Valuation, which is inextricably tied to investment adviser performance and compensation, is a perennial target of SEC scrutiny. The recent SEC settlement order (Order) against a pricing service suggests that advisers should evaluate the policies, procedures and controls of the pricing services they use to ensure that they are supplied with prices that reflect current fair market value. For example, the service allegedly lacked policies and procedures reasonably designed to ensure that it provided accurate pricing for securities that it valued using single broker quotes. This article details the pricing service’s alleged compliance violations and the Order’s terms, and it provides lessons for investment advisers. See “Is the Use of an Independent Valuation Firm Superior to a Manager’s Internal Valuation Process?” (Apr. 23, 2015); and “DLA Piper Hedge Fund Valuation Webinar Covers Fair Value Methodologies, Valuation Services, Valuing Illiquid Positions and Handling Valuation Inquiries During SEC Examinations” (Aug. 7, 2013).