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Private Credit on Regulatory Radar

May 12, 2026

Authorities are seeking better visibility into the private credit markets, now estimated at $1.5 to $2 trillion, particularly where life insurers are involved. Private credit is generally defined as loans originated by nonbanks and negotiated on a bilateral basis between borrowers and lenders.

Why it matters: Private credit has become a meaningful source of financing for mid-sized companies and, increasingly, larger borrowers and AI infrastructure projects. Regulators and policymakers are assessing whether insurers' shift toward private credit introduces opaque risks that could affect policyholders or trigger rapid asset sales.

Driving the news

• The FSB: The global body coordinating financial regulation released a report on May 6 examining the private-credit ecosystem, bank interlinkages, borrower credit quality, and data gaps. The report notes that the sector can support economic activity by offering alternative credit solutions to borrowers, but remains untested to a prolonged economic downturn.
• Treasury: On May 7, Treasury Secretary Scott Bessent met with state insurance commissioners and the National Association of Insurance Commissioners (NAIC) to discuss recent developments in private credit markets.
• Federal Reserve: On May 8, the U.S. central bank released its biannual Financial Stability Report. It noted strong household balance sheets and well-capitalized banks. However, “a wide range of market contacts who participated in the Survey of Salient Risks in March and April most frequently cited geopolitical risks, oil shocks, risks from artificial intelligence (AI), private credit, and persistent inflation.”
  • The report added the following new sections: “Updates in the Classification of Nonbank Financial Institutions” and “Developments in Private Credit.”
  • Survey respondents viewed private credit as:

Market Size and Composition

• The FSB estimates the global private-credit market to be $1.5 trillion –$2 trillion as of year-end 2024, with the United States having the largest market, with an estimated size of around $1 trillion. 
  • Bank exposure to private credit funds is a relatively small share of banks' total assets and capital, with member data capturing about $220 billion in drawn and undrawn credit lines. However, other estimates suggest the amounts could be more than twice as large.
  • Private equity-backed insurers in the U.S. now control nearly $900 billion in insurance liabilities, a significant rise from $67 billion in 2012.
• Private credit’s growth, according to the FSB, has been driven by the increased demand for high-yield and tailored credit due to:
  • Prolonged low-interest rate environment;
  • Changes in post-crisis bank regulation; and 
  • Expansion of private equity.

Regulators are focused increasingly on transparency, particularly as it relates to private credit in the insurance sector. 

• The FSB found that borrowers that are predominantly in private credit typically lack public ratings, and that valuations are often conducted less frequently and may involve significant discretion. 
• According to American Banker, Secretary Bessent said Treasury is monitoring the growing exposure of insurers to private credit to ensure that state-based oversight remains effective. 
• State regulators also shared their efforts to monitor private credit and protect policyholders. Elizabeth Dwyer, director of Rhode Island's Department of Business Regulation Director and NAIC president-elect, stated in a press release:

What's next 

• The FSB outlined four follow-up work areas:
  • Continuing to assess vulnerabilities related to interlinkages between a range of nonbanks within the private finance ecosystem;
  • Mapping the components of the complex and evolving ecosystem;
  • Facilitating supervisory discussions to enhance authorities’ ability to assess and supervise vulnerabilities and risks; and 
  • Addressing data challenges that make it difficult to monitor vulnerabilities. 
• On the insurance side, NAIC adopted a challenge process to so-called private letter ratings, which are confidential credit opinions issued by rating agencies for privately-placed securities. 
  • According to American Banker, this challenge process is the culmination of a multi-year effort that would allow the NAIC to challenge any rating. 
  • NAIC has a team of 30 analysts that review individual transactions to ensure compliance with regulatory standards. No rating challenges have been processed to date. 
  • A rating challenge would have to be a "material," requiring a three-notch downgrade or more for regulators to determine if a rating needs to be changed.

Please contact Sairah Burki (sburki@crefc.org) with questions.

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CRE Securitized Debt Update

September 30, 2025

Private-Label CMBS and CRE CLOs

1. ESA 2025-ESH, a $1.9 billion SASB backed by a floating-rate, five-year loan (at full extension) for a joint venture between Blackstone and Starwood to refinance a portfolio of 220 extended-stay hotels operated by Extended Stay America, Inc., totaling 24,560 rooms across 33 states.
2. BSPRT 2025-FL12, a $1.1 billion CRE CLO sponsored by Benefit Street Partners. The managed transaction comprises 44 loans secured by 73 properties. The pool’s top three property types are multifamily (61.8%), hotel (22.3%), and industrial (12.1%).
3. BANK5 2025-5YR17, a $1 billion conduit backed by 44 five-year loans secured by 66 properties from JPMorgan, Morgan Stanley, Wells, and BofA.
4. NRTH 2025-PARK, a $900 million SASB backed by a floating-rate, five-year loan (at full extension) for NorthPark Management to refinance the 1.9 million square foot NorthPark Center super-regional mall in Dallas.
5. BMO 2025-C13, an $814.2 million conduit backed by 47 10-year loans secured by 89 properties from BMO, Deutsche, Key, Citi, Goldman, JPMorgan, Zions, Benefit Street, LMF, Starwood, and Greystone.
6. WFCM 2025-5C6, a $622.7 million conduit backed by 26 five-year loans secured by 51 properties from Wells, JPMorgan, LMF, Rialto, Argentic, Citi, Goldman, and UBS
7. VTR 2025-STEM, a $475 million SASB backed by a fixed-rate, four-year loan for Ventas and GIC to refinance two life-science properties totaling 811,000 square feet in Pennsylvania.
8. HAVN 2025-MOB, a $278.3 million SASB backed by a floating-rate, five-year loan (at full extension) for Welltower and Wafra to refinance 22 medical office properties in 13 states.
9. WFCM 2025-AURA, a $275 million SASB backed by a floating-rate, five-year loan (at full extension) for BTG Pactual and Morning Calm Management to refinance a portfolio of 24 industrial properties totaling 4.8 million square feet across Ohio and Michigan.

By the numbers: Year-to-date private-label CMBS and CRE CLO issuance totals $114.1 billion, representing a 43% increase from the $79.6 billion recorded for same-period 2024. 

Spreads Unchanged 

• Conduit AAA and A-S spreads were unchanged at +76 and +113, respectively. YTD, AAA and A-S spreads are wider by 1 bp and 8 bps, respectively. 
• Conduit AA and A spreads were unchanged at +160 and +190, respectively. YTD, they are each wider by 25 bps.
• Conduit BBB- spreads were unchanged at +475. YTD, they are wider by 50 bps.
• SASB AAA spreads held steady in a range of +105 to +132, depending on property type.
• CRE CLO AAA and BBB- spreads were unchanged at +130 and +335, respectively.

Agency CMBS

• Agency issuance totaled $3.4 billion last week, comprising $1.4 billion of Fannie DUS, $1.2 billion of Freddie K, Q, and Multi-PC transactions, and $797.3 million of Ginnie Mae Project Loan transactions.
• Agency issuance for the year totals $105.7 billion, 39% higher than the $75.9 billion for same-period 2024.
  

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CRE Securitized Debt Update

November 10, 2025

Private-Label CMBS and CRE CLOs

Four transactions totaling $3.5 billion priced last week:

1. BX 2025-JDI, a $1.5 billion SASB backed by a floating-rate, five-year loan (at full extension) for Blackstone to refinance 94 primarily industrial properties in seven states.
2. ELP 2025-ELP, an $859 million SASB backed by a fixed-rate, five-year loan for EQT Real Estate, GIC, Blackstone, and APG to refinance a portfolio of 60 industrial properties in nine states.
3. BBCMS 2025-5C38, an $834.2 million conduit backed by 41 five-year loans secured by 76 properties from Barclays, Goldman, Citi, LMF, Rialto, Deutsche, Starwood, Benefit Street, and UBS.
4. A10 2025-FL6, a $350 million CRE CLO sponsored by A10. The managed transaction comprises nine whole loans and 12 participations secured by 27 properties. The pool’s top three property types are multifamily (54%), retail (27.9%), and industrial (9.6%).

By the numbers: Year-to-date private-label CMBS and CRE CLO issuance totals $132.1 billion, a 31% increase from the $101.1 billion recorded for same-period 2024. 

Spreads Hold Steady

• Conduit AAA and A-S spreads were unchanged at +80 and +115. YTD, they are wider by 5 bps and 10 bps, respectively. 
• Conduit AA and A spreads were unchanged at +160 and +210. YTD, they are wider by 25 bps and 45 bps, respectively.
• Conduit BBB- spreads were unchanged at +475. YTD, they are wider by 50 bps.
• SASB AAA spreads were unchanged in a range of +113 to +137, depending on property type.
• CRE CLO AAA and BBB- spreads were unchanged at +135 and +340, respectively.

Agency CMBS

• Agency issuance totaled $3.9 billion last week, comprising $2.1 billion in Freddie Multi-PC and K transactions, $1 billion in Fannie DUS transactions, and $755.4 million in Ginnie-Mae Project Loan transactions.
• Agency issuance for the year totaled $126.5 billion, 33% higher than the $95.5 billion for the same period last year.

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NDAA Passage Includes Housing Bill

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SFR/BTR Bill Update: Senate Says “Still Work to Be Done” on Housing Bill

June 2, 2026

The House version of the 21st Century ROAD to Housing Act (H.R. 6644) faces an unclear path to enactment in the Senate. 

• Both versions include a ban on large institutional investors purchasing single-family rentals (SFR). 
• The version passed by the House on May 20 removed the seven-year build-to-rent (BTR) divestment requirement, but it largely mirrors the Senate-passed language. 
• CREFC continues to push for changes to avoid impacts on multifamily rental properties, including BTR. Click here for CREFC’s statement.

Why it matters: The House and Senate have been passing and sending back different versions of house bills over the past year. 

• Since January, the White House has demanded any legislation include bans on institutional investors owning single-family homes. 
• The House introduced amended legislation on May 13 that included significant and meaningful changes to the SFR position that would have limited unintended impacts on BTR and multifamily housing. 
• However, the House abruptly changed the language to mirror the Senate version they day before the vote after negotiating with the White House. 
• The House passed its latest version on May 20 by 396-13 The Senate passed its latest version on March 12 by 89-9.
  

What they’re saying: The House bill includes key community banking bills championed by Financial Services Committee Chairman French Hill (R-AR) and Ranking Member Maxine Waters (D-CA), among other tweaks to the housing legislation. 

• Ahead of the House vote, the White House issued a Statement of Administrative Procedure supporting the bill and saying if it were to pass both chambers, staff would recommend that President Trump sign it. 
• Senate Banking Chairman (R-SC) and Ranking Member Elizabeth Warren (D-MA) said in a statement that there is “still work to be done” with the House and White House on getting a housing bill that can pass the Senate. Warren has so far opposed the community banking bills. 

Go deeper: While the opposition to the legislation has largely focused on the seven-year BTR divestment requirement, CREFC remains concerned with other aspects of the language that could impact multifamily or other excluded property types. 

• The single-family definition could still include multiple detached or townhome structures on a single-tax parcel. 
• Exemptions in the bill for servicers and creditor REO properties may still limit the resale of SFR and BTR portfolios.
• Although Treasury can issue regulation, the law goes into effect 180 days after enactment—with or without regulation. 

Beyond the SFR provisions, the House also made changes to a Senate drafting error that would have lowered HUD FHA multifamily loan limits. The new language updates them as originally intended and establishes a new inflation adjustment metric. 

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