awarded by any financial regulatory body, including stock exchanges, for defaults in respect of shareholders, debentureholders and depositors shall also be disclosed. Additionally, penalties awarded for any economic offence and violation of any securities laws shall be disclosed.2. Any pending material litigation proceedings incidental to the business of the Mutual Fund to which the Sponsor of the Mutual Fund or any company associated with the Sponsor in any capacity including the AMC, Board of Trustees /Trustee Company or any of the directors or key personnel is a party. Any pending criminal cases against the Sponsor or any company associated with the Sponsor in any capacity including the AMC, Board of Trustees/Trustee Company or any of the directors or key personnel should also be disclosed separately.3. Any deficiency in the systems and operations of the Sponsor of the Mutual Fund or any company associated with the sponsor in any capacity including the AMC or the Trustee Company which SEBI has specifically advised to be disclosed in the offer document, or which has been notified by any other regulatory agency, shall be disclosed.4. Any enquiry/adjudication proceedings under the SEBI Act and the Regulations made thereunder, that are in progress against the Sponsor of the Mutual Fund or any company associated with the Sponsor in any capacity including the AMC, Board of Trustees/Trustee Company or any of the Directors or key personnel of the Asset Management Company shall be disclosed.For and on behalf of the Board of the Directors of the Asset Management Company of the Mutual FundPlace :Name :Date :Designation :http://www.sebi.gov.in/cms/sebi_data/commondocs/cirann2_h.html