Identify your principal owner(s).
Rivulet was founded in November 2011 and became an SEC registered
investment adviser in March 2013. Rivulet provides discretionary investment
advisory services to pooled investment vehicles operating as private funds
(collectively referred to herein as “Clients” or “Advisory Clients”).
Rivulet’s private fund Clients include a family of private investment funds
operating through a master-feeder structure (collectively, the “Funds”):
o Rivulet Capital Partners, LP, a Delaware limited partnership (the
“Domestic Feeder”);
o Rivulet Capital Offshore Fund, Ltd., a Cayman Islands exempted
company (the “Offshore Feeder”);
o Rivulet Capital Master Fund, Ltd., a Cayman Islands exempted
company (the “Master Fund”) that serves as the master fund to the
Domestic Feeder and the Offshore Feeder (together, the “Feeder
Funds”);
and Rivulet Opportunity Fund, LLC, a special purpose vehicle (the “SPV”;
together with the Funds, “Client Funds”) organized as a Delaware limited liability
company.
An affiliate of Rivulet, Rivulet Capital GP, LLC (the “General Partner”), serves
as the general partner of the Domestic Feeder and the managing member of the
SPV. The ultimate principal owners and managing members of Rivulet and the
General Partner are Barry Lebovits and Joshua Kuntz (the “Managing
Members”).
specializing in a particular type of advisory service, such as financial planning,
quantitative analysis, or market timing, explain the nature of that service in
greater detail. If you provide investment advice only with respect to limited types
of investments, explain the type of investment advice you offer, and disclose that
your advice is limited to those types of investments.
Rivulet generally has broad and flexible investment authority with respect to the
Advisory Clients. Each Client Fund’s investment objectives and strategies are
set forth in a confidential private offering memorandum (and any applicable
supplements) and/or other offering documents (collectively, “offering materials”)
provided to each underlying investor in the relevant Client Fund. The investment
objectives and strategies of any SMA are set forth in the respective investment
management agreement.
The Funds’ investment objective is to achieve long-term capital appreciation by
investing both long and short primarily in public
equity securities across market
capitalizations and predominantly in North America. The SPV is a closed-end
investment vehicle established to provide investment in a single portfolio
company whose liquidity profile does not fit within the investment parameters of
the Funds.
Refer to Item 8.A for further details regarding the Funds’ investment strategy.
individual needs of clients. Explain whether clients may impose restrictions on
investing in certain securities or types of securities.
Rivulet neither tailors its advisory services to the individual needs of underlying
investors in the Client Funds, nor accepts investor-imposed investment
restrictions in these vehicles.
The Funds may enter into side letters and other agreements and arrangements
with certain investors in the Funds (“Investors”), which may provide terms and
conditions that are more advantageous than those set forth in the applicable
Fund’s offering materials. Such terms and conditions may include special rights
to make future investments in the Funds or other investment vehicles or accounts
managed by Rivulet, different transparency rights, reporting rights, different
withdrawal/redemption rights and/or different fee terms.
When deemed appropriate for a large or strategic investor, Rivulet may elect to
establish a separately managed account, which may (i) tailor its investment
objectives to specific financial instruments and/or (ii) be subject to different terms
and fees than those of other Clients. Such investment objectives, fee
arrangements and terms will be individually negotiated, and it should be noted
that any such separately managed account relationships would generally be
subject to significant account minimums.
services, (1) describe the differences, if any, between how you manage wrap fee
accounts and how you manage other accounts, and (2) explain that you receive a
portion of the wrap fee for your services.
Rivulet does not participate in wrap fee programs.
discretionary basis and the amount of client assets you manage on a non-
discretionary basis. Disclose the date “as of” which you calculated the amounts.
As of December 31, 2023, Rivulet manages approximately $3,436,632,258 of
regulatory assets on a discretionary basis. Rivulet does not currently manage any
client assets on a non-discretionary basis.