medium · FRM Part 2 Current Issues
What is the primary reason why 'Manager-Marked' valuations in private credit are criticized by systemic risk regulators (e.g., the FSB)?
- They rely on outdated SEC-mandated pricing formulas that no longer reflect the current interest rate and credit environment.
- They swing too violently from day to day, which regulators fear could needlessly spook lenders in short-term repo funding markets.
- They allow for 'Loss Forbearance', where managers avoid marking down loans despite clear evidence of borrower deterioration.
- They effectively bar the fund from collecting any performance fees at all until every underlying loan has been fully repaid.
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