The valuation practices of fund managers remain in regulators’ crosshairs. In a recently settled enforcement action, the SEC and CFTC took aim at a portfolio manager for an unnamed hedge fund adviser, alleging that he used different valuation model inputs for similar assets in order to generate paper profits for one of the adviser’s private funds – and unwarranted bonuses for himself. This article analyzes the portfolio manager’s alleged misconduct and the terms of both the SEC and CFTC settlement orders. See “Recent SEC Action Shows That Even Undervaluing Fund Assets Can Draw Significant Penalties” (Jul. 11, 2019); and “Improper Expense Allocations and Careless Valuation Practices Result in Nearly $4 Million in Fines and Disgorgement for BDC Adviser” (Jan. 10, 2019).