Risk management for private equity is essential for protecting portfolio value and meeting regulatory requirements. In June 2023, a mid-market PE firm closed a $340 million acquisition of a healthcare technology company. Sixty days post-close, a ransomware attack encrypted patient records across the portfolio company’s entire network.

The incident response cost $8.2 million, regulatory fines followed at $3.5 million, and two key hospital system clients terminated contracts worth $22 million in annual recurring revenue.

The deal thesis assumed a 3x exit multiple in five years; the revised model showed breakeven at best. Pre-acquisition cyber due diligence had consisted of a single vendor questionnaire that rated the target as “satisfactory.”

Key Takeaways
Global PE AUM reached $10.8 trillion in 2025, yet private equity risk management maturity lags far behind the capital deployed, creating material exposure for GPs and LPs.
80% of PE firms experienced cybersecurity-related disruption during the hold period in the past year, with an average financial impact of $2.1 million per incident.
The SEC’s 2026 examination priorities target fiduciary duty, fee practices, valuation methodology, and cybersecurity for private fund advisers, raising the compliance bar.
Only 12% of PE firms under $25 billion AUM enforce mandatory cybersecurity baselines across portfolio companies, compared with 55% of firms above $25 billion.
Effective private equity risk management requires a layered framework spanning deal-level due diligence, portfolio-level aggregation, and firm-level ERM governance.
KRIs calibrated to the PE lifecycle (sourcing, diligence, hold, exit) provide early warning signals that prevent value destruction at each stage.
A 90-day implementation roadmap can establish the governance, tools, and reporting cadence for a defensible private equity risk management program.

Risk management for private equity is no longer a back-office function bolted onto deal execution. With global PE AUM reaching $10.8 trillion in 2025 (McKinsey Global Private Markets Report, 2026) and the SEC’s 2026 examination priorities explicitly targeting private fund adviser practices, the industry faces a clear mandate: build disciplined enterprise risk management capabilities or accept value destruction as a recurring cost of business.

A Kroll survey of 325 PE portfolio leaders found that 80% of firms experienced cybersecurity-related disruption during the hold period over the past year, with an average financial impact of $2.1 million per incident.

Yet the governance gap persists: only 12% of firms under $25 billion AUM enforce mandatory cyber controls across their portfolios.

This guide provides PE operating partners, portfolio risk managers, CFOs, and LP allocators with a practitioner-focused framework for risk management for private equity across the full investment lifecycle.

You will find due diligence risk frameworks, portfolio-level aggregation models, KRI dashboards, SEC compliance maps, and a 90-day implementation roadmap designed for the resource constraints that PE firms actually operate under.

Risk Management for Private Equity: The 2026 Landscape

The scale and complexity of the private equity industry have fundamentally changed the risk calculus. Median purchase multiples reached 11.8x EBITDA in 2025, meaning entry prices leave less margin for error.

Dry powder is moderating after years of accumulation, forcing deployment discipline. North American fundraising increased 8% year-on-year to $432 billion, while take-private deal value rose 72% (Bain Global Private Equity Report, 2026).

These dynamics mean that risk management for private equity is no longer about avoiding catastrophic loss events alone; it is about protecting the operating value that justifies premium entry multiples.

Private Equity Market Growth and Risk Exposure

Global PE AUM reached $10.8T in 2025, with deal value recovering to $750B (Sources: McKinsey, Bain, PwC, 2025-2026)
Risk Management for Private Equity: Due Diligence, Portfolio Risk, and ERM

Figure 1: Global PE AUM reached $10.8T in 2025, with deal value recovering to $750B (Sources: McKinsey, Bain, PwC, 2025-2026)

The risk categories confronting PE firms have expanded well beyond traditional financial and market risk.

Today’s risk management for private equity universe encompasses six interconnected domains: operational risk within portfolio companies, market and valuation risk across the fund, compliance and regulatory risk driven by SEC enforcement, cybersecurity risk that can destroy deal value overnight, ESG and reputational risk that LPs increasingly screen for, and liquidity and exit risk in a market where continuation vehicles are replacing traditional exits.

Each domain requires its own risk assessment methodology while feeding into a unified firm-level view.

Private Equity Risk Universe: Impact and Likelihood

Compliance and operational risk score highest on both axes, while ESG risk is rising rapidly (Source: Author analysis based on Kroll, SEC, McKinsey, 2025-2026)
Risk Management for Private Equity: Due Diligence, Portfolio Risk, and ERM

Figure 4: Compliance and operational risk score highest on both axes, while ESG risk is rising rapidly (Source: Author analysis based on Kroll, SEC, McKinsey, 2025-2026)

Due Diligence Risk Framework for Private Equity Risk Management

Pre-acquisition due diligence is the first and highest-leverage point in risk management for private equity. A disciplined diligence process identifies risks that, if missed, become post-close value destroyers.

The framework below extends traditional financial and legal diligence into the operational, cyber, and ESG domains that increasingly drive hold-period outcomes.

Comprehensive PE Due Diligence Risk Categories

Diligence DomainKey Risk AreasAssessment MethodsRed Flags
FinancialRevenue quality, working capital, debt structure, off-balance-sheet liabilitiesQuality of earnings analysis, forensic accounting, normalized EBITDA reconciliationCustomer concentration > 20%; aggressive revenue recognition; related-party transactions
OperationalManagement depth, key-person dependency, process maturity, supply chainManagement interviews, RCSA workshops, process mapping, supplier concentration analysisSingle-source dependencies; no documented SOPs; founder-dependent customer relationships
CybersecurityIT architecture, data protection, incident history, OT/IoT exposurePenetration testing, vulnerability scanning, security rating (BitSight/SecurityScorecard), data flow mappingNo CISO/security function; unpatched critical vulnerabilities; prior breach not disclosed
Compliance & RegulatoryLicensing, regulatory filings, litigation pipeline, sanctions exposureRegulatory filing review, litigation database search, sanctions screening, interview with GCOpen regulatory investigations; history of enforcement actions; incomplete filings
ESG & ReputationEnvironmental liabilities, labor practices, supply chain ethics, DEI metricsEnvironmental site assessments, ESG questionnaire, media/social sentiment analysisEnvironmental remediation obligations; labor violations; greenwashing claims
Market & CompetitiveMarket position, competitive moats, technology disruption exposureTAM/SAM/SOM analysis, competitive benchmarking, customer NPS/churn analysisDeclining market share; commoditized offering; technology obsolescence risk

Each diligence workstream should produce a risk register that quantifies identified risks using calibrated ranges (best/most likely/worst case) rather than simple red-amber-green ratings.

This quantified output feeds directly into deal pricing, representation and warranty insurance negotiations, and the first 100-day integration plan.

The risk assessment process at the diligence stage sets the quality ceiling for all downstream risk management for private equity activities.

Portfolio-Level Risk Aggregation in Private Equity Risk Management

Deal-level diligence addresses company-specific risk, but risk management for private equity must also account for correlations and concentrations across the portfolio.

A PE fund with 12 portfolio companies may appear diversified until risk analysis reveals that 8 of them share the same cloud hosting provider, 6 operate in sectors exposed to the same regulatory change, or 4 depend on overlapping supply chains.

Portfolio-level risk aggregation surfaces these hidden correlations before they produce correlated losses.

Portfolio Risk Aggregation Matrix

Concentration TypeWhat to MeasureAggregation MethodAction Threshold
Sector ConcentrationRevenue exposure by GICS sector across all portfolio companiesSum portfolio revenue by sector; calculate Herfindahl-Hirschman Index (HHI)HHI > 2,500 = highly concentrated; diversification review required
Geographic ConcentrationRevenue and operations by country/regionMap revenue and FTE by geography; overlay geopolitical risk ratings> 40% in single country triggers geographic hedge analysis
Customer ConcentrationShared major customers across portfolio companiesCross-reference top-10 customer lists across portfolio; identify overlapsAny customer representing > 15% of aggregate portfolio revenue
Technology / VendorShared IT infrastructure, SaaS platforms, cloud providersVendor dependency mapping across portfolio; single-point-of-failure analysisSame vendor serving > 50% of portfolio = single-point risk
Regulatory ExposureCommon regulatory regimes and pending rule changesMap each portfolio company to applicable regulators; scan for pending changesRegulation affecting > 30% of portfolio value triggers scenario analysis
Key Person DependencyShared management talent and succession gapsMap critical roles across portfolio; identify succession readinessAny portfolio company with 0 successors for CEO/CFO/CTO

The output of portfolio risk aggregation should be a quarterly portfolio risk dashboard that the investment committee reviews alongside financial performance.

This dashboard integrates key risk indicators from each portfolio company into a fund-level heat map, enabling the GP to identify emerging concentration risks and take corrective action, whether through add-on acquisitions that diversify, strategic exits that reduce overweight positions, or targeted risk mitigation investments at the portfolio company level.

The risk monitoring process must be embedded in the fund’s operating cadence, not treated as a periodic exercise.

Cybersecurity Risk in Private Equity Risk Management

Cybersecurity has become the single most consequential operational risk in private equity. The Kroll 2025 survey found that 80% of PE firms experienced cyber disruption during the hold period, and the financial impact extends far beyond incident response costs.

Cyber events delay exits, trigger regulatory investigations, void representations and warranties, and destroy the operational improvements that PE firms spend years building.

risk management for private equity programs that treat cybersecurity as an IT issue rather than a board-level investment risk are systematically underpricing their exposure.

Cybersecurity Risk Management Maturity by PE Firm Size

Risk Management for Private Equity: Due Diligence, Portfolio Risk, and ERM
Risk Management for Private Equity: Due Diligence, Portfolio Risk, and ERM

Figure 2: A stark governance gap exists: 55% of large PE firms enforce cyber baselines vs. only 12% of smaller firms (Sources: Kroll, QBE, Wellington Management, 2025)

The governance disparity between large and small PE firms creates a two-tier risk management for private equity landscape.

Firms above $25 billion AUM are 4.5 times more likely to enforce mandatory cybersecurity baselines across portfolio companies, have dedicated portfolio cyber leaders, and conduct pre-acquisition penetration testing.

Smaller firms, managing the majority of mid-market deals where cyber maturity tends to be lowest, face the paradox of higher risk exposure with fewer risk management resources.

The solution is not to replicate the large-firm approach at smaller scale but to implement a risk-based tiering model that concentrates cyber investment on portfolio companies with the highest data sensitivity, regulatory exposure, and customer-facing digital operations.

PE Cybersecurity Risk Management Baseline

Control CategoryMinimum BaselineEnhanced (High-Risk Portcos)Evidence for SEC/LP
GovernanceDesignated cyber risk owner at each portcoCISO or vCISO with board reporting lineOrg chart + board reporting cadence documentation
Access ControlMFA on all privileged accounts; quarterly access reviewsZero-trust architecture; PAM solution deployedMFA audit logs; access review completion records
Patch ManagementCritical patches within 30 days; high within 60Critical within 14 days; automated patching for endpointsPatch compliance reports; vulnerability scan results
Incident ResponseDocumented IR plan; tabletop exercise annuallyIR retainer with forensics firm; quarterly exercisesIR plan document; exercise after-action reports
Third-Party RiskAnnual vendor security questionnaire for critical vendorsContinuous monitoring via security rating platformVendor risk register; security rating trend reports
Data ProtectionEncryption at rest and in transit; backup testing quarterlyDLP solution; immutable backups; air-gapped recoveryEncryption audit; backup recovery test logs

SEC 2026 Examination Priorities and Private Equity Risk Management

The SEC’s Division of Examinations released its 2026 priorities under Chairman Paul Atkins, and private fund advisers remain squarely in the crosshairs.

For risk management for private equity leaders, these priorities translate directly into the compliance controls, documentation, and governance structures that examiners will scrutinize.

The six priority areas map to specific risk management actions that PE firms must embed in their operating model.

SEC 2026 Examination Priority Areas for Private Equity

Figure 3: Fiduciary duty and cybersecurity dominate SEC exam intensity for PE advisers in 2026 (Sources: SEC, Goodwin, Harvard Law, 2025-2026)

SEC Priority AreaWhat Examiners Will ScrutinizePrivate Equity Risk Management Response
Fiduciary Duty & ConflictsFee allocation, co-investment allocation, side letter consistency, related-party transactionsConflicts register mapping all affiliated transactions; annual conflicts review by CCO; LP disclosure audit
Fee & Expense PracticesManagement fee calculations, broken-deal expenses, portfolio company monitoring fees, fee offsetsFee waterfall documentation; expense allocation policy with LP-approved methodology; quarterly fee reconciliation
Valuation MethodologyFair value policies, valuation committee governance, third-party valuation use, quarter-over-quarter changesDocumented valuation policy per ASC 820; independent valuation committee; annual third-party review of material positions
Cybersecurity & Operational ResilienceCyber policies, incident response plans, vendor oversight, business continuityCybersecurity baseline enforcement across portfolio; incident response plan with tabletop evidence; BCP testing documentation
ESG / AI GovernanceESG claims in marketing, AI use in portfolio monitoring, automated investment toolsESG policy with substantiation requirements; AI governance framework; marketing review for ESG accuracy
Marketing & Performance ClaimsPerformance track record, gross-to-net returns, cherry-picked case studies, hypothetical performanceMarketing review process per SEC Marketing Rule; standardized performance calculation methodology; pre-clearance workflow

Each SEC priority area should map to a control in your compliance risk assessment framework.

The most defensible approach is to build a regulatory compliance risk assessment template that cross-references SEC exam priorities with your firm’s specific policies, identifies gaps, and assigns remediation owners with deadlines.

risk management for private equity teams that wait for an examination letter to begin this mapping will find themselves in a reactive posture that compounds both compliance risk and examination duration.

Building an ERM Framework for Private Equity Risk Management

Traditional enterprise risk management frameworks designed for operating companies do not translate directly to PE firms, where the entity managing risk (the GP) and the entities bearing risk (portfolio companies) are legally and operationally distinct.

A risk management for private equity ERM framework must operate at three levels simultaneously: the firm level (GP operations, fund compliance, LP governance), the portfolio level (cross-company aggregation and concentration), and the company level (individual portfolio company operational risk).

ISO 31000 provides the overarching risk management principles, while COSO ERM offers the governance architecture that links strategy to risk appetite.

Three-Tier PE Risk Management Architecture

TierScopeRisk CategoriesGovernance OwnerReporting Cadence
Tier 1: Firm LevelGP operations, fund compliance, LP commitmentsRegulatory (SEC), fundraising, reputational, key-person, operationalManaging Partner + CCOQuarterly to LPAC; annual to full LP base
Tier 2: Portfolio LevelCross-portfolio aggregation and concentrationSector concentration, vendor dependency, correlated market exposure, aggregate cyber riskCIO / Head of Portfolio OperationsMonthly to IC; quarterly to LPAC
Tier 3: Company LevelIndividual portfolio company risksOperational, financial, cyber, compliance, ESG, market-specific risksPortfolio Company CEO + Operating PartnerMonthly to operating partner; quarterly to IC

The three-tier architecture requires a standardized risk register template deployed across all portfolio companies. Each company completes a quarterly RCSA that feeds into the portfolio-level aggregation engine.

The risk management lifecycle (identify, analyze, evaluate, treat, monitor) runs at all three tiers, with the portfolio tier acting as the aggregation and correlation layer that surfaces risks invisible at the company level.

Key Risk Indicators for Private Equity Risk Management

Effective risk management for private equity requires KRIs calibrated to the PE investment lifecycle.

Unlike operating companies where KRIs track steady-state performance, PE KRIs must signal risk at four distinct stages: deal sourcing, due diligence, hold period, and exit preparation.

The following KRI framework maps indicators to lifecycle stages with thresholds designed for mid-market PE firms.

KRILifecycle StageGreenAmberRed
Due Diligence Completion RateSourcing / Diligence100% of 6 diligence workstreams complete1 workstream incomplete> 1 workstream incomplete or waived
Portfolio Company EBITDA vs. PlanHold PeriodWithin 5% of plan5-15% below plan> 15% below plan
Cyber Baseline ComplianceHold Period100% of portcos meeting baseline80-99% compliant< 80% compliant
SEC Compliance Finding AgingFirm Level0 findings > 60 days open1-2 findings > 60 days> 2 findings > 60 days
LP Capital Call ComplianceFirm Level100% funded within 10 business days95-99% funded< 95% funded
Portfolio Concentration (Top Sector)Portfolio Level< 30% of NAV in single sector30-40% of NAV> 40% of NAV
Exit Readiness ScoreExit PreparationAll exit diligence items green1-2 amber itemsAny red items or unresolved findings
Vendor Risk Rating (Portfolio-Wide)Hold Period> 850 average security rating700-850 average< 700 average
Valuation Markup/Markdown FrequencyHold Period< 10% of positions adjusted > 10%10-20%> 20% of positions with large adjustments
Conflicts Disclosure CompletionFirm Level100% of conflicts disclosed per policy95-99% disclosed< 95% disclosed

These KRIs should be visualized in an integrated KRI dashboard that the investment committee reviews monthly.

The dashboard should present both individual portfolio company traffic lights and aggregated portfolio-level heat maps, enabling the GP to spot emerging patterns, such as multiple portfolio companies simultaneously missing EBITDA targets (suggesting a macro downturn rather than company-specific issues) or a clustering of cyber incidents across portfolio companies sharing the same IT service provider.

90-Day Private Equity Risk Management Implementation Roadmap

This roadmap is designed for mid-market PE firms ($1-10 billion AUM) that have informal or ad hoc risk management practices and want to build a structured, defensible risk management for private equity program.

Larger firms can accelerate timelines; smaller firms may need to phase over 120 days.

PhaseActionsDeliverablesSuccess Metrics
Days 1-30: FoundationAppoint risk management owner (CCO, Operating Partner, or dedicated hire). Conduct firm-level risk inventory across all funds and portfolio companies. Map SEC 2026 exam priorities to existing policies; identify gaps. Deploy standardized risk register template to all portfolio companies. Establish risk governance: IC risk agenda item, LPAC risk reporting cadence.Risk governance charter and RACI. Firm-level risk inventory (draft). SEC compliance gap analysis. Standardized risk register template. Risk reporting calendar.Risk owner appointed with clear mandate. Inventory covers all portfolio companies. SEC gap analysis reviewed by CCO. Risk register template deployed to 100% of portcos.
Days 31-60: Build & QuantifyComplete RCSA workshops at top 5 portfolio companies (by NAV). Quantify top 10 risks using scenario analysis (best/likely/worst case). Build portfolio-level aggregation dashboard (concentration, correlation). Implement cybersecurity baseline assessment across portfolio. Draft risk appetite statement for GP and fund level.Completed RCSAs for top 5 portfolio companies. Quantified risk register with scenario outputs. Portfolio risk aggregation dashboard (beta). Cybersecurity baseline scorecard per portfolio company. Draft risk appetite statement.All 5 RCSAs produce actionable risk registers. Top 10 risks quantified with dollar ranges. Dashboard shows concentration metrics. Cyber baseline gaps documented. Risk appetite reviewed by Managing Partner.
Days 61-90: Integrate & ReportPresent integrated risk profile to investment committee. Deliver first LP risk report (alongside quarterly financial report). Integrate KRIs into portfolio monitoring cadence. Conduct first SEC exam readiness self-assessment. Document risk management policy and procedures.IC-approved risk profile and risk appetite. LP risk report template and first issuance. KRI dashboard live with monthly monitoring. SEC exam readiness assessment with remediation plan. Risk management policy document.IC approves risk appetite covering all 6 risk domains. LP risk report delivered on schedule. KRI dashboard operational with automated data feeds. SEC readiness score > 80%. Policy approved and published.

Common Pitfalls in Private Equity Risk Management

PitfallRoot CauseRemedy
Due diligence as checkboxTime pressure and deal fever override diligence rigor; cyber/ESG workstreams waived to meet closing deadlinesEstablish non-negotiable diligence minimums across all 6 domains; use diligence risk register to track waivers
No post-close risk monitoringDiligence findings filed away after closing; no systematic follow-through on identified risksConvert diligence risk register into 100-day integration risk plan with named owners and deadlines
Portfolio-level blindnessEach portfolio company managed in isolation; no cross-portfolio risk aggregation or correlation analysisImplement quarterly portfolio risk aggregation dashboard; mandate standardized risk reporting from all portcos
Underinvesting in cyberCybersecurity treated as IT cost center rather than value protection investment; no GP-level cyber governanceEnforce minimum cyber baseline across portfolio; tie cyber KRIs to operating partner performance review
Valuation subjectivityValuation methodology applied inconsistently; no independent validation; quarter-over-quarter changes unexplainedDocument ASC 820-compliant valuation policy; establish independent valuation committee; annual third-party review
SEC compliance as CCO siloCompliance function disconnected from investment and operations teams; policies exist but are not operationalizedEmbed compliance checkpoints in deal process, portfolio monitoring, and marketing workflows; quarterly compliance testing
LP reporting gap on riskQuarterly reports focus exclusively on financial returns; risk information shared only when problems emergeInclude risk section in every quarterly LP report: top risks, KRI dashboard, compliance status, and risk appetite alignment
Ignoring ESG beyond marketingESG positioned as fundraising differentiator but not integrated into diligence, monitoring, or exit readinessEmbed ESG assessment in diligence, quarterly monitoring, and exit value story; substantiate all ESG claims per SEC guidance

Looking Ahead: Private Equity Risk Management Trends (2025-2027)

Three forces will reshape risk management for private equity over the next 24 months, creating both compliance imperatives and competitive advantages for firms that move early.

First, AI is transforming every stage of the PE lifecycle, and the risk management implications are profound.

AI-powered deal sourcing is accelerating pipeline velocity, AI-enabled due diligence is analyzing target companies at speeds impossible for human teams, and AI-driven portfolio monitoring is detecting operational anomalies before they appear in financial statements.

But AI also introduces new risks: algorithmic bias in deal screening, overreliance on AI-generated due diligence conclusions, and the SEC’s explicit focus on “automated investment tools” in its 2026 exam priorities.

risk management for private equity programs must develop AI governance frameworks that cover both the use of AI by the GP and the deployment of AI within portfolio companies. The risk assessment policy should explicitly address AI-related risks, including model validation, data quality, and human oversight requirements.

Second, LP demands for risk transparency are intensifying. Institutional investors are asking increasingly sophisticated questions about cybersecurity governance, ESG integration, and operational due diligence as part of their ODD process.

The compliance risk assessment conversation has shifted from “Do you have a compliance program?” to “Show me the evidence that your risk management program actually works.”

GPs that can produce quantified risk dashboards, demonstrated KRI monitoring, and documented risk-based decision-making will win allocations from LPs who have been burned by risk management failures at other funds.

The RCSA methodology adopted from financial services provides the structured, evidence-based approach that LPs expect.

Third, the regulatory landscape is converging. The SEC’s private fund focus, the EU’s AIFMD revisions, and evolving ILPA best practices are creating a multi-jurisdictional compliance matrix that global PE firms must navigate.

Firms that build their risk management for private equity infrastructure on a principled framework like ISO 31000 or COSO ERM will find it easier to map controls to multiple regulatory regimes simultaneously, rather than maintaining parallel compliance programs for each jurisdiction.

The ERM technology platforms designed for alternative asset managers are maturing rapidly, offering portfolio-level risk aggregation, automated KRI monitoring, and regulatory reporting that reduces the compliance burden while improving risk visibility. Firms that invest in these capabilities now will compound the advantage as regulatory complexity continues to increase.

Ready to build a defensible risk management for private equity program? Our risk management consultants specialize in PE-specific ERM frameworks, due diligence risk integration, and SEC exam readiness. Explore our services or contact us directly to schedule a discovery call.

References

1. McKinsey & Company (2026). “Global Private Markets Report 2026.”

2. Bain & Company (2026). “Global Private Equity Report 2026.”

3. PwC (2026). “Private Equity US Deals 2026 Outlook: M&A Trends.”

4. SEC Division of Examinations (2026). “Fiscal Year 2026 Examination Priorities.”

5. Harvard Law School Forum on Corporate Governance (2025). “2026 SEC Exam Priorities and Implications for Investment Advisers.”

6. Goodwin Procter (2025). “2026 SEC Exam Priorities for Registered Investment Advisers.”

7. Kroll (2025). “Private Equity Cybersecurity: A Significant Risk to Deals.”

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9. Wellington Management (2025). “Private Equity Cybersecurity & Data Transparency.”

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11. Oliver Wyman (2025). “Why Private Equity Needs Better Risk Management Now.”

12. Woodruff Sawyer (2026). “Private Equity Risk and Insurance Trends: Looking Ahead to 2026.”

13. BDO (2026). “2026 Private Equity Industry Predictions.”

14. Silicon Valley Bank (2026). “How Private Funds CFOs Can Prepare for 2026 SEC Exams.”

15. IQ-EQ (2026). “Global Private Markets Predictions for 2026.”