In one of its first enforcement actions under the new Trump administration involving the private funds industry, the SEC has settled charges against a registered investment adviser; its former managing partner and CCO; and its former COO and partner. Although the enforcement actions arose from misappropriations and clearly egregious conduct, there are nuances that may provide useful insights into how the SEC will approach CCO liability and other compliance issues under the Trump administration. This article summarizes the two settlement orders and provides key takeaways from interviews the Private Equity Law Report conducted with industry experts about the enforcement actions. For coverage of other SEC actions against CCOs, see “SEC Fines and Bars CCO From the Funds Industry for Compliance Failures and Deceiving OCIE” (Nov. 10, 2020); and “Absence of Harm No Defense Against Conflicts of Interest: SEC Issues Lifetime Bar From Compliance Work to CCO” (Sep. 13, 2018).