The City of London, where supervisory decisions meet a $2 trillion lending market.
Photo: Unsplash (stock image, not the original news picture)
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The Bank of England is examining whether Barclays shifted £1.5 billion of private credit loans into its trading book, where they need less capital. Barclays says the vast majority of its £15 billion exposure sits in the banking book.
The Bank of Englandis examiningBarclaysover private credit trades
英国央行正在调查巴克莱——围绕其私募信贷交易
PARA 01
The Bank of Englandis examiningwhether Barclays traders misrepresented illiquid private credit loans to understate their risk,1after an insider at the British bank raised concerns,the Financial Times reported on Monday.
The Prudential Regulation Authorityreceiveda complaint earlier this yearabout how Barclays was recording derivatives used to finance private credit loans.
The City of London, where supervisory judgment, capital rules and a £15 billion loan book meet.伦敦金融城：监管判断、资本规则与一笔 150 亿英镑的贷款簿，在这里交汇。Photo: Unsplash (stock image)
PARA 03
The complaintcentred onthe bank's allocation of total return swaps referencing illiquid private credit loans to its trading book,23and the report did not disclose an amount.
投诉集中在该行把参照流动性极差的私募信贷贷款的总收益互换，归入交易账簿一事，报道未披露涉及金额。
PARA 04
The complaintalso allegedthat the way Barclays handled the deals was in breach of the PRA's rules,which restrict banks from assigning derivatives backed by illiquid collateral to their trading book4unless they can supply enough evidence to justify the treatment.
这起投诉还指称巴克莱处理这些交易的方式违反了 PRA 的规则，这些规则限制银行把以流动性极差的资产作抵押的衍生品计入交易账簿，除非能提供足够证据证明这种处理方式站得住脚。
PARA 05
The regulatory concernisthat classifying derivatives linked to illiquid loans as easier-to-trade investmentscould understatethe risk of the underlying exposureand reduce the amount of money required to be set aside for potential losses.
Barclays tradersarguedthe exposure should be treated as a traded positionbecause it was hedged through a matching, or back-to-back, swap with another counterparty,despite being linked to illiquid private credit loans.
Total return swapsallow a bank to finance loans for private credit fundswhile passing the economic performance to the client for a fee.Their use in private credit financingis relatively recentand has gained momentum as funds look to increase leverage by using private loans as collateral.
Chart 1 | How a total return swap moves a private credit loan between a bank's two booksSchematic. Under PRA rules, derivatives backed by illiquid collateral belong in the banking book unless the bank can justify trading book treatment.
PARA 08
Banksclassify assetsinto either the banking book or the trading book,a decision that largely dictates the capital they must hold against potential losses.
银行把资产分为银行账簿或交易账簿两类，这个决定在很大程度上规定了它们必须为潜在损失持有多少资本。
PARA 09
The banking book5holds harder-to-sell loansthat require higher capital reserves,while the trading book is meant for assets that can be sold easily.
银行账簿装的是较难出售的贷款，需要更高的资本准备，而交易账簿本应装容易出售的资产。
Prices on a trading screen change by the second. Private credit loans have no such screen.交易屏幕上的价格随时在变；私募信贷贷款没有这样的屏幕。Photo: Unsplash (stock image)
PARA 10
Improperly allocating illiquid assets to the trading bookwould potentially reducecapital requirementsand boost profitability.The private credit loans underpinning the derivatives would ordinarily sit in the banking book, where higher capital requirements apply.
The PRAin a letter to finance directors last year,expressly warned banksagainst seeking to game the capital rules by repackaging illiquid assets as tradeable ones."We have identified that for certain financing portfolios, banks have adopted an imprudent approach,"it wrote, warning of "a potential undercapitalisation of the risks."
PRA 在去年写给财务主管的一封信中，明确警告各银行不要试图把流动性极差的资产重新包装成可交易资产，来钻资本规则的空子。“我们发现，在某些融资组合上，银行采取了一种不审慎的做法，”信中写道，并警告这会造成“风险资本不足的隐患”。
PARA 12
The letteraddedthat "the repackaging of illiquid assets into a tradeable formatis not, without appropriate supporting evidence,sufficient to justify regulatory capitalisation under trading book rules."
Barclayssaidits £15 billion ($19.97 billion) private credit exposure was treated in line with accounting and regulatory capital requirements.Its treatment of total return swapswas consistent with those rules,and the vast majority of the exposure sits in the banking book.
The mark-to-market value6of its exposure to loan total return swaps linked to private credit assetswas about £300 million,based on roughly £1.5 billion of underlying notional.
Under capital rules,Barclayssaidit was required to meet certain conditions to classify the treatment as trading book,and those conditions had been met and supported by internal governance and external advisers.
"Barclays takes seriously its regulatory obligations in markets where it operates,"the bank said in a statement.It declined to comment furtheron its interactions with the regulator,and the Bank of England declined to comment on the report.
Private credit loansare considered illiquidbecause they cannot be traded on secondary markets and lack daily mark-to-market valuations.Their valuationsits at the centre of concernsabout the $2 trillion private credit industry.
Regulators in Europe, the UK and the UShave warnedthat valuations could leave lenders exposed to losses in a market slowdown,and that links between banks and private credit funds could be contributing to systemic risks.7
Private creditis non-bank lending to unlisted companies,and it has grown rapidly over the last 15 years.Global assets under managementare projected to reach $3 trillion by 2028,nearly ten times the 2010 level.
Chart 2 | Private credit assets under management, 2010, 2026 and the 2028 forecast2010 and 2028 figures are from the Financial Times report (2028 is a projection); 2026 is the roughly $2 trillion industry size cited by regulators and the FT.
PARA 21
Bankshave helped fuelthe boomby providing hundreds of billions of dollars in financingto a sector that now handles much of the lending to higher-risk companies.
银行助推了这轮繁荣——它们向这个如今承接大量高风险企业贷款的行业提供了数千亿美元融资。
PARA 22
Barclays' overall risk-weighted assets8rose by £15.4 billionto £358.1 billion,from £342.7 billion in December 2023, with credit risk accounting for £11.2 billion of the increase.
Accounting and capital: which book a loan sits in decides how much capital is set aside.会计与资本：同一笔贷款记在哪本账，决定了要留多少资本。Photo: Unsplash (stock image)
PARA 23
"The concernsare quite technicaland relate to how its exposure to private credit loans had been recorded for accounting purposes,and the impact this had on the amount of capital Barclays has to hold as a buffer against future turbulence."9
"The market reaction,while negative,is relatively measured,suggesting markets are in 'wait-and-see' mode right now.But on the basis any probe could be extensive,it could remain a cloud hanging over the business for some time to come."
The complaintcomes at a sensitive time for the PRA,whose chief executive, Katharine Braddick, worked at Barclays immediately before taking her public sector role this year.Braddickmust recuse herselffrom any matters involving her former employer until the end of the year.
这起投诉对 PRA 来说时机敏感，因为该机构首席执行官 Katharine Braddick 今年出任公职前，刚刚离开巴克莱。Braddick 必须回避任何涉及前雇主的事务，直到今年年底。
PARA 26
The PRAlaunchedthe world's first stress test of the private markets sectorin December last year,with Apollo, Ares, Blackstone, Carlyle and KKR among those taking part;results are due in 2027.
PRA 启动了全球首例私募市场压力测试，时点是去年 12 月，参与机构包括 Apollo、Ares、Blackstone、Carlyle 和 KKR；结果预计于 2027 年公布。
PARA 27
The plumbing behind fund-level leverageis where the story really sits:bank financing lines, including swap-based structures,run underneathmany direct-lending and asset-based strategies.
Investorswill watchwhether the PRA broadens its review to other lenders' swap books,and whether banks respond by tightening terms on financing provided to private credit vehicles.Any supervisory push to reprice that financingcould raise the cost of leverage for funds.
投资者将关注 PRA 是否把审查扩大到其他银行的掉期账簿，以及银行是否会收紧对私募信贷载体的融资条件。任何要求对这类融资重新定价的监管动作都可能推高基金的杠杆成本。
PARA 29
The questionis notwhether private credit loans are risky.
问题不在于私募信贷贷款是否有风险。
PARA 30
It iswhether the books say soand whether the capital held against themreflectswhat would happen if the loans had to be sold.
Extended note: Private credit took over lending that banks found too capital-intensive after 2008. Its main risks are borrower leverage, fund-level borrowing and how often loans are repriced — the less visible these are, the worse a redemption run would be.
2total return swap/ˈtəʊtl rɪˈtɜːn swɒp/点击看中文解释 ↓
A derivative in which one side pays the total return of an asset — interest plus any gain or loss — and the other pays a fixed or floating rate. The asset itself never changes hands.
Why it matters here ▸ The complaint is about swaps referencing £1.5 billion of private credit loans, with a market value of about £300 million.
Extended note: The economic question with any TRS is who really bears the risk of the underlying asset. Using one purely to move risk into a cheaper regulatory bucket is what supervisors call capital arbitrage.
3trading book/ˈtreɪdɪŋ bʊk/点击看中文解释 ↓
The part of a bank's balance sheet meant for assets it intends to trade. Because they are assumed to be sellable, they carry a lighter capital charge than loans held to maturity.
Why it matters here ▸ Barclays put the swaps here; the PRA says that is only allowed with enough evidence.
Extended note: The split is about intent and capability, not the asset itself: can the bank price it, hedge it and exit quickly? An illiquid loan booked as tradable is the classic form of capital arbitrage.
4illiquid/ɪˈlɪkwɪd/点击看中文解释 ↓
Hard to sell quickly without moving the price. A liquid asset can be sold in days at a known price; an illiquid one may take months and a discount.
Why it matters here ▸ The PRA's rule turns on whether the collateral behind a derivative is illiquid.
Extended note: Liquidity is a stress concept: not whether a buyer exists today, but whether one exists when everyone is selling at once. That is why supervisors test it under stress, not in calm markets.
5banking book/ˈbæŋkɪŋ bʊk/点击看中文解释 ↓
The part of the balance sheet for assets the bank plans to hold, such as ordinary loans. They are harder to sell, so they require more capital.
Why it matters here ▸ Barclays says the vast majority of its £15 billion private credit exposure sits here, not in the trading book.
Extended note: The same loan can carry very different capital charges depending on the book. Hence the supervisory principle that substance beats form: re-labelling an asset is not the same as transferring its risk.
6mark-to-market/ˌmɑːk tə ˈmɑːkɪt/点击看中文解释 ↓
Valuing an asset at the price it would fetch today, rather than at what it cost. It needs a market price — which illiquid loans do not have.
Why it matters here ▸ Barclays values its private credit swaps at about £300 million mark-to-market, against £1.5 billion of notional.
Extended note: Without a market price, banks fall back on models whose assumptions they choose themselves. That is the core supervisory worry: when valuation is self-reported, losses can be deferred rather than recognised.
7systemic risk/sɪˈstemɪk rɪsk/点击看中文解释 ↓
The risk that a failure in one part of the financial system spreads and damages the whole system, not just the firm that took the risk.
Why it matters here ▸ Regulators warn that links between banks and private credit funds could be contributing to systemic risks.
Extended note: Three tests matter: size, leverage and interconnection. Bank financing and swaps link the two sides, so a fund shock hits bank capital, and a bank pullback forces fund selling — a two-way feedback loop.
Extended note: RWA is the denominator of the capital ratio. A bank can lift its ratio by holding more capital or by making assets look safer. The second route is where supervisory attention concentrates.
9capital buffer/ˈkæpɪtl ˈbʌfə/点击看中文解释 ↓
Extra capital a bank holds on top of the minimum, so it can absorb losses in a downturn without failing.
Why it matters here ▸ Mould says the dispute is about how much capital Barclays must hold as a buffer against future turbulence.
Extended note: A buffer is not there for the first loss but for a cluster of them. Thin buffers force banks to cut lending early, which deepens the downturn — the reason capital rules are set for the system, not just the firm.
In agreement with a rule, standard or expectation.
Barclays said the exposure was treated in line with accounting and regulatory capital requirements.
符合、与……一致（多用于合规、标准、预期）。
巴克莱表示，该敞口是按会计准则与监管资本要求处理的。
set aside/set əˈsaɪd/
To keep money or resources for a specific future purpose, such as covering losses.
Classifying the swaps as tradable could reduce the money required to be set aside for potential losses.
预留、拨出（资金）备用。
把掉期归为可交易资产，可能减少为潜在损失需要预留的资金。
understate/ˌʌndəˈsteɪt/
To describe something as smaller or less serious than it really is.
The concern is that traders understated the risk of the loans.
低估、少报（把风险、数字说得比实际小）。
担忧在于，交易员低估了这些贷款的风险。
game the rules/ɡeɪm ðə ruːlz/
To exploit the wording of rules to get an advantage without technically breaking them.
The PRA warned banks against trying to game the capital rules by repackaging loans.
钻规则的空子（形式上不违规，实质上绕开本意）。
PRA 警告银行不要试图通过重新包装贷款来钻资本规则的空子。
back-to-back/ˌbæk tə ˈbæk/
Two matching deals arranged together, so that the risk of one is offset by the other.
Traders said the position was hedged through a matching, or back-to-back, swap.
背对背（两笔完全对应的交易，一头的风险由另一头对冲）。
交易员称，该头寸已通过一笔对应的、即背对背的掉期做了对冲。
pass on/pɑːs ɒn/
To transfer the financial outcome of an asset to another party, usually for a fee.
A total return swap lets a bank finance the loan while passing the economic performance to the client.
把（资产的经济表现）转手给另一方，通常收取费用。
总收益互换让银行为这笔贷款融资，同时把经济表现转给客户。
take seriously/teɪk ˈsɪəriəsli/
To treat something as important and act on it, rather than dismissing it.
"Barclays takes seriously its regulatory obligations in markets where it operates," the bank said.
认真对待、当回事。
该行表示：“巴克莱认真对待其在各市场的监管义务。”
buffer against/ˈbʌfə əˈɡenst/
Something that protects you from the impact of a future shock.
The capital Barclays holds acts as a buffer against future turbulence.
抵御……的缓冲（垫）。
巴克莱持有的资本，是抵御未来动荡的缓冲。
a cloud hanging over/ə klaʊd ˈhæŋɪŋ ˈəʊvə/
A problem that threatens something and makes people uneasy about it.
The probe could remain a cloud hanging over the business for some time.
笼罩在……上的一片乌云（指挥之不去的隐患）。
这项调查可能在未来一段时间里，一直是笼罩在这项业务上的乌云。
wait-and-see/ˌweɪt ən ˈsiː/
Deliberately doing nothing until more information arrives.
The measured share reaction suggests markets are in wait-and-see mode.
观望（先不动，等更多信息）。
相对克制的股价反应说明，市场正处于观望状态。
读后测验 · Check Your Understanding
3 道题。点选项立即判分；解析需要单独点开。
Q1What exactly is the Bank of England examining at Barclays?
正确答案：B
原文的核心指控是「账簿归属」：投诉称巴克莱把参照流动性极差的私募信贷贷款的总收益互换计入交易账簿，从而低估风险、少提资本。A 项说的是「借太多」，原文没有这个指控；C 项「瞒过审计师」是把「少报风险」夸大成了舞弊；D 项「高价转卖」原文完全没有。 The complaint centred on the bank's allocation of total return swaps referencing illiquid private credit loans to its trading book.Option A confuses volume with classification; C exaggerates a reporting dispute into fraud; D invents a sale that never happened.
Q2Why does the trading book matter more than the banking book in this story?
正确答案：B
关键在于资本占用：交易账簿假定资产「随时能卖」，因此资本要求更轻；银行账簿装的是难卖的贷款，资本更重。同一笔风险换个位置，资本就省下来了——这才是投诉的要害。A、C 都是凭空添加；D 错在两者都计入 RWA，只是权重不同。 The banking book holds harder-to-sell loans that require higher capital reserves, while the trading book is meant for assets that can be sold easily.A confuses the two books' purpose; C invents an audit rule; D misstates how RWAs work — both books count, at different weights.
Q3What does the Barclays case suggest about the private credit boom?
正确答案：B
文章收尾的判断是：问题不在于贷款有没有风险，而在于「账簿是否如实反映」以及「计提的资本是否够」。也就是说，风险可能藏在银行给基金融资、再把敞口记进哪本账的环节里。A 与原文「银行提供了数千亿美元融资、行业到 2028 年达 3 万亿美元」相反；C 把「不交易」当成「没风险」，恰是文章反驳的；D 与「银行与基金的联系可能助长系统性风险」相反。 It is whether the books say so — and whether the capital held against them reflects what would happen if the loans had to be sold.A contradicts the growth figures; C mistakes illiquidity for safety; D ignores the systemic link the article stresses.
