The SEC filed a settled enforcement action (Order) against a PE sponsor on August 15, 2025, alleging the improper calculation of management fee offsets and the breach of its fiduciary duties. The SEC alleged that, by failing to defer interest on transaction fees in accordance with its funds’ limited partnership agreements, the sponsor functionally inflated its own revenue by adjusting downward the management fee offsets its funds were supposed to receive. With its focus on fee calculations and attendant fiduciary duties, the Order reflects the SEC’s ongoing focus on conflicts of interest violations regardless of its less aggressive posture toward private funds under Chairman Paul S. Atkins. This article summarizes the Order, examines how common the related management fee calculation practices are among PE firms, considers the ease with which inadvertent fee violations can occur and offers practical takeaways based on interviews with several industry experts. See “What to Expect From Today’s SEC Examinations and Enforcement Relating to PE Management Fees and Expenses (Part Two of Two)” (Oct. 5, 2023).