Conflicts of interest are always top-of-mind for the SEC. A recently settled SEC enforcement proceeding against the principal of an investment adviser is an important reminder for all fund managers that all conflicts of interest – even those arising out of arrangements that may yield little or no financial benefit – must be fully and fairly disclosed, including on an adviser’s Form ADV. This article details the facts and circumstances that gave rise to the enforcement proceeding, the alleged conflicts of interest and the terms of the settlement order (Order). Although the mutual funds referred to in the Order fall outside of the purview of the PE industry, the improper conflicts of interest and poor Form ADV disclosures detailed therein provide valuable lessons for PE sponsors. See “SEC Division of Examinations’ 2021 Priorities Track and Advance 2020 Priorities” (Apr. 27, 2021); and “OCIE Risk Alert on Private Funds: Key Takeaways for Managers (Part Two of Two)” (Sep. 1, 2020).