---
title: "The Fed's private-credit survey: three questions for manager diligence | Altss Blog"
description: "How to use the Fed’s new private-credit survey to frame direct-lending manager questions and evaluate the evidence behind an explanation."
canonical: "https://altss.com/blog/fed-private-credit-survey-direct-lending-diligence"
---

[Altss Research](https://www.linkedin.com/company/altss)

3 min read

Updated Nov 14, 2026

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# The Fed's private-credit survey: three questions for manager diligence

How to use the Fed’s new private-credit survey to frame direct-lending manager questions and evaluate the evidence behind an explanation.

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An allocator needs a direct lender to explain how its underwriting is changing. A headline yield provides only part of that explanation. The new Dallas and New York Fed survey offers a useful starting point for asking about the borrowers a manager serves, the protections it negotiates and the pressures influencing its decisions.

The two Reserve Banks [opened their voluntary pilot on November 9, 2026](https://www.dallasfed.org/news/releases/2026/nr261109privatecredit). Responses close November 18, with aggregate findings due in Q1 2027. The questionnaire is available now; the findings are still ahead. Altss's proposed use is to sharpen manager diligence before those findings arrive.

## 1. Which loans belong in the comparison?

The [participant criteria](https://www.dallasfed.org/-/media/documents/research/surveys/pcs/criteria.pdf) cover senior direct lending to below-investment-grade U.S. businesses, including first-lien and unitranche debt. Mezzanine, second-lien, distressed and other excluded strategies should not be folded into the same comparison. Eligibility requires at least $50 million dedicated to the specified U.S. direct-lending activity, rather than $50 million across an entire investment firm.

For an LP, the first request is a bridge from the manager's overall portfolio to the relevant loan population. Identify the applicable strategy and explain any excluded exposures. Otherwise, a discussion that starts with a market comparison can quietly become a comparison of different businesses.

## 2. What changed in the deal terms?

The [questionnaire](https://www.dallasfed.org/-/media/documents/research/surveys/pcs/form.pdf) groups borrowers by annual EBITDA and asks about spreads, financial covenants, documentation, subordinated capital cushions and payment-in-kind toggles.

Consider a hypothetical manager reporting unchanged pricing. That statement leaves open whether it accepted less protection elsewhere in the agreement. Ask for comparable transactions from the previous quarter and the contractual terms supporting its explanation. Compare borrower characteristics alongside terms.

## 3. What explains the change?

The form separately asks about reasons for changing standards, including competition, available investment capital and the lender's bank and nonbank borrowing conditions. It also asks about inquiries for additional credit, excluding refinancings.

An allocator can ask the manager to connect its explanation to its own financing arrangements, investment decisions and completed lending. Track inquiries through approval to completed lending.

## Understand what will become public

The form collects dollar figures for relevant assets under management, new lending and refinancing, but marks those answers as nonpublic. The [FAQ](https://www.dallasfed.org/research/surveys/pcs) says published results will show aggregate directional trends rather than specific quantities or identifiable firm responses. The survey is not intended for supervisory or regulatory use.

That publication boundary matters for attribution. An aggregate finding cannot establish what a particular manager answered. Keep the eventual market reading and the manager's own evidence as separately labelled records. The useful output for an investment committee is a short comparison: relevant loan population, changed terms, stated cause and supporting evidence. Where the records disagree, investigate the difference before treating either as a complete explanation.

Make that comparison repeatable. Date the request, name the person responsible for supplying the evidence and record what would resolve each open question. At the next review, return to the same cases before selecting new examples. A changed explanation should be accompanied by the new information that prompted it, so the committee can follow the reasoning over time.

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