The SEC recently filed an order against investment adviser Deer Park Road Management Company, LP (Deer Park) and its chief investment officer for violations relating to the firm’s valuation process for certain distressed residential mortgage-backed securities. Deer Park is the latest in a line of over a dozen cases relating to the valuation of securities conducted by investment advisers. Although the SEC’s case against Deer Park does not fit perfectly with precedent in several key ways, it is generally instructive in several respects as to the SEC’s ongoing push to address valuation-related misconduct. In a guest article, Jenner & Block partners Charles D. Riely and Stephen L. Ascher, along with associate Nicolas G. Keller, analyze the Deer Park action, ways it differs from prior SEC valuation cases and lessons that fund managers can learn from it. For more on Deer Park, see “Recent SEC Action Shows That Even Undervaluing Fund Assets Can Draw Significant Penalties” (Jul. 11, 2019). For additional commentary from a Jenner & Block attorney, see “FTI Consulting Inc. Hosts Conference on Structured Finance Securities Litigation” (Jun. 10, 2009).