Form ADV operates largely on trust. An adviser that claims exempt reporting adviser (ERA) status does not undergo the registration review process, and information reported on Form ADV becomes public without a merits-based prefiling review. The accuracy of a Form ADV is instead policed after its filing through the SEC’s authority to examine an adviser’s books and records and, if necessary, through enforcement litigation. A default judgment entered on August 3, 2026, illustrates the limits and reach of those mechanisms when an ERA cannot be located. The U.S. District Court for the District of Columbia permanently enjoined a purported ERA from violating the Books and Records Rule and the reporting provisions of the Investment Advisers Act of 1940; barred it from filing a Form ADV as an ERA; and ordered it to pay a $1,152,316 civil penalty. The SEC alleged that a Form ADV filed by the so-called ERA described an illusory advisory business – a Wall Street office occupied by someone else, a claimed public company registration that the Commission could not find and two private funds that appeared in no other filing. This article analyzes the allegations, charges and the terms of the final judgment. See “SEC Sanctions Adviser for Undisclosed Conflicts and Misleading Form ADV” (Jun. 3, 2021); and “A Checklist for Fund Managers to Ensure Form ADV, Part 2A Is Complete and Accurate” (May 6, 2021).