A settlement between the SEC and a former investment adviser is a cautionary tale for fund managers that may not realize that common practices within the industry create opportunities for malfeasance when the data used in investor communications is insufficiently scrutinized. Along that vein, the SEC released an order accusing a former registered investment adviser and its co‑founder of making “materially false and misleading statements to investors” about its flagship fund and two feeder funds and failing to disclose a conflict of interest regarding a competing fund. This article examines the issues raised by the enforcement action and offers insights from Igor Rozenblit, managing partner of Iron Road Partners, on how to avoid the inadvertent or deliberate release of materially misleading information. A common problem, Rozenblit said, is that the compliance department of any given fund manager will review investor communications to ensure their veracity and flag anything that seems exaggerated or untrue. But owing to many factors, including a possible lack of resources or specific expertise, “compliance departments rarely check the data,” he observed. For additional commentary from Rozenblit, see “Conflicts From Managing Multiple Funds and Other Current Challenges to Effective Compliance at PE Funds” (Nov. 30, 2021); and our two-part series: “Former Co‑Head of SEC Private Funds Unit Describes His New Consulting Firm and the Regulator’s Stance on ESG” (Jul. 20, 2021); and “Former Co‑Head of SEC Private Funds Unit Details Common PE Compliance Deficiencies and Steps to Avoid SEC Scrutiny” (Jul. 27, 2021).