Flexstone Partners, LLC

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.A. or
11.B. of Form ADV.
Criminal
Check item(s) being responded to:
11.A(1)
11.A(2)
11.B(1)
11.B(2)
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
Multiple counts of the same charge arising out of the same event(s) should be reported on the same DRP. Unrelated criminal actions, including separate
cases arising out of the same event, must be reported on separate DRPs. Use this DRP to report all charges arising out of the same event. One event may
result in more than one affirmative answer to the items listed above.

PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
NATIXIS
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  If charge(s) were brought against an organization over which you or an advisory affiliate exercise(d) control: Enter organization name, whether or not
the organization was an investment-related business and your or the advisory affiliate's position, title, or relationship. 
N/A
2.
Formal Charge(s) were brought in: (include name of Federal, Military, State or Foreign Court, Location of Court - City or County and State or Country,
Docket/Case number). 
PARIS CRIMINAL COURT (TRIBUNAL CORRECTIONNEL DE PARIS), PARIS, FRANCE (N° 10151096014)
3.
Event Disclosure Detail (Use this for both organizational and individual charges.)
A. Date First Charged (MM/DD/YYYY): 
06/26/2019
 Exact
 Explanation
If not exact, provide explanation:
N/A
B.
Event Disclosure Detail (include Charge(s)/Charge Description(s), and for each charge provide: (1) number of counts, (2) felony or misdemeanor,
(3) plea for each charge, and (4) product type if charge is investment-related). 
(1) ONE COUNT (2) FELONY (3) NOT GUILTY (4) N/A - CHARGE RELATES TO AN ISSUER PRESS RELEASE
C.
Did any of the Charge(s) within the Event involve a felony? 
 Yes
 No
D.
Current status of the Event? 
 Pending
 On Appeal
 Final
E.
Event Status Date (complete unless status is Pending) (MM/DD/YYYY): 
02/04/2026
 Exact
 Explanation
If not exact, provide explanation:
NATIXIS FILED AN APPEAL BEFORE THE FRENCH SUPREME COURT (COUR DE CASSATION) ON MAY 7, 2024. ON FEBRUARY 4, 2026, THE FRENCH
SUPREME COURT HANDED DOWN ITS DECISION, REJECTING NATIXIS' APPEAL. THE MATTER IS NOW FINAL, AND THE CASE IS CLOSED.
4.
Disposition Disclosure Detail: 
Include for each charge (a) Disposition Type (e.g., convicted, acquitted, dismissed, pretrial, etc.), (b) Date, (c) Sentence/Penalty, (d) Duration (if
sentence - suspension, probation, etc.), (e) Start Date of Penalty, (f) Penalty/Fine Amount, and (g) Date Paid. 
(A) CONVICTED (B) 05/07/2024 (C) FINE (D) N/A (E) N/A (F) EUR 2,000,000 (APPROXIMATELY USD 2.36 MILLION) FINE ON APPEAL AND JUST UNDER
EUR 2,000,000 (APPROXIMATELY USD 2.39 MILLION AT THE TIME) IN PRIVATE CIVIL DAMAGES.
5.
Provide a brief summary of circumstances leading to the charge(s) as well as the disposition. Include the relevant dates when the conduct which was

the subject of the charge(s) occurred. (Your response must fit within the space provided.) 
ON JUNE 24, 2021, NATIXIS SA ("NATIXIS"), THE FRENCH BANK THAT OWNS OUR PARENT COMPANY, WAS FOUND GUILTY BY A FRENCH CRIMINAL
COURT (TRIBUNAL CORRECTIONNEL DE PARIS) OF COMMUNICATING MISLEADING INFORMATION TO THE PUBLIC, BASED ON LANGUAGE REGARDING
NATIXIS' EXPOSURE TO THE SUB-PRIME CRISIS IN A 2007 PRESS RELEASE. THE FRENCH COURT ORDERED NATIXIS TO PAY A FINE OF EUR 7.5 MILLION.
IN ADDITION, THE COURT AWARDED JUST UNDER EUR 2 MILLION TO CERTAIN PLAINTIFFS THAT HAD IN 2009 REQUESTED THE OPENING OF THE
CRIMINAL INVESTIGATION. NO OFFICERS, DIRECTORS OR EMPLOYEES OF NATIXIS OR OF ITS AFFILIATES WERE CHARGED IN CONNECTION WITH THE
PROCEEDING. ON JUNE 25, 2021, NATIXIS FILED A TIMELY APPEAL TO THE PARIS COURT OF APPEAL (COUR D'APPEL DE PARIS). UNDER APPEAL, THE
CASE WAS ENTIRELY REEXAMINED ON MATTERS OF BOTH FACTS AND LAW. ON MAY 7, 2024, NATIXIS WAS FOUND GUILTY BY THE PARIS COURT APPEAL.
THE COURT REDUCED THE CRIMINAL FINE AGAINST NATIXIS TO EUR 2 MILLION. THE COURT AWARDED APPROXIMATELY EUR 2 MILLION IN PRIVATE
CIVIL DAMAGES TO CERTAIN PLAINTIFFS, THE MAJORITY OF WHICH HAD ALREADY BEEN PAID BY NATIXIS AFTER THE FIRST INSTANCE DECISION. THE
PRESS RELEASE IN QUESTION WAS ISSUED BY NATIXIS IN NOVEMBER 2007 AT THE START OF THE FINANCIAL CRISIS. AT ISSUE IN THE CRIMINAL
PROCEEDING WAS A SHORT PARAGRAPH OF THE PRESS RELEASE, RELATING TO NATIXIS' EXPOSURE TO THE SUBPRIME CRISIS AND RELATED RISKS.
NEITHER THE PREVIOUS NOR THE SUBSEQUENT COMMUNICATIONS OF THE ISSUER RELATING TO THE SUBPRIME CRISIS WERE FOUND TO BE
MISLEADING BY THE PARIS COURT OF APPEAL. THE CONVICTION RESULTED FROM AN INVESTIGATION LAUNCHED IN 2009 BY THE PARIS PUBLIC
PROSECUTOR'S OFFICE INTO A COMPLAINT FILED BY CERTAIN MINORITY SHAREHOLDERS OF NATIXIS COORDINATED BY THE ASSOCIATION TO DEFEND
MINORITY SHAREHOLDERS RIGHTS (ASSOCIATION DE DÉFENSE DES ACTIONNAIRES MINORITAIRES ­ ADAM), WHICH ARE THE PLAINTIFFS THAT
RECEIVED THE APPROXIMATELY EUR 2 MILLION AWARD REFERENCED ABOVE. THE ASPECTS OF THE PRESS RELEASE CONSIDERED BY THE CRIMINAL
COURT HAD BEEN INDEPENDENTLY ASSESSED BY NATIXIS' PRIMARY REGULATOR, THE FRENCH FINANCIAL MARKETS AUTHORITY (THE AUTORITÉ DES
MARCHÉS FINANCIERS OR "AMF"), WHICH DECLINED TO TAKE ANY ACTION AGAINST NATIXIS. THE PRESS RELEASE IN QUESTION DID NOT RELATE TO
ANY OF NATIXIS' SUBSIDIARY BUSINESSES ENGAGED IN ADVISORY OR BROKER-DEALER ACTIVITIES. NATIXIS CONTINUES TO MAINTAIN THAT THE
INFORMATION IT DISSEMINATED IN THE PRESS RELEASE IN QUESTION WAS APPROPRIATE TO THE SITUATION. THE PRESS RELEASE WAS ISSUED AT
THE BEGINNING OF THE SUBPRIME CRISIS WHEN THE EXTENT AND CONSEQUENCES OF THE CRISIS WERE NOT YET WIDELY UNDERSTOOD EITHER BY
MARKET PARTICIPANTS OR BY REGULATORS. MOREOVER, AT THE TIME OF THE PRESS RELEASE, NATIXIS WAS VERY RECENTLY CREATED AND STILL IN
THE COURSE OF A MERGER. THE COURT OF APPEAL RECOGNIZED SUCH DIFFICULT CONTEXT AS A FACTOR REDUCING THE BANK'S LIABILITY. NATIXIS
FILED AN APPEAL BEFORE THE FRENCH SUPREME COURT (COUR DE CASSATION) WHICH WAS REJECTED. UNDER FRENCH LAW, OTHER THAN THE
IMPOSITION OF THE MONETARY FINE, THERE ARE NO LEGAL CONSEQUENCES TO NATIXIS OR ITS AFFILIATES FOR A GUILTY VERDICT IN THIS CASE.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
NATIXIS SA
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is

registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
COMMODITY FUTURES TRADING COMMISSION
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
09/06/2022
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
22-23
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
NATIXIS
6.
Principal Product Type:
Derivative(s)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE COMMODITY FUTURES TRADING COMMISSION ISSUED AN ORDER FILING AND SETTLING CHARGES AGAINST NATIXIS, A GLOBAL BANK AND SWAP
DEALER, FOR FAILURE TO DILIGENTLY SUPERVISE TWO TRADERS ON THE BANK'S NEW YORK-BASED INTEREST RATE DERIVATIVES DESK (IRD DESK) AND
ITS EQUITY DERIVATIVES FLOW AND SOLUTION TRADING DESK (FAST DESK). THE TRADERS ON THE IRD DESK AND FAST DESK SEPARATELY ENGAGED IN
MISCONDUCT BY MISMARKING THEIR POSITIONS FOR THE PURPOSE OF EITHER INFLATING PROFITS AND MINIMIZING LOSSES, OR TO "SMOOTH" OUT
RETURNS, RESPECTIVELY. THE ORDER REQUIRES NATIXIS TO PAY A $2.8 MILLION CIVIL MONETARY PENALTY, CEASE AND DESIST FROM VIOLATING
APPLICABLE PROVISIONS OF THE COMMODITY EXCHANGE ACT (CEA) AND CFTC REGULATIONS, AND COMPLY WITH CERTAIN CONDITIONS AND
UNDERTAKINGS. CASE BACKGROUND BETWEEN JANUARY 2015 AND AT LEAST APRIL 2018, A TRADER ON THE BANK'S IRD DESK SUBMITTED FALSE OR
MISLEADING ENTRIES IN THE BANK'S INTERNAL RECORDKEEPING AND ACCOUNTING SYSTEM RELATING TO THE MARKING OF THE END-OF-DAY USD
LIBOR FORWARD CURVE (CLOSING CURVE), FOR THE PURPOSE OF INFLATING THE UNREALIZED PROFIT AND LOSS (P&L) OF THE DESK HE MANAGED
AND DISGUISING SIGNIFICANT TRADING LOSSES. SPECIFICALLY, THE TRADER ENGAGED IN A PATTERN OF MARKING THE CLOSING CURVE IN A MANNER
THAT VARIED FROM OBSERVED BROKER MID PRICES AND IN A MANNER THAT ALIGNED WITH THE RISK POSITIONS OF THE IRD DESK, WHILE GENERALLY
STAYING WITHIN THE LIMITS OF INTERNAL CONTROLS DESIGNED TO DETECT MISMARKING. ALTHOUGH NATIXIS MAINTAINED CERTAIN CONTROLS
RELATING TO THE MARKING OF THE CLOSING CURVE, THOSE CONTROLS WERE INSUFFICIENT TO DETECT THE TRADER'S MISCONDUCT FOR OVER THREE
YEARS. AT ITS PEAK IN EARLY 2018, THE TRADER'S MISMARKING OF THE CLOSING CURVE OVERSTATED THE P&L OF THE IRD DESK BY APPROXIMATELY
$25 MILLION. IN ADDITION, THE ORDER FURTHER FINDS THAT NATIXIS FAILED TO DILIGENTLY SUPERVISE THE ACTIVITIES OF ITS FAST DESK.
SPECIFICALLY, BETWEEN FEBRUARY 2017 AND NOVEMBER 2019, TRADERS ON THE FAST DESK MADE CERTAIN MANUAL ADJUSTMENTS TO THE BANK'S
INTERNAL TRADE BOOKING SYSTEMS FOR THE PURPOSE OF "SMOOTHING" OR HIDING THE FAST DESK'S P&L AND LATER RELEASING THE P&L DURING
DIFFICULT MARKET CONDITIONS. AT ITS PEAK, THE P&L SMOOTHING UNDERSTATED THE UNREALIZED P&L OF THE FAST DESK BY OVER $6 MILLION.
THIS MISCONDUCT RENDERED THE BANK'S BOOKS AND RECORDS INACCURATE. IN ACCEPTING THE BANK'S OFFER OF SETTLEMENT, THE CFTC
RECOGNIZED ITS SUBSTANTIAL COOPERATION DURING THE DIVISION OF ENFORCEMENT'S INVESTIGATION OF THIS MATTER. THE CFTC NOTED THAT
THE BANK'S SUBSTANTIAL COOPERATION AND REMEDIATION ARE RECOGNIZED IN THE FORM OF A REDUCED CIVIL MONETARY PENALTY.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
N/A

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Settled
11. Resolution Date (MM/DD/YYYY):
09/06/2022
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 2,800,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
N/A
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
N/A
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
SEE RESPONSE TO QUESTION 7. ALSO SEE: HTTPS://WWW.CFTC.GOV/PRESSROOM/PRESSRELEASES/8581-22