One way that investment advisers routinely run afoul of the SEC is by failing to adhere to their funds’ governing documents. They often compound their problems by failing to be forthright with their investors. In December 2024, the SEC charged a private fund manager and its founder (together, Defendants) with doing just that. Defendants allegedly committed multiple breaches of their fiduciary duty and fraud when they improperly suspended redemptions from a private fund, misrepresented the reason for the suspension, failed to honor redemption requests, failed to disclose conflicts of interest, failed to deliver financial statements and improperly calculated management fees. This article discusses the SEC’s civil enforcement action. See “Enforcement Actions Highlight Advisers’ Duty to Accurately and Honestly Communicate With Investors” (Oct. 10, 2024).