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.

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