Greater flexibility for leveraged lending? Current supervisory approaches in the EU, the US and the UK

In the aftermath of the financial crisis bank supervisors increased their scrutiny of leveraged lending by banks due to the high-risk profile of such loans. In 2013/2014, the US supervisors took a prescriptive approach, inter alia by capping the regular leverage ratios at six times debt-to-EBITDA. In 2017, the ECB followed suit in its Guidance to supervised banks, while the UK supervisors favoured a more principles-based approach. In December 2025, the US supervisory approach changed, becoming less prescriptive, thus granting greater flexibility to banks. This prompted calls for a review of the supervisory approach in Europe, in part to safeguard a level playing field for global banks. However, as our comparative review shows, the ECB has not changed its 2017 Guidance. UK supervisors, meanwhile, continue to maintain their less prescriptive approach. Therefore, as far as restrictions on leveraged lending are concerned, global US and UK banks may currently enjoy greater supervisory flexibility, and thus a more favourable competitive position, than EU banks supervised by the ECB.

Introduction

Leveraged lending commonly refers to the granting of secured loans to highly indebted, sub-investment-grade borrowers. Although definitions vary across the industry, leveraged lending generally involves borrowers whose post-financing leverage ratios, as measured by debt-to-assets, debt-to-net-worth, or debt-to-cash flow, significantly exceed industry norms or historical levels.¹ The term 'leveraged lending' is often used synonymously with the term 'leveraged transactions.' The former is commonly used by US supervisors while the European Central Bank (ECB) often uses the latter.

Leveraged lending is typically used to finance mergers and acquisitions, capital distributions, recapitalisations, refinancing of prior loans, leveraged buyouts, business expansions, and general corporate purposes. Loans used for leveraged lending usually carry a floating interest rate and, unlike high yield bonds, are secured by the borrower's assets.² Banks traditionally participate in the leveraged lending market by providing or arranging financing and facilitating syndication. They also have indirect exposure through lending to business development companies, debt funds, and investments in collateralised loan obligations containing securitised leveraged loans.³

After a surge in leveraged transactions following the financial crisis, regulators increased their scrutiny due to the high-risk profile of these loans.⁴ While UK regulators chose to address risks stemming from leveraged transactions through general supervisory principles, capital and leverage requirements, and stress-testing tools, the US federal bank regulators adopted a prescriptive product-focused stance. In 2013 and 2014, the Board of Governors of the Federal Reserve System (FRB), Federal Deposit Insurance Corporation (FDIC) and Office of the Comptroller of the Currency (OCC) issued an Interagency Guidance on Leveraged Lending ('Interagency Guidance') and FAQs.⁵ These rules inter alia capped regular leverage ratios at six times debt-to-EBITDA, with strict exceptions subject to additional scrutiny and thresholds for risk ratings and creditworthiness.⁶ The EU followed suit, with the ECB issuing similar guidance for supervised banks in 2017.⁷

Since then, the leveraged lending market has increasingly shifted from regulated banks to private credit providers.⁸ The recent withdrawal of US interagency guidance and FAQs by the OCC and FDIC in December 2025 prompts a closer look at current approaches in the EU, US, and UK, especially in light of ongoing debates on competitiveness and the need for a level playing field.

EU approach

In the EU, specifically for banks under the Single Supervisory Mechanism in the Euro area, the European Central Bank (ECB) sets out its supervisory approach and expectations for leveraged transactions in its 2017 Guidance⁹ and a 2022 Dear CEO letter.¹⁰

The ECB Guidance defines leveraged transactions as any loan or credit exposure where either

(i) the borrower's post-financing total debt-to-EBITDA ratio exceeds 4.0 times, or

(ii) the borrower is owned by one or more financial sponsors. Exceptions apply for loans to SMEs, specialised lending, trade finance, and investment grade loans.¹¹

Exceptions from this definition are provided inter alia for loans to SMEs, specialised lending, trade finance and investment grade loans.¹²

The ECB Guidance also outlines supervisory expectations for banks' risk appetite frameworks,¹³ credit approval policies,¹⁴ ongoing portfolio monitoring¹⁵ and reporting requirements¹⁶ relating to leveraged transactions. It lays down prescriptive expectations formerly aligned with those included in the now withdrawn US Interagency Guidance and FAQs.¹⁷ This includes a regular leverage cap of six times debt-to-EBITDA at deal inception, with exceptions subject to due justification,¹⁸ and mandates that borrowers must be able to fully amortise senior secured debt or repay at least 50% of total debt within five to seven years.¹⁹

In March 2022, the ECB issued a Dear CEO letter to significant institutions, criticising banks' implementation of the ECB Guidance and clarifying expectations for risk appetite frameworks and limits on high-risk transactions.²⁰ The ECB's leveraged transaction framework is also referenced in its Credit Risk SREP methodology,²¹ its Guide on significant risk transfer and securitisations,²² and the European Banking Authority (EBA) Guidelines on loan origination and monitoring.²³ Moreover, credit and liquidity facilities supporting leveraged transactions must be taken into account in liquidity coverage requirements.²⁴

Although the ECB's framework is not formally binding, it has produced factual and indirect legal effects²⁵ through supervisory actions, which has materialised in recent years through dedicated supervisory measures, including operational acts replacing the 2022 Dear CEO letter,²⁶ as well as capital add-ons. As part of its supervisory dialogue the ECB claims to consider the specific characteristics of the transactions within supervisory dialogue before taking escalating measures such as imposing capital charges.²⁷ Departing from previous supervisory priorities, the leveraged transactions are not listed in the ECB's current supervisory priorities for 2025-2027.²⁸ Nevertheless, the ECB continues to emphasise the importance of prudent management of leveraged transactions.²⁹ In recent SREP cycles the ECB has imposed Pillar 2 capital add-ons on several non-compliant banks,³⁰ thereby giving full effect to the ECB's framework of supervisory expectations for leveraged transactions and prompting questions as to their legality and the ECB's mandate.

Given that the ECB's approach was originally aligned with US standards, particularly regarding leverage limits and creditworthiness definitions, to promote a level playing field, the ECB's approach may require a review following the withdrawal of US Interagency Guidance. This seems particularly true in the light of recent calls for a more competitive EU banking sector.³¹

US approach

With the withdrawal of the Interagency Leveraged Lending Guidance and the FAQs by the OCC and FDIC in December 2025, the US has shifted from a prescriptive leveraged lending framework to a more principles-based approach, similar to that of the UK. The federal bank regulators explained that the previous guidance was too restrictive, limited banks' ability to apply general risk management principles, captured unintended loan types, was potentially inoperative due to a lack of congressional review, and drove lending activity to non-banks.³²

Following the withdrawal of the Interagency Guidance and the FAQs, banks are expected to apply the agencies' General Principles for prudent risk management of commercial loans and other types of lending to their leveraged lending activities allowing banks flexibility in their risk management approaches, whilst taking account of the specific nature of leveraged lending:³³

• Banks involved in leveraged lending are exposed to core financial risks – primarily credit and liquidity risks – which may be more pronounced given the activity and profile of the borrowers. The key to safe and sound banking is effectively managing these risks. A bank should manage the risks associated with its leveraged lending activities and tailor its risk management practices based on the quantity of the risk inherent in such activities;
• A bank should have a clearly defined risk appetite that is reasonable and reflects the aggregate level and types of risk it is willing and able to assume to achieve its strategic objectives. A bank's leveraged lending activities should clearly align with this risk appetite;
• Each bank should have effective risk management and controls for transactions in its pipeline, including loans to be held and those to be distributed;
• Each bank should determine its own definition of a "leveraged loan." A bank's application of a bank-wide, consistent definition supports its ability to identify, measure, monitor, and control its aggregate exposure to leveraged lending and to determine adherence to its risk appetite and concentration limits, including for indirect exposures;
• A bank's underwriting criteria should consider a loan's purpose and sources of repayment and the capacity to de-lever over a reasonable period. Given the risk profiles of leveraged lending transactions, underwriting criteria should be consistently applied to these transactions;
• Because leveraged borrowers start with high debt relative to cash flow, a bank should conduct an analysis of a leveraged borrower's past and current performance compared with projections, as well as the assumptions on which the projections are based;
• Because leveraged borrowers generally depend on access to the capital markets or banks for refinancing, a bank should monitor a leveraged loan throughout its life cycle to assess the risk that refinancing is unavailable and to appropriately manage changes to the loan's risk profile; and
• A bank that purchases a participation in a leveraged loan should make a thorough independent evaluation of the transaction and risk involved before committing funds. The same credit assessment and underwriting criteria should be applied as if the bank were originating the loan internally.³⁴

In this regard, federal bank agency examiners will assess banks' underwriting practices, review risk ratings, and monitor the adequacy of loan loss reserves according to general principles of safe and sound lending. These examinations will be tailored to the size, complexity, and risk of each bank's leveraged lending activities. The OCC and FDIC may also issue further guidance on leveraged lending as they deem appropriate.³⁵

UK approach

UK regulators do not provide a single, prescriptive supervisory framework for leveraged transactions comparable to that of the ECB: supervisory expectations exist but are principles-based, dispersed across supervisory tools, and not codified in a unified product-specific regime. There are no binding or formally prescribed supervisory thresholds tied to borrower-level leverage metrics (such as debt/EBITDA caps, mandatory amortisation periods, or formal "exceptional" classifications above defined leverage levels), although such metrics may be assessed by supervisors as part of firm-specific reviews. There is likewise no single statutory or Prudential Regulation Authority (PRA)'s Rulebook definition of "leveraged lending" or "leveraged transactions" that serves as the basis for a product-specific supervisory regime. Notwithstanding the development of prescriptive leveraged lending frameworks in the US (from 2013) and the EU (from 2017), the UK has not introduced a comparably prescriptive, transaction-level supervisory framework, instead relying on macro- and micro-prudential tools.

The PRA's Supervisory Statement on the UK leverage ratio (SS45/15, November 2025 update) frames supervisory expectations around managing excessive leverage across the balance sheet as a whole, rather than targeting leveraged finance as a discrete activity.³⁶ SS45/15 is a key supervisory statement through which the PRA explains and operationalises the UK leverage ratio framework supplementing the binding requirements set out in the PRA Rulebook; it imposes a firm-wide Tier 1 / exposure requirement (3.25%) applied on an aggregate balance sheet basis on firms within the scope of the framework (principally major UK banks and building societies), and does not directly set product-specific limits, though broader supervisory expectations (including the additional leverage ratio buffer applicable to the largest UK firms above the 3.25% minimum) may still indirectly influence activities like leveraged lending.

Alongside SS45/15, leveraged lending risk is addressed indirectly through:

• Pillar 2 capital requirements determined through the PRA's Supervisory Review and Evaluation Process (SREP), which provides the primary supervisory mechanism through which firm-specific risks, including concentrated or weakly underwritten leveraged lending exposures, may result in additional capital requirements;³⁷
• concentration risk and large exposure rules under the UK Capital Requirements Regulation;³⁸ and
• the Bank of England's stress-testing programme (comprising the biennial Bank Capital Stress Test, exploratory and firm-specific/tailored exercises), which incorporates credit risk scenarios relevant to leveraged loan portfolios, providing supervisors with visibility of banks' exposures without requiring transaction-level supervisory rules.³⁹

Press reporting in June 2024 indicated that the PRA instructed Barclays to commission a section 166 review of its leveraged finance business (with further such reviews expected across the industry) focusing on risk management practices, pipeline risk, and underwriting standards in syndicated loan markets: the PRA reportedly wrote to chief risk officers reminding firms of expectations to comprehensively identify and measure risks tied to private equity funds and their portfolio companies.⁴⁰ However, the PRA's reported investigations have not resulted in published sector-wide guidance: consistent with the PRA's established practice, any follow-up action is expected to have occurred through firm-specific and confidential bilateral supervisory engagement, including possible SREP adjustments.⁴¹ Senior PRA officials, including Rebecca Jackson, have highlighted in public remarks the need for more comprehensive stress testing and risk assessment of sponsor-related and leveraged exposures,⁴² but no thematic follow-up to the reported 2024 probe by the PRA has been published.

UK regulators have nonetheless highlighted leveraged finance as an identified supervisory priority, being a key discussion area in Financial Stability Reports of the Bank of England's Financial Policy Committee (FPC).⁴³ The FPC's Financial Stability Reports showed an increasing focus on leveraged lending risk, particularly in the context of rapid private credit market growth: the December 2023 Financial Stability Report identified leveraged lending and private credit interconnections as emerging systemic risks.

This is a concern that carried through to subsequent reports. The June 2024 Financial Stability Report identified elevated vulnerabilities in corporate debt markets, noting rising default rates in leveraged loan markets and the risks posed by highly leveraged borrowers to financial stability. The December 2024 Financial Stability Report similarly flagged concerns regarding private credit markets, including valuation opacity, the limited track record of private credit funds through a full credit stress cycle, and the potential for contagion to banks through credit facilities extended to private credit funds and leveraged borrowers. Most recently, the July 2025 Financial Stability Report similarly flagged the opacity of private credit valuations and the risk of delayed loss recognition, and reiterated the FPC's expectation that banks improve stress-testing capabilities for aggregate sponsor-related exposures. However, the FPC has not to date issued recommendations advocating a prescriptive, product-specific leveraged lending regime comparable to the ECB framework or the former US Interagency Guidance.⁴⁴

The Financial Stability Reports highlight that leveraged lending is addressed within the FPC's system-wide risk monitoring framework, consistent with the FPC's macro-prudential mandate, rather than through dedicated leveraged lending guidance or transaction-specific standards. UK supervisors are therefore attentive to leveraged lending risk, particularly in the context of private credit growth and the interconnections between private credit funds and regulated banks, but are not currently signalling a move towards a formal, prescriptive product- specific framework.

Any future action is more likely to remain within the existing architecture of firm-specific supervision, Pillar 2 adjustments, and system-wide stress testing, rather than a standalone leveraged lending guidance analogous to the ECB framework. The withdrawal of the US Interagency Guidance arguably reduces cross-jurisdictional pressure for the UK to introduce prescriptive product-specific requirements, even as the ECB's continued enforcement of its framework creates a potential divergence in competitive conditions for banks active in these markets.

_{1 ECB, Financial Stability Review (May 2018) p. 74, https://www.ecb.europa.eu/press/financial-stability-publications/fsr/focus/2018/pdf/ecb~7df9d8a256.fsrbox201805_05.pdf.
2 IOSCO, Leveraged Loans and CLOs Good Practices for Consideration (Final report), FR03/2024 (June 2024), p. 7-8, https://www.iosco.org/library/pubdocs/pdf/IOSCOPD766.pdf.
3 FDIC and OCC, Interagency Statement on OCC and FDIC Withdrawal from the Interagency Leveraged Lending Guidance Issuances, https://www.occ.gov/news-issuances/bulletins/2025/bulletin-2025-44a.pdf.
4 FRB, FDIC and OCC, Interagency Guidance on Leveraged Lending (21 March 2013) p. 1, 3, https://www.federalreserve.gov/supervisionreg/srletters/sr1303a1.pdf.
5 FRB, FDIC and OCC, Interagency Guidance on Leveraged Lending (21 March 2013), https://www.federalreserve.gov/supervisionreg/srletters/sr1303a1.pdf; FRB, FDIC and OCC, Frequently Asked Questions (FAQ) for Implementing March 2013 Interagency Guidance on Leveraged Lending (7 November 2014), https://www.occ.treas.gov/publications-and-resources/publications/shared-national-credit-report/files/pub-snc-faqs-2014.pdf.
6 FRB, FDIC and OCC, Interagency Guidance on Leveraged Lending (21 March 2013) p. 7, 11, https://www.federalreserve.gov/supervisionreg/srletters/sr1303a1.pdf.
7 ECB, Guidance on leveraged transactions (May 2017), https://www.bankingsupervision.europa.eu/ecb/pub/pdf/ssm.leveraged_transactions_guidance_201705.en.pdf.
8 IOSCO, Leveraged Loans and CLOs Good Practices for Consideration (Final report), FR03/2024 (June 2024), p. 8, https://www.iosco.org/library/pubdocs/pdf/IOSCOPD766.pdf.
9 ECB, Guidance on leveraged transactions (May 2017), https://www.bankingsupervision.europa.eu/ecb/pub/pdf/ssm.leveraged_transactions_guidance_201705.en.pdf.
10 ECB, Letter to banks on Leveraged transactions - supervisory expectations regarding the design and functioning of risk appetite frameworks and high levels of risk taking, SSM 2022 0239, 28.03.2022.
11 ECB, Guidance on leveraged transactions (May 2017), p. 4.
12 ECB, Guidance on leveraged transactions (May 2017), pp. 4-5.
13 ECB, Guidance on leveraged transactions (May 2017), pp. 6-7.
14 ECB, Guidance on leveraged transactions (May 2017), pp. 9-10.
15 ECB, Guidance on leveraged transactions (May 2017), pp. 10-11.
16 ECB, Guidance on leveraged transactions (May 2017), p. 13.
17 See W&C Client Alert, ECB Guidance on Leveraged Transactions (May 2017),https://service.betterregulation.com/sites/default/files/2017-06/ecb-guidance-on-leveraged-transactions_0.pdf.
18ECB, Guidance on leveraged transactions (May 2017), p. 7.
19 ECB, Guidance on leveraged transactions (May 2017), p. 9.
20 ECB, Letter to banks on Leveraged transactions - supervisory expectations regarding the design and functioning of risk appetite frameworks and high levels of risk taking, SSM 2022 0239 (28 March 2022), https://www.bankingsupervision.europa.eu/press/letterstobanks/shared/pdf/2022/ssm.2022_letter_on_leveraged_transactions.en.pdf.
21 ECB, Credit risk SREP methodology, https://www.bankingsupervision.europa.eu/activities/srep/2024/html/ssm.srep202412_creditrisksrepmethodology.en.html.
22 The guide explicitly excludes portfolios with significant leveraged exposures, using the 2017 leveraged transaction definition from the fast-track SRT process, cf. ECB, Guide on the notification of significant risk transfer and implicit support for securitisations (19 December 2025), para. 3.3.2, https://www.bankingsupervision.europa.eu/ecb/pub/pdf/ssm.supervisory_guides202512_notification_SRT_securitisations.en.pdf.
23 EBA, Guidelines on loan origination and monitoring, EBA/GL/2020/06(29May 2020), para. 5.2.9, https://www.eba.europa.eu/sites/default/files/document_library/Publications/Guidelines/2020/Guidelines%20on%20loan%20origination%20and%20monitoring/884283/EBA%20GL%202020%2006%20Final%20Report%20on%20GL%20on%20loan%20origination%20and%20monitoring.pdf.
24 Liquidity coverage requirement under Article 31 of Commission Delegated Regulation (EU) 2015/61 of 10 October 2014.
25 Josenhans/Danzmann/Krampe, Die Auswirkungen des ECB-Leitfadens für Leveraged-Transaktionen auf Akquisitionsfinanzierungen, BKR 2017, 265 (266 et seq.); cf. Lee Federman/Ewen Scott: Easier said than done: the failure of the European Central Bank’s Guidance on Leveraged Transactions, Butterworths Journal of International Banking and Financial Law, March 2019, p. 180, confirming that the guidelines were not perceived as binding.
26 Thurmann/Bélorgey/Boysen, Leveraged Transactions im Fokus der ECB, Zeitschrift für das gesamte Kreditwesen, 15.06.2025, p. 575. 
27 Supervising leveraged lending, Speech by Elizabeth McCaul, at AFME’s 17th Annual European Leveraged Finance Conference London, 20 September 2022, https://www.bankingsupervision.europa.eu/press/speeches/date/2022/html/ssm.sp220920~d41dede079.en.html; Questions after a speech by Andrea Enria at the press conference on the results of the 2021 SREP cycle, 10 February 2022, https://www.bankingsupervision.europa.eu/press/speeches/date/2022/html/ssm.sp220210~b95041902b.en.html.
28 ECB, Supervisory priorities 2025-27, https://www.bankingsupervision.europa.eu/framework/priorities/html/ssm.supervisory_priorities202412~6f69ad032f.en.html. Unlike for the period 2022 to 2024 during which the ECB conducted a Leveraged Finance Review. See for comparison the ECB’s 2022-24 Supervisory Priorities which featured preventing the build-up of unmitigated risks in the area of leveraged finance and foster banks’ adherence to the ECB’s supervisory expectations in the related ECB Guidance as a strategic objective, cf. ECB, Supervisory priorities 2022-2024, https://www.bankingsupervision.europa.eu/framework/priorities/html/ssm.supervisory_priorities2022~0f890c6b70.en.html. This included the announcement of targeted on-site inspections which were later carried out as part of a targeted review in 2023, which was subject to stark criticism, cf. The Banker, ECB delays leveraged loans probe findings amid bank criticism, July 2024, https://www.thebanker.com/content/a566bece-1b97-5562-ba0f-f27264bd20e1.
29 ECB, Aggregated results of the 2025 SREP, para. 3.1, https://www.bankingsupervision.europa.eu/activities/srep/2025/html/ssm.srep202511_aggregatedresults2025.en.html#toc26.
30 Additional capital charges were imposed on nine banks in 2024 and six banks in 2025. Cf. ECB, Aggregated results of the 2024 SREP, para. 3.1, https://www.bankingsupervision.europa.eu/activities/srep/2024/html/ssm.srep202412_aggregatedresults2024.en.html and ECB, Aggregated results of the 2025 SREP, 2025, para. 3.2, https://www.bankingsupervision.europa.eu/activities/srep/2025/html/ssm.srep202511_aggregatedresults2025.en.html#toc26.
31 See Mario Draghi, The Draghi report on EU competitiveness, September 2024, https://commission.europa.eu/to-pics/eu-competitiveness/draghi-report_en#paragraph_47059; European Commission, The Competitiveness Compass, January 2025, https://commission.europa.eu/compe-titiveness-compass_en; European Parliament, Economic Governance and EMU Scrutiny Unit (EGOV), „EU Banking Sector & Competitiveness“ (Study PE 764.188), 2025, https://www.europarl.euro-pa.eu/RegData/etudes/STUD/2025/764188/ECTI_STU(2025)764188_EN.pdf; European Commission, Directorate-General for Financial Stability, Financial Services and Capital Markets Union, „Factsheet: The Savings and Investments Union - Connecting savings and productive investments“, 19.3.2025, https://finance.ec.eu-ropa.eu/document/download/2701e5bb-e5e8-484e-b2066bb5e6a27044_en?filename=250319-factsheet-siu_en.pdf.
32 FDIC and OCC, Interagency Statement on OCC and FDIC Withdrawal from the Interagency Leveraged Lending Guidance Issuances, https://www.occ.gov/news-issuances/bulletins/2025/bulletin-2025-44a.pdf.
33 FDIC and OCC, Interagency Statement on OCC and FDIC Withdrawal from the Interagency Leveraged Lending Guidance Issuances, pp. 2-3, https://www.occ.gov/news-issuances/bulletins/2025/bulletin-2025-44a.pdf.
34 FDIC and OCC, Interagency Statement on OCC and FDIC Withdrawal from the Interagency Leveraged Lending Guidance Issuances, pp. 2-3, https://www.occ.gov/news-issuances/bulletins/2025/bulletin-2025-44a.pdf.
35 FDIC and OCC, Interagency Statement on OCC and FDIC Withdrawal from the Interagency Leveraged Lending Guidance Issuances, pp. 3, https://www.occ.gov/news-issuances/bulletins/2025/bulletin-2025-44a.pdf.
36 PRA, Supervisory Statement SS45/15, The UK Leverage Ratio Framework (November 2025 update), https://www.bankofengland.co.uk/prudential-regulation/publication/2015/the-uk-leverage-ratio-framework-ss.
37 PRA Supervisory Statement SS31/15, "Internal Capital Adequacy Assessment Process (ICAAP) and the Supervisory Review and Evaluation Process (SREP)", Bank of England (updated). URL: https://www.bankofengland.co.uk/prudential-regulation/publication/2015/internal-capital-adequacy-assessment-process-and-the-supervisory-review-and-evaluation-process-ss.
38 UK Capital Requirements Regulation (Regulation (EU) No 575/2013 as onshored by the European Union (Withdrawal) Act 2018, now amended by various UK statutory instruments), Part Four, Articles 387–403 (Large Exposures). URL: https://www.legislation.gov.uk/eur/2013/575/part/4.
39 Bank of England, The Bank of England's Approach to Stress Testing the UK Banking System (2024). Available at: https://www.bankofengland.co.uk/stress-testing/2024/boes-approach-to-stress-testing-the-uk-banking-system.
40 Reuters, ‘Barclays asked by watchdog to review private equity exposure’ (14 June 2024); Available at (paywall), https://www.reuters.com/business/finance/barclays-asked-by-watchdog-review-private-equity-exposure-source-says-2024-06-14/;  Bloomberg, ‘Barclays Told to Review Leveraged Finance as UK Probes Industry’ (14 June 2024); Available at (paywall) https://news.bloomberglaw.com/private-equity/barclays-told-to-review-leveraged-finance-as-uk-probes-industry;  City A.M., Barclays Ordered to Review Exposure to Private Equity (June 14, 2024), https://www.cityam.com/barclays-ordered-to-review-exposure-to-private-equity/.
41 PRA SS31/15 (Internal Capital Adequacy Assessment Process (ICAAP) and the Supervisory Review and Evaluation Process (SREP)): Confirms that SREP is the PRA's primary vehicle for firm-specific capital adjustments arising from identified risks. Available at https://www.bankofengland.co.uk/prudential-regulation/publication/2015/internal-capital-adequacy-assessment-process-and-the-supervisory-review-and-evaluation-process-ss.
42 Bloomberg, Shaw/Foerster, 'Barclays Told to Review Leveraged Finance as UK Probes Industry' (14 June 2024) (quoting Rebecca Jackson, PRA Executive Director for Authorisations, Regulatory Technology, and International Supervision). Available at (paywall): https://news.bloomberglaw.com/private-equity/barclays-told-to-review-leveraged-finance-as-uk-probes-industry.
43 PRA Business Plan 2024/25 (published April 2024): Identifies credit risk in corporate and leveraged lending portfolios as a supervisory priority area. Available at https://www.bankofengland.co.uk/prudential-regulation/publication/2024/april/pra-business-plan-2024-25. Bank of England Financial Stability Report, June 2024: Discusses leveraged lending and private credit risk accumulation as systemic concerns. Available at https://www.bankofengland.co.uk/financial-stability-report/2024/june-2024; FPC Meeting Records, June 2024: The Financial Policy Summary and Record from the June 2024 FPC meeting discusses leveraged finance risks. Available at https://www.bankofengland.co.uk/financial-policy-summary-and-record/2024/june-2024. 
44 Bank of England, Financial Policy Committee, Financial Stability Reports, December 2023.Available at https://www.bankofengland.co.uk/financial-stability-report/2023/december-2023; June 2024. Available at: https://www.bankofengland.co.uk/financial-stability-report/2024/june-2024; December 2024. Available at: https://www.bankofengland.co.uk/financial-stability-report/2024/december-2024; July 2025. Available at: https://www.bankofengland.co.uk/financial-stability-report/2025/july-2025.}

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