The SEC brought charges against a private fund manager, Sound Point Capital Management LP, for failing to establish, maintain, and enforce written policies and procedures reasonably designed to prevent the misuse of material nonpublic information (MNPI) concerning its trading of collateralized loan obligations (CLOs). The firm did maintain a policy regarding insider trading, which included the maintenance of a restricted list of companies in which the firm and its supervised persons were prohibited from trading. However, the SEC faulted the firm for not adequately addressing in its policies and procedures the possibility of how it might obtain MNPI in connection with its business practices. Sound Point agreed to pay $1.8 million civil penalty.