Alt Investments
Putting Private Market Investments Into 401(k) Plans – A Potential Risk Too Far?

In this article, the author argues that without rigorous fiduciary oversight, education and safeguards, putting such investments into mainstream retirement accounts is an accident waiting to happen.
When the Trump administration decided to allow holders of
401(k) retirement plans to hold private market investments,
it highlighted how the oft-used term of “democratization” of such
assets had come to pass. With more firms staying private, or
taking longer to list, there is a legitimate public policy
concern over whether the broad public are being frozen out of
sources of return if they are unable, or barred, from holding
private market assets (equity, credit, infrastructure, etc). On
the flipside, there are risks, and we have heard
skeptical comments about how wide access to private
markets should be. (As an aside, it is worth bearing in mind that
in some markets it is possible to use a listed vehicle, such as
an investment trust, that holds stakes in private equity,
although there can be a wide discount in the share price relative
to net asset value. There has also been a move into the
so-called "evergreen," aka perpetual, field of funds. We examined
potential risks only a few days ago. See
here and
here.)
In any event, debate continues – and recent sharp moves on the
private credit funds size add fuel to
arguments on whether retail investors should be
particularly careful. Entering the fray here is Patrick
Kennedy (pictured below this article), founder and managing
partner, All
Source Investment Management. The editors are pleased to
share these views; the usual editorial disclaimers operate with
views of guest writers. To respond, email tom.burroughes@wealthbriefing.com
and amanda.cheesley@clearviewpublishing.com
I spent years as an alternative investment director at Morgan Stanley before
founding All Source Investment Management, where we build
institutional-grade alternative portfolios for high net worth and
ultra-HNW families. Private credit, private equity, hedge funds,
real estate, infrastructure –these are the asset classes I
live in every day. I believe in them deeply.
And I am telling you that putting them into 401(k) plans is a
serious mistake.
The timing alone should give everyone pause. BlackRock just gated
redemptions on a $26 billion private credit fund. Multiple other
major managers have capped or restricted withdrawals in recent
weeks. These are not failures of the underlying asset class. They
are a reminder that private credit is structurally illiquid, and
the semi-liquid vehicles designed to package it for broader
distribution have real constraints that even sophisticated
investors are now confronting.
Now the proposal is to introduce these same structures into
retirement accounts where the average participant has no advisor,
no understanding of lock-up periods, and no ability to evaluate
credit risk on middle-market loans. That is not
democratization. It is distribution.
And think about how this will work in practice. Most 401(k)
participants don't pick individual funds. More than 60 per cent
of plan inflows go into target date funds. The real play here
isn't a participant choosing "Private Credit Fund X" from a menu.
It's asset managers embedding private credit inside target date
funds where participants never actively selected it and may never
know they own it. That is not giving people access. It is passive
inclusion without informed consent.
Then there's the fiduciary exposure this creates for plan
sponsors, and nobody is talking about it. The average business
owner running a 401(k) is a dentist, a contractor, a software
company founder. They are plan fiduciaries by law. They are now
being told that they can offer private credit and private equity
in their plan lineup, asset classes that require a level of
diligence most institutional allocators find challenging. How is
a business owner with no investment background supposed to
evaluate a private credit manager's underwriting standards,
portfolio concentration, or liquidity terms? They
can't.
And when an employee tries to roll over their account or take a
distribution and learns that a portion of their balance is locked
up in a gated fund, that phone call is going to the business
owner. Not to BlackRock. Not to the record keeper. To the person
who sponsored the plan. These owners did not sign up to explain
redemption queues to their employees. They should not be put in
that position.
Alternatives were built for investors with dedicated due
diligence teams and long-time horizons, not for someone selecting
from a dropdown menu during HR onboarding. The product
architecture hasn't evolved to support this use case. The
complexity hasn't been simplified. The liquidity constraints
haven't been resolved. The only thing that's changed is that the
industry wants a new distribution channel.
Private credit can be a powerful tool in the right portfolio with
the right guidance. But without proper education, fiduciary
oversight, and structural safeguards, putting these products into
401(k)s is a setup for misaligned expectations, or worse, real
harm to the people who can least afford it.

Patrick Kennedy