Max Financial Services Ltd

NSE:MFSL

Earnings Call Analysis

Max Financial Services Earnings up, Growth Momentum Strong

Max Financial Services Limited (MFSL) reported consolidated revenue growth of 16% to INR 18,398 crores and a profit after tax (PAT) increase of 11% to INR 443 crores for the 9 months of FY 2024. The Assets Under Management (AUM) grew by 20% year-on-year, reaching INR 142,000 crores. Its proprietary channels are thriving with Agency, Direct, and E-commerce sectors expanding rapidly; Agency saw a 49% growth for the quarter and 28% over the 9-month period, while E-commerce soared by 85%. The company is buoyed by the positive results and remains devoted to its mission.

MFSL Earnings Call Key Highlights: Encouraging Growth and Strategic Online Presence

Max Financial Services Limited (MFSL) reported a solid growth trajectory during the 9 months of FY '24, with consolidated revenues (excluding investment income) of INR 18,398 crores, marking a 16% increase. The Profit After Tax (PAT) rose by 11% to INR 443 crores. A significant factor in these figures is the growth in renewal premiums for Max Life by 12% to INR 11,823 crores, while gross premiums escalated by 16% to INR 18,793 crores. The value of new business marginally dipped to INR 1,152 crores from INR 1,179 crores in the previous year; however, the new business margin for the third quarter stood strong at 27.2% and averaged 25.3% for the 9-month period. Operating Return on Embedded Value (RoEV) for the timeframe was INR 18.6 crores with a Policyholder OpEx to GWP ratio at 14.8%, and Max Life profits increased by 9% year-on-year to INR 411 crores. Assets under management swelled impressively by 20%, reaching INR 142,000 crores.

Increasing Market Share and Online Expansion

MFSL has placed strategic importance on online expansion within the past two years and has seen tangible success, notably in Unit Linked Insurance Plans (ULIPs) which are part of the company's online savings initiative. This strategic move has improved Max Life's overall positioning and currently ranks them second in the market across both protection and savings plans, where ULIPs play a pivotal role. Growth has also been seen in the affluent bank segment, with the company ensuring that consumer demand for unit linked designs is met, a segment that has experienced robust market support.

Focus on Comprehensive Growth and Distribution Channels

The earnings call revealed the company's comprehensive approach toward growth, with a focus on varying distribution channels. Throughout the quarter, particularly at Axis Bank, the company experienced a slowdown but anticipates a strong upturn not only in proprietary channels but also in Banca channels as the new quarter progresses. Proprietary channels such as Agency, Direct Sales, and E-commerce have collectively contributed to nearly 40% of total individual sales, showing growth upwards of 40%, with Agency identified as one of the fastest growing in the industry. Growth rates for Agency stood at 28% for the nine-month period, and even more impressive growth in E-commerce at 85%. The proprietary channel's dynamic growth highlights the company's successful expansion and distribution strategies.

Anticipated Strategy Adjustments Following Regulatory Changes

The executive team discussed potentially significant regulatory changes related to surrender value regulations. While the company remains optimistic about finding a balance between industry growth and customer outcomes, the exact impact on margins is still uncertain pending the final draft from regulators. Notably, the management expressed confidence in the regulatory process and seemed poised to adapt the company's strategies accordingly.

Retention of Efficient Commission Structure Amidst Expansion

The company also addressed concerns about commission expenses, which increased by 46% year-on-year according to the half-year public disclosure. However, the management clarified that despite investments in expanding distribution capacity—adding more branches and personnel—the overall cost of acquisition has remained consistent and is improving. The commission expenses aligned with business growth and the apparent increase is perceived as a part of the company's strategic realignment efforts.

Earnings Call Transcript 2024-Q3

[Operator]

Ladies and gentlemen, good day, and welcome to Max Financial Services Limited Q3 and 9 Months FY '24 Earnings Conference Call. [Operator Instructions] Please note that this conference is being recorded.

I now hand the conference over to Mr. Amrit Singh, Chief Financial Officer, Max Financial Services Limited and Max Life Insurance Company Limited. Thank you, and over to you, sir.

[Amrit Singh, executive]

Good morning, everyone, and a warm welcome to the earnings call of Max Financial Services for the 9 months ended December 2023. We made our results available on our website and the stock exchanges last evening. And today, I'm joined by Prashant Tripathy, MD and CEO of Max Life Insurance. I will request Prashant to share with -- the key developments of the quarter and insights into the 9 months results. Over to you, Prashant.

[Prashant Tripathy, executive]

Thank you, Amrit. Good morning, everyone. Let me first begin by giving you a quick update on the Axis transaction. As you know, this transaction was filed for approval with IRDAI. So we are very happy and pleased to inform that IRDAI, late last evening, has approved the capital infusion by Axis Bank into Max Life for an aggregate investment of INR 1,612 crores, subject to approval of CCI. The CCI approval is expected, and we will conclude this transaction over the next 90 days.

We would like to further submit that PFRDA has already approved the proposed change in shareholding pattern of the company pertaining to the infusion of capital by Axis bank into Max Life. So from our perspective, subject to CCI approval, the decks are clear and that infusion will happen in due course into Max Life Insurance.

Moving on to the business update, focusing on key strategic areas. Let me first begin by talking about the growth. We always have been talking about predictable, sustainable growth. So let me very quickly share with you the updates on how we are building the solution and growth story.

For quarter 3, proprietary channels grew quite exceptionally, and that is aligned to last few quarters of growth. In quarter 3, our individual adjusted first year premium surged by 18%, outpacing the private sector 9% growth. We are double of the growth rate of the private industry. We are also pleased that -- to share that we regained our rank #4 on the basis of individual adjusted first year premium basis in private industry, reflecting consistent market share gains quarter-on-quarter.

This growth can be attributed to 18% rise in the number of policies. So the growth is coming from a number of policies and not just ticket size growth, primarily driven by a robust 47% growth in proprietary channels. This marks the third consecutive quarter of exceptional growth by proprietary channels.

In the online channel, we maintained leadership in the protection segment and have grown remarkably in savings segment as well. Online channels grew by 43% in quarter 3, showcasing our ability to rapidly scale up digital business. Offline proprietary channels recorded a 47% growth with the agency channel experiencing notable 73% increase in recruitment, making it the fastest growing agencies in the industry in quarter 3.

Direct customer acquisition channels also improved efficiency and expanded into new verticals contributing significantly to overall growth. Additionally, our Group Credit Life business has also grown by almost 120% for the quarter and overall APE growth, hence, is 19% for quarter 3. For the 9-month period, our APE grew by 23%, and I'm reasonably sure that amongst the top players, this is the fastest growing performance on APE, primarily driven by the success of power prop channels. Bancassurance channels grew by 12%. It is noteworthy that we've maintained our counter share in our key banking partnerships, namely Axis Bank as well as YES Bank.

As you know, we have been expanding our distribution reach, and during the quarter, we expanded our distribution by opening a representative office in Dubai as well. This move extends our reach to the Gulf region, enhances brand awareness and ensures the seamless approach to our NRI customers where we have experienced consistent growth over the last 4 years.

Additionally, we successfully onboarded 8 new partners in both Retail and Group relationships in the quarter, and that makes it almost 26 partnerships done in the first 9 months. We anticipate these partnerships to become meaningful in the next financial year. Overall, our distribution strategy is aligned with our growth projections for the year, and we have high confidence in sustaining our current momentum in the coming months.

Talking about product, which is another strategic lever that we focus on. Our strategic commitment to become one of the premier industry product companies drives us to continually enhance our product offerings. In pursuit of a balanced approach that considers both shareholder outcomes and customer needs, we introduced several new offerings for the year, contributing to a 9-month margin of 25.3%. In quarter 3, specifically, our margin stands at 27.2%, which is in the corridor of expectations that we had shared with you at the beginning of the year.

Unlike the industry trends, the reduction in margin is something, which was a part of our strategic plan, and we have been consistently sharing that we will focus on our growth, and we will expect the margins to be in the range of about 26%, 27%. Exhibiting sequential improvement in each quarter, you would have noticed that our margin has been going up from quarter 1 to quarter 2 to quarter 3.

This margin profile was reinforced by product interventions, mainly revitalizing of our flagship SWAG product. The incorporation of an immediate income design led to an increase in non-par share from 24% in Quarter 2 to 30% in Quarter 3 in individual APE. Furthermore, our focus on product segments of our choice is evident in the growth of our Protection, Health, Annuity segment, which constitutes now 16% of total APE in the 9 months of FY '24.

Quarter 3 performance reflects an 82% growth in Protection & Health, indicating robust demand in this segment supported by innovative launches. In quarter 3, we have launched a new term offering exclusively designed for the affluent category, introducing differentiated underwriting practices based on customer segments. And our Health segment launch named SEWA introduced in the last quarter represents almost a fifth of total protection sales in quarter 3. SEWA integrates Health, Protection, Savings and holistic wellness benefits, addressing evolving consumer needs.

Our focus on retirement has driven a 52% growth in the annuity segment over the 9-month period despite a transitory decline of 18% in quarter 3 due to lower contribution predominantly from Banca channel. We also actively participated in the growing unit linked insurance plan market, reflecting customer preferences in the rising equity market. ULIP constituted a 36% mix in quarter 3 individual APE, marking a 12% increase year-on-year increase in the mix.

As we approach the end of the year, we continue to expand our product suite with the launch of a new retirement offering, SWAG pension targeting customized needs, which has recently been launched in quarter 4. Additionally, we have plans for a new non-participating products tailored for the 5 lakh plus segment to offset the base effect of last year.

Talking about the third lever, which is our customer obsession across the value chain. Max Life has built a customer-centric culture by integrating customer obsession across each stage of the value chain. This culture goes beyond transactions and policies, creating a positive brand perception in the minds of our customers.

This is evident in our consistently improving brand consideration score, positioning us amongst the top brands in the sector. Our exceptional claims paid ratio of 99.51 in FY '23 served as evidence of our unwavering commitment to our customers. By prioritizing the needs, experiences and satisfaction of policyholders, we have built long-term relationships and enhanced customer loyalty, which is measured through Net Promoter Score. We are delighted to observe 4-point enhancements in our overall company Net Promoter Score rising from 52 in March '23 to 56 in December '23.

I would like to clarify that the Net Promoter Score methodology that this company follows is a combination of relationship NPS as well as transaction NPS. And all the transaction NPS, our scores are up upwards of 70%. Furthermore, Max Life proudly maintains its position as a market leader in terms of 13th month persistency for a number of policies. Specifically, our 13th month persistency of regular limited pay premium stood at 85, and our 61st month persistency was at 58 for the period ending December '23.

This achievement underscores the trust of our policyholders place in Max Life. And across all cohorts, we have seen consistent improvement in our persistency scores, either in terms of number of policies or in terms of premium.

Digitization of efficiency and intelligence is the fourth lever, and I'm very happy to share that our commitment to technology permeates various facets of our operations, encompassing product launches, prospecting, onboarding and customer service. Embracing agile methodologies, we have achieved operational excellence and heightened efficiency.

For seamless onboarding, we have introduced a dedicated help section with options, including WhatsApp, Web Chat and call. Our revamped journeys now feature Auto Debit, a vernacular WhatsApp bot with native payment journeys and customer servicing in 6 languages. Additionally, we have onboarded 2 new account aggregators and financial information providers.

In quarter 3, we implemented marketing campaigns utilizing generative AI, spanning channel marketing, personalized customer interactions and location-based campaigns on social media. These campaigns not only facilitated hyper seasonalized communication, but also significantly reduced development times. These strategic initiatives empower us to operate more efficiently, make data-driven decisions, enhance customer experiences and adapt to the evolving business landscape.

In summary, our effort to fuel growth are yielding results, and the entire team at Max Life Insurance is very excited about the prospects beyond this growth. This current trajectory instills confidence, and we are very hopeful that we'll be finishing this year with the same strength as we have run in the last 9 months.

I'm now going to hand it over to Amrit who will provide an update on the financial outcome.

[Amrit Singh, executive]

Thank you, Prashant. Moving on to the key financial metric. For MFSL consolidated revenues excluded investment income, stood at INR 18,398 crores, a growth of 16% in 9 months FY '24. The consolidated PAT for MFSL was INR 443 crores, a growth of 11%. The renewal premium for Max Life grew by 12% to INR 11,823 crores. Gross premiums grew by 16% to INR 18,793 crores.

Value of new business, over the 9-month period, stands at INR 1,152 crores versus INR 1,179 crores for last year. The new business margin for quarter 3, as Prashant mentioned, stands at 27.2%, and for 9-month period, now stands at 25.3%. The embedded value as at 30th December 2023 is now INR 18,709 crores. Operating RoEV in 9 months FY '24 is INR 18.6 crores. Although we only perform detailed EV movement analysis half yearly and report basis that, but at our estimates level, the operating ROE for 9 month FY '24 reflects negligible operating variance.

Policyholder OpEx to GWP ratio is at 14.8%. Max Life profits for 9 months stand at INR 411 crores, an improvement of 9% Y-o-Y. Our solvency ratio now at the end of December '23 is at 179%. With the additional infusion of capital, this may get added by 35% more. The assets under management on 31st December 2023, are at INR 142,000 crores and year-on-year growth of 20%.

We continue to remain committed to our purpose of inspiring people to increase the value of their life. And we'll now be happy to take any questions that you may have. And we'll hand over to the moderator to open the question -- the floor for Q&A.

[Operator]

[Operator Instructions] The first question is from the line of Avinash Singh from Emkay Global.

[Avinash Singh, analyst]

Congratulations to this IRDAI approval. Prashant, the first question on this margin. Of course, I mean, there's so many moving parts, including product mix changes and all. Just wanted to understand, from the perspective that now that Axis deal has happened at a different pricing than what you call -- envisaged 4 years back, and of course, in turn, there will be -- and also [indiscernible] and have come, so of course, there will be some change in modality to pay out and all.

So now is this -- your 9 months or this Q3 margins reflective of that kind of [indiscernible] structure? Or going forward, there could be something more coming or some place on margin from that? So that's number one.

And second, now with that Axis Bank just take a sale approval done nearly, I mean that 1% additional you can take. So what sort of plan ahead for the structure simplification, particularly given that if I see on the [indiscernible] slide, final structure is still suggesting that Max Life under Max Financial, so I mean, what is sort of your -- now plan ahead to move with this Max Financial, Max Life merger? And what are the alternatives in case, I mean, because I mean you would have several alternatives in mind how to collapse their structure, sir?

[Prashant Tripathy, executive]

Avinash, very good morning, and thank you always for your interest in our organization. Let me answer the second question first. As you would appreciate, we have followed a process of increasing the overall stake of Axis Bank in Max Life Insurance. And with this approval, Axis Bank stake will go up to about 19.02%. We are anticipating in that in near term, we will take the overall equity to about 20%. And as we have discussed, of course, the long-term impact is somehow figure out a way of collapsing both the structures.

We don't know what will be the exact structure, but that's something which we will try to explore and will work on. We remain committed to that. But of course, this is subject to all kind of approvals, regulatory approvals, but we are optimistic that we will figure out a way of doing. Internally, we have discussed a few approaches, and we will take one of them.

Talking about your first one. Of course, margin is definitely a combination of many moving pieces, products, expenses, investment in proprietary channels. And we have been sharing since the year began, that there will be a bias to drive growth in the business and gain market share, which is very important to us. And we have attempted that. So we made investments in opening new offices. We made investments in expansion. We made investment in distribution builders. And of course, this year is rather unique in terms of product mix.

If we compare with respect to last year, Avinash, last year in this quarter, we had launched a big non-par design. And you noticed that last year, this quarter, our margin was 39%. And I always maintain that this margin is unsustainable. So year-on-year basis, you will see some impact. However, the margin that we are achieving is consistent with our expectations.

I would like to confirm to you that the Axis Bank transaction doesn't mean that we need to pay any more compensation either in the past or in future, I think. It is going to be BAU from our perspective. So we are very hopeful that as our prop channels mature, as -- and as you know, there is definitely a leverage that you get on your proprietary channels as they mature, the margin expectations could be higher from them. We will be able to remain in the corridor of margins that we were talking about.

The one thing that I will also say is competition is intense. Overall, everybody is trying to ramp up and grow. So once you make the impact or you make the effort to increase the margin, competition definitely is into it. So all things being equal, I think we just need to navigate and remain in the corridor that I have always spoken about.

[Avinash Singh, analyst]

Yes. So what I get is like, I mean, yes, this Axis transaction, there's not sort of a changes materially the trajectory. I mean it is like more into business as usual. No sort of adjustments.

One quick, if I can. If I see your underwriting profit development, this year, the back book surplus generation has been slowly -- I mean the growth had been slow. So I mean, if you can just help, I mean, of course, new business strain, if I see in this quarter, I think that probably to do with maybe ULIP sales being higher in all. But back book surplus this year has been sort of emerging at a slower rate. So any sort of explanation there?

[Amrit Singh, executive]

Avinash, I'll take this question. This is Amrit here. Actually, back book surplus is a play of multiple things. It's -- I mean, assuming a very predictive growth number to it is always -- it has some inefficiency in estimations because back book surplus is getting generated about what kind of policies we have written, what duration of policies we have written. And it's a reflection of all of those things kind of put together.

And our back book surplus generation is in line with how and what the nature of the policies have been written. So there is nothing in that which has been adjusted or any operating variance that's kind of evident there. There's nothing like that. It is pure play back book profit generation. It is just that the nature of the books, when it changes, it will have some impact on the shape of back book surplus creation.

[Operator]

The next question is from the line of Sanketh Godha from Avendus Spark.

[Sanketh Godha, analyst]

On margin, typically, you used to give the Walk, how it has evolved from last year to current year. This is -- if you can give a broader Walk, how the margins are more whether -- how much it was contributed by changing product mix and whether you have seen any product level margin compression? And given we have invested into so many channels, how much OpEx has also played a role to drag the margin? So if you can give a little more clarity on how the Walk has played will be much useful. And how you expect among these Walk numbers to play out a subsequent year and see margins to play out? That's my first question.

And second question is you alluded to the point that you have multiple options to collect the structure. Considering all the options you have in your mind, likely timeline you have in your mind to collapse the structure, maybe if we take another 12 or 24 months to do so that people become direct shareholders in Max Life. Those are 2 questions that I have, one question on data keeping, which I'll ask after you answer this.

[Prashant Tripathy, executive]

So Amrit will come back on question #1. Let me answer question #2. I -- at this point in time, I can only respond in terms of our intent. Our intent is to do it quicker. However, as you would understand, there are many moving pieces, approvals, and we will internally review once our step of increasing the equity of Axis Bank in Max Life Insurance is concluded. So very hard for me to commit any timeline at this point in time. But again, I will say management bias is do it earlier than later. Amrit, on your first -- his first question.

[Amrit Singh, executive]

So, Sanketh, thank you for the question. On the nature of that impact over a 9-month period, the dominant reason for that is to do with business and product mix, actually. And when I say business, it's the channel, the product that they're writing and intrinsically the products mix contribution in overall business.

So that is the dominant reason for the reduction. As you have seen, the non-par has come off, ULIPs have increased, those kind of plays are happening. At the margin, specifically, in ULIP, we have seen some shrinkage at an overall level. That's largely again due to a choice of a particular product variant that we have sold in channels. And that is the dominant narrative around how margins have moved.

[Sanketh Godha, analyst]

But in non-par, Amrit, you have not seeing any product-level margin compression given the IRR [indiscernible] market have moved. How are you seeing market...

[Amrit Singh, executive]

I've repeated many times over. There's that actually, if you try to compare apple to apple, obviously, competitive forces are much higher. So the same -- exactly same variant with its nature of design of the product, definitely comes under margin pressure as time progresses. But there are counter strategies that we'll keep deploying wherein introduction of new designs, tweaking the PPT, premium payment term and policy terms, as levers we'll keep using.

And those are the things that we have to leverage and use to ensure that the margins are protected. But if you can ask me a 5 Pay 10 versus 5 Pay 10, yes, definitely, there has been margin pressures on these variants, largely because of competitive actions.

[Sanketh Godha, analyst]

Got it. And just on the ULIP point, what you mentioned, which you did that product online in a big way last quarter. Have you continued to sell that particular product in the same fashion? That's the reason -- ULIP or it's predominantly because of the second quarter phenomena, the ULIP -- you have seen that there is a margin compression?

[Amrit Singh, executive]

So ULIP, there are 2 places where Unit linked designs are doing very well for us. As that's part of our stated strategy, we had indicated 2 years back that we will enter into the online savings space as well. And we have done a series of action to enter into that particular space, and we have actually got a strong success out of it. Our overall positioning with respect to online space, we have improved. And we are now ranked 2 player on 9-month basis across protection and savings design, and ULIP played a big role in the -- on the savings franchise there.

The other area where unit links have done well for us is in the affluent segment of banks where the category, because of overall market help, is in demand. And we are ensuring that those consumer demands are being met. We don't want to be in a situation that we try to artificially reduce any of these things. I think if the consumer is demanding for it and is expecting. It is on to us to ensure that these products are made available to them.

[Sanketh Godha, analyst]

One more thing just on credit life. Honestly, we are very practical with respect to credit life in the past. Now the growth has been pretty strong. So there is a particular change in the view -- in strategy with respect to credit life that we are managing to deliver that kind of a growth? I just wanted to understand that point.

[Amrit Singh, executive]

Sorry. So at the start of the year, Sanketh, we had indicated that on Group Credit Life, we are now looking at this opportunity very favorably in a more strategic manner and are trying to build our portfolio. And we started -- we have been reporting every quarter many successes and wins that we are getting with respect to partners addition into the Group Credit Life portfolio.

And that is what is helping us succeed in this segment. You will see Max Life focus now remain on this particular category, which serves an important protection need to the consumer too. And hence, these are trends which will continue in its shape and form even in the future.

[Sanketh Godha, analyst]

So this is largely non-MFI, Amrit, or MFI?

[Amrit Singh, executive]

It's a mix of both MFI, non-MFIs. There are different sorts of partners that we have.

[Sanketh Godha, analyst]

Okay. Okay. And lastly, if you can on data keeping. Exact individual APE number, which I think you have not disclosed this time in 9 months number? And how much economic variance contributed to EV?

[Amrit Singh, executive]

So total individual APE?

[Sanketh Godha, analyst]

Yes, I think you have adjusted -- [indiscernible] was disclosed but not exact -- maybe it will be not materially different, but if you can spell out the number to give.

[Amrit Singh, executive]

Yes, just give me one second. It's INR 4,451 crores, individual APE.

[Sanketh Godha, analyst]

Perfect. And economic variance number in the EV?

[Amrit Singh, executive]

So economic variance, we have -- Operating RoEV is 18.6%. And the rest, you can kind of compute as the non-operating variance.

[Operator]

The next question is from the line of Madhukar Ladha from Nuvama Wealth.

[Madhukar Ladha, analyst]

Just a couple of questions from my side. First, when I look at your new business strain for the quarter has gone up significantly. And the product mix is moved more pace from non-PAR and more in favor of ULIP. So what exactly is guiding that?

Because simultaneously, I'm also observing that commissions as a percentage of gross premiums have also gone up significantly in the quarter. So some -- are we paying out higher there with channels? Some color on that will be helpful.

The -- the other thing, on individual protection, while on a year-over-year basis, it's grown quite well. On a Q-o-Q basis, there seems to be some softness. So what's again driving that? And what's our outlook on that piece of the business?

And final one question on -- again, if you look at the Banca channel, the growth for this quarter on a year-over-year basis is just about 3% or right, 3.4% odd. So I know you mentioned that you've maintained your counter shares at this time. But what's really happening out there because we see some of the other banks, the growth has been there. So what's going wrong in that channel? Is it focused? There's also new partners that are getting added over there. So Yes. Those would be my key questions.

[Amrit Singh, executive]

Yes. I'll go -- there are 4 questions, I think you have asked. I'll go one by one. The first one you asked on why this strain is higher. The first predominant reason of strain being higher is when you do higher new business volume, the strain is higher. That's an absolute number actually.

And the second is the lines of business, which have higher strain, for example, unit linked design is causing that strain to be higher. So there is nothing beyond that for in the trend that you are seeing for yourselves.

With respect to your commission question, I'd like to maintain that overall cost of acquisition, we have remained consistent, and there is no change in the overall cost of acquisitions.

In individual protection, I don't know where that is coming from because we are seeing quarter-on-quarter improvement on Protection too. And there is a growth from Quarter 2 to Quarter 3 of around 8% that we are seeing for ourselves. So we are seeing an improvement in -- even on quarterly numbers, the protection improvement.

[Prashant Tripathy, executive]

And I think the last one, I'll take, Madhukar. In terms of growth at Banca, I think the observation is valid. And overall, if you look at industry segments, all large banks, who are not predominantly unit linked sellers, and they have a bias towards maintaining a balanced product mix. The growth has been tapered. I mean, if you look at overall growth, it is in single digits.

For us, quarter 3, especially at Axis bank was a bit slower. However, there are things that we've deployed. The January numbers are not out yet, but suffices to say that you will see a strong pick up, not just in our proprietary channel, but also in Banca channels as the new quarter begins.

[Operator]

[Operator Instructions] The next question is from the line of Shreya Shivani from CLSA.

[Shreya Shivani, analyst]

Congratulations on a good set of numbers. I have 2 questions. First is on the surrender value regulation. If you guys can help us understand any latest updates. What will be the impact on margins for us? Any timelines, that will be useful.

Second is, again, going back to the commission question, Amrit. You mentioned that your cost position has not changed. But as per 1H public disclosure, commission expense is up 46% year-on-year. So this is -- it's not as high as it is for some of our peers. But if you can help us understand which channels or from where this commission expense has grown at this rate given that this is the first year of commission...

[Prashant Tripathy, executive]

So on surrender, let me just update you quickly that there is a concentrative process that is currently going on between the regulator and industry. And I'm very optimistic that when the final draft comes, it will balance out all the elements of industry growth customer outcomes, et cetera. So I'm very optimistic that it will be an outcome that will kind of work for all the stakeholders.

At this point in time, very hard for me to say the exact nature in the impact because unless we see the draft, it is very hard -- or final outcome, it is very hard to estimate. But at the same time, suffices to say that I have extreme confidence in the regulatory action. And I think overall balance will be maintained, and there is a very concentrative process which is currently undergoing. Amrit?

[Amrit Singh, executive]

The commission, Shreya, I'll just kind of go back to the cost of acquisition as a frame. You are aware that we have invested in new distribution capacity, which is whether addition of more branches and more number of people. Keeping that cost aside for a moment, I'm reiterating that the cost -- overall cost of acquisition color is actually consistent and only improving.

So what you are seeing and witnessing is a bit of a realignment that is happening. And the way you should read and you made a comment around peers as well, you should read that with line with business growth as well. So adjusted for business growth, I believe that some of these numbers are in line with how the commissions are set up in the system.

[Operator]

[Operator Instructions] The next question is from the line of Gaurav Jain from ICICI Prudential Mutual Fund.

[Gaurav Jain, analyst]

Congrats on a good set of numbers and the deal moving forward. I have a question on the distribution side. If you can help us understand the proprietary channel a little better in terms of how much of this is agency and how much of this is Agency and how much of this is Direct Retail or Direct Group?

Because from 9-month FY '22 to 9-months FY '24, Banca as a channel, has remained broadly flattish with 10% growth in --10% growth in '23 and 10% growth in '24, but it is proprietary that has really fired well for us. So what is the real composition of this in terms of different channels? And where are you seeing the real growth here?

[Prashant Tripathy, executive]

So basically, proprietary for us is a combination of 3 things: Agency, Direct Sales, as well as E-commerce. And as you can see, these 3 elements, as a percentage of our total individual sales, have been growing this year for the first 9 months. It is close to about 40%. And the balance 60% is partnership.

I would like to confirm to you that all the 3 Agency, Direct as well as E-commerce are growing at a phenomenal pace for us. It's -- and all of them are upwards of 40%, all of them. So if I were to break the 40% of total that is coming from prop, about half of that is -- about half of that is Agency, and the balance half will be Direct and E-commerce. That's the overall math.

And there's great work happening in all 3 areas. Everywhere, we are gaining market share. We are gaining -- we are growing faster than industry. And our Agency is perhaps one of the fastest, the top 2 fastest in the industry right now. Our Direct is one of the fastest. Our E-commerce is one of the fastest. All the 3 elements are firing really well for us.

[Gaurav Jain, analyst]

For the 9-months, what is the growth rate in Agency, if you can just tell?

[Prashant Tripathy, executive]

I think the growth rate in Agency on APE basis for the 9-months will be...

[Amrit Singh, executive]

28%.

[Prashant Tripathy, executive]

No. The agency growth rate?

[Amrit Singh, executive]

28%.

[Prashant Tripathy, executive]

It's 28%.

[Gaurav Jain, analyst]

Understood. Okay.

[Amrit Singh, executive]

For quarter-to-quarter, it is 49%, and we have kind of provided that slide. Agency grew 49% for the quarter. Our Direct channel grew 41%, and E-commerce grew 43%. For the 9-month period, Agency has grown 28%. Direct channel, which is our own team on the ground, 48%. And then E-commerce has grown 85%. So those kind of numbers is what these channels have clocked.

[Operator]

Ladies and gentlemen, that was the last question. I would now like to hand the conference over to the management for closing comments. Over to you, sir.

[Amrit Singh, executive]

Sorry. Was that the last question? Actually, we missed this.

[Operator]

I'm sorry, sir. I'll repeat it for you. It was the last question for today. I would now like to hand the conference over to the management for closing comments. Over to you, sir.

[Amrit Singh, executive]

Thanks a lot. Thank you. Thank you, everyone, for your interest in Max Financial Services and for being on this particular call. We continue to look forward for such more interactions. And thank you once again. Goodbye.

[Operator]

Thank you, members of the management. Ladies and gentlemen, on behalf of Max Financial Services Limited, that concludes this conference. We thank you for joining us, and you may now disconnect your lines. Thank you.