The private credit question ASIC carried into advice

A private credit review might seem to stop at the fund: its assets, fees and conflicts. ASIC’s second major surveillance carried the inquiry into retail advice. On 10 November 2026, ASIC published findings from a review of 24 wholesale and retail funds, with a combined $18 billion in assets under management, and a sample of financial advice to retail investors relating to private credit. ASIC’s findings cover work conducted between November 2025 and August 2026.

The fund is only part of the picture

ASIC’s REP 846 examines retail distribution, including financial advice, as well as fund structures, fee arrangements and related-party relationships affecting transparency and investor outcomes.

The fund-level findings help explain why advice cannot stop at the asset-class label. Eighteen of the 24 funds used multiple layers of intermediary entities, including special purpose vehicles and fund-of-funds structures. Nine of 12 retail funds did not clearly disclose key information for investor decisions, including information about underlying assets, structures or risks. Only two of 22 funds passed on the full economic benefits of interest earned and borrower fees to investors, according to ASIC’s release.

For an advice practice, the practical question is how the particular fund’s risks, fees and conflicts informed the recommendation, and how the recommended exposure fits into the client’s portfolio. A fund’s name or headline terms alone cannot explain those considerations.

Concentration is where the advice findings sharpen

Most of the financial advice ASIC reviewed demonstrated compliance with legal obligations. But advice files recommending higher portfolio concentration to a single private credit fund were less likely to demonstrate compliance with the duty to act in the investor’s best interests.

A useful practice response is to sample relevant advice files and trace the reasoning from the fund information considered through to the recommended portfolio allocation. That makes the findings a prompt to examine the quality of reasoning in relevant cases, not a verdict on every private credit recommendation.

ASIC also reported regulatory interventions arising from its surveillance, including six interim stop orders and referrals for further enforcement investigation. The stop orders were lifted once the issues ASIC identified were promptly addressed.