Registered investment adviser Structured Portfolio Management, L.L.C. and two affiliated investment advisers have agreed to settle SEC charges stemming from allegedly inadequate compliance policies and procedures that resulted in improper trade allocations among the funds they advised and failure to disclose a change of strategy to fund investors. For more on SPM, see “Dispute between Structured Portfolio Management and Jeffrey Kong Offers a Rare Glimpse into the Compensation Arrangements between a Top-Performing Hedge Fund Management Company and a Star Portfolio Manager,” Hedge Fund Law Report, Vol. 4, No. 8 (Mar. 4, 2011). “Cherry picking” of trades, and the conflicts of interest that arise when advisers allocate trades, have been ongoing focus areas for the SEC. See, e.g., “SEC Charges Hedge Fund Manager and Its Founder with Securities and Investment Adviser Fraud Based on ‘Cherry Picking’ of Trades,” Hedge Fund Law Report, Vol. 6, No. 1 (Jan. 3, 2013).