Loomis, Sayles & Company, L.P.: investment adviser

Item 11 questions answered Yes

These questions cover the firm and its advisory affiliates.

• In the past ten years, have you or any advisory affiliate: been convicted of or pled guilty or nolo contendere ("no contest") in a domestic, foreign, or military court to any felony?
• Has the SEC or the Commodity Futures Trading Commission (CFTC) ever: found you or any advisory affiliate to have been involved in a violation of SEC or CFTC regulations or statutes?
• Has the SEC or the Commodity Futures Trading Commission (CFTC) ever: imposed a civil money penalty on you or any advisory affiliate, or ordered you or any advisory affiliate to cease and desist from any activity?

Actions about affiliates (1)

1. Sep 6, 2022
   Regulatory Action: CFTC FinalAbout an affiliate: Natixis SASanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $2.8M · Begun Sep 6, 2022 · Resolved Sep 6, 2022 · Settled · Docket 22-23

   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.

   N/a

   See response to question 7. Also see: HTTPS://www.cftc.gov/pressroom/pressreleases/8581-22 No information Filed

Disclosures filed elsewhere

The firm's Form ADV names these and the kind of action only; the details are on the named firm's own filing.

• 1 criminal disclosure about Natixis

Form ADV Item 11 and its Disclosure Reporting Pages, via the SEC record. All adviser disciplinary records.