Valuation by private fund managers remains a focus of SEC attention for its effect on performance, the fees payable to managers and the price at which investors enter and exit a fund. As it relates to illiquid or thinly traded assets, this exercise is particularly nettlesome. In a recently settled enforcement proceeding, the SEC asserted that, in contravention of its funds’ governing documents and valuation policies, a registered investment adviser and one of its principals ignored for valuation purposes its own trades in certain assets. Instead, the adviser favored the higher valuations provided by a third-party pricing service that did not use actual market inputs, resulting in a significant overvaluation of those securities. For another recent action in which a manager improperly used pricing service marks instead of actual trades, see “SEC Settlement With PIMCO Highlights the Importance of Proper Valuation and Performance Disclosures” (Dec. 8, 2016). This article summarizes the valuation practices that the SEC challenged, the sanctions imposed and the other relevant terms of the settlement order. For additional coverage of the SEC’s recent attention to valuation of illiquid assets, see “Hedge Fund Platinum Partners and Principals Face Civil and Criminal Proceedings From SEC and DOJ Over Alleged Fraudulent Valuation Practices and Liquidity Misrepresentations” (Jan. 12, 2017); and “SEC Continues to Focus on Insider Trading and Fund Valuation” (Jun. 30, 2016).