Private credit’s next differentiator: an operating model built for trust, control and growth

ASIC and the Financial Services Council (FSC) new principles make a clear case for fund managers to reassess not only policy and governance, but also the technology foundations that make those disciplines repeatable.

For managers navigating greater scale, investor scrutiny and portfolio complexity, the right technology stack can turn controlled operations into a source of confidence—helping to support regulatory expectations through reliable data, documented workflows and clear audit trails, while freeing teams to focus on investment insight, client relationships and building alpha.

 

Private credit has outgrown fragmented operations

Private credit is meeting a real financing need, but its growth has heightened the consequences of weak controls. ASIC’s November 2025 report identified risks relating to opacity, illiquidity, valuation inconsistency, conflicts, fee transparency and credit-risk practices, and called on the sector to assess and strengthen its practices. FSC Standard 30, issued in August 2026, reinforces these themes through a formal industry framework for relevant FSC Full Members. Mandatory from 1 July 2027, it sets expectations across governance, disclosure, fees, valuations, liquidity, leverage, credit risk and conflicts, supporting stronger investor outcomes and confidence in Australia’s private markets.

For fund managers, the practical challenge is not simply knowing what good practice looks like. It is being able to execute it consistently as portfolios grow across facilities, borrowers, amendments, cashflows, pricing inputs, approvals, exceptions, impairments and investor reporting.

Involuntary remediation is reactive, mandated by a regulatory body through a consent order or enforcement action following a finding of non-compliance or systemic failure. With involuntary remediation, the firm has less control over the process and timelines in addressing the issue. Proceedings may be a matter of public record. There can be significant legal, operational, and reputational costs.

That is where technology matters. A patchwork of spreadsheets, email approvals and disconnected data sources can make it difficult to establish a reliable operational record, demonstrate who approved what and when, or bring decision-useful information to boards, trustees and oversight teams. It also diverts skilled people from higher-value work.

Sentry is designed to help private credit managers centralise loan operations, strengthen controls and support accountable oversight. It is an operational-control platform—not a substitute for regulatory obligations, manager policies, independent oversight or professional advice. But deployed with sound governance, it can provide the controlled data, workflow discipline and audit evidence that help turn policy into day-to-day practice.

ASIC has set a clear benchmark for private credit

As private credit grows, ASIC has highlighted the need for stronger practices around transparency, liquidity, valuations, conflicts, fees and credit risk. Its ten principles provide a clear benchmark for managers to assess and strengthen practices that support investor trust and market integrity.

ASIC also identifies adequate technology resources as part of organisational capability. Its principles reinforce the importance of technology and controls that enable managers to operate efficiently, honestly and fairly as funds grow in size and complexity.

A more connected technology foundation can help reduce reliance on fragmented spreadsheets and manual processes by supporting controlled data, consistent workflows, timely reporting and clear audit trails. Broadridge outsourcing services can also provide additional operational support and an independent review layer, subject to the manager’s governance arrangements and oversight requirements.

FSC Standard 30 provides a practical implementation framework

FSC Standard 30 reinforces ASIC’s principles and sets clear expectations for relevant FSC Full Members managing Australian private markets funds. Private credit managers are also subject to specific credit-risk management provisions.

Mandatory from 1 July 2027, the Standard covers governance, disclosure, fees, valuations, liquidity, fund leverage and refinancing, credit risk and conflicts. It also requires relevant members to attest annually to their compliance.

The Standard is designed to be applied proportionately, based on each fund’s structure, investor base, scale, complexity and risk profile. Its message is clear: strong governance must be embedded in day-to-day operations through reliable information, clear decision-making, documented escalation and effective oversight.

Why the technology decision is now a strategic one

ASIC explicitly identifies adequate human, financial and technological resources as part of organisational capability. That recognition matters. Technology is no longer simply an efficiency consideration for private credit managers; it is increasingly part of the infrastructure needed to operate efficiently, honestly and fairly as a fund grows in size and complexity

A modern loan-operations platform can help management teams move from retrospective control checks to a more controlled and visible operating rhythm. Instead of asking teams to reconstruct information from multiple sources at month-end or during a board review, managers can establish a more consistent source of operational truth across the loan lifecycle.

  • More confidence in data: centralised records help reduce ambiguity across trades, positions, lifecycle events and exceptions
  • More accountable decisions: configurable workflows, approval rules and audit trails can make decision rights and overrides more visible and easier to evidence.
  • More resilient operations: reducing manual handoffs and spreadsheet dependency can help teams scale without adding proportionate operational risk.
  • More useful oversight: boards, trustees, risk and operations teams can receive a clearer operational picture, enabling attention to focus on judgement, challenge and action.
  • More capacity for alpha: when core processes are controlled and repeatable, investment and client teams can spend less time reconciling operational information and more time on origination, portfolio insight and investor service.

From principles on paper to controls in practice

How Broadridge can support a best-practice private credit operating model

Sentry captures and monitors key portfolio information, including exposures, valuations, risks and fees, so it can be readily presented in investor reporting.Broadridge can review investor-facing documentation to help assess whether it is clear, accessible and easy for investors to understand.Sentry calculates and captures loan-level fees across the portfolio, enabling managers to produce clear fee reports that show all charges within the loan book.
ASIC principle How Broadridge can help
1. Stewards of other people’s money Sentry can help by setting up a board/trustee overview report in which elements such as valuations, fees, conflicts of interest, audit trail, governance, risk and liquidity are covered
2. Organisational capability Broadridge has a team that can help assess your operational resilience and readiness. Alternatively, you may choose to engage an external provider to undertake an independent audit or review.
3. Transparency Sentry captures and monitors key portfolio information, including exposures, valuations, risks and fees, so it can be readily presented in investor reporting.
4. Design and distribution Broadridge can review investor-facing documentation to help assess whether it is clear, accessible and easy for investors to understand.
5. Fees and costs
6. Conflicts of interest Configure tailored governance checks within Sentry and generate clear, results-based reports to support ongoing monitoring, transparency and informed decision-making.
7. Governance Sentry enables you to configure approval layers and compliance checks, while maintaining a clear audit trail of escalations, decisions and final approvals.
8. Valuations Sentry captures valuations throughout the life of a fund, providing a clear view of valuation history, trends and significant changes over time. It can record the valuation methodology, including whether the valuation was independently sourced, and maintain an audit trail of valuation changes and their supporting rationale. This can help managers support robust valuation governance, oversight and reporting.
9. Liquidity Sentry helps provide a clear view of loan liquidity by reporting when loans can be liquidated under their contractual terms, along with applicable notice periods and expected timeframes.
10. Credit risk Sentry enables you to configure tailored governance checks, track their outcomes over time and define risk thresholds with clear escalation steps when those thresholds are met.

Additional FSC Standard 30 focus: leverage and refinancing risk

Technology can help private markets managers identify, monitor and govern material fund-level leverage and refinancing arrangements by centralising facility terms, maturity dates, repayment obligations, cashflows and covenant-related information.

A connected operating view can support consistent reporting, scenario analysis and timely escalation where leverage or refinancing risk may affect liquidity, valuations, distributions, redemptions or investor outcomes.

A practical path forward

Fund managers do not need to solve every operating challenge at once. They should begin with an honest assessment of where the current technology stack supports—or inhibits—the ten principles, using the FSC guidance as a more detailed implementation reference.

  1. Map the operating model: Identify where trade, position, valuation, lifecycle, fee, liquidity and credit-risk data is created, changed, approved and reported.

  2. Assess governance evidence: Confirm that decision rights, delegated authorities, approvals, escalation pathways, committee reporting and independent challenge are documented and can be evidenced.

  3. Identify control breaks: Focus on fragmented data, manual reconciliations, undocumented approvals, stale pricing inputs, weak exception escalation and unclear ownership.

  4. Prioritise the highest-impact workflows: Target the controls that most directly support governance, valuations, conflicts, transparency and credit-risk monitoring.

  5. Embed accountability: Configure roles, permissions, limits, workflows and audit requirements to reflect documented policies and delegation frameworks.

  6. Build for the next stage of growth: Choose a platform that can support changing asset classes, portfolio complexity, reporting expectations and operating volumes.

The opportunity: build the operating foundation for what comes next

ASIC’s principles are a timely call for private credit managers to strengthen practices before market conditions shift or control gaps become more difficult to address. The FSC guidance provides a practical framework to translate those principles into detailed operating disciplines.

The firms best placed to respond will not view technology as a back-office replacement exercise. They will view it as a strategic operating foundation for disciplined growth.

Broadridge can help managers centralise loan operations, strengthen control processes and support accountable oversight across the private credit lifecycle. Combined with strong policies, experienced teams and independent governance, it can help create the operational confidence managers need to protect investors, serve clients and stay focused on building alpha.

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