Arrow's Third Credit Fund Reports 1.14 Billion Euros Sold, Its First SEC-Reported Sales Since 2020

Arrow Credit Opportunities III SCSp, SICAV-RAIF reported $1,306,105,700 sold to 25 investors in a Form D/A filed with the Securities and Exchange Commission on September 8, 2026 (accession 0002074974-26-000001). The Luxembourg fund discloses the rate behind that figure in a clarification of response: one euro to 1.1422 dollars. Run in reverse, the dollar total resolves to exactly 1,143,500,000 euros, a round number in euros, which indicates the SEC dollar figure was converted from a euro-denominated sales figure rather than chosen in dollars.

Two sibling vehicles filed amendments the same day. Arrow Credit Opportunities III USD Feeder SCSp reported $506,750,000 from 19 investors, and Arrow Credit Opportunities III Corporate Feeder SCSp reported $382,500,000 from 21. All three give the same date of first sale, September 9, 2025.

What the filings show

Each of the three vehicles filed an initial Form D on September 8, 2025 reporting no sales and a first sale yet to occur, then filed its first amendment a year later to the day. The date of first sale on all three amendments is September 9, 2025, the day after those original notices. The twelve-month gap is the interval between filings, not a delay before selling: these funds began selling immediately and reported a year later, which is the ordinary annual-amendment cadence for a Form D.

All three claim Rule 506(b) together with Investment Company Act exclusions 3(c), 3(c)(1) and 3(c)(7), classify themselves as a private equity fund, list an indefinite offering amount and set no minimum investment. The master names five related persons: Marion Broch, James Culshaw, Charlotte Gilbert, Clarissa Steland and Revel Wood. Its address is 26, Boulevard Royal, L-2449 Luxembourg, and its year of incorporation is 2025.

A second clarification on the master's filing states that the investment manager receives an annual management fee and that carried interest recipients are entitled to carried interest, with details 'disclosed in the Issuer's confidential offering materials.' The filings put no number on either.

• —Master: $1,306,105,700, or 1,143,500,000 euros at the filing's disclosed 1.1422 rate, from 25 investors
• —USD Feeder: $506,750,000 from 19 investors (accession 0002074970-26-000001)
• —Corporate Feeder: $382,500,000 from 21 investors (accession 0002074386-26-000001)
• —Date of first sale on all three: 2025-09-09; all three amendments filed 2026-09-08
• —Offering amount: indefinite. Minimum investment: none stated.

The two earlier vintages in the SEC record

EDGAR carries five earlier Arrow Credit Opportunities registrants. The first vintage reported sales. Arrow Credit Opportunities SCSp, SICAV-RAIF filed a Form D on January 2, 2020 reporting $120,650,373 from six investors, with its own disclosed conversion rate of 1.11 and a first sale of December 18, 2019. Arrow Credit Opportunities USD Feeder SCSP reported $66,650,000 from two investors in May 2020 and amended to $100,150,000 from five that September.

The second vintage did not. Arrow Credit Opportunities II SCSp, SICAV-RAIF and Arrow Credit Opportunities II USD Feeder SCSp both filed Form Ds on July 29, 2022, and Arrow Credit Opportunities II Feeder A LP filed on October 3, 2022. All three reported no sales and a first sale yet to occur, and none has been amended since. On the SEC record as it stands, the ACO II vehicles have reported zero dollars for four years.

That makes this month's filings the first sales the Arrow Credit Opportunities complex has reported to the SEC since 2020. Form D calls for an annual amendment while an offering remains ongoing, so a silent notice can mean an offering that closed as readily as one that raised money without updating. The filings do not distinguish between the two, and AltStreet is not asserting either.

The figure to be careful with

The three amendments report three different dollar amounts, which sets them apart from the pattern AltStreet watches for most closely in Form D data: master and feeder vehicles that share one combined Item 13 total across every sibling, where summing them multiplies the same money. That is not what happened here. Each vehicle reports its own number.

It does not follow that the three numbers add to $2,195,355,700. Feeder vehicles typically subscribe into their master, which would place the feeders' dollars among the master's 25 reported investors rather than beside them. The master's figure is denominated in euros while both feeders report round dollar amounts, which is what dollar commitments pooled into a euro fund would look like. None of the three filings states whether the feeder totals sit inside the master's or alongside it, so AltStreet does not add them.

Why it matters

For anyone sizing a European private credit manager from public records, the euro figure is the usable one, and the roundness of it is the reason to trust the conversion. The filing's reported dollar sales convert exactly to 1,143,500,000 euros, which strongly suggests the dollar total was converted from a euro-denominated sales figure rather than chosen as a dollar target. What the filing does not say is whether that figure represents a final close, drawn capital or total commitments, so it should not be read as a completed fundraise.

The investor counts are the other signal, and they are consistent with institutional-scale fundraising: 1,143,500,000 euros reported across just 25 investors, an average of roughly 45,740,000 euros per reported investor. That average is arithmetic, not a distribution. The filing discloses no investor identities or types, individual commitments could be very unequal, and the two feeders may themselves account for some of the 25 entries. The three-vehicle shape is consistent with feeders serving different investor groups into a common strategy.

Against the first vintage, the step-up is the point, and because both filings disclose their own rates the comparison can be made in euros, which removes six years of currency movement from it. The 2020 master's $120,650,372.50 at its stated 1.11 converts to about 108,694,029 euros from six investors. This one reports 1,143,500,000 euros from 25, roughly 10.5 times as much. That conversion is approximate in one direction: unlike ACO III's, ACO I's euro figure is not a round number, so its rate was either rounded in the filing or applied to a non-round amount. Whatever the ACO II vehicles did off the SEC record, the complex's reported scale has moved by an order of magnitude across the two vintages that did report.

What the filings do not show

The Form D/A does not disclose the fund's target size, its final close, whether the offering remains open, the identity or type of its investors, the use of proceeds, or whether the reported amount reflects drawn capital or total commitments. The offering amount is listed as indefinite, so the reported sales cannot be read as a share of any goal.

The filings do not state the relationship among the three ACO III vehicles beyond their shared naming, nor whether Arrow Credit Opportunities III Aggregator SCSp, SICAV-RAIF, a separately LEI-registered entity in the same name series, holds any part of the reported amount. That entity is not named in any of the three filings.

Reporting on Arrow Global's fundraising targets, its prior fund sizes and its ownership was attributed to outlets outside AltStreet's citation allowlist and has been excluded from this article. The euro figures above come from the filings' own disclosed conversion rates, not from an outside rate applied by AltStreet.