It was a shock to pretty much everyone when the government changed tax rules for debt mutual funds in the 2023 budget.
AMCs have since then been trying to adapt by shoehorning “debt-like” funds into unrelated categories. For example, Edelweiss has a multi-asset fund that is offered as a debt fund replacement (but with better taxation). Parag Parikh has launched a similar fund in the dynamic asset allocation category (the “balanced advantage” category).
I was wondering if ULIPs—the infamous Unit Linked Insurance Policies—can be used for debt investment. An investor can invest up to ₹2,50,000 every year into ULIPs and get tax free returns. There is a lock-in period of 5 years, but the funds become redeemable after 5 years irrespective of how long the policy term is. Since the returns are tax free, ULIP debt investments can be attractive even if they earn 1 or 2% less return than an average debt mutual fund.
That’s the theory. But we need to check if that theory holds any water.
The story of my ULIP investment
I started a ULIP 2 years ago to help a bank employee meet their sales target. I had been thinking of repurposing this ULIP as a pure debt investment. But I didn’t pull the trigger as I wasn’t 100% sure. Coincidentally, I received the annual statement for this policy last week, and it was eye opening.
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2022 statement for my ULIP (click to enlarge) |
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2023 statement for my ULIP (click to enlarge) |
If you can’t see the issue in these statements, you’re not alone. Most people can’t spot this.
There are 2 kinds of deduction in the statements.
- “Mortality Charge” is what the insurer is charging for providing life cover. This is tiny because pure life insurance is very cheap. This charge can be ignored.
- The other deduction, called “Allocation Charge”, is more sinister. This is for charges like policy administration, agent commission, etc. In 2022, when this policy started, they deducted 12% of the premium as the allocation charge. In 2023, this deduction was 8% of the premium.
Let’s look at the impact of allocation charges more carefully. I paid ₹60,000 as the premium in 2022. Of this, ₹7,200 was deducted upfront for fees and commissions, and only the remaining ₹52,800 was invested. To break even by the end of the first year—i.e. for the fund value to be ₹60,000 by the end of the first year—this investment needed to grow by 14%! Making such a return is no easy feat, so it is no surprise that the policy value never touched ₹60,000 throughout the first year.
I paid the next ₹60,000 premium by the end of the first year. Again, ₹4,800 was deducted from this money and only ₹55,200 was invested causing the investment to stay underwater for most of the second year too.
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My ULIP’s fund value over the first 22 months |
A policy that started in March 2022 has remained underwater till September 2023! This was the reality for a 70:30 portfolio. It took the 2023 equity rally and a big 70% equity exposure to get this investment to break even. Since debt returns are subdued, ULIPs with 100% debt portfolio may even stay underwater for 7+ years.
My hypothesis is still correct: if pure debt ULIPs make 2% less return than average debt mutual funds, ULIPs will be an attractive option. But my assumption that ULIP returns will fall short only by 2% is way off the mark.
Is there a way to salvage ULIPs that are already bought?
What follows is an untested idea. Say, I let my ULIP stay as a equity+debt blend for the first 7 years or so. Hopefully, the portfolio grows to a reasonable size. After this, I can switch the entire portfolio to debt. Given there is no allocation charge after the first 5 years, this can probably be considered a reasonable debt investment. Fresh investments won’t be possible, but partial and full withdrawals will be available.
If you already have a ULIP, this may be a way to salvage the situation. But don’t buy a new ULIP only to get tax-free debt return. ULIPs make a lot of money for insurance companies and agents. Investors have a slim chance of making money through ULIPs.