Arnaud Julien (Office Managing Partner, Investment Fund Partner), Stella Rante (Associate) (Photo: Ashurst)

Arnaud Julien (Office Managing Partner, Investment Fund Partner), Stella Rante (Associate) (Photo: Ashurst)

Demand is no longer the primary constraint on the growth of the CLO fund market; execution is. Success increasingly depends on the quality of fund structuring, including the alignment of portfolio and fund terms, transparent governance arrangements, reliable valuation methodologies, and rigorous documentation standards.

In a world navigating between persistent inflation and slowing growth, the CLO market is breaking records, attracting new capital, and redefining investor access to this asset class.

The global CLO market crossed the $1.5 trillion mark in 2025, explaining the growing interest from sponsors, particularly in Europe. The rise of CLO ETFs is the market’s most decisive development.

Choosing the Right Vehicle

Beyond ETFs, a key question arises: what vehicle suits a given CLO strategy? For AAA and AA tranches, which are liquid and floating-rate with predictable cash flows, open-ended structures with daily or weekly liquidity work well, which is certainly why the UCITS ETF wrapper has succeeded for senior CLO strategies in Europe.

For insurance allocators, the amended Solvency II Delegated Regulation introduced a revised look-through approach, allowing insurers to apply risk-sensitive capital charges rather than punitive default treatment. Senior AAA tranches now attract significantly lower capital charges, making them more capital-efficient for insurers seeking floating-rate exposure.

For mezzanine tranches (A to BB), less liquid and more sensitive to credit events, a prudent approach would be semi-liquid vehicles with appropriate dealing periods and liquidity management tools.

Multi-Tranche Strategies and the Platform Approach

Multi-tranche CLO platforms allow investors to access different parts of the capital structure through a single manager, via distinct vehicles tailored to each strategy’s risk and liquidity characteristics. An insurer may want AAA exposure via a separately managed account, its pension affiliate may seek BB exposure through a semi-liquid fund, and its alternatives allocation may include a closed-end CLO equity vehicle.

Despite efficiencies created, building such a platform is complex. Each vehicle requires its own governance, documentation, and fee structure, from bespoke IMAs and detailed reporting for SMAs to full partnership agreements covering capital calls, distributions, and fund lifecycle for closed-end vehicles.

Private Credit Meets CLO

Mid-market CLOs, backed by directly originated loans rather than broadly syndicated leveraged loans, represent roughly 10% of the overall market. These CLOs present different structuring challenges: underlying loans are illiquid, unrated, with no secondary market price discovery, requiring robust valuation frameworks.

The manager’s role also differs. In BSL CLO funds, managers select tranches from third-party deals. In mid-market, the fund manager is often also the CLO manager, originating loans and structuring deals, creating alignment but also conflicts requiring robust governance.

Getting the Foundations Right

The constraint on CLO fund market growth is no longer demand but execution. What makes the difference is structuring quality: alignment between portfolio and fund terms, governance clarity, valuation robustness, and documentation precision. For fund managers entering the CLO space and allocators evaluating the growing fund universe, the question is no longer whether CLOs belong in the portfolio, but whether the fund delivering that exposure has been built to last.