The SEC reaffirmed its focus on conflicts of interest and valuation issues in a recent settlement order against an investment adviser that, at relevant times, was controlled by an entity that administers a marketplace lending platform that matches consumer borrowers with investors. The investment adviser and two of its principals allegedly improperly used the assets of a private fund they managed to purchase loans on the platform to help the adviser’s parent company, and they used valuation adjustments to improve the monthly returns of several funds they managed. This article details the SEC’s allegations and the terms of the settlement. See our two‑part series “Ropes & Gray Survey and Forum Consider Credit Fund Structures, Leverage, Conflicts of Interest and Challenging Environment”: Part One (Jul. 19, 2018); and Part Two (Jul. 26, 2018).