A recent SEC resolution with an unregistered fund manager, its principal and several affiliates serves as yet another reminder that private fund managers must make scrupulously accurate disclosures to investors – both in their offering documents and when conflicts of interest arise – and must use appropriate valuation methodologies. For more on proper disclosure, see “Flawed Disclosures to Avoid – and Policies and Procedures to Adopt – for Managers to Reduce Risk of SEC Scrutiny of Fee and Expense Practices (Part Two of Three)” (Sep. 8, 2016). The SEC charged that, in an effort to prop up one fund that they managed, the defendants caused another fund to purchase a 50 percent interest in a portfolio company owned by the first fund at a price set “unilaterally” by the principal. The defendants also allegedly violated the investment-company, broker-dealer and securities-registration provisions of the securities laws. This article summarizes the allegations in the SEC’s 17-count complaint and the terms of the resolutions. See also “Ten Key Risks Facing Private Fund Managers in 2017” (Apr. 6, 2017); and “Eight Bad Excuses Fund Managers Have Raised Trying to Avoid SEC Sanctions for Fee and Expense Allocation Violations and Undisclosed Conflicts of Interest” (Oct. 13, 2016).