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NCREIF and CREFC Release Fourth Quarter 2024 Debt Fund Aggregate Report

April 17, 2025

• Is a project by the industry for the industry that has been in the works for several years with input from NCREIF, CREFC and its members, and data contributing managers, investors, and consultants. 
• Is anticipated to be published quarterly. Results will never reveal individual fund performance. 
• Is NOT a BENCHMARK, yet, but is a major step toward the goal of creating a more focused index/benchmark of funds that meets certain investment inclusion criteria (which are to be determined)
• Will enhance investors’ interest and understanding of the rewards and risks of private real estate debt funds, which may lead to increased allocations to debt, benefiting managers, investors, and commercial real estate finance industry professionals. 
• Contains funds with various strategies and styles ranging from core to value-add, as reported by the managers. The performance metric is a time-weighted return. The returns are equally weighted across the funds since the aggregate contains a few large funds that would dominate the results if it they were value weighted. 

Aggregate Furthers CREFC’s and NCREIF’s Missions

• CREFC is the trade association for the commercial real estate finance industry. Member firms include balance sheet and securitized lenders, loan and bond investors, private equity firms, servicers and rating agencies, among others. 
• Our industry plays a critical role in the financing of office buildings, industrial and warehouse properties, multifamily housing, retail facilities, hotels, and other types of commercial real estate that help form the backbone of the American economy.
• CREFC promotes liquidity, transparency, and efficiency in the commercial real estate finance markets. It does this by acting as a legislative and regulatory advocate for the industry, serving a vital role in setting market standards and best practices, providing education for market participants, and publishing the well tracked CREFC Board of Governors Sentiment Index. Our most recent collaborative effort is working with our friends at NCREIF to develop the NCREIF/CREFC Open End Debt Fund Aggregate.
• CREFC hosts major industry conferences that bring together market participants from leading commercial real estate finance companies and organizations. Complementing these major conferences are regular After-Work Seminars and regional conferences held throughout the year on an annual basis

About NCREIF

• NCREIF is the leading provider of investment performance indices and transparent data for US commercial properties. Data Contributor Members submit data to NCREIF for inclusion in its various indices and data products. NCREIF is a member-driven, not-for-profit association that improves private real estate investment industry knowledge by providing transparent and consistent data, performance measurement, analytics, standards, and education.
• NCREIF serves the institutional real estate investment community as a non-partisan collector, validator, aggregator, converter and disseminator of commercial real estate performance and benchmarking information. Our members include investment managers, investors, consultants, appraisers, academics, researchers and other professionals in the real estate investment management industry.
• NCREIF is a data service provider that meets its members' and the investment and academic community's need for high quality, transparent, timely and accurate commercial real estate data, performance measurement and benchmarking indices, investment analysis, reporting standards, research, education and peer group interaction 

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First 100 Days: Regulatory Update

April 15, 2025

President Donald Trump issued a Presidential Memo (Directing the Repeal of Unlawful Regulations) on April 9, allowing agency heads to “finalize rules without notice and comment, where doing so is consistent with the ‘good cause’ exception in the Administrative Procedure Act.” 

• The memo seems to assume that the 2024 Loper Bright ruling applies retroactively, although as reported in previous CREFC Policy and Capital Markets Briefings, the Supreme Court explicitly stated that the decision was forward-looking.
• Loper Bright overturned what had been known as the “Chevron Doctrine,” which directed courts to defer to agency interpretations of ambiguous federal laws and regulations.

What they're saying: Treasury Secretary Scott Bessent, in a speech to the American Bankers Association on the same day as the issuance of the the memo, said that the Treasury now “intends to play a greater role in bank regulation” and ensure “that the financial services regulators fulfill their statutory mandates consistent with [Trump’s] priorities.”

Bessent also stressed the need to modernize the bank capital regime. Arguing that the Biden-era proposed Basel Endgame was not the right starting point for this modernization effort, Bessent stated:

• Former Securities and Exchange Commissioner (SEC) Paul Atkins was confirmed as the agency’s new Chair on April 9. 
• According to Politico, Atkins is considered the “intellectual godfather of Republican market regulation” and will seek to usher in a “sweeping age of deregulation.” He is expected to make it easier for companies to go public in the U.S., pull back on enforcement, and develop new rules for digital assets.
• Yes, but: The SEC has lost a lot of staff, including hundreds of whom took a $50,000 offer to voluntarily leave the agency. A former SEC official told Politico:

• Please see recent CREFC Policy and Capital Markets Briefings for more color on Atkins.

• Democrats questioned Bowman about President Trump’s tariff policies and the Fed’s independence, raising concerns about the Fed’s ability to counter potential risks to financial stability. 
• Republicans focused their questions on easing regulatory burdens and the Fed’s shortcomings leading up to the March 2023 bank failures.

• She stated that such a request would not necessarily infringe on the Fed’s independence and emphasized her support of providing a cost-benefit analysis to justify the agency’s rulemakings. 

• Bowman’s remarks echoed similar themes shared by Treasury Secretary Scott Bessent earlier in the week. 

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Go Deeper: Potential Tax Provisions in Focus

April 15, 2025

With the reconciliation process full steam ahead (as described in the story above), we will begin to see specific tax policy provisions introduced by lawmakers in the coming weeks.

Key provisions believed to be in contention are described below.

Reauthorize Expiring TCJA provisions: The Senate is counting this as budget neutral rather than a roughly $4 trillion cost, though the parliamentarian or House deficit hawks could balk and trigger a stalemate.

Fix the SALT Cap: The TCJA capped the federal deduction for state and local tax (SALT) at $10,000 per filer, even for joint returns. 

• The GOP SALT caucus has been effective in winning over President Donald Trump and leadership in advocating to raise the $10,000 cap. 
• The exact number is to be determined, but insiders are estimating a $25,000 to $50,000 range.

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