At the recent Alternative Asset Management General Counsel Luncheon presented by international recruiting firm Major, Lindsey & Africa (MLA) and hosted by MLA partners Brian T. Davis and Dimitri G. Mastrocola, Gibson Dunn partner Reed Brodsky and of counsel Mary Beth Maloney offered their thoughts on the trial of Patriarch Partners and Lynn Tilton, who had been charged with fraudulently managing certain collateralized loan obligations. This article, the second in a two-part series, evaluates the SEC’s three principal charges against Tilton. The first article summarized Brodsky’s and Maloney’s views on the fairness of SEC administrative proceedings, the key takeaways from the trial and the primary defense themes, including due process and equal protection claims about administrative law judge proceedings generally. For additional commentary from Gibson Dunn attorneys, see “Implications for Fund Managers of the Supreme Court’s Ruling in Kokesh v. SEC” (Jun. 15, 2017); and “Is This an Inspection or an Investigation? The Blurring Line Between Examinations of and Enforcement Actions Against Private Fund Managers” (Mar. 29, 2012). For coverage of prior programs hosted by MLA, see “Client Consent and Other Issues Requiring Careful Consideration by Fund Managers Involved in M&A Transactions” (May 18, 2017); and “Former Prosecutors Address Trends in Cybersecurity for Alternative Asset Managers, Diligence When Acquiring a Company and Breach Response Considerations” (Oct. 6, 2016).