A recent SEC settlement order against a fund manager illustrates that advisers that stray from their disclosed redemption practices may be subject to regulatory scrutiny. Although the governing documents of one of the manager’s funds required 90 days’ notice for redemptions, the adviser had an unpublicized policy allowing investors to make partial redemptions on shorter notice and inadvertently permitted several full redemptions on 60 days’ notice. As a result, the SEC claimed that the manager had engaged in fraudulent conduct and lacked appropriate compliance policies and procedures. The manager also ran afoul of the custody rule and SEC filing requirements while winding down its funds. This article details the alleged violations and the terms of the SEC’s order. See “Can a Hedge Fund Retroactively Amend Its Partnership Agreement to ‘Rescind’ an Investor’s Redemption Request?” (May 8, 2014).