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Adviser Profile

As of Date 03/15/2024
Adviser Type - Large advisory firm
Number of Employees 10
of those in investment advisory functions 7
Registration SEC, Approved, 03/20/2013
Other registrations (1)
AUM* 3,436,632,258 2.77%
of that, discretionary 3,436,632,258 2.77%
Private Fund GAV* 3,436,632,258 2.77%
Avg Account Size 859,158,065 2.77%
SMA’s Yes
Private Funds 2
Contact Info 212 xxxxxxx
Websites

Client Types

- Pooled investment vehicles

Advisory Activities

- Portfolio management for pooled investment vehicles
- Portfolio management for businesses

Compensation Arrangments

- A percentage of assets under your management
- Performance-based fees

Recent News

Reported AUM

Discretionary
Non-discretionary
4B 3B 3B 2B 2B 1B 569M
2015 2016 2017 2018 2019 2020 2021 2022 2023

Private Funds



Employees

Private Funds Structure

Fund Type Count GAV
Fund TypeHedge Fund Count2 GAV$3,436,632,258

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Top Holdings

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Stck Ticker78410G104 Stock NameSBA COMMUNICATIONS CORP NEW $ Position$143,168,360 % Position11.00% $ Change # Change
Stck Ticker98138H101 Stock NameWORKDAY INC $ Position$149,530,038 % Position11.00% $ Change # Change
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Stck Ticker653656108 Stock NameNICE LTD $ Position$106,989,404 % Position8.00% $ Change # Change
Stck Ticker038336103 Stock NameAPTARGROUP INC $ Position$99,462,452 % Position7.00% $ Change # Change
Stck Ticker136375102 Stock NameCANADIAN NATL RY CO $ Position$97,990,118 % Position7.00% $ Change # Change
Stck Ticker31620M106 Stock NameFIDELITY NATL INFORMATION SV $ Position$90,592,375 % Position7.00% $ Change # Change
Stck Ticker88023U101 Stock NameTEMPUR SEALY INTL INC $ Position$92,172,990 % Position7.00% $ Change # Change
Stck Ticker337738108 Stock NameFISERV INC $ Position$72,147,440 % Position5.00% $ Change # Change

Brochure Summary

Overview

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.