The SEC charged Marathon Asset Management, L.P. with failing to establish, maintain, and enforce written policies and procedures reasonably designed to prevent the misuse of material nonpublic information (MNPI) related to its participation on ad hoc creditors’ committees. While Marathon had established Insider Trading and Information Barrier policies and procedures in place, as well as MNPI procedures, the SEC faulted the firm for not effectively monitoring or supervising employees to effectively address the risk of receiving or misusing MNPI during participation on ad hoc creditors’ committees. Marathon agreed to pay a $1.5 million civil penalty.