Bluestone Capital Management, 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.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
No Information Filed
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) 
UNITED STATES SECURITIES AND EXCHANGE COMMISSION (SEC)
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
THE SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE
AND CEASE-AND-DESIST PROCEEDINGS BE, AND HEREBY ARE, INSTITUTED PURSUANT TO SECTIONS 203(E) AND 203(K) OF THE INVESTMENT ADVISERS
ACT OF 1940 ("ADVISERS ACT") AGAINST BLUESTONE CAPITAL MANAGEMENT, LLC ("BLUESTONE" OR "RESPONDENT").
3.
Date Initiated (MM/DD/YYYY): 
09/05/2023
 Exact
 Explanation
If not exact, provide explanation:
INVESTMENT ADVISERS ACT OF 1940 RELEASE NO. 6398 / SEPTEMBER 5, 2023 ADMINISTRATIVE PROCEEDING FILE NO. 3-21607
4.
Docket/Case Number:
FILE NO. 3-21607
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
LIQUIDATING PRIVATE FUND
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THIS DISCIPLINARY ACTION CONCERNS BLUESTONE'S VIOLATIONS OF THE FEDERAL SECURITIES LAWS IN CONNECTION WITH THE FINANCIAL

STATEMENT AUDITS OF A PRIVATE FUND THAT BLUESTONE ADVISED. THE FUND IN QUESTION WAS IN LIQUIDATION. BLUESTONE FAILED TO HAVE THE
REQUIRED AUDITS PERFORMED AND TIMELY DISTRIBUTE ANNUAL AUDITED FINANCIAL STATEMENTS PREPARED IN ACCORDANCE WITH GENERALLY
ACCEPTED ACCOUNTING PRINCIPLES ("GAAP") TO INVESTORS IN A PRIVATE FUND THAT IT ADVISED. IN ADDITION, BLUESTONE DID NOT PROPERLY
DESCRIBE THE STATUS OF ITS FUND'S FINANCIAL STATEMENT AUDITS WHEN FILING ITS FORMS ADV AND DID NOT UPDATE CERTAIN RESPONSES IN ITS
FORM ADV ANNUAL UPDATING AMENDMENTS FOR MULTIPLE YEARS AS REQUIRED BY THE FORM ADV INSTRUCTIONS. THESE FAILURES RESULTED IN
VIOLATIONS OF SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-2 THEREUNDER, COMMONLY REFERRED TO AS THE "CUSTODY RULE," AND
SECTION 204(A) AND RULE 204-1(A) THEREUNDER, WHICH REQUIRED BLUESTONE TO UPDATE CERTAIN INFORMATION ABOUT BLUESTONE'S PRIVATE
FUND AUDITS IN ITS FORMS ADV. THE ADVISER PAID A CIVIL MONEY PENALTY IN THE AMOUNT OF $75,000 TO THE COMMISSION FOR TRANSFER TO THE
GENERAL FUND OF THE UNITED STATES TREASURY, SUBJECT TO THE SECURITIES EXCHANGE ACT OF 1934 SECTION 21F(G)(3).
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:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Decision & Order of Offer of Settlement
11. Resolution Date (MM/DD/YYYY):
09/05/2023
 Exact
 Explanation
If not exact, provide explanation:
INVESTMENT ADVISERS ACT OF 1940 RELEASE NO. 6398 / SEPTEMBER 5, 2023 ADMINISTRATIVE PROCEEDING FILE NO. 3-21607
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 75,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
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: 
A FINE OF $75,000 WAS IMPOSED AND BLUESTONE SATISFIED ITS PAYMENT OBLIGATION.
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).
BLUESTONE SHALL, WITHIN 10 DAYS OF THE ENTRY OF THIS ORDER, PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $75,000 TO THE COMMISSION
FOR TRANSFER TO THE GENERAL FUND OF THE UNITED STATES TREASURY, SUBJECT TO THE SECURITIES EXCHANGE ACT OF 1934 SECTION 21F(G)(3).
IF TIMELY PAYMENT IS NOT MADE, ADDITIONAL INTEREST SHALL ACCRUE PURSUANT TO 31 U.S.C. §3717. BLUESTONE HAS SATISFIED ITS PAYMENT
OBLIGATIONS.

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:
4570496
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
SHEVLAND, BRIAN, C.
(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) 
2.
Principal Sanction:
Suspension
Other Sanctions: 
ONE YEAR SUSPENSION BEGINNING IN MARCH OF 2024
3.
Date Initiated (MM/DD/YYYY): 
03/04/2024
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2019062544201
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
MCG SECURITIES LLC
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, SHEVLAND CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT HE MADE
NEGLIGENT MISREPRESENTATIONS ABOUT THE PERFORMANCE OF TWO PRIVATE EQUITY FUNDS (THE FUNDS) TO INVESTORS. THE FINDINGS STATED
THAT SHEVLAND CAUSED THE FUNDS TO INVEST MORE THAN $20 MILLION (INCLUDING SOME OF HIS OWN MONEY) IN A SEPARATE PRIVATE EQUITY
FUND (THE MASTER FUND), WHICH WAS MANAGED BY A FORMER EMPLOYER OF SHEVLAND. THE FUNDS CREATED DOCUMENTS THAT CONTAINED

MATERIALLY INACCURATE PERFORMANCE RESULTS, WHICH SHEVLAND DISTRIBUTED AND DIRECTED OTHERS AT THE FUNDS TO DISTRIBUTE TO
INVESTORS ON A REGULAR BASIS. TO PREPARE THESE DOCUMENTS, THE FUNDS RELIED ON INFORMATION THAT SHEVLAND RECEIVED FROM THE
MASTER FUND, INCLUDING UNAUDITED FINANCIALS CLAIMING THAT THE MASTER FUND EARNED CONSISTENT POSITIVE MONTHLY RETURNS AND
REALIZED AN ANNUAL RATE OF RETURN, NET OF FEES, EXCEEDING 80 PERCENT DURING ONE YEAR. SHEVLAND FAILED TO ACT WITH DUE CARE UPON
LEARNING OF MATERIAL DISCREPANCIES IN THE FINANCIAL RESULTS REPORTED BY THE MASTER FUND. IN ADDITION, CERTAIN OF THE MASTER FUND'S
MONTHLY REPORTS DID NOT ACCURATELY REFLECT THE FUNDS' INVESTMENT. SHEVLAND DID NOT ASK ANYONE AT THE MASTER FUND ABOUT THESE
DISCREPANCIES OR TAKE ANY OTHER STEPS TO INVESTIGATE THEM. INSTEAD, SHEVLAND NEGLIGENTLY CONTINUED TO DIRECT OTHERS AT THE FUNDS
TO USE THE MASTER FUND'S CLAIMED FINANCIAL RESULTS TO CREATE DOCUMENTS THAT HE AND OTHERS DISTRIBUTED TO FUND INVESTORS. THOSE
DOCUMENTS MATERIALLY OVERSTATED THE PERFORMANCE OF THE FUNDS. SUBSEQUENTLY, THE MANAGER OF THE MASTER FUND WAS ARRESTED AND
CHARGED WITH SECURITIES FRAUD IN CONNECTION WITH HER OPERATION OF THE MASTER FUND. THE MASTER FUND IS SUBJECT TO A RECEIVERSHIP
AND LOSSES TO INVESTORS IN THE FUNDS HAVE YET TO BE ASCERTAINED.
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:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
02/01/2024
 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: $ 10,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
ONE YEAR SUSPENSION.
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: 
ALL SERIES LICENSES HAVE BEEN SUSPENDED FROM 03/04/2024 - 03/03/2025.
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).
MR. SHEVLAND WAS FINED $10,000 AND AND HIS APPLICABLE LICENSES SUSPENDED FROM 03/04/2024 - 03/03/2025