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Part 2A of Form ADV
Firm Brochure
1441 Brickell Av. Suite 1016, Miami, Fl 33131
305-456-7645
As of: December 31, 2024
This Brochure (the “Brochure”) provides information about the qualifications and business practices of
LXG Wealth Advisory LLC (“LXG” or “the Firm”). If you have any questions about the contents of this
Brochure, please contact us at compliance@lxgwa.com. The information in this brochure has not been
approved or verified by the United States Securities and Exchange Commission (the “SEC”) or by any
state securities authority.
Additional information about LXG Wealth Advisory LLC is also available on the SEC’s website at
www.adviserinfo.sec.gov. You may also request a copy of our Brochure by contacting us at +1 (305) 456-
7645 or compliance@lxgwa.com.
LXG Wealth Advisory LLC is a registered investment adviser. Registration of an investment adviser does
not imply that LXG or any of our principals or employees possesses a particular level of skill or training.
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Item 2 – Material Changes
LXG is required to advise you of any material changes to our business since our last annual update.
You will receive a summary of any material changes to this and subsequent brochures within 120 days
and without charge. You may also request a copy of the brochure by contacting us at 305-456-7645 and/or
by writing us an email at compliance@lxgwa.com.
Information about LXG is also available through the SEC’s public disclosure website (“IAPD” at
www.adviserinfo.sec.gov. The SEC’s website also provides information about any persons affiliated with
LXG who are registered, or are required to be registered, as investment adviser representatives of LXG.
LXG has amended this brochure to clarify the type of clients it renders investment advisory services to and
to reflect its assets under management (as of December 31, 2024) and to provide greater clarity on
potential conflict of interest it may have.
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Item 3 – Table of Contents
Item 2 – Material Changes ............................................................................................................................. 2
Item 3 – Table of Contents ............................................................................................................................. 3
Item 4 – Advisory Business ............................................................................................................................ 4
Item 5 – Fees and Compensation ................................................................................................................... 6
Item 6 – Performance-Based Fees and Side-by-Side Management ............................................................... 7
Item 7 – Types of Clients ................................................................................................................................ 7
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ......................................................... 7
Item 9 – Disciplinary Information ................................................................................................................. 10
Item 10 – Other Financial Industry Activities and Affiliations ...................................................................... 10
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................ 11
Item 12 – Brokerage Practices ..................................................................................................................... 14
Item 13 – Review of Accounts...................................................................................................................... 15
Item 14 – Client Referrals and Other Compensation .................................................................................... 15
Item 15 – Custody ........................................................................................................................................ 15
Item 16 – Investment Discretion .................................................................................................................. 16
Item 17 – Voting Client Securities ................................................................................................................ 16
Item 18 – Financial Information ................................................................................................................... 16
Item 19 – Requirements for State-Registered Advisors ............................................................................... 16
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Item 4 – Advisory Business
LXG is organized as a Florida limited liability company under the laws of the State of Florida and is a
registered Investment Adviser with the SEC. LXG has been in business since May 2021. LXG is owned by
LXG Capital, LLC. a Delaware corporation and by FM Segura LLC., a Florida corporation. LXG Capital, LLC is
an affiliate of LXG Group based in Lima Perú. LXG Group affiliates in Perú provide investment banking,
asset management and wealth advisory services to high-net-worth individuals and entities in Perú.
LXG Capital’s clients are organizations with business interests in Latin America and include corporations,
financial institutions, private equity funds and private families.
LXG provides investment advisory services to high-net-worth individuals, families, estates, trusts,
corporations, or other qualified entities (“Clients”). The Firm works with clients to help them define
appropriate investment objectives and to design and implement an investment process and individualized
strategies with client unique asset allocations that seeks to achieve those objectives. The client will be
provided with an Investment Policy Statement that will include the recommended asset allocation
strategy.
LXG investment advisory services include, but are not limited to, asset allocation analysis, instrument and
security selection, performance reporting, and portfolio monitoring. LXG provides advisory services to
Clients on a non-discretionary and discretionary basis. With respect to non-discretionary Clients, if the
Client approves LXG’s asset allocation and recommendation, the Firm can arrange or effect the approved
transaction at the request and on behalf of the Client, if authorized to do so by the Client. Otherwise, it
is incumbent upon the client to implement the recommended strategy. With respect to discretionary
Clients, the Firm arranges or effects transactions on behalf of the Client in order to implement the agreed
upon investment strategy (please refer to the section on Investment Discretion for additional information
on discretionary Clients).
LXG does not and will not have custody of client assets. Clients select the financial institutions that custody
their assets. LXG can recommend a particular custodian to our Clients, at their request, but the Firm does
not receive any compensation from the custodians for such recommendations (please refer to the section
on Brokerage Practices for additional information). LXG assists Clients in establishing investment
objectives, return expectations, risk tolerance, measuring time horizons for their strategies, liquidity
needs, and other Client-specific requirements, which are set forth in the Client’s Investment Policy
Statement. The Investment Policy Statement also includes specific portfolio management parameters and
associated restrictions by instrument type, asset class, sector, and geography, as applicable.
Based on the Investment Policy Statement, LXG offers investment advisory services regarding the
following instruments, and, on occasion, others not included below:
• Fixed income, including, but not limited to, investment grade and high yield corporate bonds
• Municipal securities
• Exchange traded funds
• Equity securities: exchange listed, over the counter, and foreign securities
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• Private equity funds and direct private equity
• Private debt funds and direct private debt investments
• Real Estate funds and direct real estate investments
• Hedge funds and other alternative investments
• Certificates of deposit
• Managed accounts
• Mutual funds
• Options and other derivative products
From time to time, LXG offers non-advisory services to its clients including, but not limited to, reporting
services and the coordination of the following: recommendations on legal representation and strategic
business planning, wealth transfer planning, estate planning, research on trustee placement, and select
administrative services. However, LXG does not provide legal or tax advice.
Clients may impose reasonable restrictions on investing in certain securities or types of securities for their
account(s). When a client requests certain restrictions, LXG will review these and determine, in its sole
discretion, if the conditions would materially impact the performance of a management strategy or prove
overly burdensome to the Firm’s account management efforts before accepting such restrictions. If LXG
determines that the restrictions prove to have a material impact to the strategy designed, LXG will notify
the client that it can not continue with the advisory relationship.
The Firm currently manages approximately $ $1,635,087,803 net assets on both a discretionary basis
and non-discretionary basis.
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Item 5 – Fees and Compensation
LXG charges Clients an Advisory Fee for services provided. The Advisory Fee is established and defined in
the Investment Advisory Agreement between LXG and the Client (the “Advisory Agreement”). Generally,
the Advisory Fee is expressed as a percentage of Assets Under Management (“AUM”), and typically ranges
from 0.35% to 1% of total AUM. Alternatively, the fee can be a fixed amount, based on the client's current
portfolio, and in some specific cases, a minimum annual Advisory Fee may apply. LXG’ fee schedule is
generally as follows:
Annual Fee
Assets Under Management
Up to 1.0%:
For AUMs lesser than $10 million
Up to 0.80%:
For AUM from $10 million up to $15 million
Up to 0.75%:
For AUM from $15 million up to $20 million
Up to 0.70%:
For AUM from $20 million up to $25 million
Up to 0.65%:
For AUM from $25million up to $50 million
Up to 0.55%:
For AUM from $50 million up to $100 million
Up to 0.50%:
For AUM from $100 million up to $150 million
Up to 0.45%:
For AUM from $150 million up to $200 million
Up to 0.35%:
For AUM above 200 million
In some instances, Advisory Fees are negotiable based upon the types of assets included in a Client’s
portfolio, the complexity and size of the portfolio, the services to be provided, and other factors including
the nature of the Client’s objectives as articulated in the Risk Profile.
Generally, Advisory Fees are calculated and billed on a quarterly basis, payable in advance. Some Clients’
fee schedules and billing procedures may differ from the general process described herein, as provided in
such Clients’ Advisory Agreements. Clients can elect to be billed directly for fees or to authorize LXG to
directly debit fees from client accounts at the custodian. Upon termination of any account, any
unearned fees will be promptly refunded
Aside from fixed and minimum fees, Advisory Fees are based on the value of the Client’s portfolio as
reported by the Client’s custodians, third- party fund managers, and other independent pricing services.
Depending on each specific custodian, Fees are calculated based on either the portfolio value on the last
day of the previous billing period or based upon the average daily market value of the portfolio during the
billing period The specific methodology is disclosed in the client agreement and discussed as part of the
client onboarding process.
Clients agree to the terms of their fee calculation methodology in the Client Advisory Agreement
with LXG.
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Separate reporting or concierge service fees may be charged, and such fees are determined on a case-by
case basis and are included and prominently disclosed in the Client’s Advisory Agreement.
Clients may also incur certain expenses, such as brokerage commissions and markups, margin interest (if
applicable), currency exchange costs, transfer of asset costs and other transactions costs, imposed by the
transacting broker-dealers (“Brokers”), custodians, third-party investments, and other third-parties.
These other expenses are not included in the Advisory Fee and are borne separately by the Client to the
extent incurred (please refer to the Brokerage Practices section for additional information). LXG may
recommend investing a portion of a client’s assets in shares of mutual funds or other investment
companies, including exchange traded funds, as well as private funds. Assets invested in these funds bear
other additional fees and expenses, which may include but are not limited to, expenses of organizing the
funds, administration, accounting and tax, audit, legal, and filings and regulatory compliance. When
investing in these types of securities, LXG will recommend that clients invest in the most costs effective
share class. Clients invested in these funds should refer to the applicable fund’s offering documents or
prospectus for complete information on other fees and expenses.
In addition to fees, Clients may be responsible for certain out-of-pocket expenses for reasonable and
direct costs incurred by LXG on the Client’s behalf, as directed by the Client. These out-of-pocket expenses
include payments made on behalf of a Client for Client expenses such as postage costs, utility bills, or
other miscellaneous third-party expenses. All out-of-pocket expenses are pre-approved by the Client, in
writing, before LXG pays them. LXG provides an invoice for such services, which is due upon receipt.
Clients should note that similar advisory services can or cannot be available from other registered
investment advisors for similar or lower fees. The size of an account and the nature of the advisory
services provided factor into the fees charged.
Item 6 – Performance-Based Fees and Side-by-Side Management
LXG does not charge performance-based fees to Clients.
Item 7 – Types of Clients
LXG generally provides investment advisory services to Clients who are high net worth individuals,
families, trusts, corporations, or other qualified entities that have a minimum of $5 million of investable
assets. On certain instances, LXG may provide its services to potential clients with less than $5 million of
investable assets. Factors to consider when making this determination is the type of services requested,
the type of investment strategy sought, relationship the potential client may have with LXG and its
affiliates.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
LXG gathers and analyzes Client information, such as investment objectives, investment experience,
financial circumstances, and risk tolerances. LXG’ investment philosophy is built around the concept of
helping Clients achieve their investment objectives and goals in a manner that emphasizes liquidity, risk
measurement and management, and investment cost efficiency. This process begins with the formulation
of a broad asset allocation, first determined through a top-down process to establish long-term target
allocations by asset class and is followed by a bottoms-up analysis of individual, investable instruments.
A. Methods of Analysis
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Based on a Client’s risk assessment, investment objectives, life events and preferences, assets are
allocated across traditional asset classes, asset types, and individual investments. In selecting individual
investments, LXG’ methods of analysis include:
Qualitative Analysis. This analysis is of particular relevance when evaluating third-party fund managers
and fund management companies, and may include analysis of regulatory records, public records,
background research, third-party fund manager team profiles, hiring processes, reference checks, audit
results, and other analyses.
Statistical Analysis. This involves the analysis of past market data, primarily price, volume, and volatility
data, as well as statistical analysis based on that raw data. This statistical analysis may include, but is not
limited to, correlations, beta, alpha, stress testing, peer benchmarking, and other analytical tools.
Cyclical Analysis. This involves the analysis of business cycles to seek favorable conditions for buying
and/or selling a security, sector, geography, or asset class. Investing in securities involves a substantial
degree of risk of loss that Clients should be prepared to bear. All investments carry risk of loss and there
is no guarantee that any investment strategy will meet its objective.
B. Investment Strategies
LXG emphasizes the need for disciplined, long-term investment strategies (involving securities typically
held at least a year) in order to achieve Clients’ objectives. Nevertheless, LXG will selectively and
occasionally use short-term investments (securities held less than a year) and trading (securities held for
less than 30 days) for tactical reallocations in an effort to manage or moderate risk or to attempt to
capture a specific investment opportunity. LXG can utilize one or more of these investment strategies in
an effort to achieve the risk-adjusted returns as articulated in the Client’s Investment Policy Statement.
C. Risk of Loss Fixed-Income Securities.
LXG sometimes recommends investments in bonds or other fixed-income securities (or funds that hold
these type of securities) to certain Clients, including, without limitation, sovereign debt, investment grade
corporate debt securities, and “higher yielding” (and, therefore, higher risk) debt securities (or funds that
hold these types of securities). Such securities may be below “investment grade” and may face ongoing
uncertainties and exposure to adverse business, financial, or economic conditions that could lead to the
issuer’s inability to make timely interest and principal payments. The market values of some of these lower
rated debt securities tend to reflect individual corporate developments to a greater extent than that of
higher rated securities, which react primarily to fluctuations in the general level of interest rates and tend
to be more sensitive to economic conditions than higher rated securities. Issuers that issue lower rated
debt securities are often highly leveraged and may not have access to more traditional methods of
financing. Trading in such securities may be limited or disrupted by an economic recession, resulting in an
adverse impact on the value of such securities. In addition, it is likely that any such economic downturn
could adversely affect the ability of the debt issuers to repay principal and pay interest thereon and,
therefore, increase the incidence of default for such securities. In the event of a default, there is the risk
of losing most or all of the assets invested in such defaulted security.
D. ETFs.
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LXG also recommends investments in ETFs to certain Clients. ETFs are hybrid investment companies that
may be registered as open-end investment companies or unit investment trusts, but which possess some
of the characteristics of closed-end funds. ETFs often hold a portfolio of common stocks, or bonds, that is
intended to track the price and dividend (or interest) performance of a particular index. Certain ETFs are
actively managed, and the performance of such entities will be dependent upon third-party managers.
The market price for ETF shares may be higher or lower than the ETF’s net asset value. With regard to
sales not conducted in the market (which typically require the sale of a larger number of shares), the sale
and redemption prices of ETF shares purchased from the issuer are based on the issuer’s net asset value.
The total return on ETF investments will be reduced by the operating expenses and fees of such
investment companies, including advisory fees.
E. Other Risks.
Additional risks involving LXG’ investment strategies include, but are not limited to:
General Economic and Market Conditions. General economic or market conditions may adversely affect
the investments recommended to Clients. In addition, a downturn or contraction in the economy or in the
capital markets, or in certain industries or geographic regions thereof, may restrict the opportunity to
liquidate any such investments, each of which could prevent Clients from meeting their investment
objectives.
Illiquid Investments. Certain investments may be illiquid with no assurance that Clients will be able to
realize on any such investment in a timely manner. Illiquidity may result from the absence of an
established market for the investments, as well as legal or contractual restrictions on the investment’s
resale.
Private Funds. LXG recommends investments in private funds to certain clients. Investments in private
funds involve risks distinct from those of publicly traded securities. Specific risks are explained in more
detail with clients for whom we recommend investing in private funds. Also, clients who invest in private
funds will receive copies of the private funds’ offering documents, which also discuss the risks of such
investments.
Foreign Investments. LXG may invest in opportunities located in countries outside the US. Accordingly, the
business and financial results of Clients could be adversely affected due to social or judicial instability, acts
or threats of terrorism, changes in governmental policies or policies of central banks, expropriation,
nationalization and/or confiscation of assets, price controls, fund transfer restrictions, capital controls,
exchange rate controls, taxes, inadequate intellectual property protection, unfavorable political and
diplomatic developments, changes in legislation or regulations and other additional international
developments or restrictive actions.
Cyber Security Breaches and Identity Theft. Cybersecurity incidents and cyber-attacks have been occurring
globally at a more frequent and severe level and will likely continue to increase in frequency in the future.
The information and technology systems of LXG and their respective investments may be vulnerable to
damage or interruption from computer viruses, network failures, computer and telecommunication
failures, infiltration by unauthorized persons and security breaches, usage errors by their respective
professionals, power outages and catastrophic events such as fires, tornadoes, floods, hurricanes and
earthquakes. Although LXG has implemented disaster recovery and business continuity plans to manage
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risks relating to these types of events, the failure of these systems and/or of disaster recovery plans for
any reason could lead to an interruption in LXG’ operations.
Settlement Risks. Execution may expose a client to the credit risk of parties with whom the Adviser, on
behalf of the client and through the Broker-Dealer, trades and to the risk of settlement default. Clearing,
settlement, and registration systems in emerging markets are less developed and may provide increased
risks.
ETF Risks including Net Asset Valuation and Tracking Error. ETF performance may not exactly match the
performance of the index or market benchmark that the ETF is designed to track because 1) the ETF will
incur expenses and transaction costs not incurred by any applicable index or market benchmark; 2) certain
securities comprising the index or market benchmark tracked by the ETF may, from time to time,
temporarily be unavailable; and 3) supply and demand in the market for either the ETF and/or for the
securities held by the ETF may cause the ETF shares to trade at a premium or discount to the actual net
asset value of the securities owned by the ETF. Certain ETF strategies may from time to time include the
purchase of fixed income, commodities, foreign securities, American Depositary Receipts, or other
securities for which expenses and commission rates could be higher than normally charged for exchange-
traded equity securities, and for which market quotations or valuation may be limited or inaccurate.
Clients should be aware that to the extent they invest in ETF securities they will pay two levels of advisory
compensation – advisory fees charged by the Adviser plus any management fees charged by the sponsor
of the ETF. An ETF typically includes embedded expenses that may reduce the fund's net asset value, and
therefore directly affect the fund's performance and indirectly affect a client’s portfolio performance or
an index comparison. Expenses of the fund may include investment management fees, custodian fees,
brokerage commissions, and legal and accounting fees. ETF expenses may change from time to time at
the sole discretion of the ETF sponsor. ETF tracking error and expenses may vary.
Item 9 – Disciplinary Information
LXG and its employees have not been involved in any legal or disciplinary events that would be material
to an evaluation of LXG’ advisory business or the integrity of the Firm’s management.
Item 10 – Other Financial Industry Activities and Affiliations
As stated previously, LXG is part of the LXG Group based in Lima, Peru. Its affiliates in Peru provide
companies and high net worth individuals with investment banking services, wealth management and
financial planning services. LXG Group provides its clients with advisory services for a wide range of
corporate finance situations, such as:
Acquisition
Mergers
Disposals
Capital and fund raisings
Capital Restructuring
Valuation Fairness opinions
Raising of private equity funds
Assisting issuers in international bond and equity offerings
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LXG Group’s clients are organizations with business interests in Latin America and include corporations,
financial institutions, private equity funds and private families.
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
LXG has adopted a Code of Ethics (the “Code”) that imposes on each employee a duty to place the
interests of Clients first. The Code requires officers, owners, and employees to, among other things, report
to the Chief Compliance Officer (“CCO”) any actual or potential conflict of interest relating to any Firm
Client. The Code also imposes restrictions and safeguards on the reporting and use of material, non-public
information.
Prevention of Insider Trading
LXG has adopted policies designed to prevent insider trading that are more fully described in the Code.
Adviser’s policy on insider trading applies to securities trading and information handling by all Supervised
Persons (including spouses, minor children and adult members of their households and any other relative
of a Supervised Person on whose behalf Supervised Person is acting) for their own account or the account
of any client of the Adviser.
Adviser takes its obligation to detect and prevent insider trading with the utmost seriousness. Adviser
may impose penalties for breaches of the policies and procedures contained in the Code, even in the
absence of any indication of insider trading. Depending on the nature of the breach, penalties may include
a letter of censure, profit “give ups,” fines, referrals to regulatory and self-regulatory bodies and dismissal.
Personal Securities Transactions
Periodic Reports
As more fully described in the Code, “access persons” are required to submit reports detailing their
personal securities holdings to the Chief Compliance Officer on an initial basis, and thereafter on a
quarterly and annual bases.
As an alternative to submitting quarterly transaction reports, Adviser requires persons who are “access
persons” to submit brokerage statements or trade confirmations as long as such documents contain the
information required under Rule 204A-1(b)(2)(i)(A)-(E) under the Advisers Act.
Initial Public Offerings and Limited Public Offerings
Access Persons must obtain prior written approval from the Chief Compliance Officer before investing in
initial public offerings (“IPOs”) or limited offerings (i.e., private placements).
Review of Personal Securities Reports
The Chief Compliance Officer (or designee) is responsible for reviewing the Access Person’s Quarterly
Transaction Reports as well as the Initial Holdings Report and the Annual Holdings Report as part of LXG’s
duty to maintain and enforce its Code.
Outside Business Activities and Private Investments of Employees
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Unless otherwise consented by the Chief Compliance Officer, all employees are required to devote their
full time and efforts to the LXG’s business. As such, no person may make use of either his or her position
as an employee or information acquired during employment or make personal investments in a manner
that may create a conflict, or the appearance of a conflict, between the employee’s personal interests and
LXG’s interests. Accordingly, every employee is required to complete a disclosure form and have the form
approved by the Chief Compliance Officer prior to serving in any of the capacities or making any of the
investments more fully described in the Code.
Reporting Violations
All Supervised Persons (any officer, director, partner, and employee of Adviser) are required to report
actual or known violations or suspected violations of the Code promptly to the Chief Compliance Officer
or his designee.
Any report of a violation or suspected violation of the Code will be treated as confidential to the extent
permitted by law. As part of Adviser’s obligations to conduct an annual review of all of its policies and
procedures pursuant to Rule 206(4)-7 of the Advisers Act, the Chief Compliance Officer shall review on an
annual basis the adequacy of the Code and the effectiveness of its implementation.
Acknowledgement of the Code
Each employee will execute a written statement certifying that the employee has (i) received a copy of
Adviser’s Code; (ii) read and understands the importance of strict adherence to such policies and
procedures; and (iii) agreed to comply with the Code.
Investments in Securities by the Adviser and its Personnel
LXG’s personnel or a related person of the LXG may invest in the same or similar securities and
investments as those recommended to or entered into on behalf of LXG’s clients. The results of the
investment activities of the LXG’s personnel or its related persons for their accounts may differ from the
results achieved by or for client accounts managed by LXG. The conflicts raised by these circumstances
are discussed below.
LXG may recommend or effect the purchase or sale of securities in which its related persons or an affiliate,
directly or indirectly, has a position or interest, or of which a related or affiliated person buys or sells for
itself. Such transactions may also include trading in securities in a manner inconsistent with the advice
given to the LXG’s clients.
Activities and transactions for client accounts may be impaired or effected at prices or terms that may be
less favorable than would otherwise have been the case had LXG or related persons did not pursue a
particular course of action with respect to the issuer of the securities
Transactions undertaken by LXG’s clients may also adversely impact one or more client accounts. Other
clients of the Adviser may have, as a result of receiving reports or otherwise, access to information
regarding LXG’s transactions or views that may affect their transactions outside of accounts controlled by
LXG, and such transactions may negatively impact other clients’ accounts. A client’s account may also be
adversely affected by cash flows and market movements arising from purchase and sale transactions by,
as well as increases of capital in and withdrawals of capital from, other clients’ accounts. These effects
can be more pronounced in less liquid markets.
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The results of the investment activities of a client’s account may differ significantly from the results
achieved by the LXG’s related persons and from the results achieved by the LXG for other client accounts.
As more fully described above, LXG has adopted a Code of Ethics. Such Code of Ethics together with LXG’s
policies and procedures restrict the ability of certain officers and employees of the LXG from engaging in
securities transactions in any securities that its clients have purchased, sold, or considered for purchase
or sale, for an appropriate “black out” period. Other restrictions and reporting requirements are included
in the LXG’s procedures and Code of Ethics to minimize or eliminate conflicts of interest.
Trading Alongside by LXG and its Personnel
Client accounts managed by LXG may trade in the same or similar securities at or about the same time as
accounts managed or advised by affiliates of the LXG. Investments by LXG’s affiliates and their clients may
have the effect of diluting or otherwise disadvantaging the values, prices, or investment strategies of a
client’s account, particularly in small capitalization, emerging market, or less liquid strategies. This may
occur when portfolio decisions regarding a client’s account are based on research or other information
that is also used to support portfolio decisions for LXG’s affiliates. If a portfolio decision or strategy for
LXG’s affiliates’ accounts or the accounts of clients of affiliates is implemented ahead of, or
contemporaneously with, similar portfolio decisions or strategies for the LXG’s client’s account, market
impact, liquidity constraints, or other factors could result in the account receiving less favorable trading
results and the costs of implementing such portfolio decisions or strategies could be increased.
Errors
Errors may occur from time to time in transactions for client accounts. The LXG will typically correct any
such errors that are the fault of the LXG or an affiliate at no cost to the client, other than costs that the
LXG deems immaterial. To the extent that the subsequent sale of such securities generates a profit to the
LXG, the LXG may retain such profits, and may, but is not required to, use such profits to offset errors in
the future or pay other client-related expenses. The LXG will not be responsible for any errors that occur
that are not the fault of the LXG or any affiliate.
Privacy Policy
LXG considers your privacy our utmost concern. LXG does not share information of clients with non-
affiliated third parties, except such information may be disclosed to process a transaction an investor has
requested, to the extent the investor specifically authorized the disclosure, to service providers or joint
marketers who agree to limit their use of such information, and to the extent required or specifically
permitted by law or reasonably necessary to prevent fraud, unauthorized transactions, or liability.
The Code requires all officers, owners, and employees of the Firm to report monthly and annually their
own and immediate family members’ security holdings and transactions to the CCO.
Clients or prospective Clients may request a copy of LXGs’ Code of Ethics by contacting the Firm at +1
(305) 361 3631 or at compliance@lxgwa.com
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Item 12 – Brokerage Practices
investment advice, the Client generally selects
For non-discretionary
its own Broker for the
implementation of the Firm’s recommendations. However, the Client may ask the Firm to evaluate the
quality of the Client’s relationship with its current Broker(s) and/or recommend a different Broker. In
making such a recommendation, the Firm will evaluate the Client’s needs, as disclosed to the Firm, and
will focus primarily on the financial strength, execution costs, and responsiveness of the Broker. However,
such Clients are advised that they must independently evaluate these Brokers before opening an account
or transacting business, and that they are not under any obligation to effect business through any
recommended firm.
When LXG provides non-discretionary advisory services to certain Clients pursuant to which LXG makes
recommendations on purchasing, selling, holding, valuing, or exercising rights with respect to particular
investments, it does not have discretion to effect purchases or sales on behalf of such Clients without
their prior approval. It is highly likely that discretionary and non-discretionary Clients hold the same or
similar securities. There may be timing differences related to the transmission of advice to a non-
discretionary Client for consideration and the Client’s decision of whether or not to act on the advice. As
a result, it is possible that trades or recommendations will be effected on behalf of discretionary Clients
in advance of accounts for non-discretionary Clients. This could result in discretionary and non-
discretionary Clients receiving more or less favorable execution prices on the same security and may result
in potential differences in performance for the same security.
There may be instances, where a client in a non discretionary relationship has granted LXG authority to
transmit orders to the custodian on its behalf. In cases where LXG is authorized to order transactions on
behalf of Clients, the Firm will seek to obtain “best execution,” the best available combination of
execution, price (which includes the cost of the transaction), and other factors, among each Client’s list of
approved Brokers. In seeking best execution, the Firm takes into account all factors it deems relevant
including, but not limited to, the financial stability and reputation of the particular Broker, the ability to
achieve prompt and reliable executions at favorable prices, and the operational efficiency with which
transactions are effected. In instances where the client has a single custodian, LXG will enter the
transactions with that custodian and will monitor the competitiveness of transaction execution.
On occasion, Clients require that their financial assets remain in the custody of various financial
institutions that are not able to implement LXG’ recommendations. In such instances, LXG will select from
the investment options available at such institutions in order to implement the Client’s investment
strategy. In these circumstances, direction by a Client to use a particular financial institution may result in
higher costs, less favorable investments, and (materially) different performance than if LXG could freely
recommend investments not limited to a particular financial institution or platform.
LXG executes all Client trades through each Client’s custodial Broker(s) or other Brokers approved by
Clients. LXG does not effect transactions with Brokers that have not been approved in advance by the
Client. The Firm will attempt to negotiate lower commission schedules for Clients where possible.
However, the most favorable execution may not be obtainable at all custodial Brokers, which may cost
Clients more money.
The Firm’s business model, which includes non-discretionary and directed brokerage accounts, does not
support aggregating orders among Client accounts. This may or may not result in some Clients paying
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higher brokerage commissions because of the Firm’s inability to reduce transaction costs through order
aggregation. In addition, directed brokerage may result in Clients receiving less favorable prices. However,
in the event of the purchase of a new issue, the sale of a particular security, or other investment related
reasons, LXG may aggregate orders in an attempt to receive a better execution price for its clients.
Notwithstanding, LXG seeks to allocate orders fairly between Clients and has established trade order
procedures for both discretionary and non-discretionary accounts. For discretionary accounts, LXG
typically executes its recommendations in a random order immediately and normally within the same day,
after the same trade has been submitted for pre-approval to all non-discretionary Clients the Firm has
deemed to be suitable. Trade approvals from non-discretionary Clients are queued and executed in the
order in which they are received. The use of different executing Brokers will likely result in some Clients
paying different Broker-imposed trade fees compared to other Clients. In addition, the timing in which
transactions are affected by various Brokers may result in different execution prices on transactions.
The Firm does not have any soft dollar relationships.
With respect to discretionary Clients, the Firm is responsible for selecting the Brokers used for a securities
transaction from a client’s approved Brokers list. In negotiating commission rates and selecting Brokers,
the Firm seeks to obtain best execution, as described above. It is noted that since commission rates are
generally negotiable, selecting Brokers on the basis of considerations which are not limited to applicable
commission rates may, at times, result in higher transaction costs than would otherwise be obtainable.
Item 13 – Review of Accounts
LXG’ portfolio managers monitor Clients’ portfolios on an ongoing basis. At least one primary portfolio
manager is assigned to each Client. LXG uses tools to monitor, record, analyze, and report estimated and
unaudited Client account performance on a daily basis.
Pricing data used for calculating performance, is provided the Client’s custodians, third-party fund
managers, and other independent pricing services.
At least quarterly, portfolio managers evaluate the performance of Client portfolios on an absolute,
relative, and for compliance with the Client’s Investment Policy Statement. At least annually, the portfolio
managers will review each Client’s Investment Policy Statement to confirm that it remains consistent with
the Client’s stated goals and objectives.
Item 14 – Client Referrals and Other Compensation
LXG does not receive any economic benefit from someone who is not a client for providing investment
advice or other advisory services to its clients.
LXG may compensate person(s) for Client referrals. In such cases, LXG will provide full disclosure to the
client on the referral agent and fee paid to such referral agent, this, in addition to providing other
regulatory disclosures.
Item 15 – Custody
LXG does not have custody of any Client funds or securities, is not a qualified custodian, and does not
provide custodial services to its clients. Clients select the Broker(s) or other qualified custodian to provide
such services. In some instances, LXG may recommend a particular custodian to its clients, but the Firm
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does not receive any compensation, other services, or benefits from the custodians or their affiliates for
doing so.
Item 16 – Investment Discretion
LXG generally receives discretionary (or non-discretionary) investment authority from its clients at the
outset of the advisory relationship. Depending on the terms of the applicable Advisory Agreement, LXG’
authority may include the ability to execute trades or recommendations and select Brokers from a Client’s
approved Broker list through which to execute transactions, on behalf of Clients. In making decisions as
to which securities are to be bought or sold and the amounts thereof, the Firm will be guided by any
reasonable Client-imposed guidelines or restrictions set forth in the Client’s Investment Policy Statement.
Unless LXG and the Client have entered into a non-discretionary arrangement, the Firm is generally not
required to provide notice to consult with or seek the consent of its clients prior to engaging in
transactions. LXG’ discretion is limited to purchasing and selling securities and LXG is not authorized to
transfer any funds or securities out of any Client account.
Item 17 – Voting Client Securities
LXG does not have voting authority with respect to Client securities. Clients should receive all proxy
materials from their account Broker or other qualified custodian. Clients are responsible for receipt and
voting of proxies for all securities maintained in their portfolios. Upon a Client’s request, the Firm may
provide information and advice to such Client regarding a particular vote by proxy, but Clients retain the
responsibility for the determination and the actual act of voting.
From time to time, LXG may receive notices regarding class action lawsuits involving securities that are or
were held by Clients. As a matter of policy, LXG can assist Clients in gathering documentation, but refrains
from serving as the lead plaintiff in class action matters and from submitting proofs of claim unless LXG
has accepted the authority to do so through the Client’s Investment Advisory Agreement.
Item 18 – Financial Information
LXG is not aware of any financial condition that is reasonably likely to impair its ability to meet its
contractual commitments to Clients and has never been subject to a bankruptcy petition.
Item 19 – Requirements for State-Registered Advisors
This section does not apply to LXG.
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Brochure Supplement (Part 2B of Form ADV)
1441 Brickell Av. Suite 1016, Miami, Fl 33131
(305) 456-7645
As of: December 31, 2024
Supervised Persons:
Félix Segura
Pablo Luzardi
Salvador Biguria
Rafael Isola
Aldo Oyadomari
Carlos Palacios
All Supervised Persons can be reached at the address and telephone number listed above. This Brochure
Supplement provides information about the above listed Supervised Persons that supplements the LXG
Wealth Advisory Brochure. You should have received a copy of that Brochure. Please contact LXG at
(305) 465-7645 or compliance@lxgwa.com if you did not receive LXG’s Investment’s Brochure or if you
have any questions about the contents of this supplement.
The information in this supplement has not been approved or verified by the United States Securities
and Exchange Commission (“SEC”) or by any state securities authority. Additional information about all
Supervised Persons is available on the SEC’s website at www.adviserinfo.sec.gov.
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SEGURA, FELIX
Item 2 - Educational Background and Business Experience Education:
Born in 1970
Education:
Babson College; Bachelor of Business Administration and Management 1992,
Harvard Business School; Masters in Business Administration 2002
Business Experience:
LXG Multi Family Office
Managing Partner
Lima, Peru
2015 – Present
Credit Suisse Securities (USA), LLC
Registered Representative
2015-2010
JP Morgan Securities, Inc.
Registered Representative
2008-2010
Item 3 - Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of each supervised person providing
investment advice.
No information is applicable to this Item.
Item 4 - Other Business Activities
Mr. Segura does not have any outside business activity.
Item 5 - Additional Compensation
None
Item 6 - Supervision
Felix Segura is the Managing Member of LXG and is responsible for his own supervision. Supervisory
contact information: felix.segura@lxgmfo.com
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LUZARDI, PABLO
Item 2 - Educational Background and Business Experience Education:
Born in 1979
Education:
Universidad de Buenos Aires (UBA); Bachelor of Business Administration 2002,
Tuck School of Business Administration; Masters in Business Administration 2002
Business Experience:
LXG Multi Family Office
Senior Advisor, Manager
Buenos Aires, Argentina
2020 – Present
LXG Capital
MD – Partner
Lima, Peru/ Buenos Aires, Argentina
2010-2020
Cordia Bancorp Private Equity
Associate
Washington DC, U.S.A.
2009-2010
Item 3 - Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of each supervised person providing
investment advice.
No information is applicable to this Item.
Item 4 - Other Business Activities
Mr. Luzardi does not have any outside business activity.
Item 5 - Additional Compensation
None
Item 6 - Supervision
Pablo Luzardi is a Managing Member of LXG and is responsible for his own supervision. Supervisory
contact information: pablo.luzardi@lxgwa.com
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BIGURIA, SALVADOR
Item 2 - Educational Background and Business Experience Education:
Born in 1975
Education:
Massachusetts Institute of Technology (MIT); Bachelor of Science in Chemical Engineering 1997,
Harvard Business School; Masters in Business Administration 2002
Business Experience:
•
LXG Multi Family Office
Senior Advisor, Operating Partner
Guatemala City, Guatemala
2022 – Present
IDC
Managing Partner
Guatemala City, Guatemala
2019-2022
Pantaleon Group
Chief Sustainability Officer
Chief Commercial Officer
Brazil Country Manager
Head of M&A and Business Development
Guatemala City, Guatemala
2002-2019
Item 3 - Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of each supervised person providing
investment advice.
No information is applicable to this Item.
Item 4 - Other Business Activities
Mr. Biguria does not have any outside business activity.
Item 5 - Additional Compensation
None
Item 6 - Supervision
Salvador Biguria is a Senior Member of LXG and is responsible for his own supervision. Supervisory
contact information: sbiguria@lxgwa.com
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ISOLA, RAFAEL
Item 2 - Educational Background and Business Experience Education:
Born in 1979
Education:
Universidad de Ciencias Aplicadas (UPC); Bachelor of Administration and Finance 2003,
HEC Paris School of Business; Masters in Business Administration 2010
Business Experience:
LXG Multi Family Office
Senior Advisor, Chief Investment Officer
Miami, U.S.A.
2019 – Present
• Banco de Credito del Peru
Potfolio Manager
Lima, Peru
2017-2019
J.P. Morgan Securities, Inc
Investment specialist
New York, U.S.A.
2010-2017
Item 3 - Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of each supervised person providing
investment advice.
No information is applicable to this Item.
Item 4 - Other Business Activities
Mr. Isola does not have any outside business activity.
Item 5 - Additional Compensation
None
Item 6 - Supervision
Rafael Isola is a Senior Member of LXG and is responsible for his own supervision. Supervisory contact
information: rafael.isola@lxgwa.com
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OYADOMARI, ALDO
Item 2 - Educational Background and Business Experience Education:
Born in 1991
Education:
Pontificia Universidad Catolica del Peru (PUCP); Bachelor of industrial Engineering 2014,
The Fuqua School of Business; Masters in Business Administration 2014
Business Experience:
LXG Multi Family Office
Advisor
Miami, U.S.A.
2024 – Present
• Amazon
Finance Manager
Washington, U.S.A.
2023
LXG Multi Family Office
Advisor
Analyst
Lima, Peru
2015-2022
Pacifico Seguros
Analyst
Lima, Peru
2014-2015
Item 3 - Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of each supervised person providing
investment advice.
No information is applicable to this Item.
Item 4 - Other Business Activities
Mr. Oyadomari does not have any outside business activity.
Item 5 - Additional Compensation
None
Item 6 - Supervision
Supervisory contact information: felix.segura@lxgmfo.com
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PALACIOS, CARLOS
Item 2 - Educational Background and Business Experience Education:
Born in 1977
Education:
Universidad de Ciencias Aplicadas (UPC); Bachelor of industrial Engineering 1999,
Michigan Ross Business School; Masters in Business Administration 2007
Business Experience:
LXG Multi Family Office
Advisor
Lima, Peru
2023 – Present
• EFG Capital International Corp.
Registered Representative
Washington, U.S.A.
2020-2023
Inteligo Group Corp.
Wealth Management Team Leader
Lima, Peru
2014-2019
Banco de Credito del Peru
Wealth Management Advisor
Lima, Peru
2010-2014
Item 3 - Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of each supervised person providing
investment advice.
No information is applicable to this Item.
Item 4 - Other Business Activities
Mr. Palacios does not have any outside business activity.
Item 5 - Additional Compensation
None
Item 6 - Supervision
Supervisory contact information: felix.segura@lxgmfo.com
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