The Adviser
The Adviser is an investment firm organized as a Delaware limited liability company that has
its principal place of business located in New York, New York. The Adviser is wholly owned
by Integral Health Advisors, LP which is owned primarily by Bhagwan Jay Rao (the
“Principal”)
The Adviser was formed in 2019 by the Principal.
Adviser Services
The Adviser provides discretionary investment advisory and sub-advisory services to sub-
advised accounts (referred to herein as “Managed Accounts”), and also serves as the
investment manager to affiliated pooled investment vehicles that are exempt from registration
under the Investment Company Act of 1940, as amended (the “1940 Act”), and whose
securities are not registered under the Securities Act of 1933, as amended (the “Securities
Act”) (each, a “Fund”, collectively, the “Funds”, and together with the Managed Accounts, the
“Clients”). The Funds are organized in a master-feeder structure. The Funds currently advised
by the Adviser are Integral Health Newton, LP, a Delaware limited partnership (the “Onshore
Fund”), Integral Health Newton, Ltd., an exempted company incorporated and existing under
the laws of the Cayman Islands (the “Offshore Fund”), and Integral Health
Newton Master
Fund, LP, an exempted limited partnership existing under the laws of the Cayman Islands (the
“Master Fund”). The Onshore Fund and the Offshore Fund pursue their objectives by investing
substantially all of their assets in the Master Fund. Integral Health GP, LLC, a Delaware
limited liability company (the “General Partner”) serves as general partner to the Onshore
Fund and the Master Fund.
The Adviser may tailor the specific advisory services with respect to each Client based on the
particular investment objectives and strategies as described in the applicable Client’s
confidential offering memorandum, operating agreement, investment management
agreement, sub-advisory agreement separate account agreement (as applicable) (referred to
as, the “Governing Document(s)”). The Governing Document(s) for a Managed Account
may be tailored to reflect the specific needs of the Managed Account. Investments by the
Funds are restricted by the terms of each Fund’s Governing Documents.
The Adviser does not participate in wrap fee programs.
Assets Under Management
As of December 31, 2023, the Adviser manages $815,150,147 in discretionary regulatory
assets under management and $0 in non-discretionary regulatory assets under management.