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Jan 5, 2026

Does “Skin in the Game” Align Incentives? The Case of CRE CLOs

Abstract

This paper examines whether high levels of risk retention effectively align incentives in securitizations, using evidence from the $100 billion-plus commercial real estate collateralized loan obligation (CRE CLO) market. CRE CLO sponsors retain all equity and non–investment-grade tranches, far exceeding Dodd–Frank Act minimums. Despite this substantial retention, we find that security returns are driven in part by resolving distressed loans through par-value buyouts back to sponsor balance sheets, shifting losses outside the trust. Moreover, sponsors vertically integrated across servicing functions manage distressed loans in ways that reduce the likelihood of failing note protection tests that would divert cash flows away from retained interests. Although these actions bolster reported performance, they raise concerns about resilience if market stress deepens.

Authors

Daniel Broxterman, Florida State University
Larry Cordell, Federal Reserve Bank of Philadelphia
Casey Dougal, Florida State University
Xingliang Ma, Federal Reserve Bank of Philadelphia

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