On February 26, 2026, the SEC announced settled charges against a private credit adviser for improperly applying its valuation policies to its season and sell program – i.e., the adviser originates loans and then sells them to affiliated funds after a specified period of time – during the market dislocations caused by the coronavirus pandemic. According to the SEC’s cease-and-desist order (Order), the adviser promised investors the sale of loans would be at “fair value” or “fair market value,” but they were merely priced at the loan sale price minus an unamortized loan fee without factoring in asset valuation changes during the pandemic. The Order resulted in a significant penalty – despite the respondent’s voluntary remediation – reflecting the Commission’s ongoing focus under SEC Chair Paul S. Atkins on examining investment advisers’ practices to assess adherence to representations made to investors. This article summarizes the Order; explores why the adviser’s loan valuation and selling practices raised concerns for the SEC; considers the likelihood of similar enforcement actions in the future; and offers practical takeaways for advisers with season and sell programs or that otherwise engage in principal transactions. See “Coronavirus’ Impact on Valuation Results and IRR Calculations Highlights the Need for Backtesting and Remediation Measures” (Mar. 2, 2021).