A fund manager that needs to divest assets may be tempted to cut corners, especially when the buyer is another vehicle advised by the manager. Doing so comes with great risk, however. The SEC recently charged an adviser and its principal with fraudulently rigging the auction of an asset held by a collateralized debt obligation they advised for the benefit of a different fund that they advised. The settlements are an important reminder of the need for managers to adhere scrupulously to both the letter and spirit of their governing documents and to mitigate all conflicts of interest. This article analyzes the terms of the settlement orders. See “Panel Examines Compliance Issues Faced by Credit Managers” (Nov. 15, 2018); and “As Cross Trades Between Client Accounts Continue to Draw SEC Scrutiny, Fund Managers Should Review Internal Policies and Client Disclosures” (Sep. 27, 2018).