Commingled Funds

A commingled fund is a pooled investment vehicle where assets from multiple accounts are combined into a single portfolio, managed collectively.
Commingled Fund
3 min

A commingled fund, often likened to a mutual fund, is a pooled investment vehicle where assets from multiple investors are aggregated to pursue a common investment strategy. These funds are typically managed by a professional fund manager who allocates the pooled resources across a variety of securities, aiming to achieve economies of scale and reduce individual investment costs. Investors benefit from diversified portfolios that might otherwise be inaccessible due to high entry costs, with their returns and risks shared proportionally among all participants. The regulation and oversight by authorities like the Securities and Exchange Board of India (SEBI) ensure transparency and protection for investors, making commingled funds a favoured choice for collective investment among Indian investors seeking to enhance their portfolio without the complexities of managing individual assets.

What is a commingled fund?

A commingled fund is a type of investment vehicle where assets from multiple investors are pooled together to be managed collectively by a professional fund manager. This arrangement allows individuals to participate in a broader range of investments with a diversified portfolio, which might be difficult to achieve individually due to higher costs or access limitations. These funds operate under a common investment strategy and aim to maximise returns by leveraging economies of scale in buying, selling, and managing investments. Typically found in retirement accounts and insurance company portfolios, commingled funds offer the benefits of mutual funds but are usually not available to the general public, thus they lack the same level of regulatory oversight as mutual funds.

Purpose of commingled funds

The primary purpose of commingled funds is to pool resources from multiple investors to access a broader range of investments and manage these assets collectively, thereby achieving economies of scale that reduce individual costs and enhance potential returns. These funds allow investors, especially those with smaller amounts of capital, such as individual retirees or small institutions, to participate in diversified portfolios that are professionally managed. This pooling method not only minimises the costs associated with investment transactions and management but also spreads out the risk across a larger asset base, offering a balance of risk and return that might not be feasible for individual investors. SIP investment allows for regular, smaller contributions over time, while lumpsum investment involves a one-time large investment; commingled funds pool money from multiple investors to invest collectively in various assets.

How does commingled funds work?

Below mentioned is the process which helps us understand how commingled funds work:

  • Pooling of resources: Commingled funds aggregate monetary contributions from multiple investors into a single investment pool.
  • Managed by professionals: A professional fund manager is responsible for managing the pooled investments.
  • Investment in diverse securities: The fund invests in a variety of securities, such as stocks, bonds, or real estate, enabling access to markets that might be otherwise unavailable to individual investors.
  • Collective goals and risk management: Investment decisions are made based on the collective goals and risk tolerance of all the investors in the fund.
  • Proportional returns: Returns from the investments are distributed to the investors proportionally to their contributions in the fund.
  • Advantages for smaller investors: This arrangement offers smaller investors the opportunity to participate in diversified portfolios and professional management without high entry barriers.

Advantages of commingled funds

Commingled funds, while beneficial for pooling resources and reducing costs, come with certain disadvantages. One major drawback is their lack of transparency compared to mutual funds, as they typically do not provide regular, detailed disclosures to investors. This can make it difficult for investors to assess the exact composition and performance of the fund’s assets. Additionally, commingled funds are generally not as strictly regulated as mutual funds, which may increase the risk of mismanagement or unethical practices by fund managers. Another disadvantage is the limited accessibility; these funds are often only available to institutional investors or through specific retirement plans, excluding smaller or individual investors from participating. Furthermore, because investments are pooled, individual investors have less control over their specific investment choices, relying entirely on the decisions of the fund manager.

Difference between commingled funds vs mutual funds

Aspect Commingled funds Mutual funds
Investor access Typically available to institutional investors and through retirement plans. Available to the general public, including individual investors.
Regulation Less regulated, providing fewer investor protections. Highly regulated with stringent investor protections.
Transparency Generally offer less transparency regarding fund compositions and operations. Provide high transparency with daily disclosures of NAV and periodic reporting.

Disadvantages of commingled fund

  • Limited transparency: Commingled funds often lack the level of detailed reporting and transparency seen in mutual funds, making it difficult for investors to fully understand the fund’s holdings and performance.
  • Reduced regulation: They are subject to fewer regulatory requirements compared to mutual funds, which might increase the risk of mismanagement or unethical practices.
  • Restricted accessibility: Generally available only to institutional investors or within certain retirement plans, commingled funds are not accessible to the general public or smaller individual investors.
  • Less control for investors: Investors in commingled funds have less control over individual investment choices as all decisions are made by the fund manager.
  • Potential for conflict of interest: The fund manager's decisions might not always align with the interests of all individual investors, leading to potential conflicts.
  • Liquidity constraints: Depending on the specific fund's structure, investors might face restrictions on when they can withdraw funds, affecting liquidity.

What is illegal commingling with example?

Illegal commingling occurs when funds meant to be kept separate are improperly mixed, often violating legal or regulatory requirements. This is commonly seen in professions where client funds are to be kept in trust; for example, attorneys must separate client monies from their firm's operational funds. When such funds are mixed, it can obscure the source of the funds, complicate accounting, and potentially facilitate misappropriation or misuse. In businesses, illegal commingling can also refer to using company funds for personal expenses, blurring the lines between corporate and personal finances and leading to serious legal consequences, including charges of fraud or embezzlement. This lack of separation not only undermines trust but also violates legal standards designed to protect stakeholder interests.


In summary, commingled funds serve as a practical investment option for pooling resources and accessing diversified portfolios with professional management. However, they come with certain drawbacks such as limited transparency and reduced individual control over investment choices, which may not suit all investors. While they offer cost efficiency and the potential for substantial returns, the lower level of regulation compared to mutual funds can raise concerns about fund management and investor protection. It's crucial for potential investors to weigh these aspects carefully against their personal or institutional investment goals and risk tolerance. Understanding both the advantages and the disadvantages of commingled funds helps in making informed decisions that align with one's financial strategies and long-term objectives.

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Frequently asked questions

What are examples of commingled funds?

Examples of commingled funds include pension funds, real estate investment trusts (REITs), and certain types of hedge funds. These funds pool money from multiple investors to invest collectively in various assets, aiming to achieve diversification and potentially higher returns.

What is the difference between fund of one and commingled fund?
Fund of one refers to a customised investment vehicle managed for a single investor, while a commingled fund pools assets from multiple investors. Fund of one offers personalised investment strategies, while commingled funds spread risk among participants, often with lower fees and minimum investment requirements.
Is a commingled fund a mutual fund?
Yes, a commingled fund is a type of mutual fund where investors' money is pooled together and invested in various securities by a professional fund manager. It differs from traditional mutual funds in that it typically caters to institutional investors and may offer customised investment strategies.
What is the difference between SMA and commingled fund?
SMA (Separately Managed Account) and commingled funds differ primarily in their structure and management approach. SMA involves individualised portfolio management for each investor, offering more customization and control. In contrast, commingled funds pool assets from multiple investors, providing diversification and potentially lower costs.
What does funds commingled mean?
Funds commingled refer to the pooling of assets from multiple sources into a single investment vehicle or account. This pooling allows for increased diversification and potentially lower costs due to economies of scale. Commingling funds can occur in various financial contexts, including mutual funds, pension funds, and investment trusts.
What is an example of commingling?
An example of commingling is when a mutual fund combines investments from multiple investors into a single pool of assets, which are then managed collectively by a professional fund manager. This pooling of resources allows investors to access diversified portfolios and potentially benefit from economies of scale in investment management.
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The information contained in this article is for general informational purposes only and does not constitute any financial advice. The content herein has been prepared by BFL on the basis of publicly available information, internal sources and other third-party sources believed to be reliable. However, BFL cannot guarantee the accuracy of such information, assure its completeness, or warrant such information will not be changed. 

This information should not be relied upon as the sole basis for any investment decisions. Hence, User is advised to independently exercise diligence by verifying complete information, including by consulting independent financial experts, if any, and the investor shall be the sole owner of the decision taken, if any, about suitability of the same.