Large banks have offloaded riskier loans to private credit, which is now more accessible to retail investors. According to Crossmark's Victoria Fernandez, this concentration of risk in a less transparent market, where "cockroaches" may be hiding, is a primary systemic concern.

The removal of leverage lending guidelines will not cause a simple shift from private credit back to banks. Instead, it will accelerate the convergence of public and private credit markets. Banks will now compete across the entire financing continuum, further blurring the distinctions in terms and cost between the two.

Private credit grew by taking on riskier loans that banks shed after Dodd-Frank, making the core banking system safer. However, banks now provide wholesale leverage to these private credit funds with minimal due diligence, creating a new, less transparent concentration of risk.

Despite investor concerns about private credit, banks involved in the space feel reassured by their risk management strategy. They structure deals to be senior, are over-collateralized by hundreds or thousands of loans, and partner exclusively with established, prime sponsors, creating multiple layers of protection.

When a corporate client is acquired by private equity and requires higher leverage, the bank risks losing the entire relationship. By partnering with a private credit fund to handle the loan, the bank can keep the client and all associated high-margin fee-based services like treasury management.

Regulatory leverage lending guidelines, which capped bank participation in highly leveraged deals at six times leverage, created a market void. This constraint directly spurred the growth of the private credit industry, which stepped in to provide capital for transactions that banks could no longer underwrite.

While most US economic cycles appear healthy, the opaque private credit market represents the most significant systemic risk. Recent signs of stress, such as fund redemption limits and high exposure to volatile sectors like software, are reminiscent of the "contained" problems that preceded the 2008 financial crisis.

The Basel III regulations, intended to de-risk the financial system by making risky lending expensive for banks, had an unintended consequence. The demand for risky loans didn't vanish; it simply migrated from the regulated banking sector to the opaque, unregulated private credit market, creating a new systemic risk.

The migration of risk-taking from banks after the financial crisis spawned three major, distinct industries. Private credit absorbed bank lending, proprietary trading firms took over market-making, and multi-strategy hedge funds replicated the activities of internal proprietary trading desks.