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Private credit: the Fed takes the pulse of new lending

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dated revision: November 11, 2026primary sourcesno tracker
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A company needs financing for an acquisition. Its lender is still willing to back the deal, but asks for a larger equity contribution, reduces the loan size and tightens the contractual protections. The transaction may go ahead. The fund’s loan portfolio may even keep growing. Yet something has changed: the next borrower faces a higher hurdle.

This is an illustrative example. It captures the difference between measuring a stock of loans and observing the decisions that replenish it. A central bank needs both to understand how financing reaches businesses.

The pilot opened by the Dallas and New York Feds on November 9 addresses that decision-making process. Responses are being collected through November 18, 2026, with initial aggregate results expected in the first quarter of 2027. S01 Its questionnaire focuses on direct lending: debt negotiated with a nonbank lender or a small group of lenders, rather than placed across a broad lending market. It asks about changes in lending terms, inquiries from potential borrowers or their sponsors, and lenders’ reasons for adjusting credit conditions. S03

The exercise has a useful purpose. Assessing its contribution requires some care. The information in this field comes in several forms: reconstructed balance sheets, confidential survey responses and public indicators whose methodology has yet to be detailed. Each reveals a different part of the financing process.

Private credit was already entering the official accounts

The chronology matters. The Fed’s Financial Accounts, published as the Z.1 release, added new sectors and instruments covering private credit in September 2026. A note published on October 16 explains how they were constructed. It advances the issues examined in our investigation of gaps in private credit data. The November pilot therefore follows a substantial improvement in the measurement of outstanding credit. S06

The statisticians’ task is to connect investors, the vehicles holding the loans and the businesses that must repay them. They draw on confidential Form PF filings, disclosures by registered vehicles and commercial datasets, among other sources. Bringing those records together allows more financial relationships to be tracked within a common framework. It also requires estimates and imputations where observations are missing or reported less frequently. S06

This can make a considerable difference to the reported composition of corporate debt. A loan that is classified more accurately appears under the appropriate instrument. The measured total for that instrument changes even though the contract was already in place. Understanding a statistical series requires attention to both the economic activity and the way it has been measured over time.

Terminology adds another complication. “Private credit assets” can refer to the holdings of specialist vehicles, the loans on their balance sheets or claims on businesses in a particular country. Those categories overlap, but their boundaries differ. The Fed’s November 9 note provides an opportunity to separate them. S07

At the end of 2025, the four groups of US-domiciled vehicles shown in our chart held $1,857 billion in financial assets. Their private loan holdings amounted to $1,118.1 billion, including loans to foreign borrowers. The remainder comprised other assets, including securities, equity investments and cash. All these figures come from the same Z.1 release, dated September 11, 2026. S08 S09 S10 S11

Assets held by private credit vehicles Horizontal bars share a common scale, USD billions at end-2025. Four vehicle types hold $1,857.0 billion of financial assets, including $1,118.1 billion of private credit loans to U.S. and foreign borrowers. Other assets are calculated as the difference. {"figure": "01-actifs", "language": "en", "period": "2025:Q4", "release_date": "2026-09-11", "retrieved_date": "2026-11-11", "units": "USD billion unless explicitly pct", "geography": "U.S.-domiciled vehicles", "adjustment": "End-of-period stocks, not seasonally adjusted, current dollars", "precision": "Amounts copied at one decimal; computed percentages are for geometry and should be displayed rounded.", "rounding": "Sums of rounded published components can differ slightly from rounded published aggregates.", "balance_sheet_warning": "Asset stocks, debt funding and equity claims are different layers of one intermediation chain, not additive measures of unique borrower debt.", "data": [{"id": "pd", "label_fr": "Fonds de dette privée", "label_en": "Private debt funds", "total_assets_usd_bn": 938.7, "private_credit_loans_usd_bn": 532.2, "other_assets_usd_bn": 406.5, "private_credit_share_pct": 56.69542984979227, "source_table": "S124.8.s", "total_line": 1, "private_credit_line": 4}, {"id": "bdc", "label_fr": "Business development companies", "label_en": "Business development companies", "total_assets_usd_bn": 572.2, "private_credit_loans_usd_bn": 455.9, "other_assets_usd_bn": 116.3, "private_credit_share_pct": 79.67493883257602, "source_table": "S124.5.s", "total_line": 1, "private_credit_line": 4}, {"id": "interval_tender", "label_fr": "Fonds interval et tender offer", "label_en": "Interval and tender offer funds", "total_assets_usd_bn": 292.4, "private_credit_loans_usd_bn": 76.3, "other_assets_usd_bn": 216.1, "private_credit_share_pct": 26.094391244870042, "source_table": "S124.6.s", "total_line": 1, "private_credit_line": 7}, {"id": "mm_clo", "label_fr": "CLO middle-market", "label_en": "Middle-market CLOs", "total_assets_usd_bn": 53.7, "private_credit_loans_usd_bn": 53.7, "other_assets_usd_bn": 0.0, "private_credit_share_pct": 100.0, "source_table": "F4.4.s", "private_credit_line": 10, "total_note": "The FEDS notes specify that MM CLO assets are private credit loans; post-launch scope, excluding warehouse loans."}], "formulas": {"other_assets": "total_assets - private_credit_loans", "asset_total": "938.7 + 572.2 + 292.4 + 53.7 = 1857.0", "private_loans_total": "532.2 + 455.9 + 76.3 + 53.7 = 1118.1"}, "sources": {"S06": "https://www.federalreserve.gov/econres/notes/feds-notes/introducing-private-credit-into-the-financial-accounts-of-the-united-states-20261016.html", "S07": "https://www.federalreserve.gov/econres/notes/feds-notes/u-s-private-credit-vehicles-institutional-structure-and-aggregate-balance-sheets-20261109.html", "S08": "https://www.federalreserve.gov/releases/z1/20260911/html/S124_8_s.htm", "S09": "https://www.federalreserve.gov/releases/z1/20260911/html/S124_5_s.htm", "S10": "https://www.federalreserve.gov/releases/z1/20260911/html/S124_6_s.htm", "S11": "https://www.federalreserve.gov/releases/z1/20260911/html/F4_4_s.htm"}} l0g PRIVATE CREDIT FIG. 01 Assets held by private credit vehicles Four U.S.-domiciled structures, with very different asset mixes. TOTAL FINANCIAL ASSETS 1,857.0 $bn OF WHICH: PRIVATE CREDIT LOANS 1,118.1 $bn Private credit loans Other assets USD billions · end-2025 0 250 500 750 1,000 Total Private debt funds 57% of assets in private loans 532.2 406.5 938.7 Business development companies (BDCs) 80% of assets in private loans 455.9 116.3 572.2 Interval and tender offer funds 26% of assets in private loans Loans: 76.3 216.1 292.4 Middle-market CLOs 100% of assets in private loans Loans: 53.7 53.7 Loans held by U.S.-domiciled vehicles include lending to foreign borrowers. Uncalled capital is excluded. Other assets include equities, bonds, cash and miscellaneous assets; they are not necessarily liquid. Z.1 loan amounts; other assets = total assets − private loans. Published components have one decimal place. Source: Federal Reserve, Sep 11, 2026 Z.1 release · end-2025 stocks, current dollars, not seasonally adjusted. S08 S09 S10 S11 l0g.fr · November 11, 2026

FIG. 01 · Billions of US dollars; outstanding amounts at the end of 2025; US-domiciled vehicles. Loans include lending to foreign borrowers. “Other assets” equals financial assets minus private loans. Uncalled capital commitments are excluded. Sources: Z.1 tables S124.8.s, S124.5.s, S124.6.s and F4.4.s; the Fed’s November 9 methodological note. S07 S08 S09 S10 S11

The mix varies considerably. Private loans account for roughly 57% of the assets of private debt funds, 80% of those held by business development companies, or BDCs, and 26% of the assets of interval and tender offer funds. Interval funds make periodic repurchase offers; tender offer funds can offer repurchases at their discretion. Middle-market CLOs, vehicles that pool loans and issue securities against them, consist entirely of private loans within the statistical perimeter used here. S07 S08 S09 S10 S11

Those proportions affect what a headline market-size figure actually means. Using total assets as a measure of lending would bring in other kinds of holdings. Switching from the domicile of the vehicle to the location of the borrower would change the perimeter again. Our comparison uses year-end 2025, the reference period in the November 9 note; some series in the same tables already extend to the second quarter of 2026. It describes a documented historical structure, with an explicit date.

Five pages focused on the lending decision

The questionnaire narrows the scope considerably. It covers senior secured first-lien direct loans, including unitranche facilities, to businesses assessed as below investment grade that are organized in the United States or have their principal place of business there. The credit assessment can rely on an internal or private credit rating. Distressed debt strategies, subordinated loans and broadly syndicated lending fall outside the stated scope. S03

From the borrower’s perspective, a unitranche combines different components of financing in a single facility. The loans are secured by collateral; seniority describes a creditor’s contractual priority. The amount ultimately recovered will still depend on the assets, competing claims and the company’s circumstances. These features give the survey a more consistent lending universe, while leaving parts of private credit to other measures.

Participation criteria require at least $50 million in assets under management devoted to the eligible activity. The questionnaire then groups borrowers by annual EBITDA: below $30 million, $30 million to $100 million, and above $100 million. EBITDA is earnings before interest, taxes, depreciation and amortization; here it serves as a measure of business size. S04 S03

The distinction matters. A large company able to approach several financing markets may secure different terms from a smaller business dependent on a few lenders. An overall average can conceal those different experiences. Tracking them separately helps identify which companies are encountering constraints.

The form also asks for three confidential amounts: assets under management devoted to the defined activity, new-money loans extended during the previous quarter, and refinancings during that same quarter of loans previously made by the respondent’s own firm. That last qualification sets a specific boundary around the refinancing measure. Our analysis of borrower exits and refinancing examines how these movements affect lenders. The three fields describe different things; interpreting them together requires consistent definitions. S03

Most of the remaining questions concern changes. The detailed questions on loan terms cover loans a firm was willing to approve in the previous quarter, whether or not they ultimately closed. A loan’s spread is the margin charged above its reference interest rate. A covenant is a contractual undertaking by the borrower. A payment-in-kind, or PIK, provision allows interest to be added to principal under the terms of the agreement, deferring its payment in cash. Changes to these provisions can affect both access to finance and the lender’s protection.

The economic value of the exercise lies in observing how the terms of new lending evolve. An existing portfolio can contain several generations of contracts. Recent decisions give a more immediate indication of what borrowers face, subject to the period covered and the respondent’s customer base.

From lender to public signalDallas–New York pilot: eligibility, confidential amounts, qualitative changes, aggregation and publication. Weighting remains to be confirmed. l0g PRIVATE CREDIT FIG. 02 From lender to public signal Survey scope, confidential responses and aggregate trends. PILOT SCOPE Senior first-lien direct lending to US businesses below investment grade. Eligible assets under management ≥ $50m; borrower sizes grouped by EBITDA. CONFIDENTIAL AMOUNTS REPORTED CHANGES 2a Assets under management dedicated to the defined activity 2b New-money loans extended over the previous quarter 2c Previous-quarter refinancing of loans previously made by the respondent Lending terms Spreads, covenants, protections, PIK options Reported reasons Funding, competition, portfolio performance Inquiries and outlook Asked separately from lending standards AGGREGATION OF RESPONSES Public coverage and weighting details still awaited AGGREGATED DIRECTIONAL TRENDS First release expected: Q1 2027 Announced remit: economic analysis; individual responses kept separate from supervision. Terms relate to loans the respondent was willing to approve. Sources S02–S04: FAQ updated 9 November 2026, questionnaire and criteria. l0g diagram.

FIG. 02 · Structure of the pilot opened on November 9, 2026. Individual amounts remain confidential; the planned publication will report aggregate directional trends. The diagram reflects the public documents and makes no assumption about the eventual weighting method. Sources: questionnaire, participation criteria and FAQ updated on November 9. S02 S03 S04

Reading the answers alongside other evidence

Tighter conditions can originate with the lender, its own funding providers or its borrowers. The form asks respondents to assess the importance of several reasons, including bank and nonbank financing conditions, competition, the economic outlook and portfolio performance. It separately asks how the number of inquiries from potential borrowers or their sponsors has changed, covering additional or increased credit lines and excluding refinancings. This measures inquiry activity, distinct from the dollar amounts requested or the number of loans approved. S03

That separation makes the responses potentially more informative than a single lending total. If inquiries are rising while lending standards tighten, a supply constraint is a plausible explanation. If inquiries fall while terms remain unchanged, businesses’ financing needs or investment plans may be playing a larger role. These combinations help frame hypotheses. The customer mix may also change, a respondent may withdraw from a sector, and several forces may act at once.

The survey records the lender’s assessment. Establishing a cause would require comparing those responses with contracts, similar transactions and borrower data. The questionnaire provides direction and reported explanations; the work of testing them remains.

The same applies to capitalized interest. A response indicating more flexible PIK provisions may signal a change in the terms on offer. Establishing how much interest has actually been added to debts, how much cash has been received and what was lost after a restructuring requires portfolio-level follow-up. The Financial Stability Board’s May 2026 report specifically highlights the importance of examining amendments and restructurings beyond a narrow definition of default. S03 S15

The economic outcomes can differ sharply. A concession may give a viable company time to recover. It may also extend financing whose repayment has become less likely. Subsequent cash flows and recoveries reveal which outcome materializes. The same contractual feature can appear in either case.

Who responds will shape the result

The survey relies on voluntary participation and confidentiality. The FAQ states that individual responses will be accessible only to a limited number of people at the two Reserve Banks. They will not be shared with the Fed’s supervisory teams or other regulators. Anonymous comments can be published only with consent. The stated purpose concerns financing and the economy; the pilot rules out supervisory use of the responses. S02

That commitment may encourage participation. It also sets a boundary between what the researchers can analyze and what a reader can reproduce from the published results. Documentation will therefore be central to confidence in an aggregate indicator.

Voluntary participation alone says little about the eventual quality of the data. The Fed’s Senior Loan Officer Opinion Survey on Bank Lending Practices, or SLOOS, is also voluntary. Its public documentation allows users to assess its coverage. The relevant questions concern recruitment, continuity of the panel and the treatment of responses. S12

Consider a hypothetical example, unrelated to the pilot’s eventual results. Ten lenders respond. Six tighten their standards; four ease them. Giving each lender equal weight produces a net tightening balance of +20 percentage points: 60% minus 40%.

Now suppose the six lenders that tighten account for 30% of a reference lending volume, while the other four account for 70%. Weighting by that volume produces a balance of −40 percentage points. The responses are unchanged. The calculation now answers a different question: how many lenders are changing their position, or how much lending is represented by those that do?

Ten responses. Two ways to count.Hypothetical example: six lenders tighten and four ease. Equal-weight net balance: +20 points. The same groups hold 30% and 70% of a reference volume, yielding a volume-weighted balance of −40 points. l0g PRIVATE CREDIT FIG. 03 Ten responses. Two ways to count. Hypothetical example: same opinions, different weights. 01 / ONE VOTE PER LENDER Each block represents one lender. 6 tighten 4 ease 60% − 40% +20 points Share of respondents 02 / WEIGHTED BY LOAN VOLUME Each block represents one lender. 6 tighten 4 ease 30% − 70% −40 points Share of an assumed reference volume THE SAME RESPONSES CAN PRODUCE OPPOSITE SIGNS −100 −50 0 +50 +100 −40 +20 Net easing Net tightening A net balance needs a clearly defined denominator. Counting lenders and measuring their share of financing answer different questions. l0g educational calculations. No actual pilot observations. The Fed’s future method remains to be confirmed.

FIG. 03 · Illustrative example constructed by l0g. Six lenders tighten and four ease. They account for 30% and 70%, respectively, of an assumed lending volume. Equal-weight calculation: 60 − 40 = +20 percentage points. Volume-weighted calculation: 30 − 70 = −40 percentage points. None of the figures describes the pilot; the Fed’s eventual formula remains to be confirmed.

Weighting by outstanding loans would primarily reflect the existing portfolio. Weighting by new originations would give more influence to recent activity. Size categories could help address some imbalances. Each choice has a purpose that needs to be explained.

Nonresponse creates a further question. A panel can include many firms and still miss a particular segment. Large platforms, smaller specialist lenders and vehicles aimed at retail investors have different structures. High coverage by dollar value can coexist with limited coverage of a business model. Conversely, a panel with relatively low coverage may still provide a useful signal if its stability and relationship with other data can be established.

As of November 11, the public documents reviewed do not establish the final number of respondents, the share of the market covered or the chosen aggregation rule. The survey remains open. These are questions for the publication of results, without prejudging the quality of responses being collected.

Banks enter the picture through the lender’s funding

The relationship between private lenders and banks becomes clearer when the financing of the lender itself is examined. A fund can raise capital from investors and borrow to supplement it. The bank then holds a claim on the vehicle, while the vehicle holds claims on businesses. Risk passes through different contracts and balance sheets. Our investigation of NAV loans follows one specific form of fund-level leverage; it does not describe every bank loan to an investment vehicle.

The Z.1 tables measure part of that connection. At the end of 2025, bank loans to US-domiciled private debt funds stood at $150.3 billion; those to BDCs at $180.8 billion; and those to interval and tender offer funds at $18.4 billion. The published components sum to $349.5 billion, or roughly $350 billion. These are outstanding loans to vehicles in the three groups. Undrawn commitments and other possible exposures are outside that measure. S08 S09 S10

How banks remain connected to private credit At end-2025, U.S.-domiciled private debt funds, BDCs and interval/tender offer funds owe depository institutions $150.3, $180.8 and $18.4 billion respectively. The sum is $349.5 billion, or approximately $350 billion. Bars also show other identified debt. The diagram distinguishes the bank's claim on the vehicle, investor equity and loans to borrowers; no amount is assigned to onward lending. {"figure": "04-banques", "language": "en", "period": "2025:Q4", "release_date": "2026-09-11", "retrieved_date": "2026-11-11", "units": "USD billion unless explicitly pct", "geography": "U.S.-domiciled vehicles", "adjustment": "End-of-period stocks, not seasonally adjusted, current dollars", "precision": "Amounts copied at one decimal; computed percentages are for geometry and should be displayed rounded.", "rounding": "Sums of rounded published components can differ slightly from rounded published aggregates.", "balance_sheet_warning": "Asset stocks, debt funding and equity claims are different layers of one intermediation chain, not additive measures of unique borrower debt.", "data": [{"id": "pd", "label_fr": "Fonds de dette privée", "label_en": "Private debt funds", "bank_loans_usd_bn": 150.3, "other_debt_usd_bn": 83.8, "total_debt_usd_bn": 234.1, "other_label_fr": "Autres prêts et avances", "other_label_en": "Other loans and advances", "table": "S124.8.s", "bank_line": 13, "other_line": 14, "total_line": 12, "bank_share_of_debt_pct": 64.20333190944042}, {"id": "bdc", "label_fr": "Business development companies", "label_en": "Business development companies", "bank_loans_usd_bn": 180.8, "other_debt_usd_bn": 81.5, "total_debt_usd_bn": 262.3, "other_label_fr": "Obligations émises", "other_label_en": "Bonds issued", "table": "S124.5.s", "bank_line": 11, "other_line": 10, "total_formula": "line 10 + line 11; excludes miscellaneous liabilities", "bank_share_of_debt_pct": 68.92870758673276}, {"id": "interval_tender", "label_fr": "Fonds interval et tender offer", "label_en": "Interval and tender offer funds", "bank_loans_usd_bn": 18.4, "other_debt_usd_bn": 2.7, "total_debt_usd_bn": 21.1, "other_label_fr": "Pensions livrées", "other_label_en": "Repurchase agreements", "table": "S124.6.s", "bank_line": 16, "other_line": 15, "total_line": 14, "bank_share_of_debt_pct": 87.2037914691943}], "formula": "150.3 + 180.8 + 18.4 = 349.5", "official_rounded_aggregate_usd_bn": 349, "diagram_note": "Qualitative balance-sheet relationships, not annual flows or a quantified tracing of funds. Arrow widths are not quantities. Creditor domicile is not inferred.", "sources": {"S06": "https://www.federalreserve.gov/econres/notes/feds-notes/introducing-private-credit-into-the-financial-accounts-of-the-united-states-20261016.html", "S07": "https://www.federalreserve.gov/econres/notes/feds-notes/u-s-private-credit-vehicles-institutional-structure-and-aggregate-balance-sheets-20261109.html", "S08": "https://www.federalreserve.gov/releases/z1/20260911/html/S124_8_s.htm", "S09": "https://www.federalreserve.gov/releases/z1/20260911/html/S124_5_s.htm", "S10": "https://www.federalreserve.gov/releases/z1/20260911/html/S124_6_s.htm", "S11": "https://www.federalreserve.gov/releases/z1/20260911/html/F4_4_s.htm"}} l0g PRIVATE CREDIT FIG. 04 How banks remain connected to private credit The vehicles borrow too, creating another layer of credit exposure. ≈ $350bn 349.5: sum of published components Bank loans to three types of U.S.-domiciled vehicle. End-2025 outstanding stock · CLOs excluded Identified debt on each category’s balance sheet Bank loans Other identified debt USD billions · end-2025 0 100 200 300 Total Private debt funds 150.3 83.8 Bank share: 64% 234.1 BDCs 180.8 81.5 Bank share: 69% 262.3 Interval and tender offer funds 18.4 + 2.7 Bank share: 87% 21.1 The vehicle’s balance sheet connects the claims Investors Equity capital Banks Claim on the vehicle Credit vehicles Loans and other assets Borrowers Owe the vehicle Loan to vehicle Loan to borrower Asset losses first reduce equity. The bank’s protection depends on its contractual rights and safeguards. Claims at these two levels cannot be added to measure credit received by the final borrowers. Balance-sheet stocks, not undrawn commitments. These tables do not establish the domicile of lending banks. CLOs are excluded from the sum. Arrows are qualitative, not annual flows or a tracing of $349.5bn to clients. Other debt: other loans for private debt funds, bonds for BDCs, and repos for interval/tender offer funds. Source: Fed, Sep 11, 2026 Z.1 release · S08–S10. The S06 aggregate is independently rounded to $349bn. S06 S07 S08 S09 S10 l0g.fr · November 11, 2026

FIG. 04 · Outstanding amounts at the end of 2025, in billions of US dollars; US-domiciled vehicles. The $349.5 billion total is the sum of components published to one decimal place; the summary table in the October 16 note reports $349 billion at a different level of precision. The chart uses “roughly $350 billion.” These are successive layers of financing and should not be added together as a measure of a single underlying corporate debt. S06 S08 S09 S10

This helps explain why bank funding conditions appear in the questionnaire. A more expensive credit line, higher collateral requirements or reduced borrowing capacity can affect the next loan a fund offers. Transmission can begin through the price or availability of financing, well before a loss is ultimately realized.

Tracing the process in the other direction requires more information. Deterioration in a corporate loan first affects the value of the portfolio holding it. The consequences for a creditor of the fund depend on the equity available to absorb losses, the priority of its claim, the collateral and the relevant contractual terms. The Fed’s August 7 study of BDCs documents banking relationships and their pricing using historical supervisory data. It helps explain the channel without providing a comprehensive picture of November 2026. S18

Adding a bank’s loan to a fund and the fund’s loan to a company would count two links in the same chain as independent sources of financing for the final borrower. Measuring a concentration of risk instead requires matching counterparties and tracing who absorbs losses at each stage.

Information also follows a regulatory timetable

The survey arrives as another reporting framework is undergoing an explicit reassessment. Form PF is a confidential filing covering certain private funds. Some of its data already feed into the Fed’s statistical work. On April 20, 2026, the SEC and CFTC proposed changing its requirements, including raising the general reporting threshold from $150 million to $1 billion in private fund assets under management. As of November 11, the SEC’s website still lists the measure as a proposal. S13 S06

The proposal also sought comments on information tailored to private credit, including its definition, leverage, funding, loan quality and investor liquidity. The official comment deadline was June 23; the record also includes later contributions. The final design of any such reporting remains to be confirmed. S13

A separate decision has already taken effect. A rule issued on August 31 and effective September 3 moved the compliance date for the 2024 amendments to Form PF from October 1, 2026, to July 1, 2027. Existing reporting continues; the postponement concerns those new requirements. S14

The agencies’ explanation sets out the tradeoff without requiring any inference about intent. Adapting systems to questions that may subsequently change can create avoidable costs. Their analysis also acknowledges that the extension delays the benefits of additional information and may leave some data unavailable if market events occur in the meantime. S14

Timing determines part of the value of information. Detailed data become useful when they arrive early enough to support comparisons, connect exposures or inform a decision. A faster, lighter survey offers a different contribution. The approaches can complement one another; treating them as substitutes would require showing that they meet the same needs.

The Dallas–New York pilot has a distinct role, focused on lending conditions and expressly separated from supervision. Its launch therefore provides no basis for concluding that prudential information needs have been met.

How the safeguards affect the analysis

Private credit’s varied structures provide important reasons to question any account of uniform fragility. A closed-end fund with capital committed for several years can hold a loan and negotiate a restructuring. Shares in a listed BDC can change hands on an exchange without requiring the company to repay the sellers. A vehicle offering periodic repurchases must manage those withdrawals within the limits set out in its documents. These arrangements affect how quickly pressure can spread. The repurchase windows of semi-liquid funds illustrate the importance of contractual limits and timetables. S07

In its July 2026 report, the Bank of England observes that repurchase limits at certain vehicles had largely worked as designed, while also examining the possible incentive for investors to request an exit early. A contractual restriction can preserve cash for the fund as a whole and alter investor behavior. Both effects warrant attention. S16

The ECB offers another counterpoint. Its May study finds observed direct exposures sufficiently limited to make systemic instability in the euro area arising from private credit alone unlikely at that time. It also examines broader valuation losses in an adverse scenario and identifies gaps in the data. The conclusion is conditional on its scope, assumptions and date. S17

These findings call for examining the sources of resilience as carefully as the points of vulnerability. A confidential contract can coexist with close monitoring of the borrower. Patient capital can absorb volatility that other structures struggle to accommodate. The cost of credit, a vehicle’s liquidity and the ultimate loss are distinct outcomes that need to be tracked separately.

The first results will need a clear guide to interpretation

The next meaningful milestone is the publication of results expected in the first quarter of 2027. Assessing them will require a clear picture of the panel, an explanation of how responses are weighted and a way to distinguish changes in activity from changes in the composition of respondents. If the quarterly survey envisaged after the pilot goes ahead, tracking those features over time will make the series more useful. S01 S02

The most useful comparisons will then bring several sources together: reported lending terms, inquiries from borrowers or sponsors, new contracts, changes in outstanding credit and borrower outcomes. Tightening reported by lenders could precede slower credit growth. An end to that tightening could reflect improvement or a different customer mix. Comparing the evidence will establish how much weight those explanations deserve.

The Fed is seeking a closer view of a decisive moment: when a lender agrees to finance a deal, asks for more protection or passes on it. The public value of that view will depend on the strength of the signal and the clarity of the framework around it. With that context, the first results can provide a sounder account of how credit is reaching the economy.

Method and limitations

Research is dated November 11, 2026. FEDS Notes present their authors’ analyses. Pilot results are still to come; no interviews or access to confidential responses are claimed. Regulatory documents are examined in the sections cited, without claiming an exhaustive reading of the 328-page Form PF proposal. S01 S06 S13

The financial figures use end-2025 stocks from the September 11, 2026 Z.1 release, matching the November 9 note’s reference period. Some series already extend to the second quarter of 2026. The vehicles are US-domiciled; their loans include foreign borrowers. Uncalled capital is excluded. Vehicle assets, loan holdings and funding describe different layers. S07 S08 S09 S10 S11

Reproducible calculations, in billions of US dollars: assets = 938.7 + 572.2 + 292.4 + 53.7 = 1,857.0; private loans = 532.2 + 455.9 + 76.3 + 53.7 = 1,118.1; bank loans = 150.3 + 180.8 + 18.4 = 349.5. Other assets are calculated by subtraction; percentages use published amounts before rounding. Undrawn commitments are distinct from outstanding loans. S08 S09 S10 S11

The weighting example is wholly hypothetical: ten respondents, six tightening and four easing, give 60 − 40 = +20 percentage points at equal weights. With assumed volume shares of 30% and 70%, the balance is 30 − 70 = −40 points. These calculations describe neither pilot observations nor its future method. The form refers to the “previous quarter” without explicit calendar dates and does not specify the reporting date for requested AUM. No further timetable is assumed. S03

Sources and references

  1. S01 · Federal Reserve Bank of New York · Published: 2026-11-09 · Accessed: 2026-11-11 Federal Reserve Banks of Dallas and New York Open Pilot Survey of the Private Credit Market
    Passages and scope

    Paragraphs 1–5: pilot opening on 9 November, collection through 18 November 2026 and initial aggregate results expected in Q1 2027. The release describes voluntary participation, an economic purpose and no supervisory use. It is a launch announcement, with no results, final response count or aggregation weights. The results and any continuation of the survey remain future events at this analysis’s cutoff.

  2. S02 · Federal Reserve Bank of Dallas · Updated: 2026-11-09 · Accessed: 2026-11-11 Private Credit Survey FAQs
    Passages and scope

    Sections on purpose, timing, enrolment, handling responses and public release. Enrolment runs through 12 November; collection from 9 to 18 November; results are expected in Q1 2027. Individual amounts are confidential; the planned publication covers aggregate directional trends without specific amounts. The FAQ does not specify weighting or final coverage. Its current version was updated on 9 November; the September announcement should not be treated as a copy of the updated text. FAQ announcement, 2 September.

  3. S03 · Federal Reserve Banks of Dallas and New York · No printed publication date · Accessed: 2026-11-11 Pilot Survey of the Private Credit Market: questionnaire
    Passages and scope

    Five pages. Page 1: loan scope and EBITDA groups; Q2a–c: dedicated AUM, new-money loans and refinancings of loans previously made by the respondent. Q3–Q5, pages 1–3: terms the lender was willing to approve and reported reasons. Q6–Q7, pages 4–5: outlook and inquiries excluding refinancing. “Previous quarter” has no explicit dates; the PDF provides no AUM reporting date or detailed valuation convention. The absence of detailed loss, recovery and PIK fields concerns this questionnaire, not all data available to the Fed.

  4. S04 · Federal Reserve Banks of Dallas and New York · No printed publication date · Accessed: 2026-11-11 Private Credit Survey: Participant Criteria
    Passages and scope

    One-page document: at least $50m in AUM dedicated to eligible direct lending; senior first-lien loans, including unitranche facilities, to US businesses assessed as below investment grade; specified product and strategy exclusions. The threshold is neither the group’s total assets nor a minimum loan size. A US domicile for the lender is not expressly required. The document supplies no count of the eligible population, participant list or sampling plan.

  5. S06 · Federal Reserve Board · FEDS Notes · Published: 2026-10-16 · Accessed: 2026-11-11 Introducing Private Credit into the Financial Accounts of the United States
    Passages and scope

    Section 3: reclassification and identification of existing positions. Section 4.1, Table 1: vehicle balance sheets at end-2025; section 4.2 and footnotes 7–10: sources, imputations and interpolation. Statistical integration began with the September 2026 Z.1 release. Vehicle assets, loans, shares and liabilities are different measures. The summary table reports $349bn of bank loans at whole-billion precision; our sum of one-decimal components is $349.5bn. This is the authors’ analysis, not an official position of the Board.

  6. S07 · Federal Reserve Board · FEDS Notes · Published: 2026-11-09 · Accessed: 2026-11-11 U.S. Private Credit Vehicles: Institutional Structure and Aggregate Balance Sheets
    Passages and scope

    Sections 2.2–2.5: structures and liquidity; sections 3.1–3.3 and Figures 2–8: assets, debt and leverage; appendix: data construction. Main comparisons are for end-2025; interval and tender offer fund data begin in 2021:Q4. Loans held by US-domiciled vehicles can include foreign borrowers. Uncalled capital and pre-launch CLO warehouse financing are excluded. Mean fund-level debt/NAV ratios are winsorised at the 5th and 95th percentiles; they are not the ratio of two sector aggregates. This is the authors’ analysis.

  7. S08 · Federal Reserve Board · Financial Accounts Z.1 · Release: 2026-09-11; selected observations: 2025:Q4 · Accessed: 2026-11-11 S124.8.s: Private Debt Funds
    Passages and scope

    Lines 1, 4 and 11–18: end-2025 financial assets of $938.7bn, private credit loans of $532.2bn, bank loans of $150.3bn and other loans of $83.8bn. Debt in loan form totals $234.1bn; total liabilities also include miscellaneous liabilities. Private loans should not be replaced with the separate fair-value memo item or increased by uncalled capital. These are end-period stocks in current dollars, not seasonally adjusted, at published one-decimal precision. The table also contains observations through 2026:Q2.

  8. S09 · Federal Reserve Board · Financial Accounts Z.1 · Release: 2026-09-11; selected observations: 2025:Q4 · Accessed: 2026-11-11 S124.5.s: Business Development Companies
    Passages and scope

    Lines 1, 4 and 9–15: end-2025 financial assets of $572.2bn, private loans of $455.9bn, bank loans of $180.8bn and bonds of $81.5bn. Identified debt is calculated as $262.3bn, excluding miscellaneous liabilities. The scope includes the different BDC structures, not just exchange-listed companies. These are end-period stocks in current dollars, not seasonally adjusted; fair-value memo items are separate. The chart selects 2025:Q4 although the table extends through 2026:Q2.

  9. S10 · Federal Reserve Board · Financial Accounts Z.1 · Release: 2026-09-11; selected observations: 2025:Q4 · Accessed: 2026-11-11 S124.6.s: Interval and Tender Offer Funds
    Passages and scope

    Lines 1, 7 and 13–20: end-2025 financial assets of $292.4bn, private loans of $76.3bn, bank loans of $18.4bn and repurchase agreements of $2.7bn. Identified debt totals $21.1bn, distinct from total liabilities. These vehicles also hold equities, bonds and other assets, so total assets do not measure private loans alone. These are end-period stocks in current dollars, not seasonally adjusted, at one-decimal precision. The table also includes observations through 2026:Q2.

  10. S11 · Federal Reserve Board · Financial Accounts Z.1 · Release: 2026-09-11; selected observations: 2025:Q4 · Accessed: 2026-11-11 F4.4.s: Private Credit Loans
    Passages and scope

    Lines 1–11: private-loan borrowers and holders; line 10, series FL673067205: $53.7bn held by US CLOs at end-2025. The instrument total includes foreign lenders; holdings of the four US-domiciled vehicle groups have a different scope. Loans to US borrowers also include financial businesses. This “.s” table reports stocks, not annual flows. Observations through 2026:Q2 are not mixed with the end-2025 figures selected for the charts.

  11. S12 · Federal Reserve Board · Methodology page; publication date not stated · Accessed: 2026-11-11 About the Senior Loan Officer Opinion Survey on Bank Lending Practices
    Passages and scope

    Description of SLOOS: a voluntary, generally quarterly bank survey with documentation of its panel, collection and confidentiality. The comparison concerns voluntary participation and the value of published methodology; it does not establish that the private credit pilot will use the same sampling or aggregation. Historical panel counts on the page are not November 2026 observations. Identifier FR 2018 / OMB 7100-0058 belongs to SLOOS, not the new pilot.

  12. S13 · SEC and CFTC · Proposed: 2026-04-20; announced comment deadline: 2026-06-23 · Accessed: 2026-11-11 Form PF; Reporting Requirements for All Filers: proposal IA-6959
    Passages and scope

    Sections II.A, p.14 onwards; II.D, pp.32–38; II.Q, pp.94–96; III.F.7, p.204. Selected sections of the 328-page text were examined: the proposed increase from $150m to $1bn in the general threshold, estimates of certain indirect exposures and questions on reporting tailored to private credit. The threshold increase remains proposed on 11 November, separate from final extension S14. June 23 is the announced deadline; the index also contains later submissions and October meetings, without establishing a formal extension. The stated coverage of more than 90% concerns gross assets of all private funds, not private credit risk. Rulemaking docket and submissions.

  13. S14 · SEC and CFTC · Final rule: 2026-08-31; effective: 2026-09-03 · Accessed: 2026-11-11 Form PF: Further Extension of Compliance Date, IA-6992
    Passages and scope

    Section I, pp.3–5: compliance with the 2024 amendments is postponed from 1 October 2026 to 1 July 2027. Section II, pp.6–7: avoided transition costs and delayed information benefits. This final rule is separate from the April proposal: it does not adopt the $1bn threshold or suspend all Form PF reporting. The published trade-off establishes no intention to conceal losses. Final-rule docket.

  14. S15 · Financial Stability Board / FSB · Published: 2026-05-06 · Accessed: 2026-11-11 Report on Vulnerabilities in Private Credit
    Passages and scope

    Section 3.1, notably p.23, and Annex 2, p.46: distinctions between narrow defaults, restructurings, distressed exchanges and other concessions. Sections 3.3 and 4: valuation, layered leverage, liquidity and interconnectedness. Stale valuations may create incentives to exit early; the report also considers governance and safeguards. This vulnerability assessment uses heterogeneous periods and sources; it is neither a crisis forecast nor a universal default rate. Report overview.

  15. S16 · Bank of England · Published: 2026-07-07 · Accessed: 2026-11-11 Financial Stability Report, July 2026
    Passages and scope

    Section 4.2: redemption pressures in a subset of US funds, mainly non-traded BDCs, and the operation of repurchase caps. Box A: funds without redemption rights and vehicles offering periodic liquidity. Caps have largely operated as expected, but may encourage pre-emptive exits when investors fear reduced future access to capital or adverse valuations. An activated cap proves neither borrower default nor fund insolvency. These are July findings, not new observations for November 2026.

  16. S17 · European Central Bank · Financial Stability Review · Published: 2026-05; exact day not established · Accessed: 2026-11-11 Stress in global private credit markets and its implications for euro area financial stability
    Passages and scope

    Sections 2–5, Chart D.4 and the conclusion: limited direct euro area exposures in available data; systemic instability from private credit in isolation is assessed as unlikely at that time, with larger spillover losses in an adverse scenario. Periods differ: drawn private-credit exposures for 12 banks at end-2024, leveraged lending in Q4 2025, and end-2024 insurance and pension data projected to Q2 2025. The illustrative scenario assumes default and valuation shocks; it is not a forecast. Data gaps and potential spillovers remain explicit.

  17. S18 · Federal Reserve Board · FEDS Notes · Published: 2026-08-07; sample: 2012:Q3–2023:Q4 · Accessed: 2026-11-11 The Price of Bank Funding Behind Private Credit: Evidence from Business Development Companies
    Passages and scope

    Sections 3–6, Figure 1 and Tables 1–2: BDC bank credit lines, committed and utilised amounts, pricing during the 2022 tightening, collateral and bank concentration. Supervisory FR Y-14Q H.1 data are matched with BDC data for 2012:Q3–2023:Q4. These are historical results for this sample, not a November 2026 snapshot or a finding for all private lenders. Commitments, drawdowns and end-2025 Z.1 bank-loan stocks are not interchangeable; $349.5bn is not a measure of NAV loans.

This analysis is not investment advice.

// cite this analysis

l0g, “Private credit: the Fed takes the pulse of new lending”, l0g.fr, published November 11, 2026, updated November 11, 2026, https://l0g.fr/en/analysis/private-credit-fed-survey-new-lending/


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