The SEC recently announced that it had settled charges against an investment adviser for failing to maintain and preserve off-channel communications in breach of its recordkeeping obligations (Order). The violations in the Order are largely unexceptional. Instead, the most notable feature of the Order is that the SEC’s Division of Enforcement (Enforcement) decided not to issue a civil penalty due to the firm’s self-reporting, cooperation and remedial measures. In the accompanying press release, then‑Director of Enforcement Gurbir S. Grewal touted that the resolution “shows that the full benefits of cooperation are available in recordkeeping matters.” He went on to emphasize that the firm’s “self-reporting and prompt remedial efforts weighed heavily in [Enforcement’s] decision to recommend that the Commission not impose a penalty . . . [and that t]his resolution should serve as a model for other investment advisors that are not currently in compliance with federal recordkeeping requirements.” At first glance, the Order may seem like a panacea to beleaguered investment advisers searching for the right balance of self-reporting, cooperation and remediation to manage their SEC examination risks. In reality, however, the facts in the Order are sufficiently nuanced and bespoke to the matter at hand as to render the outcome more underwhelming than touted by the SEC. This article summarizes the key features of the Order and provides insights from experts interviewed by the Private Equity Law Report. See our two-part series on SEC cooperation credit: “Examining HeadSpin as a Framework for Optimal Remediation Measures” (Jun. 1, 2023); and “Inherent Obstacles to Fund Managers Receiving Full Credit” (Jun. 15, 2023).