Private company
GLENVIEW CAPITAL MANAGEMENT, LLC
American company, incorporated in Delaware. Summary from the record
Last updated Oct 21, 2026.
Overview
- HeadquartersDE1
Corporate structure
GLENVIEW CAPITAL MANAGEMENT, LLC is part of a group headed by Rinc Family Partnership LLC. 17 entities, 1 country on record. Switch between the flow chart and the network, and select any entity to see its details.
Major holders of GLENVIEW CAPITAL MANAGEMENT, LLC
- Lawrence Michael Robbins Owns 75% or more of Rinc Family Partnership LLC, since 05/2021 (Form ADV)
- Rinc Family Partnership LLC
- GLENVIEW CAPITAL MANAGEMENT, LLC DE
- Alight Solutions Stake · Chicago, Illinois
- ATI Physical Therapy, Inc. Stake · Downers Grove, Illinois
- Bausch Health Stake · Wilmington, Delaware, United States
- Brookdale Senior Living Stake · Brentwood, Tennessee, United States
- Butterfly Network, Inc. Stake · Wilmington, Delaware, United States
- DXC Technology Stake · Ashburn, Virginia, United States
- Evolv Technologies Holdings, Inc. Stake · Waltham, Massachusetts
- Genius Sports Ltd Stake · London, United Kingdom
- Meritor Stake · Troy, Michigan, United States
- Myriad Genetics Stake · Salt Lake City, Utah, United States
- Quantum-Si Inc Stake · Branford, Connecticut
- Surgery Partners Stake · Nashville, Tennessee, United States
- Tenet Healthcare Stake · Dallas, Texas, United States
- Velocity Acquisition Corp. Stake · Ridgefield, Connecticut
- ZoomInfo Stake · Vancouver, Washington, United States
- GLENVIEW CAPITAL MANAGEMENT, LLC DE
Built from major holders from Schedules 13D and 13G; stakes of 5% or more it reported on Schedules 13D and 13G (15 companies); owners and owned firms from Form ADV, the registration investment advisers file with the SEC. Each entity in the chart links to its source.
Investment adviser
GLENVIEW CAPITAL MANAGEMENT, LLC is registered with the SEC as an investment adviser. This is what it reports on Form ADV, the registration every adviser files and keeps current.
- Assets it manages$6.4B2 5 accounts, all with discretion
- Employees49 25 in investment advice or research
- ClientsPooled investment vehicles (other than investment companies and: 5 ($6.4B)
- How it is paidA percentage of assets under its management; Performance-based fees
- What it doesPortfolio management for pooled investment vehicles (other than investment companies)
- Holds client assetsYes: cash and securities
- RegistrationSEC 801-73695, CRD 137640 IAPD record
Who owns it
Owners of 5% or more as the firm lists them (Schedule A), and the owners of those owners up the chain (Schedule B).
- RINC FAMILY PARTNERSHIP LLCowns 75% or more, since 05/2021
- Lawrence Michael Robbinsowns 75% or more of RINC FAMILY PARTNERSHIP LLC, since 05/2021
In its own words: the client brochure
Form ADV Part 2A, the plain-English document an adviser must give its clients, quoted as filed 3/31/2026.3 It covers the firm’s services, fees, investment strategies and their risks, and its conflicts of interest.
Item 4: Advisory business Services
Glenview is a privately held investment management firm founded in 2000. Glenview manages capital for qualified investors through a series of private investment funds. Larry Robbins is the principal owner of Glenview and has ultimate responsibility for the management, operations and investment decisions of Glenview. Glenview is headquartered in New York, with an additional office in Florida. Glenview manages the following “families” of private investment funds -- the “Glenview Funds”, the “Opportunity Funds”, the “Healthcare Funds” and the “Suggestivist Funds”. The Glenview Funds employ a long/short strategy focused on investments in equity and fixed income securities using a bottom-up, fundamental research process. The Glenview Funds have position size and gross exposure guidelines, as further described in the offering documents of the Glenview Funds. The Opportunity Funds employ a purely opportunistic investment approach, and there are no limits regarding the number of positions, size of positions, types of securities or industry concentration. The Healthcare Funds employ a long/short strategy focused on investments in issuers operating in or adjacent to the healthcare industry. The Healthcare Funds have position size and gross exposure guidelines, as further described in the offering documents of the Healthcare Funds. The Suggestivist Funds solely invest in the securities of a single diversified healthcare services company. The Suggestivist Funds began operating on July 1, 2024 as limited life funds and are no longer being offered to investors. The individual investment funds managed by Glenview are: The Glenview Funds: Glenview Institutional Partners, L.P., Glenview Capital Partners (Cayman), Ltd. and Glenview Capital Master Fund, Ltd. Glenview Institutional Partners, L.P. and Glenview Capital Partners (Cayman), Ltd. are “feeder funds” that invest all of their assets in Glenview Capital Master Fund, Ltd., which in turn conducts investment and trading operations. The Opportunity Funds: Glenview Capital Opportunity Fund, L.P., Glenview Offshore Opportunity Fund, Ltd. and Glenview Offshore Opportunity Master Fund, Ltd. Glenview Capital Opportunity Fund, L.P. and Glenview Offshore Opportunity Fund, Ltd. are “feeder funds” that invest all of their assets in Glenview Offshore Opportunity Master Fund, Ltd., which in turn conducts investment and trading operations. The Healthcare Funds: Glenview Healthcare Partners, L.P., Glenview Healthcare Offshore Partners, L.P. and Glenview Healthcare Master Fund, L.P. Glenview Healthcare Partners, L.P. and Glenview Healthcare Offshore Partners, L.P. are “feeder funds” that invest all of their assets in Glenview Healthcare Master Fund, L.P., which in turn conducts investment and trading operations. The Suggestivist Funds:
GCM Suggestivist I Partners, L.P., GCM Suggestivist I Offshore Partners, L.P. and GCM Suggestivist I Master Fund, L.P. GCM Suggestivist I Partners, LP and GCM Suggestivist I Offshore Partners, LP are “feeder funds” that invest all of their assets in GCM Suggestivist I Master Fund, LP, which in turn conducts investment and trading operations. GCM Investment Partners, L.P.: Glenview manages GCM Investment Partners, L.P., a private investment fund that is open to qualified employees of Glenview and certain other persons. GCM Investment Partners, L.P. allocates its capital to individual funds in the Glenview Fund family, the Opportunity Fund family and the Healthcare Fund family. All of the entities listed above are collectively referred to in this document as the “Funds”. The Funds have a number of wholly-owned subsidiaries and affiliated entities which have been formed for the purpose of facilitating various investments, but which do not themselves accept direct investments from investors. References in this Brochure to a Fund include such Fund’s wholly-owned subsidiaries and affiliated entities, if any. Separately Managed Account: Glenview anticipates serving as the investment adviser to a managed account, which is expected to pursue a healthcare focused investment program that will trade in positions that overlap with the Glenview Funds, the Opportunity Funds, the Healthcare Funds and the Suggestivist Funds (the “Managed Account”). As used throughout this Brochure, the term “Client” generally refers to each Fund and the Managed Account. Glenview’s investment advice is subject to each Fund’s and the Managed Account’s investment objectives and guidelines, as set forth in each Fund’s and the Managed Account’s offering and governing documents and is not subject to modification by individual investors. Glenview does not currently participate in wrap free programs. As of March 1, 2026, Glenview managed approximately $2,151,300,000 of net assets on a discretionary basis. Glenview does not manage any assets on a non-discretionary basis.
Item 5: Fees and compensation Fees
Prior to investing in a Client, each investor is asked to carefully read and review the particular Client’s offering and/or governing documents for a complete understanding of the key terms, including, the compensation received by Glenview and its affiliates and how such compensation is calculated, the expenses paid by the Client and withdrawal rights. The information contained in this Brochure is only a summary and is qualified in its entirety by each such Clients’s offering and/or governing documents. GCM Investment Partners, L.P., which is an investment vehicle for qualified employees and certain other persons, does not currently assess management fees or performance-based allocations with respect to its investors. In addition, the Managed Account will be subject to a separately negotiated fee arrangement. The fee terms applicable to the Managed Account will differ from those applicable to the Glenview Funds, the Opportunity Funds, the Healthcare Funds and the Suggestivist Funds, and may include different management fee rates and/or performancebased compensation structures. As such, any discussion herein relating to the management fees and performancebased allocations will only apply to the Glenview Funds, Opportunity Funds, the Healthcare Funds and the Suggestivist Funds. Glenview or one of its affiliates typically receives management fees from each Fund based on a percentage of assets under management and a performance-based allocation based on a percentage of the performance achieved for such Fund, as described further below. Management Fees Each of the Glenview Funds and Opportunity Funds and certain other affiliated entities pay a (i) 0.5% (equal to a 2% annual rate) or (ii) 0.125% (equal to a 0.5% annual rate, (in the case of the alternative fee arrangement)1 quarterly management fee to Glenview based on fee paying assets under management. The Healthcare Funds pay a 0.375% (equal to 1.5% annual rate) quarterly management fee to Glenview based on fee paying assets under management. The Suggestivist Funds pay a (i) 0.0625% (equal to a 0.25% annual rate) quarterly management fee to Glenview based on fee paying assets under management. In each case, management fees are deducted quarterly as of the first day of each calendar quarter and charged monthly to the account of each management fee paying investor. Management fees are prorated for any subscriptions made by an investor that are effective other than as of the first day of a calendar quarter. Similarly, management fees are prorated and reimbursed for any withdrawals made by an investor that are effective other than as of the last calendar day of a calendar quarter. In the event that an investor in a Fund withdraws all of its liquid capital and holds only certain illiquid “side pocket” investments which are not redeemable at the option of the investor (as more fully described in the offering documents for each relevant Fund), Glenview may hold back a special investment reserve from the distribution of withdrawal proceeds to such an investor for estimated management fees expected to be incurred or invoice such investor quarterly for its allocable portion of the management fee. From time to time, Glenview, its principals, partners, employees and/or affiliates may receive fees or other forms of compensation for certain services provided to a portfolio company (e.g., appointment to the board of directors of a portfolio company) in connection with certain investments made by a Client in such portfolio company (“Transaction Fees”). Certain Transaction Fees will be used to offset the management fees paid by the Client to Glenview, as more fully described in the offering documents for each relevant Client. In turn, any such reduction will
1 Investors in the Glenview Funds and the Opportunity Funds may elect to participate in an “alternative fee arrangement” whereby (i) Glenview will receive an annual management fee attributable to such an investment equal to 0.5% of such assets (rather than the 2% annual rate) and (ii) any performance-based allocations attributable to such investment will equal 30% (rather than 20%) of the net appreciation, subject to certain limitations further described herein.
proportionately reduce the management fees borne by an investor that would have otherwise been due from such investor. Performance-Based Allocations With respect to the Glenview Funds, Opportunity Funds and the Healthcare Funds, certain affiliates of Glenview receive performance-based allocations equal to (i) 20% or (ii) 30% (in the case of the alternative fee arrangement) 2 of the net returns of each Fund, which generally includes the net realized and unrealized appreciation allocated to each investor in the Fund. With respect to the Suggestivist Funds, certain affiliates of Glenview receive performance-based allocations equal to (i) 10% of the net returns of each Fund, which generally includes the net realized and unrealized appreciation allocated to each investor in the Fund. In each case, performance-based allocations are assessed (i) at the end of the fiscal year of the respective Fund and (ii) upon full or partial withdrawal of an investor’s capital and re-allocated to certain affiliates of Glenview at such time, other than the Suggestivist Funds which only assess a performance based allocation upon the return of investor capital. Performance-based allocations are calculated after deducting certain Fund expenses, including, without limitation, brokerage commissions, management fees, operational and research costs (as more fully described below). In calculating the net returns of the Fund, prior losses are carried forward and must be made up before performancebased allocations are made as further described in the offering documents and governing documents for each Fund. Any income or loss attributable to an unrealized illiquid “side pocket” investment is not included in the calculation of new net income until such investment has been realized in cash or marketable securities. Additional information relating to the calculations of net returns and the re-allocation of performance-based allocations is further described in the offering documents and governing documents for each Fund. Fee Waivers Management fees and performance-based allocations are non-negotiable, although Glenview has the discretion to permit certain investors to invest on different fee terms. In addition, Glenview, either directly or through one of its affiliates, has the discretion to waive all or a portion of the management fee and/or performance-based allocations. In general, principals, partners and employees of Glenview and their respective estate planning vehicles do not pay management fees and are not subject to performance-based allocations. In addition, certain family members of the principals, partners and employees of Glenview and certain other persons may be granted a waiver with respect to management fees and performance-based allocations, at the discretion of Glenview or one of its affiliates. Expenses In addition to the fees and compensation described above, each Fund bears its operational expenses as more fully described in the offering documents of such Fund, which include, but are not limited to: management fees, fees for legal, audit, tax and other professional services and advisors; commissions, banking, brokerage and custody fees; filing fees and expenses (including expenses associated with regulatory filings with the SEC (as they relate to the offering of interests or shares in the Fund as well as securities or other property of the Fund), the Commodity Futures Trading Commission or other regulatory authorities including foreign regulatory authorities, including Form PF, but excluding the preparation of Form ADV), tax filings and tax preparation expenses (including tax filing fees, reporting costs and any expenses incurred in order to satisfy tax reporting requirements in an investor’s jurisdiction (if applicable), such as the equivalent of passive foreign investment company (“PFIC”) reporting requirements, and
Investors in the Glenview Funds and the Opportunity Funds may elect to participate in an “alternative fee arrangement” whereby (i) Glenview will receive an annual management fee attributable to such an investment equal to 0.5% of such assets (rather than the 2% annual rate) and (ii) any performance-based allocations attributable to such investment will equal 30% (rather than 20%) of the net appreciation, subject to certain limitations further described herein.
including compliance with FATCA and similar regimes), and any other required filings in connection with the affairs of the Fund; fund accounting software; third-party fund administration and tax and investor servicing fees and expenses; investment research expenses, including consulting and legal fees related to investment research, whether or not such investments are consummated; investment-related travel expenses (including transportation, lodging, conference fees and associated travel expenses); fees for market data (including market data and pricing feeds) and research services and systems, including Bloomberg data and interface services and related user license fees, costs and expenses, and research management systems; trade order management systems; counterparty management software; risk management and portfolio analysis and reporting expenses, including related systems and software development expenses; computer, newswire, quotation services, data processing charges and periodical subscription fees as they relate to investment research or the operations and affairs of the Fund; insurance expenses (including the cost of any insurance covering the potential liabilities of the Fund, Glenview, its affiliates or any agent or employee of the Fund, as well as the potential liabilities of any person serving at the request of the Fund as a director of a corporation in which the Fund has an investment); directors’ fees (including any associated fees regarding corporate services, if applicable) or fees of an independent investment representative or Partners’ or Shareholders’ Representative Committee member (if applicable); costs, fees and expenses associated with opening, maintaining and closing of bank accounts, custodial accounts and accounts with brokers on behalf of the Fund (including the customary fees and charges applicable to transactions in such broker accounts); interest expenses, spreads, short dividends, negative rebates, financing charges and currency hedging costs; transfer, capital and other taxes, duties and costs incurred in connection with the making of investments by the Fund in portfolio securities (or the disposition of such investments) and other reasonable expenses (including those for agents, attorneys, accountants, financial advisors or other professionals) necessary for the Fund to receive, buy, sell, exchange, trade, and otherwise deal in and with securities and other property of the Fund, and other reasonable expenses necessary to perform the operation of the Fund as determined by the Fund in its sole discretion; and any costs and expenses properly incurred in connection with the winding up and dissolution of the Fund. For the avoidance of doubt, “other reasonable expenses” refers to any expenses that are similar in type and nature to the expenses described in the previous paragraph and is intended, given the dynamic ongoing nature of the business of the Fund, to cover any expenses determined by Glenview to be related to the categories listed above, but not specifically enumerated. As an example, Glenview considers (x) fees for filings associated with the Hart-ScottRodino Antitrust Improvements Act of 1976, as amended, to be “other reasonable expenses” related to the category of filing fees and expenses that are borne by the Fund but not specifically enumerated above, and (y) work related to implementing Sections 1471-1474 of the U.S. Internal Revenue Code of 1986, as amended from time to time (the “Code”) (also known as “FATCA”), and the Organization for Economic Co-operation and Development (“OECD”) Standard for Automatic Exchange of Financial Account Information – Common Reporting Standards (“CRS”) to be “other reasonable expenses” related to the category of tax filing and tax preparation-related expenses that are borne by the Fund but not specifically enumerated above, as applicable. In addition, the Fund is authorized to bear the cost of the continuous offering of interests or shares in the Fund, if any, including the cost of producing and distributing offering memoranda and other offering materials, the negotiation of side letters, any printing, postage and related costs and legal and regulatory expenses associated with the offering of interests or shares in the Fund (e.g., “blue sky” filings, compliance with Directive 2011/61/EU of the European Parliament and the Council of 8 June 2011 on Alternative Investment Fund Managers (“AIFMD”) and any similar regime). The Fund will also pay any extraordinary costs that it may incur (e.g., taxes, indemnification expenses, litigation costs or damages). To the extent that expenses to be borne by the Fund are paid by Glenview, the Fund will reimburse Glenview for such expenses. If any of the above expenses are incurred jointly for the account of a Fund and any other investment funds, affiliated entities or trading accounts sponsored or managed by Glenview, such expenses will be allocated among such Fund and such other funds or accounts pro rata based on the net asset value of the relevant funds, pro rata based on relative holdings of an investment among the relevant funds for expenses related to a specific investment, or in such other manner as Glenview considers fair and equitable. Notwithstanding the foregoing, any expenses incurred jointly for the Managed Account as well as for the account of some or all of the Glenview Funds, the Opportunity Funds, the
Item 8: Methods of analysis, investment strategies and risk of loss Investment strategies and risks
As further described in the offering documents of the Funds, Glenview’s investment process employs an intense focus on deep, fundamental research and individual security selection primarily within equity and credit-oriented strategies. Since inception, Glenview’s primary skill set and value driver has been the ability to assess the fundamental attractiveness of industries, companies and securities based upon their growth characteristics, profit drivers, competitive dynamics and financial attributes. When combining these factors with an absolute valuation discipline focused on economic earnings and recurring cash flow, we make determinations as to the most attractive securities on a risk/reward basis. Glenview’s philosophy of what makes a good investment is a business: (i) whose fundamental characteristics are known and knowable; (ii) that compounds value over time at an annual rate of mid-teens or greater; and (iii) whose securities trade at an attractive price relative to earnings, free cash flow, growth and business quality. These qualities are measured over a long period of time, and our investment horizon generally focuses on a period of one to three years, while also paying attention to nearer-term dynamics (e.g., catalysts, changes in valuation). In practice, given that our investment philosophy is to think and act like owners, our holding periods may extend beyond this range and in certain instances have extended beyond ten years. Glenview’s investing style is most commonly tied to the category of Growth at a Reasonable Price or “GARP” and focuses on companies in industries that are stable, predictable and steady, with recurring revenue streams or entrenched market positions. Glenview has traditionally avoided investments in industries that do not offer characteristics of transparency, predictability, and defensiveness. In addition to GARP, Glenview may also focus on contrarian investments which may be cyclical (e.g., business model changes or long-cycle supply/demand) or company specific (e.g., turnarounds). Often GARP and contrarian investing are combined, in the case where a steady growth business emerges within a company as the dominant economic force over a more challenged business unit. We also invest in stored value or hidden value situations, where excess balance sheet capacity may be put to productive use to accelerate investment returns or where contractual rights or startup operations show no value in the income statement today but may be significant drivers of value tomorrow. Finally, arbitrage opportunities often intersect with investing, with post-merger integration stories creating scale, synergies and in turn shareholder value. In order to identify investments, our research efforts encompass a variety of activities to gather, assimilate and analyze information about industries and companies, which will help us make fundamentally sound, intelligent investment decisions. Glenview’s investment team is structured by industry groups, which have the relevant experience and analytical framework to understand businesses. Our investment professionals perform a rigorous financial analysis of past results to help identify factors that may influence future performance. Our financial models for each investment are thoroughly reviewed with regard to the forecasting assumptions being made, and these models are stress tested to identify various potential scenarios. Our investment professionals have established deep ecosystems of industry specific knowledge, and within our compliance framework speak with a variety of sources including management teams, industry analysts, competitors, suppliers and consultants in an effort to ensure a thorough research process. Glenview’s senior investment professionals form the investment committee, which engages in a thorough discussion of the business, industry, management, competition and financials to determine the risk/return profile for all potential investments. Consistent with our ownership philosophy, Glenview frequently and regularly shares its perspectives on long term value creation initiatives with the management teams of portfolio companies, and occasionally, with their Board of Directors directly. Such communications, which we refer to as “Suggestivism”, generally center around issues of long-term capital acquisition, long-term capital allocation, optimal corporate form, financial statement presentation and opportunities to improve competitive or strategic positioning. Glenview believes such dialogues are optimal in a respectful, patient and private forum. In addition to our long equity investments, with respect to the Glenview Funds, the Opportunity Funds and the Healthcare Funds, Glenview commits significant capital to short equity positions. In general, we are looking for companies whose industries face cyclical, transitory or secular headwinds, whose competitive position is likely to
erode over the near to medium term, and companies whose liquidity profile will potentially create equity value impairment or cause future issuance of additional equity at lower prices. In addition to these short equity investments, Glenview may maintain short positions in equity index futures or other index products in order to reduce the net market risk to the Glenview Funds, the Opportunity Funds and the Healthcare Funds. With respect to the Glenview Funds and the Opportunity Funds, Glenview also engages in long and short credit positions with the same fundamental principles as set forth for equity positions, with an additional emphasis on business or asset stability over growth. As well, Glenview may seek to reduce the risk through other hedges that protect the overall portfolio of the Funds, including, but not limited to, interest rates, foreign currencies or sovereign, corporate or asset-backed credit spreads. In Glenview’s experience, however, the primary means to reduce risk of permanent capital loss is through our deep research process as described herein. In addition, from time to time, the Glenview Funds, the Opportunity Funds and the Healthcare Funds may evaluate investment opportunities in special purpose acquisition companies (“SPACs”) and invest in SPAC securities, including SPACs sponsored by certain members, partners, officers, managers and/or employees of Glenview and its affiliates (such persons, “Glenview SPAC Persons”). Although the Funds generally focus on equities with a market capitalization in excess of $1 billion, there are no absolute restrictions in regard to the size or operating experience of the companies in which the Funds may invest. In addition, consistent with the Funds’ investment programs, the Funds also make investments in private investments and/or in certain illiquid securities that lack a readily ascertainable market value. Finally, with respect to the Healthcare Funds, Glenview generally employs a substantially similar fundamental investment process and philosophies relating to the Glenview Funds and the Opportunity Funds as set out above, but with a focus on investments in issuers operating in or adjacent to the healthcare sector. Investing in securities involves a risk of loss that investors should be prepared to bear. Investors should be aware that they will be required to bear the financial risks of an investment in a Client for a substantial period of time. An investment in one or more Clients is suitable only for sophisticated investors who fully understand and are willing to assume the risks involved in the investment program of the relevant Client(s), including, without limitation, the risks that Glenview may not achieve the investment objectives of the Client and that investors may lose all or part of their investment. The following is a summary of certain material risks associated with Glenview’s primary investment strategy and the types of securities in which Glenview primarily invests. This list does not purport to be a complete enumeration or explanation of the risks involved with an investment in any Client. These risk factors include only the risks that Glenview believes to be material, significant or unusual and relate to Glenview’s significant investment strategies. In addition, while there is overlap among the portfolios of Clients, some of the risk factors set out below may apply to certain Clients and not the others. Additional details regarding risk factors are available in the offering documents of each Fund. DEPENDENCE OF GLENVIEW AND THE CLIENTS ON LARRY ROBBINS As Chief Investment Officer, Larry Robbins has ultimate authority for all investment and trading decisions on behalf of the Clients. There can be no assurance that his services will be available for any length of time. Furthermore, his death or incapacity could have a material and adverse effect on the Clients’ performance and could result in substantial withdrawals of investor capital from the Clients. LIMITED LIQUIDITY An investment in a Client provides limited liquidity, since the securities of the Clients are not freely transferable and the withdrawal rights of the investors are limited as set forth in each Client’s offering documents and/or governing documents.
LEVERAGE The Clients use leverage, including buying and maintaining securities on margin from prime brokers or through the use of derivatives or similar financial instruments. The amount of borrowings which the Clients may have outstanding at any time may be large in relation to the capital of the Clients. The use of leverage, as applicable, magnifies the potential gains and losses from an investment and can significantly increase the risk of higher expenses or significant or even total loss of capital. Accordingly, as applicable, any event which adversely affects the value of a Client’s investment would be magnified to the extent the Client employs leverage. As described in the offering documents of the relevant Fund, the Glenview Funds and the Healthcare Funds have general limitations on their ability to utilize leverage, while the Opportunity Funds have no such limitations. CONCENTRATION The Clients’ investments may be concentrated in a relatively small number of markets, industry sectors, investment strategies, regions and/or issuers. Concentration tends to increase volatility in the portfolio. Changes in the value of a small number of positions may have a significant impact on the value of the Clients’ investments. In addition, the Clients’ investments will be more susceptible to any single economic, political, or regulatory occurrence, or the fortunes of a single company, industry or investment strategy than would be the case if the Clients’ investments were more diversified. GENERAL ECONOMIC AND MARKET CONDITIONS General economic and market conditions may affect the level and volatility of securities prices and the liquidity of the Clients’ investments. Volatility and/or illiquidity could impair the Clients’ profitability or result in losses. For example, inflation, rapid fluctuations in inflation rates and interest rate policies may have negative effects on economies and financial markets, which may have an adverse impact on portfolio companies or the Clients’ returns. In addition, many businesses experience significant disruptions to operations or other difficulties with their supply chains or internalized supply processes due to, among other factors, COVID-19, exchange rate fluctuations, volatility in regional or international markets from where materials are obtained, changes in the general macroeconomic outlook, political instability, expropriation or nationalization of property, climate change, civil strife, strikes, insurrections, acts of terrorism, acts of war or natural disasters. Similar market dislocations and disruptions in the future could have a material adverse effect on the performance of the Clients. ACTS OF GOD AND PUBLIC HEALTH EMERGENCIES The Clients’ investments will be subject to the risk of loss arising from exposure that they may incur due to various force majeure events (i.e., acts of God, fire, flood, earthquakes, outbreaks of infectious disease, epidemic, pandemic or any other serious public health concern, war, terrorism, labor strikes or other similar national or local emergencies) that are beyond the control of, and are not easily foreseeable by, the Clients or Glenview. Such events could have a continued adverse impact on global economic and market conditions and could have a material adverse effect on the performance of the Clients. In particular, the effects of a public health emergency, including COVID-19 and subsequent COVID-19 variants are difficult to assess, and may adversely affect many economies, global financial markets, the underlying investments of the Clients, the business and operations of Glenview and its ability to achieve its investment objectives, all of which could result in significant losses. SHORT SALES The Funds engage in short selling as a fundamental component of their investment programs. Short selling involves selling securities which are not owned and borrowing them for delivery to the purchaser, with an obligation to replace the borrowed securities at a later date. Short selling allows the investor to profit from declines in market prices of the sold securities to the extent such decline exceeds the transaction costs and the costs of borrowing the securities. A short sale creates the risk of a theoretically unlimited loss, in that the price of the underlying security
Item 7: Types of clients
Glenview provides investment advisory services to the Clients as set forth in Item 4. Investors in the Clients include pension plans, charitable foundations, endowments, fund of funds, sovereign wealth funds, family offices, investment companies, trusts, high net worth individuals and other entities and institutions. Investors in the Clients must meet certain suitability requirements as set forth in each Client’s offering and governing documents. In addition, the minimum initial investment amount is $1,000,000 for the Glenview Funds and the Suggestivist Funds, $5,000,000 for the Opportunity Funds and $10,000,000 for the Healthcare Funds. The minimum investment amount required to maintain an investment is $1,000,000 in respect of the Glenview Funds and $5,000,000 in respect of the Opportunity Funds. GCM Investment Partners, L.P., which is open to Glenview principals, partners, employees and certain other persons, requires a $10,000 minimum for initial investments and account maintenance. The minimum initial investment amounts and minimum maintenance amounts for all Funds may be waived at the discretion of Glenview or its affiliates.
Item 6: Performance-based fees and side-by-side management Conflicts of interest
As described in Item 5 above, affiliates of Glenview receive certain performance-based allocations from certain of the Clients. Accordingly, Glenview may have an incentive to make investments that are riskier or more speculative than would be the case if such arrangements were not in effect. Furthermore, since performance-based allocations are calculated on a basis that includes unrealized appreciation of certain Client’s assets, such compensation may be greater than if it were based solely on realized gains. In addition, Glenview may be incentivized to favor certain Clients over other Clients (i) as a result of higher investment participation levels by principals, partners and employees of Glenview and their respective estate planning vehicles in certain Clients, and/or (ii) because the compensation received from some Clients may exceed the compensation received from other Clients. In order to mitigate this risk and conflict, Glenview has implemented procedures designed to seek fair and equitable treatment for all Clients and to prevent conflicts from influencing the allocation of investment opportunities among the Clients, as further described in Item 12.
Item 10: Other financial industry activities and affiliations Conflicts of interest
None of Glenview or its management persons are registered as, or have any application pending to register as, broker-dealers or registered representatives of a broker-dealer. Glenview is not registered as, nor does it have any application pending to register as, a futures commission merchant, commodity pool operator, commodity trading advisor or associated persons of any of the foregoing entities. Glenview Opportunity GP, LLC (“Glenview Opportunity GP”), an affiliate of Glenview, currently relies on commodity pool operator exemptive relief provided pursuant to Commodity Futures Trading Commission (“CFTC”) Letter No. 25-50, as amended or superseded from time to time, and expects to rely on such other future exemptive relief that reinstates the exemption from registration for CPOs for pools offered solely to qualified eligible persons previously set forth in CFTC Rule 4.13(a)(4). Glenview Opportunity GP previously relied upon CFTC Rule 4.7 with respect to the Fund, pursuant to which it was required to become a registered CPO and a member of the National Futures Association (“NFA”). Following Glenview Opportunity GP’s transition to reliance on CFTC Letter Number 25-50 (or future exemptive relief discussed above), it is no longer subject to these requirements. Glenview Capital GP, LLC (“Glenview Capital GP”) serves as the general partner of GCM Investment Partners, L.P. and the domestic Glenview Fund and as sponsor of the offshore Glenview Funds. Glenview Opportunity GP serves as the general partner of the domestic Opportunity Fund, the Healthcare Funds and the Suggestivist Funds, and as sponsor of the offshore Opportunity Funds. Each principal, partner, and employee of Glenview, Glenview Capital GP and Glenview Opportunity GP is subject to Glenview’s Compliance Manual, including, without limitation, Glenview’s Code of Ethics (as discussed in Item 11). Glenview believes that its relationships or arrangements with Glenview Capital GP and Glenview Opportunity GP do not create a material conflict of interest for Glenview with its Clients and/or investors. In addition, Glenview has entered into investment management agreements with each of the Funds and the Managed Account. The material terms of the investment management agreements are fully disclosed to the applicable investors prior to their investment. Glenview regularly reviews any relationships in which Glenview’s principals, partners and employees have with investors and service providers to the Clients to identify and address any potential conflicts of interests. While Glenview serves as the investment manager to the Clients, it is not required to devote any particular amount of time exclusively to a Client. In addition, Glenview does not recommend or select other investment advisers for its clients.
Item 11: Code of ethics, participation or interest in client transactions and personal trading Conflicts of interest
Glenview has adopted a Code of Ethics in accordance with Rule 204A-1 under the Investment Advisers Act of 1940, as amended (the “Advisers Act”). Glenview expects its employees to adhere to the highest standards of professional conduct, whether or not required by law or regulation. The Code of Ethics helps us fulfill our fiduciary obligation to place the interests of the Clients before the interests of Glenview and its affiliates, principals, partners and employees. In addition, it protects Glenview’s reputation and instills in our employees Glenview’s commitment to honesty, integrity and professionalism. The Code of Ethics applies to all of the principals, partners, officers and employees or any other person subject to the supervision and control of Glenview, Glenview Capital GP and Glenview Opportunity GP. The Code of Ethics contains guidelines concerning, among other things, compliance with applicable securities laws, handling of confidential information, service on boards of directors and other outside business activities, personal account trading, political contributions and gifts and entertainment. Each person covered by the Code of Ethics must acknowledge at the time of hire, and on an annual basis thereafter, that he or she understands and agrees to adhere to the Code of Ethics. We also provide training on the Code of Ethics and other compliance issues at the start of employment and regularly thereafter. The Code of Ethics also includes provisions for sanctions in the event of violations. A copy of the Code of Ethics will be provided upon request to any investor or prospective investor in the course of their due diligence process by contacting us at 212.812.4700 or by email at info@glenviewcapital.com. POLICIES ON INSIDER TRADING Glenview maintains policies and procedures that are designed to prevent the improper use of material nonpublic information (the “Insider Trading Policies”). Glenview’s Insider Trading Policies prohibit Glenview and its personnel from (i) trading either personally or on behalf of the Clients, or recommending trading, in securities of a company while in possession of material nonpublic information in violation of applicable law and/or (ii) communicating material non-public information to others in violation of applicable law. By reason of its various activities, including, without limitation, appointment to the board of directors of a portfolio company, Glenview may become privy to material non-public information or be restricted from effecting transactions in investments that might otherwise have been initiated. Glenview has designed and implemented policies in order to comply with the requirements of the securities laws relating to insider trading. Each person covered by the Insider Trading Policies must acknowledge at the time of hire and on an annual basis thereafter that he or she understands and agrees to adhere to the Insider Trading Policies. OUTSIDE BUSINESS ACTIVITIES Any outside business activity of an employee is subject to approval by Glenview. For example, an employee may not serve as an officer or director of a public or private company without obtaining the requisite approval. In granting approval, Glenview will consider whether any outside business activity conflicts or may conflict with the business of Glenview or the Clients. PERSONAL ACCOUNT TRADING Glenview’s principals, partners and/or employees and certain family members of such persons (collectively, “Glenview Persons”) may trade securities for their own account. Personal account trading by Glenview Persons is subject to internal compliance policies and procedures, as set out in the Code of Ethics, which place certain restrictions and/or limitations on personal securities trades, including pre-approval of many types of personal securities transactions and regular disclosure of personal securities holdings and transactions. In certain circumstances,
Glenview Persons are permitted to invest in the same securities as the Clients and as such, there is a possibility that Glenview Persons might benefit from market activity by a Client in a security held by a Glenview Person or may hold positions potentially in conflict with positions held by a Client. Glenview has established policies and procedures to monitor and resolve conflicts with respect to personal securities transactions to ensure that any such transactions are not intended to violate Glenview’s fiduciary and ethical obligations to the Clients. Glenview’s policies and procedures are designed to ensure that at the time of approval, any personal securities transactions, activities and interests of Glenview Persons will not interfere with the ability of Glenview to make decisions in the best interests of the Clients. POLITICAL CONTRIBUTIONS Glenview maintains policies and procedures to govern and monitor the political contributions made by its employees in order to comply with the Advisers Act and local laws and regulations. GIFTS AND ENTERTAINMENT Glenview maintains policies and procedures intended to prevent employees from being unduly influenced in their decisions by the receipt of gifts or other inducements from third parties, such as trading counterparties, vendors and investors. Glenview also maintains related policies and procedures intended to prevent employees from attempting to unduly influence investors or government officials in order to obtain inappropriate benefits for Glenview or its Clients. CROSS TRADES AND PRINCIPAL TRANSACTIONS Glenview may from time to time to cause the Clients to enter into cross trades, whereby the buyer and the seller of a particular security are Clients managed by Glenview. Cross trades may be effected when an independent portfolio management decision has been made to decrease one Client’s exposure to a certain security and increase another Client’s exposure to the same security. Such decisions may be motivated by a number of reasons, including different projected return thresholds, different risk parameters, tax, regulatory or liquidity reasons. Cross trades are only executed for securities where independent quotes or valuations can be obtained and in some cases are approved by an independent investor representative. To the extent that any such cross transaction may be viewed as a principal transaction due to the ownership interest in a Client by personnel or entities affiliated with Glenview, Glenview will comply with the requirements of Section 206(3) of the Advisers Act. OTHER RELATED CONFLICTS AND PRACTICES Investments by Principals, Partners and Employees Principals, partners and employees of Glenview invest their personal capital in the Funds, either through GCM Investment Partners, L.P. (which in turn invests in certain Glenview Funds, Opportunity Funds and Healthcare Funds) or through direct investments in one or more of the Funds. We believe that this alignment of financial interest with our investors minimizes certain conflicts of interest that may arise. Glenview’s principals, partners and employees and any of their respective estate planning vehicles are, however, privy to more up-to-date information than are other investors and nonetheless will generally be permitted to withdraw from the Funds more frequently and/or upon shorter notice, including, without limitation, during a period when other investors in the Funds receive an in-kind distribution or distribution through a liquidating special purpose vehicle, due to the ability of Glenview and its affiliates to waive notice, lockup periods, redemption charges (as applicable) and redemption provisions pursuant to authority granted to them in the offering and governing documents of the Funds. If a Fund is required to liquidate holdings to satisfy these withdrawal requests, additional costs and expenses will be incurred and will be borne primarily by the remaining investors in the Funds. Accordingly, notwithstanding the ability to exercise such authority, any withdrawals remain subject to a determination that there are no material adverse consequences to the Fund(s) as a result of such a withdrawal.
Also, as described in Item 5, in general, principals, partners and employees of Glenview and any of their respective estate planning vehicles do not pay management fees and are not subject to performance-based allocations. In addition, potential conflicts may arise due to the fact that Glenview personnel have investments in some Funds but not in others or may have different levels of investments in the various Funds. In order to mitigate this risk and conflict, Glenview has implemented procedures designed to seek fair and equitable treatment for all Funds and to prevent conflicts from influencing the allocation of investment opportunities and expenses among the Funds, as further described in Item 12. Other Fiduciary Duties As part of managing the Clients’ portfolios, Glenview may try to secure the appointment of certain persons to the management or board of directors of a portfolio company, including with respect to any acquisition target of SPACs sponsored by Glenview SPAC Persons that becomes publicly listed on an exchange (each, an “Acquired Company”), for which certain Glenview SPAC Persons may serve as directors and/or officers. In so doing, Glenview personnel are likely to acquire fiduciary duties to the portfolio company and to the portfolio company’s other shareholders. These fiduciary duties may compel Glenview personnel to take actions that, while in the best interests of the portfolio company and/or its shareholders, may not be in the best interests of the Clients or the investors of the Clients. Accordingly, Glenview may have a conflict of interest between the fiduciary duties (if any) that its personnel owe to such company(ies) and its (their) shareholders, on the one hand, and those that it owes to the Clients or the investors of the Clients, on the other hand. Conflicts Relating to Investments in SPACs Sponsored by Glenview SPAC Persons and Acquired Companies In connection with sponsoring SPACs and managing the Clients’ investments in such SPACs and/or an Acquired Company, Glenview and Glenview SPAC Persons are and will be faced with actual and potential conflicts of interest. The devotion, time and effort of certain Glenview SPAC Persons in sponsoring SPACs and/or engaging with an Acquired Company could be viewed as creating a conflict of interest in that the time and effort of certain Glenview SPAC Persons will not be devoted exclusively to the business of the Clients. The Glenview SPAC Persons will devote such time and resources to the Client’s business and affairs as they deem necessary or advisable to effectively manage a Client. As described above, certain Glenview SPAC Persons currently serve, and are expected to continue to serve, as directors and/or officers of Acquired Companies. Glenview SPAC Persons face a conflict between the duties owed to the Clients and the duties owed to such Acquired Companies. In addition, Clients have invested in the securities of Acquired Companies. By directing the Clients to invest in the securities of Acquired Companies, Glenview faces a conflict of interest in determining the size and scope of the Client’s investment in any Acquired Company. There can be no assurance that the board membership and/or the involvement of certain Glenview SPAC Persons with respect to Acquired Companies will result in favorable results for the Clients. In addition, from time-to-time Glenview SPAC Persons may receive compensation in connection with serving as a director of a SPAC or an Acquired Company in which a Client is invested. With respect to any cash payments received by a Glenview SPAC Person in connection with such board positions, such amounts will be applied to reduce the Management Fees paid by such Client to Glenview. Any other non-cash compensation received in connection with such board positions (e.g., stock, options, warrants or otherwise) will not be used to offset Management Fees and will be retained by Glenview SPAC Persons, which is unlike instances in which Transaction Fees are received in connection with other types of portfolio companies. Given these differences, Glenview may face a conflict of interest in allocating investment opportunities of the Clients. Expenses Glenview may, in its sole discretion, allocate expenses among the Clients in any manner which it determines is fair and equitable. In general, expenses are allocated among the Clients pro rata based on the net asset value of the applicable Client. Expenses that are attributable to a specific Client will only be borne by the Client that incurred such expense. In addition, certain expenses that are attributable to a specific security will be allocated among the
Item 12: Brokerage practices Conflicts of interest
In placing securities transactions with broker-dealers for the Clients, we seek to obtain best execution, which requires us to take into account the circumstances of each specific transaction. Best execution is not necessarily determined by lowest possible commission cost, but also considers the best qualitative execution. The factors to be considered in selecting and approving broker-dealers that may be used to execute trades for the Clients and determining the reasonableness of their compensation include:
Quality of execution - accurate and timely execution, clearance and error/dispute resolution, with emphasis placed on quality of execution demonstrated through a long-term track record
Reputation, financial strength and stability
Ongoing reliability and consistency of coverage
Overall costs of a trade (i.e., net price paid or received) including commissions, mark-ups, mark-downs or spreads
Provision of research and research-related services, including access to company management, idea generation and market insight
Willingness to execute difficult transactions and ability to commit capital
Nature of the security and the available market makers
Desired timing of the transaction and size of trade
Access to underwritten offerings and secondary markets
Block trading and block positioning capabilities
Confidentiality of trading activity
Market impact
Glenview need not solicit competitive bids and does not have an obligation to seek the lowest available commissions or other transaction costs. Accordingly, the commissions and other transaction costs (which may include dealer mark-ups or mark-downs) charged to the Clients by broker-dealers that offer certain products or services may be higher than those charged by other brokers-dealers that may not offer certain products or services. To help oversee Glenview’s best execution policies, Glenview has established a Best Execution Committee. The Best Execution Committee meets quarterly and is responsible for developing, evaluating and changing, when necessary, Glenview’s order execution practices in selecting and using its brokers. In particular, the Best Execution Committee reviews, among other things, commission rates paid to each broker, quality of executions, existence of conflicts of interest in connection with the use of brokers, dark pool usage, commission sharing arrangements and other issues related to the use of brokers. Glenview also conducts annual internal broker evaluations to ensure that Glenview’s commission spend is appropriate in light of the services obtained by Glenview and/or the Clients. RESEARCH AND OTHER SOFT DOLLAR BENEFITS “Soft dollar” arrangements refer to the provision by broker-dealers of research services or products in connection with the allocation of trades. Soft dollar arrangements generally arise when an investment adviser obtains products and/or services, other than securities execution, from a broker-dealer and pays a rate higher than the lowest commission rate available. As described herein, Glenview is entitled to and does use commissions or “soft dollars” generated by the Clients to pay broker-dealers for certain brokerage and research services. Consequently, a conflict of interest may exist as Glenview has an incentive to select a broker-dealer based on Glenview’s interest in receiving research or other products or services, rather than the Client’s interest in receiving the most favorable execution. At the same time, Glenview believes that paying such higher commissions is in the best interests of the Clients as it is important to the investment decision-making process to have access to such research and other products and services. Accordingly, Glenview regularly assesses the value and quality of the brokerage and research services provided by
the broker-dealers with which it does business to determine that the cost of such services is appropriate and reasonable in light of the brokerage and research services provided. An investment adviser has a fiduciary obligation to ensure that brokerage commissions (or mark-ups and markdowns) are used for the benefit of its clients and that its clients are fully informed of the adviser's use of brokerage commissions (or mark-ups or mark-downs) to purchase soft dollar products. Section 28(e) of the Securities Exchange Act of 1934, as amended, provides investment advisers with a safe harbor that allows them to pay more than the lowest possible commission in return for the receipt of research and brokerage services, subject to certain conditions. The receipt of soft dollar products from broker-dealers generally must be limited to research and brokerage services, if such practices are to fall within the safe harbor set forth in Section 28(e). Glenview’s brokerage activities are designed to stay within the safe harbor of Section 28(e). Research services provided by broker-dealers (including those acquired during the last fiscal year) include information on the economy, industries, groups of securities, individual companies, statistical information and analytics, accounting and tax law interpretations, political and legal developments affecting portfolio securities, and technical market action. Such research services are received primarily in the form of written reports, telephone contacts and personal meetings and may include access to computer generated data. In addition, such research services may include invitations to attend conferences or meetings with management teams, security analysts, industry consultants and economists. The soft dollar benefits that Glenview receives do not generally have a “mixed use”, nor does Glenview utilize such research or services for functions unrelated to its investment process. To the extent a “mixed use” product or service is received by Glenview, such product or service will be reviewed and analyzed to ensure that only the proportion of the product or service that Glenview uses to formulate and execute investment decisions is paid for with soft dollars. In addition, Glenview has entered into “commission sharing arrangements”, under which a broker that is involved in effecting transactions for the Clients pays third-party brokers or in some cases third-party research providers that provide eligible research to Glenview but that do not offer sufficient trading services or capabilities. In some cases, Glenview also chooses to pay certain brokers in cash (“hard dollars”) for research and corporate access rather than with soft dollars. Third-party providers of research other than brokers are generally paid by the Clients in cash (“hard dollars”). Research products or services obtained with soft dollars generated by one or more Clients may be used by Glenview to service other Clients, including Clients that may not have paid for the soft dollar benefits. As there is substantial overlap in the holdings of the Clients, Glenview believes that all the Clients benefit from the research services received through soft dollar arrangements. Accordingly, we do not seek to specifically allocate soft dollar benefits to client accounts in proportion to the commissions or fees the client accounts generate. Glenview regularly considers the amount and nature of research and research services provided by brokerdealers, as well as the extent to which such services are relied upon and attempts to allocate a portion of the brokerage business of its clients on the basis of that consideration. Broker-dealers sometimes suggest a level of business they would like to receive in return for the various products and services they provide. Actual brokerage business received by any broker-dealer may be less than the suggested allocation, but can also exceed the suggested level, because total brokerage is allocated on the basis of multiple considerations. In no case will Glenview make binding commitments as to the level of brokerage commissions it will allocate to a broker-dealer. A broker-dealer is not excluded from receiving business because it has not been identified as providing research products or services. TRADE AGGREGATION AND ALLOCATION When Glenview determines that it would be appropriate for particular Clients to participate in an investment opportunity, Glenview will seek to allocate orders on a basis that it deems to be fair and equitable, taking into account several factors, including, without limitation, the risk-return profile of the proposed investment in light of the respective Client’s investment objectives and program, diversification requirements, risk parameters, liquidity requirements, leverage considerations (including, margin and financing considerations), position sizing, exposure limitations and any applicable tax and regulatory considerations (collectively, the “Allocation Factors”).
Item 14: Client referrals and other compensation Conflicts of interest
The Funds’ prime brokers or other broker-dealers may assist the Funds in raising capital from investors by, among other things, referring investors to the Funds and providing an opportunity for representatives of Glenview to speak at investor conferences and programs sponsored by brokers. While neither Glenview, the Funds nor their affiliates separately compensate any broker in return for such capital introductions services or for any other referrals, Glenview will at times place transactions with brokers that provide such capital introduction services and/or other referrals. As such, Glenview could have a conflict of interest when allocating such business to prime brokers or other broker dealers. Glenview conducts periodic reviews in an effort to identify and mitigate the risks associated with such potential conflicts of interest. From time to time, Glenview may use the services of a placement agent, consultant, finder, introducer, municipal advisor or other solicitor for the solicitation of prospective investors. Any fees paid to any such consultants and/or placement agents for the solicitation of prospective investors will be borne by Glenview; no deduction will be made from an investor’s subscription amount with respect to such fees. If an investor is introduced to a Fund through a consultant and/or placement agent pursuant to an arrangement with Glenview, the arrangement, if any, with such consultant and/or placement agent will be disclosed to, and acknowledged by, the investor. Interests of the Funds may also be made available through the distribution platforms of certain financial institutions. While none of the Funds, Glenview or any of their affiliates pay any placement agent fees to make interests of a Fund available through such distribution platforms, individual investors purchasing interests through a distribution platform may incur fees charged by the applicable financial institution. Such fees will be in addition to any amounts invested in the Fund and will not be shared by the applicable financial institution with the Funds, Glenview or any of their affiliates.
Item 9: Disciplinary information
There are no legal or disciplinary events that are material to our advisory business or the integrity of our management.
Item 13: Review of accounts
Glenview’s senior investment professionals, trading personnel and senior financial, risk, compliance and operational personnel regularly and continuously review the accounts of the Clients. Such reviews, which may occur on a daily, weekly, monthly, quarterly, annual or a periodic basis, include: performance of the Clients and individual security positions; performance attribution by security type and industry sector; position size by individual security and issuer; gross and net exposures, in the aggregate as well as by security type, industry sector, geographic region and market type; portfolio liquidity; currency risk; credit and counterparty exposure; volatility, correlations and other risk factors and valuation. In addition, a review of a client account may be triggered by an unusual activity or special circumstances. Investors are provided with the following written reports:
For investors in the Glenview Funds and the Opportunity Funds only, monthly performance and exposure reports and statements of assets under management
Monthly capital balance statements or statements of net asset value
Monthly investor services reports that are prepared by the Funds’ administrator which contain (i) the Fund’s net asset value, (ii) the balances held at each counterparty and (iii) the assets of the Funds broken down by Level I, Level II and Level III classification per Accounting Standards Codification No. 820
Annual audited financial statements with a report by the independent auditors of the Fund
In certain Funds, a Schedule K-1
In addition to the reports discussed above, investors in the (i) Glenview Funds, the Opportunity Funds and the Healthcare Funds are provided with their respective monthly performance estimates and a quarterly letter, and (ii) Glenview Funds receive written weekly performance estimates. Investors in GCM Investment Partners, L.P. and the Suggestivist Funds receive monthly capital balance statements, Schedule K-1s and annual audited financial statements. As described in Item 11, the Managed Account will benefit from certain differing transparency and reporting requirements.
Item 15: Custody
Glenview is deemed to have custody of funds and securities of the Funds because it has the authority to obtain funds or securities of the Funds, for example, by deducting advisory fees from a Fund’s account or otherwise withdrawing funds from a Fund’s account. Rule 206(4)-2 under the Advisers Act imposes certain requirements on registered investment advisers who have actual or deemed custody of client assets. However, Glenview is exempt from (or is deemed to comply with) many of the provisions of the custody rule because (i) each Fund is audited in accordance with U.S. Generally Accepted Accounting Principles on an annual basis by an independent public accountant that is registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board, and audited financial statements are distributed to each investor in the Funds within 120 days of the end of each Fund’s fiscal year, and (ii) each Fund’s assets are held at a qualified custodian to the extent required by Rule 206(4)-2. Such qualified custodians include prime brokers, banks and other broker-dealers. Glenview is not deemed to have custody of the assets of the Managed Account pursuant to Rule 206(4)-2.
Item 16: Investment discretion
Glenview has been granted discretionary authority to manage the securities accounts of the Clients pursuant to investment management agreements entered into with each of the Funds and the Managed Account. Glenview’s investment decisions and advice with respect to each Fund and the Managed Account are subject to the investment objectives and guidelines, as set forth in such Fund’s offering documents and the Managed Account’s investment management agreement.
Item 17: Voting client securities
Glenview has adopted proxy voting policies and procedures in compliance with Rule 206(4)-6 under the Advisers Act. Glenview’s policy is to vote proxy proposals, amendments, consents or resolutions relating to securities held by the Clients in a manner that serves the best interests of the Clients, as determined by Glenview in its discretion. Glenview’s general policy is to vote in accordance with the recommendation of an issuer’s management on routine and administrative matters, unless Glenview determines that such recommendation is not in the best interests of the relevant Client(s). With respect to non-routine matters, Glenview will vote on a case-by-case basis, taking into account all relevant factors, including the anticipated impact of the proposals on the value of the securities, the costs and benefits associated with the proposal, customary industry and business practices, the recommendations of proxy advisory firms and any other factors we deem relevant. Under certain circumstances, we may abstain from voting specific proxies if we believe that doing so is in the best interests of the relevant Client(s). Furthermore, we may determine not to vote proxies issued by companies if the Client no longer has any economic exposure to the issuer of the proxy. There may be occasions where the voting of proxies may present an actual or perceived conflict of interest between Glenview and the Clients. Glenview will not vote proxies contrary to the best interests of the Clients due to (for example) business or personal relationships with an issuer’s management or where Glenview or an employee has a personal relationship with participants in proxy contests, corporate directors or candidates for corporate directorships, or where Glenview or an employee may have a personal interest in the outcome of a particular matter before shareholders. Each employee involved in a proxy voting decision is required to disclose any potential conflict of interest that such employee is aware of relating to a proxy vote by Glenview. Glenview’s Chief Compliance Officer will determine whether a conflict of interest is material based on an assessment of the particular facts and circumstances. When there exists an actual or potential material conflict of interest, Glenview’s Chief Compliance Officer will review the facts and circumstances of such conflict and determine the appropriate steps to ensure that Glenview votes all proxies in the best interests of the Clients. Glenview may engage a third party to recommend a vote with respect to the proxy or utilize any such method deemed appropriate under the circumstances given the nature of the conflict. Any attempts to influence the proxy voting process by others not authorized to make proxy voting decisions must be promptly reported to Glenview’s Chief Compliance Officer. In addition, Glenview maintains compliance oversight to ensure that the voting of proxies complies with Glenview’s proxy voting policies and procedures, including, without limitation, reviewing for any potential conflicts of interest. Investors may not direct Glenview to vote in a particular way for a particular solicitation. Investors may obtain a copy of Glenview’s proxy voting policies and procedures, and information about how we voted securities in a particular proxy vote, upon request by contacting us at 212.812.4700 or info@glenviewcapital.com.
Item 18: Financial information
Glenview is not required to include a balance sheet for its most recent fiscal year, is not aware of any financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients and has not been the subject of a bankruptcy proceeding.
Filings
25 filings to the SEC since October 2021: 25 other. The latest 20:
- Aug 27, 2026N-PX EDGAR
- Aug 14, 202613F-HR EDGAR
- May 15, 202613F-HR EDGAR
- Feb 17, 202613F-HR EDGAR
- Nov 14, 202513F-HR EDGAR
- Sep 2, 2025N-PX EDGAR
- Aug 14, 202513F-HR EDGAR
- May 15, 202513F-HR EDGAR
- Feb 14, 202513F-HR EDGAR
- Nov 14, 202413F-HR EDGAR
- Aug 30, 2024N-PX EDGAR
- Aug 14, 202413F-HR EDGAR
- May 15, 202413F-HR EDGAR
- Feb 14, 202413F-HR EDGAR
- Nov 14, 202313F-HR EDGAR
- Aug 14, 202313F-HR EDGAR
- May 15, 202313F-HR EDGAR
- Feb 14, 202313F-HR EDGAR
- Nov 14, 202213F-HR EDGAR
- Aug 11, 202213F-HR EDGAR
The 25 filings since October 2021 can be filtered by form type and year here when JavaScript is on.
Every filing from the last five years, summarized. The full record is on SEC EDGAR.
Stakes it holds
GLENVIEW CAPITAL MANAGEMENT, LLC has told the SEC it owns more than 5% of 15 companies, latest first (Schedules 13D and 13G).
- Surgery PartnersSCHEDULE 13G Oct 13, 20264
- Butterfly Network, Inc.SCHEDULE 13D/A Feb 14, 2023 to Aug 17, 20265
- DXC TechnologySCHEDULE 13G/A Nov 13, 2023 to Aug 14, 20266
- Myriad GeneticsSCHEDULE 13G/A Mar 1, 2023 to Aug 14, 20267
- ZoomInfoSCHEDULE 13G/A Jul 11, 2025 to Aug 14, 20268
- Genius Sports LtdSCHEDULE 13G May 21, 20269
- Alight SolutionsSCHEDULE 13G/A Jan 16, 2024 to Aug 14, 202510
- Brookdale Senior LivingSC 13G/A Feb 14, 2022 to Nov 14, 202411
- Tenet HealthcareSC 13G/A Feb 14, 2022 to Nov 14, 202412
- Quantum-Si IncSC 13G/A Feb 14, 2022 to Feb 14, 202313
- MeritorSC 13G Feb 22, 202214
- ATI Physical Therapy, Inc.SC 13G/A Feb 14, 202215
- Evolv Technologies Holdings, Inc.SC 13G/A Feb 14, 202216
- Velocity Acquisition Corp.SC 13G/A Feb 14, 202217
- Bausch HealthSC 13D/A Dec 13, 202118
Sources
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