SAAGA, LLC

SAAGA, LLC Form ADV Part 2A – Disclosure Brochure CRD 327015 Effective: March 30th, 2025 Item 1 - Cover Page This Brochure provides information about the qualifications and business practices of SAAGA, LLC (“SAAGA”). If you have any questions about the contents of this brochure, please contact us at info@saagawealth.com. The information in this brochure has not been approved or verified by the United States Security Exchange Commission or by any state securities authority. SAAGA, LLC is a U.S. Securities and Exchange Commission Registered Investment Adviser. Registration of an Investment Advisor does not imply a certain level of skills or training. The oral and written communications offered by the Advisor should provide you with the information required to assist you in determining whether to hire or retain the Adviser. Additional information about SAAGA is available on our website www.saagawealth.com and on the SEC’s website at www.adviserinfo.sec.gov. You may request a copy of our brochure by contacting Juan Pablo Martinez-Blat at 786-940-3505 or info@saagawealth.com SAAGA, LLC 1221 Brickell Ave, Suite 2410, Miami FL 33131 Tel. +1 (786) 362-6819 www.saagawealth.com 1  Item 2 – Material Changes As of November 1st, 2024, SAAGA business structure changed to a multi member LLC where some existing clients became capital members and have purchased non-voting minority interest in the firm. This is explained in detail in Item 10 Other Financial Industry Activities and Affiliations. SAAGA, LLC 1221 Brickell Ave, Suite 2410, Miami FL 33131 Tel. +1 (786) 362-6819 www.saagawealth.com 2  Item 3 -Table of Contents Item 1 - Cover Page ...................................................................................................................................... 1 Item 2 – Material Changes ........................................................................................................................... 2 Item 4 - Advisory Business ........................................................................................................................... 4 Item 5 – Fees and Compensation ................................................................................................................. 7 Item 6 – Performance-Based Fees and Side-by-Side Management............................................................ 8 Item 7 – Types of Clients .............................................................................................................................. 9 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ..................................................... 9 Item 9 – Disciplinary information .............................................................................................................. 14 Item 10- Other Financial Industry Activities and Affiliations.................................................................... 14 Item 11 – Code of Ethics ............................................................................................................................. 15 Item 12 – Brokerage Practices ................................................................................................................... 16 Item 13 – Review of Accounts .................................................................................................................... 17 Item 14 – Client Referrals and Other Compensations .............................................................................. 18 Item 15 – Custody ....................................................................................................................................... 18 Item 16 – Investment Discretion ............................................................................................................... 19 Item 17- Voting Client Securities ............................................................................................................... 19 Item 18 – Financial Information ................................................................................................................. 20 Item 19 – Other and miscellaneous ........................................................................................................... 20 SAAGA, LLC 1221 Brickell Ave, Suite 2410, Miami FL 33131 Tel. +1 (786) 362-6819 www.saagawealth.com 3  Item 4 - Advisory Business SAAGA, LLC is a registered investment adviser firm with office in Miami, Florida. We have been providing a comprehensive range of family office services to a quality group of ultra-high net worth client families since 2002. The firm became a registered investment adviser adding financial advice to our services. While our clients completely own the discretion over their investment decisions, SAAGA provides support in the management and long term preservation of their wealth for their future generations. SAAGA operates independently and has no interest in any financial product or service. Our clients pay us a fixed advisory fee for our services. Principal Owners of SAAGA SAAGA LLC is organized as a limited liability company under the laws of the State of Florida1. As of November 1st, 2024. SAAGA LLC is majority owned by AGAAS, LLC a Florida limited liability company owned by Juan Pablo Martinez-Blat. AGAAS, LLC is the managing member and only Class “A” member of SAAGA, LLC. There is a minority of SAAGA’s units represented by Class “B” members with no voting rights. No single Class “B” member of SAAGA, LLC holds more than 5% on the company. Juan Pablo Martinez-Blat maintains ultimate responsibility for SAAGA’s operation as the Principal Officer in a dual role as Chief Executive Officer and Chief Compliance Officer The following paragraphs describe our services and fees. As used in this brochure, the words “the firm”, "our”, “us” and “we” refer to SAAGA and the words "you", "your" and "client" refer to you as either a client or prospective client of our firm. You may also see the term “Associated Person” throughout this Brochure. As used in this Brochure, our Associated Persons are our firm's officers, employees, and all individuals providing investment advice and support on behalf of our firm. (Chief Compliance Officer) at 786-940-3505 or via email This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by SAAGA. For information regarding this Disclosure Brochure, please contact to Juan Pablo Martinez-Blat info@saagawealth.com. Types of Services SAAGA offers non-discretionary investment advisory and customized family office services to, high net- worth individuals (each referred to as a “Client”) their wealth enterprise. trusts, estates and business entities. Besides advisory services, we offer family office services including but not limited to tactical, 1 Organized as a limited liability company (LLC) formed under the laws of the State of Florida. SAAGA was established in 2002 as ONNE CONSULTING PARTNERS, LLC and amended its Articles of Incorporation to rebrand name to SAAGA, LLC in 2018. SAAGA, LLC 1221 Brickell Ave, Suite 2410, Miami FL 33131 Tel. +1 (786) 362-6819 www.saagawealth.com 4  governance and educational services designed to advance wealth creation, including the coordination of all required services providers. Advisory Services SAAGA provides advisory services on a non-discretionary basis. We do not have the authority to make investment decisions for our clients. After receiving information, advice and recommendations from us, our clients retain the authority and ultimate responsibility for all investment and investment-related decisions, including securities trades, decisions about particular asset allocations and portfolio composition, manager selection, and service provider selection. Our investment advisory services start with an extensive assessment of the client’s financial and non- financial assets, individual situation and goals including all assets that impact their wealth and cash flow requirements. SAAGA advises client portfolios in accordance with each client’s investment objectives considering factors such as risk tolerance, time horizon, estate planning, liquidity, tax issues and cash flow requirements. SAAGA’s investment advisory services include but are not limited to: • Assess client’s situation, needs and investment objectives. • Evaluate client’s sources of wealth and liquidity. • Develop appropriate asset allocation. • Coordinate appropriate manager selection and investment strategies. • Review and report regularly on portfolio performance and market conditions. • Recommend changes as conditions in the market, portfolio, or client’s needs change. Each client decides to invest with certain managers, custodians or funds who have their own practices described in their forms ADV, offering or disclosure documents. SAAGA does not have any interest or receive any compensation from any manager, fund or investment we may recommend. Selection of Other Advisers and Custodians As part of our services, we provide recommendations for third-party money manager(s) to manage a portion of our client’s investment portfolios. There are several factors that we take into consideration when making our recommendations. They include, but are not limited to their performance, methods of analysis, fees, your financial needs, investment goals, risk tolerance, and investment objectives. We monitor the MM(s)' performance on a regular basis to ensure its management and investment style over time, remains aligned with your investment goals and objectives. SAAGA does not have custody or provide custody services for our client’s assets. Clients themselves select the custodians for their assets. At client’s request, we recommend a particular “global” or other custodian, but we do not receive any compensation from the custodian or its affiliates for such recommendations. SAAGA, LLC 1221 Brickell Ave, Suite 2410, Miami FL 33131 Tel. +1 (786) 362-6819 www.saagawealth.com 5  Also, we do not receive compensation from, or have a sales interest in, any manager, fund, or other investment we recommend. SAAGA does not participate in wrap fee programs. Family Office Services SAAGA offers its clients a complete array of services designed to support the wealth creation process. Family Office Services include but are not limited to: • Family Office Design & Advisory • Family Office Outsourcing • Global Balance Sheet Reporting • Investment Committee Advisory • Risk Management Coordination Tactical and Strategic Services We also provide services aimed at enhancing the value creation in our clients’ family business operations. Tactical and strategic services include but are not limited to: • Growth Strategy Design • Financial Forecasting & Valuation • Board of Directors Advisory • Effective Decision-Making Workshops • Managerial Due Diligence Governance Services At SAAGA we also help our clients by providing guidance and service providers’ coordination on multiple governance and succession matters. Governance Services include but are not limited to: • Governance Advisory • Succession Plan Coordination • Estate and Tax Planning Providers Coordination • Governance Effectiveness Workshops • Counseling & Conflict Mediation • Family Council Advisory SAAGA, LLC 1221 Brickell Ave, Suite 2410, Miami FL 33131 Tel. +1 (786) 362-6819 www.saagawealth.com 6  Client Assets Under Management SAAGA provides investment advice to our clients only on a non-discretionary basis. As of December 31, 2024, SAAGA had approximately $603,470,494 in assets under management. This total includes client assets as to which SAAGA provides investment advice and family office services and includes clients’ liquid and illiquid securities; cash and cash assets; and certain of their other assets, including any family operating company interests and real assets such as real estate (excluding their personal houses). In addition to these assets under management, SAAGA provides only consolidated reporting for an additional $224,516,242 of assets. In total SAAGA gives investment advice or consolidated reporting services on $827,986,736 in client assets. Item 5 – Fees and Compensation We are compensated for our overall investment advice and family office services through an advisory fee, typically paid in arrears and billed monthly. Most of our clients are billed an all-encompassing flat fee for the scope of services agreed. SAAGA does not receive compensation based on the sale of securities or any other investment product, in other words, the firm does not buy or sell securities to earn commissions and does not receive any compensation for securities transactions in any Client’s account. Our fees are tailored to each client unique circumstances based on the scope of services required and complexity of the wealth structure. Fees are not tied to assets under management (AUM), ensuring that our recommendations remain unbiased and aligned with the client’s best interest. Each Client engaging SAAGA for services is required to sign a written agreement that specifies contractual terms and the advisory flat fee. This agreement ensures transparency regarding our services and costs. Occasionally clients also engage us on short-term projects. Fees for these projects are agreed on a one- on-one basis according to the requirements of such projects. If a client engages us for additional services all or a portion of the fees for those services may be offset based upon the amount paid for the family office services. Depending on the complexity of the onboarding process we may require a one-time fee payable upon entering into the written agreement. Either party may terminate the agreement at any time by written notice to the other party. The client’s agreement with SAAGA is non-transferable without the client’s prior consent. SAAGA believes that its fees are reasonable in relation to (1) the services provided and (2) the type of fees charged by other financial advisors offering similar services. Fees may be reviewed and adjusted periodically based on changes in the complexity or scope of services provided, adjustments for inflation or cost changes in service delivery. Client requests for additional services or modifications to their engagement. Any fee changes are subject to mutual agreement and will be disclosed in writing before implementation. SAAGA, LLC 1221 Brickell Ave, Suite 2410, Miami FL 33131 Tel. +1 (786) 362-6819 www.saagawealth.com 7  SAAGA’s Family Governance services fees will be based on the nature and complexity of the services to be provided. In most cases, our governance services are embedded in our fixed fee. SAAGA’s Educational Workshops directed to advance and improve the personal development and wealth creation skills of our clients are priced separately. Prices depend on the scope and length of each workshop. Workshops are offered as separate services or products and can also be marketed to the public. New workshops may be added to the current curricula. Other Fees: From time to time, SAAGA makes payments of expenses on behalf of clients such as courier services, government charges, translations etc. Such payments are then invoiced for reimbursement by the specific client at cost for the client. Referrals to Third Parties Fees for the services of any outside professional will be in addition to and separate from the fees charged by SAAGA. In no event will the services of an outside professional be engaged without your express approval. To the extend SAAGA, at your request, engage an outside professional (such as an attorney, independent investment advisor or accountant) while providing services to you, SAAGA will not be responsible for the payment of the fees for the services of such an outside professional, and you will be required to pay directly to the professional firm providing the service(s). To the extent that you personally engage such an outside professional, you will be responsible for the payment of the fees for the services of such an outside professional, and SAAGA will not be required to reimburse the Client for such payments. Fees paid to SAAGA are separate and distinct from the commissions charged by broker-dealers or money management fees charged by an investment advisor engaged to implement investment decisions. SAAGA does not receive compensation or revenue-sharing from custodians, fund managers, or third-party professionals. It should be noted that lower fees for comparable services may be available from other providers. SAAGA is committed to fee transparency and ensuring that clients fully understand the cost of services before engagement. If you have any questions about fees, please contact our Chief Compliance Officer at info@saagawealth.com. Item 6 – Performance-Based Fees and Side-by-Side Management Performance-based fees are defined as fees based on a share of capital gains or on capital appreciation of the assets of a client. This type of fee structure may, under certain circumstances, create a conflict with our client’s interests. SAAGA does not charge or accept any performance-based fees. SAAGA, LLC 1221 Brickell Ave, Suite 2410, Miami FL 33131 Tel. +1 (786) 362-6819 www.saagawealth.com 8  Item 7 – Types of Clients SAAGA typically provides investment advisory and family office services to high-net-worth individuals and their families. We generally serve clients with total net worth exceeding $20 million. In exceptional cases, account minimums are waived or negotiated. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss SAAGA uses different methods of analysis or investment strategies in formulating its advice, subject to client’s profile, investment objectives, risk appetite and/or tolerance, time horizon, other sources of wealth and specified guidelines. Asset allocation constitutes one of the most important factors in meeting each client’s goals and understanding their risks. Methods of Analysis • Asset Allocation. Rather than focusing primarily on securities selection, we attempt to identify an appropriate ratio of securities, fixed income, cash, and other alternative investments suitable to the client's investment goals, yield requirements and risk tolerance. The asset allocation recommendations SAAGA provides to its clients also take into consideration multiple factors such as: asset class preferences, expected returns, time horizons, cash flow forecasts and investment objectives. With a few exceptions, most of the advice to our clients is done at the level of the portfolio asset allocation and managers’ level and we rarely provide advice at the individual bonds, stocks, or security level. On an ongoing basis, SAAGA corresponds with third party investment managers and bank representatives to compare and analyze market trends, valuations and any other factors that might be included in the development of the asset allocation. In designing an appropriate asset allocation for our clients, we factor in current views on the markets and the economy as reported by analysts, economists, market reports and the views of other investment professionals our clients might also work with. We also take into consideration the assumed risk profile, long-term expected returns, and liquidity characteristics of the underlying securities under each asset class or portfolio manager. • Mutual Fund, ETF and Portfolio Manager Analysis. We look at the experience and track record of the manager and/or funds in an attempt to assess the manager’s ability to invest and deliver appropriate returns over a period of time and in different economic conditions. We also look at the underlying assets in a mutual fund or ETF and we try to establish if there is an overlap in the underlying investments held in other vehicles within in the Client's portfolio. • Alternative Non-traded Private Investments. We look for potential transactions sourced by sponsors known to SAAGA, clients, and its related persons. All such sponsors or their control persons will be experienced with a verifiable track record of prior transactions. Analysis will include evaluation and due SAAGA, LLC 1221 Brickell Ave, Suite 2410, Miami FL 33131 Tel. +1 (786) 362-6819 www.saagawealth.com 9  diligence of the transaction, sponsors and related persons, performance history and experience of sponsors and related persons, liquidity of investment, current and future cash flow potential, and associated risks. We consider how these investments might complement the client’s asset allocation. Significant risk may be associated with private non-traded investments, and such risk may not necessarily be mitigated by our analysis. This is for sophisticated investors with large net worth and liquid assets to cover losses if necessary. Investment Strategy Recommendations Simultaneously with the recommended asset allocation, we will also recommend exposure to various types of investment strategies such as a combination of active vs passive investment, value and growth, large, mid, and small caps, and other. We could also recommend exposure to global markets and emerging markets in addition to developed markets to achieve diversification through various asset classes, investment strategies and geographic markets. We also take a holistic view on the client’s wealth including real estate holdings, direct investments, real assets and, if necessary, the enterprise value of the family business. We will consider all these elements to propose an investment strategy that contains a full view of the client’s needs and overall risks. Risk of Loss Investing involves a risk of loss. Clients should be prepared to bear investment loss, including the loss of the original principal. Clients should never presume that future performance of any specific investment or investment strategy will be profitable. Further, there may be varying degrees of risk depending on different types of investments. Clients should know that all investments carry a certain degree of risk ranging from the variability of market values to the possibility of permanent loss of capital. Although portfolios seek principal protection, asset allocation and investment decisions may not achieve this goal in all cases. There is no guarantee a portfolio will meet a target return or an investment objective. Risks to capital include, but may not be limited to, changes in the economy, market volatility, company results, industry sectors, accounting standards and changes in interest rates. Investments are generally subject to risks inherent in governmental actions, exchange rates, inflation, deflation, and fiscal and monetary policies. Market risks include changes in market sentiment in general and styles of investing. Diversification will not protect an investor from these risks and fluctuations. SAAGA does not engage in high-frequency trading activities or algorithmic trading strategies. Additional risks may include: Market risk: Either the stock market as a whole, or the value of an individual company, goes down resulting in a decrease in the value of Client investments. Stocks are susceptible to general stock market fluctuations and to volatile increases and decreases in value as market confidence in and perceptions of their issuers change. Common stock (or its equivalent) is generally exposed to greater risk than preferred stocks and debt obligations of an issuer. Company risk: There is always a certain level of company or industry specific risk that is inherent in each investment. Although this risk can be reduced through appropriate diversification, it cannot be eliminated. There is the risk that the issuer will perform poorly or have its value reduced based on factors specific to SAAGA, LLC 1221 Brickell Ave, Suite 2410, Miami FL 33131 Tel. +1 (786) 362-6819 www.saagawealth.com 10  the issuer or its industry. If the issuer experiences credit issues or defaults on debt, the value of the issuer may be reduced. Exchange traded fund and mutual fund risk: The risk of owning an ETF or mutual fund generally reflects the risks of owning the underlying securities the ETF or mutual fund holds. Clients will incur additional costs associated with ETFs and mutual funds. Consumer Discretionary ETF Shares are listed for trading on NYSE Arca and can be bought and sold on the secondary market at market prices. Although it is expected that the market price of a Consumer Discretionary ETF Share typically will approximate its net asset value (NAV), there may be times when the market price and the NAV vary significantly. Thus, the Client may pay more or less than NAV when you buy Consumer Discretionary ETF Shares on the secondary market, and you may receive more or less than NAV when you sell those shares. Although Consumer Discretionary ETF Shares are listed for trading on NYSE Arca, it is possible that an active trading market may not be maintained Trading of Consumer Discretionary ETF Shares on NYSE Arca may be halted by the activation of individual or market wide "circuit breakers" (which halt trading for a specific period of time when the price of a particular security or overall market prices decline by a specified percentage). Trading of Consumer Discretionary ETF Shares may also be halted if the shares are delisted from NYSE Arca without first being listed on another exchange or exchange officials determine that such action is appropriate in the interest of a fair and orderly market or to protect investors. A risk of mutual funds and/or ETF analysis is that, as in all securities investments, past performance does not guarantee future results. A manager who has been successful may not be able to replicate that success in the future. In addition, as we do not control the underlying investments in a fund or ETF, managers of different funds held by the Client may purchase the same security, increasing the risk to the Client if that security were to fall in value. There is also a risk that a manager may deviate from the stated investment mandate or strategy of the fund or, which could make the holding[s] less suitable for the Client's portfolio. Management risk: Investments managed by us vary with the success and failure of our investment strategies, research, analysis, and determination of portfolio securities. Our investment advice incorporates subjective elements made in good faith that may not be fully successful not fully meet client expectations. Foreign investments risk: Non-U.S. investments, currency and commodity investments may contain additional risks associated with government, economic, political or currency volatility. Emerging markets risk: Emerging markets can experience high volatility and risk in the short term. Liquidity risks: Generally, assets are more liquid if many investors are interested in a standardized product, making the product relatively easy to convert into cash. Specialized investments may have reduced liquidity. Bond risks: Investments in bonds involve interest rates and credit risks. Bond values change according to changes in interest rates, inflation, credit climate and issue credit quality. Interest rate increases will reduce the value of a bond. Longer term bonds are more susceptible to interest rate variations than shorter term, lower yield bonds. SAAGA, LLC 1221 Brickell Ave, Suite 2410, Miami FL 33131 Tel. +1 (786) 362-6819 www.saagawealth.com 11  Alternative Investments (Private non-traded securities, limited partnerships) Risks: An alternative investment is normally an investment in a company or sectors that are not publicly traded. Private investments relate to various asset classes such as real estate, commodities, venture capital and other types of assets. There is no public or secondary market for those investments. Further, depending on the terms of the investment, the investor may not be able to transfer or sell his/her shares. Generally, are not transferable without prior written approval of the issuer and the ability of investors to withdraw their interest is subject to limitations under the investment governing documents. These investments are normally illiquid and can be volatile; therefore, they are not ideal for clients with frequent or unknown cash needs. There is normally no public market for alternative investments. The risk of investing in alternative investments is the majority or complete loss of invested funds depending on the underlying companies. In addition, investors may not see any return on investment for some time depending on the type of investment; these investments should be seen as a long-term investment subject to high risk of loss. Clients contemplating private investments are encouraged to seek independent legal, accounting and tax advice. Global Markets Security Risks: Investments in foreign markets securities implicate different risks than those risks involved with U.S. issuers. Risks such as limited public information, limited regulations of trade markets or government supervision, higher brokerage commissions, foreign taxable income and withholding regulations, country macroeconomic policies, currency fluctuations or exchange controls, political instability among others are factors that may affect the volatility of securities and the liquidity of investments in Client’s portfolio. Real Estate Investment Trusts (“REITs”) risks: Investing in Real Estate Investment Trusts (“REITs”) involves certain distinct risks in addition to those risks associated with investing in the real estate industry in general. Equity REITs may be affected by changes in the value of the underlying property owned by the REITs, while mortgage REITs may be affected by the quality of credit extended. REITs are subject to heavy cash flow dependency, default by borrowers and self-liquidation. REITs, especially mortgage REITs, are also subject to interest rate risk. Asset Allocation risk: A risk of asset allocation is that the Client may not participate in sharp increases in a particular security, industry, or market sector. Another risk is that the ratio of securities, fixed income, and cash will change over time due to stock and market movements and, if not corrected, will no longer be appropriate for the Client's goals. Options risks: Investments in options contracts have the risk of losing value in a relatively short period of time. Option contracts are leveraged instruments that allow the holder of a single contract to control many shares of an underlying stock. This leverage can compound gains or losses. Non-Purpose Loan risk: Non-Purpose Loans carry several risks, including but not limited to the risk of a market downturn, tax implications if collateralized securities are liquidated, and an increase in interest rates. A decline in the market value of collateralized securities held in the account[s] at the Custodian, may result in a reduction in the draw amount of the Client’s line of credit, a demand from the Lending Program that the Client deposit additional funds or securities in the Client’s collateral account[s], or a forced sale of securities in the Client’s collateral account[s]. SAAGA, LLC 1221 Brickell Ave, Suite 2410, Miami FL 33131 Tel. +1 (786) 362-6819 www.saagawealth.com 12  Because of the inherent risk of loss associated with investing, we are unable to represent, guarantee or even imply that our services and methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate Clients from losses due to market corrections or declines. Past performance is not a guarantee of future returns. Investing in securities and other investments involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with the Advisor. Pandemic risk: Pandemic risk can result in market volatility and may have long-term effects many nations including the United States, individual companies, and the market(s). Pandemics may cause extreme volatility and disruption in both the U.S. and global markets causing uncertainty and risks to economic growth, etc. SAAGA cannot predict the effects of significant future events on the global economy and securities markets. A similar disruption of the financial markets could impact interest rates, credit risk, inflation, and other factors. Generally: Cash balances are typically invested daily in interest-bearing money market accounts unless the Client directs otherwise. Tax matters: Regardless of account size or other factors, SAAGA strongly recommends that its clients continuously consult with a tax professional prior to and throughout the investing process. Each Client is responsible for contacting his/her tax advisors to determine which cost basis accounting method is the right choice for the Client. Clients should provide SAAGA with written notice of a client’s selected accounting method, and SAAGA will alert the Client's custodian of the individually selected accounting method. Cybersecurity: Cybersecurity incidents may affect SAAGA or our service providers and can impact or interfere with the ability to conduct business operations and potentially affect client’s accounts. Adverse consequences may also result from incidents affecting other entities such as issuers of invested securities, government institutions, counterparties to transactions, exchange market, operators, banks broker/dealers, insurance companies ect. Risk management policies and business continuity plans help prevent and mitigate the occurrence of cyber incidents but have inherent limitations leaving space to the possibility of occurrences of certain risks not identified. SAAGA cybersecurity resources are limited and we rely on third parties for some functions that may also have limited cybersecurity methods. Cybersecurity incidents could adversely impact investors. Artificial Intelligence (AI): The use of artificial intelligence and machine learning technology solutions (AI) is becoming increasingly employed by registered financial advisors helping with a variety of day to day tasks including client service, data analysis, portfolio optimization, risk assessment, trends and forecasts. AI poses risks to individual investors as well as to the financial system in general. Firms need to evaluate and document all conflicts of interest that may arise by using AI, such as the use and safeguard of clients’ non-public information or the break of the fiduciary duty if recommendations fail to take into account reasonable available alternatives. No assurance can be made that clients’ accounts will not be adversely affected nor that misleading statements would be made when using AI tools. SAAGA use of AI is currently limited to operational tasks efficiency enhancements using tools such as ChatGPT or similar. SAAGA does not use AI for investment related processes. The firm is currently not SAAGA, LLC 1221 Brickell Ave, Suite 2410, Miami FL 33131 Tel. +1 (786) 362-6819 www.saagawealth.com 13  using nor relying on any AI tool or model to make predictions, trend analysis, develop investment strategies and/or asset allocations. No client private/non-public information is inputted into AI Tools. Item 9 – Disciplinary information We are required to disclose all material facts regarding any legal or disciplinary events that would be material to clients or prospective clients’ evaluation of SAAGA or the integrity of SAAGA’s management. SAAGA has no knowledge of any outstanding items or issues applicable to this disclosure. Criminal or Civil Actions SAAGA and its management persons have not been involved in any criminal or civil action. Administrative Enforcement Proceedings SAAGA and its management persons have not been involved in administrative enforcement proceedings. Self-Regulatory Organization Enforcement Proceedings SAAGA and its management persons have not been involved in legal or disciplinary events that are material to a client’s or prospective client’s evaluation of SAAGA or the integrity of its management. Item 10- Other Financial Industry Activities and Affiliations We are required to disclose any relationships and inform how those relationships may create a conflict of interest. Where a conflict of interest exists, we will describe the nature of the conflict and discuss the steps we have taken to ensure that we always put the client’s interest first. Related Persons: As of November 1st, 2024, SAAGA’s business structure changed from a single member LLC to a multimember LLC. A minority percentage of membership interests in the firm are now in hands of capital investors who hold Class “B” non-voting membership units. None of these investors holds over 5% of the firm. A new entity AGAAS, LLC where Juan Pablo Martinez-Blat owns 100% interest is the only holder of Class “A” membership units of SAAGA with voting rights and management control. AGAAS LLC owns over 80% of SAAGA LLC. Certain clients of SAAGA, LLC have purchased a minority, non-voting ownership interest in the firm. This creates a potential conflict of interest, as SAAGA and its management may have an incentive—whether perceived or actual—to provide preferential treatment to these investor-clients over other advisory clients. To mitigate this risk SAAGA has implemented the following: SAAGA, LLC 1221 Brickell Ave, Suite 2410, Miami FL 33131 Tel. +1 (786) 362-6819 www.saagawealth.com 14  • • SAAGA ensures equal treatment of all clients regardless of their investment status in the firm. No preferential terms exist for investors-clients regarding fees, services or investment opportunities. • The control, management and operation of the firm remains to be conducted by Juan Pablo Martinez-Blat who owns all membership interest with voting rights and management power. Investor-clients hold only non-voting Class B membership units, meaning they have no control over firm operations, investment decisions, or client service policies. • Each client advise services and fee structure are customized based on individual client factors such as investment objectives, risk tolerance, financial situation and services to be provided. SAAGA operates as a single family office for each client. • SAAGA does not receive compensation based on the sale of securities or any other investment product that could be preferred by any of the advisory clients that hold capital interest. • SAAGA does not have discretionary power over clients’ accounts. The ultimate decision to invest or not in certain securities or funds relies solely and individually on each client. • Clients who own capital interest in SAAGA are committed by the invested equity to preserve and grow the value of the firm, which relies on the success of its solid fiduciary relations with clients while at the same time are bounded by the fact that they do not have voting powers nor management participation. • Clients’ private information and holdings are never shared with shareholders. Broker-Dealer Affiliation: SAAGA is NOT a broker-dealer and none of our employees or contractors are currently registered representatives of a broker-dealer. This means that we do not receive commissions for buying or selling securities. Item 11 – Code of Ethics Pursuant to Rule 204A-1 promulgated under the Adviser’s Act, SAAGA has adopted a written Code of Ethics (“Code”) that sets forth standards of conduct and federal securities law requirements applicable to all supervised persons as defined in the Advisers Act. The Advisers Act imposes a fiduciary duty on investment advisers. As a fiduciary, SAAGA has a duty of utmost good faith to act solely in the best interest of each of our clients. Our clients entrust us with their funds and investments, which place a high standard on our conduct and integrity. This fiduciary duty compels all employees to act with the utmost integrity in all their dealings. The fiduciary principle is the foundation of our Code of Ethics and represents the expected standard for all interactions with our clients. The Code includes policies and procedures developed to protect clients’ interests in relation to the following topics: • The duty to always place the interests of clients first. SAAGA, LLC 1221 Brickell Ave, Suite 2410, Miami FL 33131 Tel. +1 (786) 362-6819 www.saagawealth.com 15  • The requirement that all personal securities transactions be conducted in a manner consistent with the Code and to avoid any actual or potential conflicts of interest or abuse of an employee’s position of trust and responsibility. • The principle that investment adviser personnel should not take inappropriate advantage of their positions. • The fiduciary principle that information concerning clients' security holdings and financial circumstances is confidential. • The principle that independence in the investment decision-making process is paramount. The Code of Ethics is available upon request. Personal Trading and Conflicts of Interest While SAAGA allows our Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities, we recommend to you present a potential conflict of interest that, as fiduciaries, we must disclose to you and mitigate through policies and procedures. As noted above, we have adopted, consistent with Section 204A of the Investment Advisers Act of 1940, a Code of Ethics, which addresses insider trading (material non-public information controls) and personal securities reporting procedures. We have also adopted written policies and procedures to detect the misuse of material, non-public information. We may have an interest or position in certain securities, which may also be recommended to you. At no time will SAAGA or any associated person of SAAGA, transact in any security to your detriment. As required by Advisers Act Rule 204A-1, Access Persons must report to the Chief Compliance Officer their securities holdings annually and their securities transactions quarterly. The personal trading reviews ensure that the personal trading of employees does not affect the markets, and that clients of the Adviser receive preferential treatment. We have also adopted written policies and procedures to detect the misuse of material, non-public information. Item 12 – Brokerage Practices A. Recommendation of Custodian[s] SAAGA does not have discretionary authority to select the broker-dealer/custodian for custody and execution services. The Client will engage a broker-dealer/custodian to custody Client assets. The custodians will serve as the Client’s “qualified custodian”. Although SAAGA does not exercise discretion over the selection of the custodian, we recommend one or more custodians to Clients for custody and execution services. Clients are not obligated to use the recommended custodian. SAAGA may recommend the custodian based on criteria such as, but not limited to, reasonableness of commissions charged to the client and services made available to the client. In some SAAGA, LLC 1221 Brickell Ave, Suite 2410, Miami FL 33131 Tel. +1 (786) 362-6819 www.saagawealth.com 16  cases, at a client request SAAGA participates in the negotiation of fees and charges the client pays for brokerage, custody and management services. Following are additional details regarding the brokerage practices of the Advisor: 1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and other services. SAAGA does not participate in soft dollar programs sponsored or offered by any broker dealer/custodian except as permitted under the safe harbor rules. 2. Brokerage Referrals - SAAGA does not receive any compensation from any third party in connection with the recommendation for establishing an account. 3. Directed Brokerage – To the extent the Client does not enter an engagement with a recommended custodian (see above), that client may direct its trades be executed through the broker-dealer/custodian as directed by the Client (a “directed brokerage”). For directed brokerages, SAAGA will not be obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs are determined by the applicable broker-dealer/custodian Item 13 – Review of Accounts A. Frequency of Reviews Clients are in frequent contact with our Adviser team. In addition to these ongoing interactions, clients will have their account(s) reviewed no less than on a quarterly basis. Such reviews are led by Juan Pablo Martinez-Blat in conjunction with the supporting staff of the client’s service team. B. Causes for Reviews In addition to quarterly reviews, each client account will be reviewed at least annually. Additional reviews may be prompted due to: • Contributions or withdrawals • Year-end tax planning • Market-moving events • Security-specific developments • Changes in risk/return objectives Clients are encouraged to notify SAAGA of any changes in their personal financial circumstances that could affect their investment plans. C. Review Reports Clients receive brokerage statements from their custodian at least quarterly. These statements can also be accessed electronically and will include details of all positions, transactions, and fees related to the Client’s accounts. SAAGA, LLC 1221 Brickell Ave, Suite 2410, Miami FL 33131 Tel. +1 (786) 362-6819 www.saagawealth.com 17  SAAGA provides clients with a monthly global balance sheet reports that summarize their holdings, allocations, and performance. These reports are based on transaction confirmations and regular summary account statements from the broker-dealer or custodian. It is important to note that SAAGA’s global balance reports are not intended to replace the official statements provided by the custodian, which should be considered the authoritative record for all pertinent account information. While SAAGA strives for accuracy in its monthly reports, clients are encouraged to compare these reports against the official statements from their qualified custodian, which are the definitive records of their account activity. Item 14 – Client Referrals and Other Compensations SAAGA occasionally receives client referrals from various third parties, including current clients, attorneys, accountants, employees, personal friends of employees, and other similar sources. It is important to note that SAAGA does not accept referral fees or any form of remuneration from other professionals for referring prospects or clients. Similarly, SAAGA may refer clients to unaffiliated, non-advisory professionals (e.g., attorneys, accountants, estate planners) to provide essential services that help clients achieve their goals. Clients are not obligated to use the services of any professionals we refer, and we encourage them to seek multiple opinions. We remain committed to disclosing any potential conflicts of interest that may arise from our referral practices. Our supervised persons may occasionally receive de minimis meals or entertainment from industry third parties. However, these instances are reviewed to ensure they do not influence our advisory decisions. Item 15 – Custody Custody, as it applies to investment advisors, has been defined by regulators as having access to or control over client funds and/or securities, in other words, custody is not limited to physically holding client funds and securities. If an investment advisor has the ability to access or control client funds or securities, the investment advisor is deemed to have custody and must ensure proper procedures are implemented. We do not have physical custody of any client’s funds and/or securities. Your funds and securities will be held with a bank, broker-dealer, or other independent qualified custodian. Clients’ funds and securities will be maintained by unaffiliated qualified custodians; banks, broker/dealers, mutual funds companies or transfer agents. Clients should receive at least quarterly statements from the qualified custodian that holds and maintains the client’s investment assets. Custodial statements are the official record of the holdings and values of assets contained therein. We urge clients to carefully review such statements and compare such official custodial records to the reports we provide to reconcile the information reflected on each statement. SAAGA, LLC 1221 Brickell Ave, Suite 2410, Miami FL 33131 Tel. +1 (786) 362-6819 www.saagawealth.com 18  If you have a question regarding your account statement or if you did not receive a statement from your custodian, please contact your advisor. Trusteeships Our advisors have in the past served as trustee (or co-trustee) of client trust accounts to which we provide family office services. These are cases where the trusteeship is not a result from SAAGA providing advisory services to the client, but more of family relationship nature, or other relationships that pre-date the client’s and advisor association with SAAGA. The Firm does not claim custody over these client trusts (based on SEC guidance). Item 16 – Investment Discretion At SAAGA we only provide non-discretionary investment advice. In our role as advisers, we make investment recommendations, but we do not have the authority to make decisions, execute or direct any security transaction on the client’s account. The discretion to do so always remains with the client. However, we typically facilitate the administrative aspects of our client’s security transactions. For example, by coordinating instruction letters to be reviewed and signed by the client. In some cases, the client signs trade instructions and sends them directly to their respective bank, broker dealer or other qualified custodian for execution. In other cases, the client signs and sends the executed trade instructions to SAAGA and SAAGA forwards- by client’s direction- such trade instructions to the client respective bank, broker, dealer or other qualified custodian for execution. Item 17- Voting Client Securities SAAGA does NOT vote proxies on behalf of clients. We have determined that taking the responsibility for voting clients’ securities does not add enough value to the services provided to you to justify the additional compliance and regulatory cost associated with voting client securities. Therefore, it is your responsibility to vote on all proxies for securities held in your account(s). You will receive proxies directly from the qualified custodian. We will not provide you with the proxies, you are encouraged to read through the information provided with the proxy-voting documents and make a determination based on the information provided. With respect to assets managed by a third-party money manager, we will not vote the proxies associated with these assets. You will need to refer to each third-party money manager’s disclosure brochure to determine whether the third-party money manager will vote proxies on your behalf. You may request a complete copy of third-party money manager’s proxy voting policies and procedures as well as information on how your proxies were voted. SAAGA, LLC 1221 Brickell Ave, Suite 2410, Miami FL 33131 Tel. +1 (786) 362-6819 www.saagawealth.com 19  Item 18 – Financial Information This item 18 is not applicable to this brochure. SAAGA does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance. Therefore, we are not required to include a balance sheet for the most recent fiscal year. SAAGA is not aware of any financial condition that is reasonable likely to impair our ability to meet contractual commitments to clients. SAAGA has not been subject to bankruptcy proceedings at any time. Item 19 – Other and miscellaneous Privacy Policy Notice of SAAGA LLC SAAGA, LLC is committed to safeguarding the confidential information of its clients. SAAGA, LLC holds all personal information provided by clients in the strictest confidence and it is the objective of the firm and its representatives to protect the privacy of all clients. We restrict internal access to clients’ non-public personal information to employees who require such information in order to provide services. We maintain physical and procedural safeguards that comply with regulatory standards to guard your non-public personal information and to ensure our integrity and confidentiality. We do not share your information unless it is required to process a transaction or mandate, at your request, or required by law. In the event that there were to be a change in this policy, SAAGA LLC will provide clients with written notice and clients will be provided with an opportunity to direct SAAGA, LLC as to whether such disclosure is permissible. You will receive a copy of our privacy notice prior to or at the time you sign an advisory agreement with our firm. Thereafter, we will deliver a copy of the current privacy policy notice to you on an annual basis. Business Continuity Plan SAAGA has a business continuity and contingency plan in place, designed to respond to significant business disruptions. These disruptions can be both internal and external in nature. Internal disruptions will impact our ability to communicate and do business, such as a fire in the office building. External disruptions will prevent the operation of the securities market or the operations of a number of firms, such as earthquakes, wildfires, hurricanes, terrorist attack or other wide-scale regional disruption. Our continuity and contingency plan have been developed to safeguard employees and/or representatives’ lives and firm property, to allow a method of making financial and operational assessments, to quickly recover and resume business operations, to protect books and records, and to allow clients to continue transacting business. SAAGA, LLC 1221 Brickell Ave, Suite 2410, Miami FL 33131 Tel. +1 (786) 362-6819 www.saagawealth.com 20  The plan includes the following: • Alternate locations to conduct business. • Hard and electronic back-up of records. • Alternative means of communications with employees, representatives, clients, critical business constituents and regulators; and, • Details on the firm’s succession plan Our business continuity and contingency plan is reviewed and updated on a regular basis to ensure that the policies in place are sufficient and operational. SAAGA, LLC 1221 Brickell Ave, Suite 2410, Miami FL 33131 Tel. +1 (786) 362-6819 www.saagawealth.com 21  SAAGA, LLC Form ADV Part 2B – Brochure Supplement For Juan Pablo Martinez-Blat Chief Executive Officer Chief Compliance Officer Effective: June 01, 2023 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Juan Pablo Martinez-Blat in addition to the information contained in the SAAGA, LLC (“SAAGA”) CRD# 327015 ADV Par 2 Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the SAAGA Disclosure Brochure or this Brochure Supplement, please contact us at (786) 362-6819. Additional information about Mr. Martinez-Blat is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 7745735. SAAGA, LLC 1221 Brickell Ave, Suite 2410, Miami FL 33131 Tel. +1 (786) 362-6819 www.saagawealth.com Page 1  Year of Birth Born in 1960. Education IESA, Venezuela, 1984 -1985, MBA, Honor Graduate, Full Scholarship Universidad Metropolitana, Venezuela, 1977 – 1982, BS in Civil Engineering Business SAAGA – Founder, CEO EFC Holdings Family Office – COO Vox2Vox Communications – CFO SAIC – International Financial Planning Director 2002-Present 2002-2008 2000-2002 1999-2000 Disciplinary Information There are no legal, civil, or disciplinary events to disclose regarding Mr. Martinez-Blat. Mr. Martinez-Blat has never been involved in any regulatory, civil, or criminal action. There have been no client complaints, lawsuits, arbitration claims or administrative proceedings against Mr. Martinez Blat. Other Business Information We are required to disclose any outside business activities that are investment related or that provide a substantial source of income or involve a substantial amount of time. No information is applicable to this item. Additional Compensation We are required to disclose any additional compensation for providing advisory services received from anyone who is not a client. This would include sales awards, or any bonus based on the number of sales. No information is applicable to this item. Supervision Mr. Martinez-Blat serves as the Chief Executive Officer and Chief Compliance Officer of SAAGA. Mr. Martinez-Blat can be reached at (786) 940-3510. SAAGA, LLC 1221 Brickell Ave, Suite 2410, Miami FL 33131 Tel. +1 (786) 362-6819 www.saagawealth.com Page 2  SAAGA, LLC Form ADV Part 2B – Brochure Supplement For Daniel Gonzalo Director of Investments Effective: March 30th, 2025 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Daniel Gonzalo, in addition to the information contained in the SAAGA, LLC (“SAAGA”) CRD# 327015 ADV Part 2 Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the SAAGA Disclosure Brochure or this Brochure Supplement, please contact us at (786) 362-6819. Additional information about Daniel Gonzalo is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 5906545. SAAGA, LLC 1221 Brickell Ave, Suite 2410, Miami FL 33131 Tel. +1 (786) 362-6819 www.saagawealth.com Page 3  Year of Birth Born in 1984. Education Universidad de Alcala, Spain, Master of Finance, 2008-2009 Universidad Catolica Andres Bello, Venezuela, Business, 2002-2007 Experience SAAGA – Director of Investments UBS – Senior VP Portfolio Manager Santander Private Banking - Trader Santander Asset Management - Trader 2024-Present 2014-2023 2011-2014 2009-2010 Disciplinary Information There are no legal, civil, or disciplinary events to disclose regarding Mr. Gonzalo. Mr. Gonzalo has never been involved in any regulatory, civil, or criminal action. There have been no client complaints, lawsuits, arbitration claims or administrative proceedings against Mr. Daniel Gonzalo. Other Business Information Director of AL7Management who acts as Portfolio Manager of a long/short portfolio for a funds of funds. Additional Compensation We are required to disclose any additional compensation for providing advisory services received from anyone who is not a client. This would include sales awards, or any bonus based on the number of sales. No information is applicable to this item. Supervision Mr. Daniel Gonzalo is under the supervision of Mr. Juan Pablo Martinez-Blat who serves as the Chief Executive Officer and Chief Compliance Officer of SAAGA. Mr. Martinez-Blat can be reached at (786) 940-3510. SAAGA, LLC 1221 Brickell Ave, Suite 2410, Miami FL 33131 Tel. +1 (786) 362-6819 www.saagawealth.com Page 4