Valuation, which is inextricably linked with a fund’s performance and its adviser’s compensation, is a perennial focus of SEC examiners. The SEC recently threw the book at the founder, former owner and former CEO of an adviser, as well as several of the adviser’s employees who allegedly engaged in fraudulent valuation practices by improperly booking certain anticipated fee revenue and interest associated with the firm’s lending business. Notably, the SEC also took issue with the adviser’s waivers of management and performance fees, which it allegedly employed selectively to boost its funds’ returns. Those questionable practices had the effect of increasing the net asset values of the adviser’s funds and generating millions in unwarranted management and performance fees. This article describes the allegedly fraudulent bookkeeping practices and digests the terms of the multiple enforcement actions and settlements. See “Division of Examination’s 2021 Exam Priorities: Perennial Focus Areas for Private Fund Managers (Part Two of Two)” (Apr. 22, 2021); and “HFLR Program Explores Valuation of Illiquid Assets and Valuation Governance” (Jan. 28, 2021).