Private Credit Scrutiny and Institutional Exposure Concerns Accelerate into Year-End 2025

Tricolor Details Emerge, Reinforce Private Credit Fraud Concerns

New information about the collapse of Tricolor Holdings released in December has crystallized what many observers are increasingly characterizing as a structural vulnerability of private credit markets. Perscient's semantic signature tracking the density of language claiming that lenders are using the same collateral multiple times reached a z-score of 7.2 in December, strengthening by 1.2 from the prior month[1]. This represents the largest single-month increase among all tracked signatures and the highest absolute reading in the dataset, signaling that media discussion of collateral integrity has moved well beyond isolated commentary into sustained, elevated concern.

It also suggests that the Tricolor event is becoming a media lightning rod for more generic and often unrelated concerns about private credit more broadly. Prosecutors unsealed an indictment in December charging the subprime auto lender's executives with orchestrating schemes that allowed the company to obtain billions of dollars from lenders by misrepresenting collateral. According to prosecutors, Tricolor held $1.4 billion in real collateral but pledged $2.2 billion to creditors, leading to a $1 billion shortfall when the company filed for Chapter 7 liquidation in September. The fraud allegedly ran for seven years, with one executive manually editing Excel files to make thousands of delinquent loans appear current.

The mechanics of the scheme illuminate broader structural concerns. As CNBC reported, senior managers allegedly orchestrated schemes that misrepresented collateral to major financial institutions including JPMorgan and Jefferies Financial Group, which had extended hundreds of millions in credit facilities. The opacity inherent in private credit structures made detection difficult; the mismatch was ultimately flagged not by auditors or regulators but by a junior analyst who noticed inconsistencies in spreadsheet columns.

This reemergence of double-pledging at the current stage of the credit cycle has prompted observers to question whether such incidents represent isolated frauds or symptoms of deeper systemic weaknesses. WTW has identified double-pledging as a key risk in private credit, noting it involves the reuse of collateral across loans, undermining protection and increasing fraud risk. The related semantic signature tracking language alleging sponsors offload risks through complex securitizations also strengthened in December, rising by 0.5 to a z-score of 4.5. Meanwhile, Perscient's signature tracking language claiming that private credit valuations are fictional or manipulated rose by 0.8 to a z-score of 2.6, suggesting growing unease about how assets are being marked across the sector.

JPMorgan Chase CEO Jamie Dimon's warning about "cockroaches" in private credit has resonated through advisory circles, prompting asset managers to emphasize underwriting discipline and manager selection as essential safeguards. Yet the structural opacity that enabled Tricolor's alleged fraud persists across the broader market, particularly when lenders rely on borrower self-reporting or sample-based verification of collateral pools.

Alternative Asset Manager and Insurance Exposure Concerns Accelerate

The collateral integrity questions examined above have coincided with mounting concern about institutional exposure to private credit, particularly among alternative asset managers and insurers. Perscient's semantic signature tracking language expressing worry about alt managers' private credit concentration rose by 1.0 to a z-score of 6.6 in December, the second-highest absolute level in the dataset. The parallel signature tracking language expressing concern about insurers' allocations strengthened by 0.6 to reach 4.0.

Throughout December, headlines have trained attention on the intersection of insurance capital and alternative asset management. UBS Chair Colm Kelleher accused insurers of ratings shopping and labeled the trend a "looming systemic risk." Bank of England Governor Andrew Bailey expressed doubts about the role of rating agencies, stating that "alarm bells are starting to go off." The criticism has particular resonance given Fitch Ratings' finding that life insurers affiliated with alternative investment managers hold 24% of their total financial assets in so-called "level III" assets, compared to only about 6% for traditional insurers.

The European Insurance and Occupational Pensions Authority's December 2025 Financial Stability Report flagged private credit as characterized by higher credit and liquidity risk, valuation uncertainty, and hidden leverage. EIOPA warned that if not properly managed, these characteristics can affect exposed undertakings. The IAIS Global Insurance Market Report 2025 struck a similar note, highlighting valuation uncertainty, liquidity challenges, borrower credit quality concerns, and structural complexity as distinct risks, even as aggregate exposures remain moderate.

WTW's analysis of private credit risks and their insurance implications has emphasized heightened oversight leading to investigations and costly enforcement actions. Federal Reserve research has noted that through innovative financing structures, life insurers have sought to further develop their role in the intermediation chain of public and private credit to risky firms. The research observes that insurers' exposure to below-investment-grade firm debt now exceeds the industry's exposure to subprime residential mortgage-backed securities in late 2007.

Concern has broadened beyond insurers and alternative managers to encompass other distribution channels as well. Perscient's signature tracking the density of language expressing worries about Business Development Companies' private credit risks rose by 0.4 to a z-score of 4.2, while the signature tracking language expressing concern about retail investors' holdings strengthened by 0.21 to 4.65. As Reuters reported, new offerings could raise risks for retail investors, who have the most at stake and the least expertise in assessing complex products.

Regulatory Attention Sharpens as Systemic Risk Narratives Gain Traction

The convergence of collateral integrity questions and institutional exposure concerns has drawn regulatory attention that now extends across multiple jurisdictions and supervisory bodies. Perscient's semantic signature tracking language asserting regulators are recognizing private credit dangers rose by 0.49 to a z-score of 2.60 in December. The signature tracking language questioning private credit's resilience during market stress strengthened by 0.27 to reach 6.11, reflecting persistent uncertainty about how the asset class would perform under adverse conditions.

The Financial Stability Board has expressed high-level concerns about the potential for ratings shopping in private markets, where firms can seek grades on transactions from multiple providers and opt for the most favorable one. The Bank of England will examine the role of ratings firms as part of a system-wide exploratory scenario exercise covering private markets, with the stress test aiming to capture how private markets as a whole would respond to a sharp economic shock.

As we observed in our last private credit Pulse report, the interconnections between private credit and the traditional banking system have attracted special regulatory attention. Federal Reserve Bank of Boston research finds that bank lending to business development companies has been growing both as a share of banks' total loan balances and as a share of BDCs' balance sheets, suggesting banks retain indirect exposure to private credit risk even when they do not directly originate or hold those loans. The FDIC's 2025 Risk Review highlights that large banks provide essential services to private credit funds through capital call facilities, joint lending arrangements, and credit risk transfers, creating indirect exposures that make banks vulnerable to downturns in the private credit space.

Harvard's Mossavar-Rahmani Center has recommended that regulators and central banks consider expanding the regulatory perimeter to include significant private credit funds and monitor risk concentrations, including leverage and liquidity mismatches. Australia's ASIC is conducting further surveillance on numerous private credit funds as part of a broader review.

Morningstar DBRS has likewise reaffirmed its negative outlook for the sector, citing weakening profit margins at private credit borrowers globally that will likely lead to further loan defaults in 2026. It is a narrative that seems to have legs. Perscient's signature tracking language describing specific credit events as potential canaries in the coal mine for private credit problems rose by 0.42 to a z-score of 5.60, indicating that commentators are keen to frame just about all news in context of this more pessimistic narrative for the sector.

[1] While we characterize this as a z-score, in practice many such event-driven narratives are not normally distributed (this is no exception). Suffice it to say that the density of this language is “extreme.”

Archived Pulse

December 16, 2025

• Regulatory Momentum on Retirement Access Slows Despite Policy Tailwinds
• Interval Fund Narratives Strengthen as Alts Managers Expand Retail Offerings
• Banking System Interconnection Concerns Rise Alongside Regulatory Scrutiny

December 09, 2025

• Insurance-Private Credit Nexus Emerges as Focal Point for Systemic Concern
• Market Stress Resilience Questions Reach All-Time High Amid Default Warnings
• BDC Exposure Concerns Rise as Retail Access Narratives Moderate

November 24, 2025

• Private Credit Faces Collateral Integrity Questions as Stress Narratives Intensify