National Veterinary Associates
National Veterinary Associates (NVA) is one of the largest veterinary hospital networks in North America, with about 1,300 locations including general practice hospitals, specialty and emergency hospitals (Ethos Veterinary Health), equine hospitals and pet resorts. Owned by JAB Holding Company, a Luxembourg-based investment firm, NVA grew through a decades-long PE-backed roll-up that drew three FTC consent orders and a 2024 Senate investigation over its effect on pet care costs and competition.
Score generated by AI agents based on publicly cited evidence and reviewed by the project maintainer. Not independently validated. Last assessed 2026-10-01. Score revised 2026-10-01: 56 → 46.
Score History
Timeline events are AI-curated from public reporting. Score trajectory is derived from documented events.
Founded in 1996 by veterinarian Stanley Creighton, NVA took backing from Willis Stein & Partners in 1997 to buy its first 22 hospitals, targeting well-regarded practices whose owners wanted to sell. By 2007 it ran 96 hospitals in 29 states. At that scale it had little market power, and the record shows no pricing, labor or regulatory problems.
Summit Partners bought NVA for $128 million to speed up acquisitions, building a dedicated deal team and a larger credit facility; NVA added more than 150 hospitals during Summit's ownership. Greg Hartmann, recruited as COO, succeeded the founder as CEO in 2009, moving NVA from veterinarian-led to professional corporate management.
Ares Management bought NVA (more than 240 hospitals in 39 states) and pushed into new markets and services: PetSuites boarding in 2015, VetPartners in Australia in 2016 and an OMERS minority stake in 2017, when NVA had 502 locations. In 2018 two Spokane vets sued, alleging NVA's planned purchase of the city's emergency clinic would tie its veterinarian shareholders to noncompetes and referral obligations. NVA owned more than 670 hospitals by 2019.
JAB, which had bought Compassion-First's specialty and emergency hospitals months earlier, agreed to buy NVA in a deal the FTC later described as $5 billion. Ryuk ransomware hit about 400 NVA hospitals in October 2019, and in February 2020 the FTC required three divestitures to clear the Compassion-First combination. JAB then bought pet insurers (2021), with a JAB partner saying clinic spending data would help price premiums, and NVA signed the $1.65 billion Ethos deal.
Two June 2022 FTC orders on the $1.1 billion SAGE and $1.65 billion Ethos deals required 11 more divestitures and imposed 10-year prior-approval terms in six jurisdictions plus nationwide prior notice. Closing both deals gave NVA more than 100 specialty, emergency and surgical hospitals. Employee reviews date the first of three support-center layoff rounds to 2022, and NVA dropped its early IPO plans.
NVA split into a general-practice business (about $4 billion run-rate revenue) and Ethos (about $2 billion) to prepare separate IPOs, named Larry Allgaier CEO, sold VetPartners Australia/NZ to EQT and pivoted from acquisitions to organic growth. Scrutiny peaked in 2024 with a Senate investigation of JAB, while noncompetes survived after courts struck down the FTC ban. Since 2025 a public-company leadership team (chairman Ken Burdick, CEO John Bruno, CFO Todd Young) has been assembled and Ethos folded under company-wide COO and CMO roles; no IPO has happened.
Alternatives
Privately owned, non-corporate vets are the most direct escape from PE-driven price extraction in the veterinary market. They set their own prices, are not bound by corporate revenue targets, and often provide more continuity of care. Ask directly whether a practice is independently owned or affiliated with NVA, VCA, Banfield, Thrive, or BluePearl networks. Private Equity Vet's searchable ownership map can help check who owns practices in your area.
Accredited veterinary schools (Cornell, UC Davis, Tufts, Colorado State, etc.) operate teaching hospitals where faculty veterinarians supervise students. They are university-run rather than PE-owned and offer a full range of specialty care. Best suited for complex cases or specialist care; usually not practical for routine wellness visits unless you're near a veterinary school.
Dimensional Breakdown
Summaries below were written by AI agents based on the cited evidence. They are editorial interpretations, not independent research findings.
Dimension History
Timeline (49 events)
Dr. Stanley Creighton Founds National Veterinary Associates
Dr. Stanley Creighton, DVM, founded NVA with the vision of consolidating the fragmented veterinary practice market through an acquisition model that provided practice management support while preserving local medical standards. The founding model emphasized letting veterinarians focus on care while NVA handled business operations.
Willis Stein & Partners Invests, Acquires Initial 22 Hospitals
Chicago-based private equity firm Willis Stein & Partners invested in NVA, funding the acquisition of 22 initial veterinary hospitals. This marked NVA's entry into the PE-backed roll-up model, targeting practices with strong local reputations whose retiring owners were looking to sell.
Summit Partners Acquires NVA for $128 Million
Growth capital firm Summit Partners acquired NVA from Willis Stein & Partners. At this point NVA operated 96 animal hospitals with 1,800 employees including 300 veterinarians across 29 states. Summit's $128 million investment was specifically earmarked to accelerate acquisition pace.
NVA Builds Dedicated Acquisition Team Under Summit
Summit Partners helped recruit and build a dedicated business development team focused on identifying and completing veterinary practice acquisitions, and supported an upsized credit facility to fund them. This professionalized the roll-up pipeline; Summit says NVA added more than 150 hospitals during its investment.
Greg Hartmann Succeeds Founder as CEO
Greg Hartmann, who had been recruited as COO, became CEO of NVA as part of a planned succession from founder Dr. Stanley Creighton. Hartmann's appointment marked the shift from a veterinarian-led company to professional corporate management, and he would lead NVA through three PE ownership changes over the next 14 years.
Ares Management Acquires NVA from Summit Partners
A fund managed by Ares Management's private equity group agreed to acquire NVA from Summit Partners; terms were not disclosed. NVA operated more than 240 hospitals across 39 states. Under Ares, NVA expanded internationally (Australia and New Zealand via VetPartners), entered pet boarding and resorts, and accelerated acquisitions, describing itself by 2017 as the largest independent owner-operator of veterinary hospitals and pet resorts in the U.S., Canada, Australia and New Zealand.
NVA Acquires PetSuites of America Boarding Chain
NVA acquired PetSuites of America, a pet boarding, grooming, and daycare chain founded in 2000. The acquisition expanded NVA's service footprint beyond veterinary care into the pet hospitality segment, deepening the company's ability to monetize multiple touchpoints of pet ownership.
NVA Launches VetPartners in Australia
NVA invested in and partnered with Australian veterinary practices to form VetPartners, launching in 2016 with 32 practices. This marked NVA's first major international expansion outside North America. VetPartners became the largest owner of veterinary practices in Australia and New Zealand, reaching 267 locations before NVA agreed in October 2023 to sell it to EQT.
OMERS Private Equity Takes Minority Stake in NVA
Canadian pension fund OMERS Private Equity acquired a minority stake in NVA alongside Ares Management. At this point NVA had grown to 502 locations with more than 1,800 affiliated veterinarians across the U.S., Canada, Australia, and New Zealand. The investment provided additional capital for continued acquisition growth.
Spokane Veterinarians File Antitrust Suit Against NVA
Two veterinarians who had worked at Pet Emergency Clinic (PEC) in Spokane, Washington, sued PEC and NVA in Spokane County Superior Court, alleging the two were jointly trying to monopolize emergency veterinary care. Under NVA's proposed deal to buy PEC, the clinic's roughly 50 veterinarian shareholders would have been bound by noncompetes, and those in general practice obligated to refer emergency and specialty cases to PEC.
JAB Acquires Compassion-First Pet Hospitals for $1.2 Billion
JAB Holding Company acquired Compassion-First Pet Hospitals from Quad-C Management at a total enterprise valuation of $1.215 billion. Compassion-First operated specialty, emergency, and general practice veterinary hospitals. This was JAB's first pet care investment and the beginning of its veterinary roll-up strategy.
JAB Agrees to Acquire NVA from Ares and OMERS
JAB Holding Company agreed to buy a majority stake in NVA from Ares Management and OMERS for an undisclosed price; the FTC later described it as a $5 billion purchase. NVA then owned more than 670 veterinary hospitals and 70 pet resorts in 43 states, Canada, Australia and New Zealand. It was JAB's second major U.S. pet care deal of 2019 after Compassion-First. CEO Greg Hartmann and senior management kept a significant minority stake.
Ryuk Ransomware Cripples 400 NVA Hospitals
NVA was hit by a Ryuk ransomware attack discovered on Sunday, October 27, 2019, that affected roughly 400 of its veterinary hospitals, cutting many off from patient records, payment systems and practice-management software. More than three weeks later NVA said it expected all facilities to be fully back up within the next week. A source told KrebsOnSecurity it was the second Ryuk incident at NVA that year; NVA said the earlier incident was not ransomware.
FTC Requires Divestiture of 3 Clinics for Compassion-First/NVA Merger
The FTC required Compassion-First and NVA to divest three specialty/emergency clinics to MedVet Associates as a condition of their $5 billion combination. The affected clinics were in Asheville (NC), Norwalk (CT), and Manassas (VA), where the merger would have resulted in monopoly conditions for specialty and emergency veterinary services.
Spokane Veterinarians File Federal Antitrust Suit Against NVA
The two Spokane veterinarians who had sued NVA in state court in 2018 filed a federal antitrust lawsuit in the U.S. District Court for the Eastern District of Washington, alleging NVA tried to corner the regional emergency pet care market through noncompete and referral agreements tied to its planned purchase of Pet Emergency Clinic. In early 2021 the judge allowed the case to proceed.
JAB Acquires Pet Insurance Business from Independence Holding
Under a May 17, 2021 agreement with JAB Holdings, Independence Holding Company sold its 85% stake in PetPartners to JAB's Independence Pet Holdings on June 30, 2021, and completed the sale of underwriter Independence American Insurance Company in December 2021. With NVA's roughly 1,200 clinics, JAB now owned both a large veterinary care provider and a pet insurer.
NVA Signs $1.65 Billion Deal to Acquire Ethos Veterinary Health
JAB-backed NVA agreed to acquire Ethos Veterinary Health, an operator of specialty and emergency hospitals (about 23 hospitals in nine states at the time), for approximately $1.65 billion. The FTC later required divestitures in four markets as a condition of the deal.
JAB Acquires Figo Pet Insurance to Expand Insurance Platform
JAB expanded its pet insurance platform through the acquisition of Figo Pet Insurance by Independence Pet Holdings. Figo became a wholly-owned subsidiary of PetPartners. JAB now insured over 200,000 pets with premiums exceeding $120 million annually, deepening vertical integration between veterinary care and pet insurance.
JAB Partner Says NVA Clinic Spending Data Will Help Price Pet Insurance
As JAB's pet insurance platform agreed to buy Figo, JAB senior partner David Bell said in an interview that JAB's access to large amounts of consumer spending data at its veterinary clinics would help it price insurance premiums accurately. JAB controlled NVA, then about 1,200 practices, alongside its insurers, so data from NVA clients could feed a sibling business without clients being told.
NVA Completes $1.1 Billion Acquisition of SAGE Veterinary Partners
NVA closed its $1.1 billion acquisition of SAGE Veterinary Partners, which operated specialty and emergency clinics across the western United States including California, Arizona, Washington, and Alaska. The acquisition further consolidated JAB's hold on the specialty veterinary segment.
FTC Orders JAB to Divest Six Clinics and Accept Prior-Approval Terms Before SAGE Deal
The FTC required JAB to sell six clinics (three SAGE hospitals in Austin and JAB clinics in San Mateo, Berkeley and Fairfield, California) to United Veterinary Care as a condition of its $1.1 billion SAGE acquisition. For 10 years JAB must get FTC approval before buying a specialty or emergency clinic within 25 miles of its own in California or Texas, and give 30 days' notice of such deals anywhere in the U.S.
FTC Takes Second 2022 Action Against JAB, Orders 5 More Divestitures for Ethos Deal
Two weeks after ordering JAB to divest clinics in California and Texas before buying SAGE, the FTC required JAB to sell five clinics in Richmond (VA), the Washington D.C. area, Denver and the San Francisco area as a condition of its $1.65 billion Ethos acquisition. JAB must get FTC prior approval for 10 years before buying any specialty or emergency clinic within 25 miles of a JAB clinic in California, Colorado, D.C., Maryland and Virginia, and must give 30 days' prior notice of such acquisitions anywhere in the U.S.
NVA Closes $1.65 Billion Ethos Acquisition
NVA completed its acquisition of Ethos Veterinary Health, a specialty and emergency hospital operator, which joined NVA Compassion-First, NVA's specialty and emergency group. Together with SAGE, acquired a month earlier, the group comprised more than 100 specialty, emergency and surgical hospitals.
Spokane Antitrust Lawsuit Dismissed on Summary Judgment
A federal judge granted summary judgment in favor of NVA in the Spokane antitrust lawsuit, approximately 18 months after allowing the monopoly case to proceed. The dismissal eliminated the legal challenge to NVA's emergency care acquisition strategy in the region.
Employee Review Describes Three Rounds of NVA Support-Center Layoffs Since 2022
A Glassdoor review says NVA's support center went through three rounds of mass layoffs beginning in 2022: the first hit the business operations team, the second cut 12-15% of every department, and the last depleted departments tied to employee development. Reviewers said layoffs came whenever the bottom line was not met and hung over employees for months.
NVA Splits Into Two Entities to Prepare for Dual IPOs
NVA announced its reorganization into two separately managed businesses: NVA (about 1,400 general practice hospitals, equine hospitals and pet resorts, with run-rate revenue of about $4 billion) and Ethos Veterinary Health (145 specialty and emergency hospitals, run-rate revenue of about $2 billion). The company said the move would let each prepare for an eventual IPO within two to three years.
Larry Allgaier Replaces Hartmann as NVA CEO
As part of the NVA/Ethos split, long-time CEO Greg Hartmann moved to Chairman, and Larry Allgaier was appointed CEO. Allgaier, with 30+ years of consumer, healthcare, and veterinary experience, was tasked with preparing NVA for its eventual IPO. The leadership change accelerated the shift from veterinary-culture management to IPO-readiness corporate governance.
NVA Announces Sale of VetPartners Australia/NZ to EQT
NVA agreed to sell its VetPartners business, 267 general and specialty practices in Australia, New Zealand and Singapore, to Swedish private equity firm EQT. The price was not disclosed; local media put it at roughly AUD 1.4 billion. VIN News reported the sale would provide a cash injection into NVA as JAB prepared to take its veterinary businesses public.
FTC Chair Khan Addresses Veterinary Consolidation at AVMA Forum
FTC Chair Lina Khan addressed the 2023 AVMA Veterinary Business and Economic Forum, warning about 'roll-up activities, serial acquisitions, and stealth consolidation schemes' in the veterinary sector. Khan stated the FTC was 'really doubling down' on enforcement because of 'harms to people at the level of higher prices, but also worse quality.'
Ninth Circuit Affirms Dismissal of Spokane Antitrust Suit Against NVA
The Ninth Circuit affirmed the dismissal of the Spokane veterinarians' Sherman Act claims, which alleged NVA and Pet Emergency Clinic tried to create a closed emergency-care network through noncompete, non-solicitation and mandatory-referral agreements. The ruling turned on antitrust standing, not on whether the agreements were lawful. The vets then petitioned the Supreme Court.
NVA Vet Describes Per-Appointment Revenue Targets
Veterinarian Melissa Ezell told Stateline that management at her NVA-owned clinic in Huntsville, Alabama, began pressing vets to make a set amount from every appointment, to offer more services when owners weren't spending enough and to see more patients outside normal hours. NVA said its philosophy is grounded in vets making medical decisions, not a corporate office.
FTC Votes to Ban Noncompete Agreements Nationwide
The FTC voted to issue a rule banning most noncompete agreements nationwide, which would have barred the noncompetes common in corporate veterinary employment contracts. Veterinarians were among the most active commenters during the rulemaking. The ban was set to take effect September 4, 2024.
FTC and DOJ Launch Joint Inquiry Into Serial Acquisitions and Roll-Ups
The FTC and DOJ jointly launched a public Request for Information on serial acquisitions and roll-up strategies across the U.S. economy. The RFI cited the FTC's June 2022 action against JAB Consumer Partners' veterinary acquisitions, with its first-of-its-kind prior-approval and nationwide prior-notice provisions, as an example of addressing roll-ups.
Supreme Court Declines Spokane Veterinarians' Appeal Against NVA
The U.S. Supreme Court denied certiorari in Choker v. National Veterinary Associates (No. 23-1191), ending the Spokane veterinarians' antitrust case over NVA's planned emergency-clinic deal.
Senators Warren and Blumenthal Launch Investigation of JAB Holdings
U.S. Senators Elizabeth Warren and Richard Blumenthal wrote to JAB Holding Company leaders Joachim Creus and David Bell asking for a list of all veterinary practices JAB had acquired in the U.S. since 2019, prices charged for common services and drugs, veterinarian and technician salaries, executive pay, dividends and dividend recapitalizations, and real estate sales. The letter said private equity firms were 'profiteering while reducing quality of care.'
Federal Court Blocks FTC Noncompete Ban
The U.S. District Court for the Northern District of Texas ruled the FTC lacked statutory authority to issue its noncompete ban, blocking the rule before its September 4 effective date. Noncompetes in veterinary employment contracts remained enforceable wherever state law allows them; the FTC formally abandoned the rule in September 2025.
JAB Answers Senators: ~1% Dividend Yield, No Dividend Recaps, NVA Under 4% of Hospitals
Replying to Senators Warren and Blumenthal, JAB said NVA had paid only modest annual dividends averaging about 1% of equity value, had done no dividend recapitalizations, and that sale-leaseback proceeds were about 1% of its veterinary investment. It said NVA runs fewer than 4% of U.S. veterinary hospitals and that its margins had not risen since 2019. The senators later said the reply omitted key financial data.
AELP Documents Stealth Veterinary Consolidation in FTC/DOJ Comment
The American Economic Liberties Project submitted a detailed comment to the FTC/DOJ serial acquisitions RFI documenting how veterinary consolidators like NVA retain acquired clinics' original names to hide corporate ownership. The comment noted price hikes up to 100% at acquired practices and called for stronger enforcement against stealth roll-ups.
FTC Chair Khan Returns to AVMA Forum on Veterinary Consolidation
FTC Chair Lina Khan opened the 2024 AVMA Veterinary Business and Economic Forum, her second appearance, with an update on litigation over the noncompete rule and an explanation of how the new merger guidelines apply to serial veterinary acquisitions. She said she was struck by how many veterinarians described noncompetes burying them in litigation and forcing them to relocate.
Brewster Horse Veterinarian Sues NVA for $9 Million Breach of Contract
Dr. Christopher 'Kit' Miller, who sold 65% of his equine practice to NVA in 2019 for $25.6 million, sued NVA for $9 million in Westchester Supreme Court. Miller alleged NVA 'changed the policies, processes and procedures of the practice,' making it 'less collaborative, less collegial, and a less desirable place to work.' The case was settled in March 2025.
Warren and Blumenthal Send Follow-Up Investigation Letter to JAB
Senators Warren and Blumenthal sent a follow-up letter to JAB CEO demanding additional information by December 2, 2024, including the value of JAB's veterinary care companies, shareholder dividends, whether JAB-owned diagnostic labs charge different prices to JAB-owned clinics, and details on noncompete usage. The escalation followed stakeholder events in the senators' home states.
CBC Marketplace: NVA Canada Keeps Clinic Names, Hiding Corporate Ownership
CBC Marketplace reported that NVA Canada is one of the three largest owners of Canadian vet clinics and that, unlike VCA, it does not brand its clinics, so clients may not know who owns them. NVA told CBC it keeps local clinic names to respect the heritage built by the original veterinarian.
NVA Appoints Ken Burdick Executive Chairman for IPO Preparation
NVA appointed Ken Burdick, former CEO of WellCare Health Plans and current Executive Chairman of LifeStance Health (NASDAQ: LFST), as Executive Chairman. The appointment brought public company healthcare expertise to NVA's board ahead of its planned IPO, signaling JAB's exit timeline was accelerating.
New York Assemblymember Introduces Veterinary Ownership Transparency Bill
New York Assemblymember Linda Rosenthal introduced Assembly Bill A9042, requiring acquiring entities to file notice with the Attorney General before purchasing a veterinary practice. The bill would allow the AG to block acquisitions deemed against the public interest, a direct response to consolidation by chains like NVA.
FTC Formally Abandons Noncompete Ban
The FTC voted 3-1 to vacate its 2024 noncompete rule and dropped its appeals, conceding the court rulings that it lacked authority. Noncompetes in veterinary contracts, including at corporate chains like NVA, remain enforceable where state law allows; the FTC said it would pursue case-by-case enforcement instead.
John Bruno Appointed NVA CEO, Replacing Allgaier
NVA's board appointed John G. Bruno, a former Xerox president and COO, as CEO effective immediately. Bruno replaced Larry Allgaier, who had led NVA since the 2023 split. The appointment of a technology-focused corporate executive from outside veterinary medicine underscored JAB's IPO-readiness priorities over veterinary domain expertise.
Ethos Folded Under NVA CEO With New President Leslie Storms
NVA named former Johnson & Johnson executive Leslie Storms president of Ethos Veterinary Health, which NVA now calls its specialty and emergency network of more than 140 hospitals, reporting to NVA CEO John Bruno. She replaced an interim president who had served for the prior year.
NVA Hires Former Public-Company CFO Todd Young
NVA named Todd Young, former CFO of Acadia Healthcare and Elanco (where he helped separate it from Eli Lilly as a public company), as CFO from May 1, 2026, citing his public company experience. With Executive Chairman Ken Burdick and CEO John Bruno, it completed a leadership team suited to an eventual IPO.
NVA Names Company-Wide COO and First Chief Medical Officer Across All Hospitals
NVA appointed Leslie Storms chief operating officer and promoted board-certified internist Dr. Stacy Burdick to chief medical officer across its whole network of general practice, specialty and emergency hospitals, the first such company-wide role, which NVA said elevates the voice of medicine in decision-making.
Evidence (51 citations)
D1: User Value Erosion
D2: Business Customer Exploitation
D3: Shareholder Extraction
D4: Lock-in & Switching Costs
D5: Twiddling & Algorithmic Opacity
D6: Dark Patterns
D7: Advertising & Monetization Pressure
D8: Competitive Conduct
D9: Labor & Governance
D10: Regulatory & Legal Posture
Scoring Log (6 entries)
Checked 91 items + prose. 23 verified, 37 corrected (12 date-only), 25 re-sourced, 6 removed. Invented: $7.7B JAB-NVA price (AVMA: undisclosed; FTC: $5B); '11 clinics in two FTC actions' (FTC: 14 in three); FTC prior approval 'nationwide' (FTC: state-specific); Ethos '140+/145 hospitals' at acquisition (CARE for Pets: 23); Warren letter 'since 1994' + noncompete questions (letter: since 2019, none); split '$4B/$2B valuations' (LABJ: run-rate revenue); 'Save Our Pets Act' S.4543 (S.4543 is a SNAP bill); JAB 'controlling 75-80% of specialty care' (PESP: all consolidators ~75%). Many dead/fabricated URLs re-sourced (PESP, PitchBook, WaPo, ConsumerAffairs, AVMA pages, Glassdoor IDs).
56→46. Since Feb 2026 (window Oct 2025–Sep 2026): leadership rebuilt for an eventual IPO (CEO Bruno Sept 2025, Ethos president Dec 2025, public-company CFO Apr 2026, board Jul 2026, company-wide COO/CMO Aug 2026); Allgaier-era pivot from acquisitions to organic growth disclosed; FTC noncompete rule formally vacated Sept 2025; U.S. vet services CPI +7.8% YoY (Sep 2025); JAB insurers relaunched as Doubtless; no new enforcement, litigation or IPO. D1 6→5 (recalibration: no NVA-specific quality/safety failures; old continuity/ER-wait claims unsourced), D2 6→4 (correction: fact audit removed in-house pharmacy pillar; remaining record is one settled seller suit, Spokane noncompete terms, per-appointment targets), D3 7→5 (recalibration: layoffs and exit prep fit 4-5; JAB says ~1% dividend yield, no recaps; no verified leverage/recap evidence; $7.7B price was invented), D4 5→4 (recalibration: no data lock-in; hidden ownership + noncompetes + auto-renew plans), D6 5→4 (recalibration: PawPlans auto-renew/written notice + undisclosed ownership; no regulatory or class action), D8 7→6 (event: organic-growth pivot and Australia/NZ exit; FTC orders still in force), D9 6→5 (recalibration: layoffs and revenue pressure fit 4-5; no anti-union or mass layoffs during record profits), D10 5→4 (recalibration: settled consent orders, partial Senate reply; no lobbying evidence found). Eras: 1997-06-01→1997-06-23 (Willis Stein), 2007-04-01→2007-04-19, 2014-07-01→2014-07-18, 2019-06-01→2019-06-17, 2022-06-01→2022-06-13 (FTC SAGE order) re-dated; current era re-dated 2026-02-17→2023-03-27 (NVA/Ethos split for IPOs) and relabeled 'Peak Extraction'→'Split for IPO Exit'. All eras re-scored; JAB-era D2/D7 cells lowered where gap searches found no events. Category: guide fits; no flag.
Triaged 2026-06-30 (Wave A); no rescore warranted (no material change / changes sub-threshold / flag refuted on verification).