A. Description of the Advisory Firm
Lumida is a Delaware limited liability company formed in July 2022. Lumida is a wholly
owned subsidiary of Lumida, Inc., a Delaware C-Corp. The principal owner of Lumida is
Ram Ahluwalia, Chief Executive Officer of Lumida.
B. Types of Advisory Services
INVESTMENT ADVISORY SERVICES - Lumida provides investment advisory services to
high net worth and ultra-high net worth individuals, family offices, and institutions
(“Separate Account Clients”). Lumida also provides investment advisory services to one
or more pooled investment vehicles (“Fund Clients”) that are exempt from registration
under the Investment Company Act of 1940, as amended (the “Company Act”) and whose
securities are not registered under the Securities Act of 1933, as amended (the “Securities
Act”). Each Separate Account Client and Fund Client is referred to as a “Client” and they
are collectively referred to herein as “Clients”.
Lumida is a digitally native, independent investment advisor, offering full wealth
management and family office services, and specializing in alternative investments
(including privately placed securities such as private equity, venture capital, and hedge
funds) and digital asset management strategies. Lumida aims to construct a strategic
allocation of assets, including individual equity and debt securities, mutual funds (including
interval funds), exchange-traded funds (“ETFs”), variable annuity products, alternatives,
and digital assets. The Firm specializes in offering investment strategies to Clients seeking
exposure to alternatives and digital assets through an adviser with the knowledge to invest
intelligently in alternatives and digital assets. Lumida provides Clients with carefully
researched insights into alternatives (including privately placed securities such as private
equity, venture capital, and hedge funds) and digital assets, including cryptocurrencies;
decentralized application tokens; protocol tokens and other cryptofinance coins, tokens
and other assets that are currently or may in the future become associated with or utilize
blockchain technology; stablecoins; non-fungible tokens (“NFTs”); security tokens, which
link real world assets to blockchains; and other publicly traded digital asset related entities
including crypto-related companies, projects, and protocols.
The Firm’s advisory services consist of researching and evaluating investment
opportunities, recommending, or making the appropriate investments on behalf of Clients,
monitoring the performance of these investments, and exercising its judgment related to
the disposition of such investments.
Lumida provides investment advisory services in accordance with the terms and
conditions of the investment management agreement for each Separate Account and the
limited partnership and/or advisory agreement of Fund Clients (each, an “Advisory
Agreement”). Lumida offers discretionary and non-discretionary advisory services to
Separate Account Clients and Fund Clients.
Fund Clients will offer limited partnership or limited liability company interests (“Interests”)
to certain qualified investors as described in response to Item 7, below (such investors are
referred to herein as “Investors”). Investment advisory services provided directly to Fund
Clients are subject to the discretion and control of Lumida or the applicable affiliated
general partner or managing member, as applicable, and not individually to the Investors
in a Fund Client. Services are provided to a Fund Client in accordance with Lumida’s
Advisory Agreement with Fund Client and/or organizational documents of Fund Client,
including its limited partnership agreements or operating agreement, as applicable, and
offering memoranda (such documents collectively, a Fund Client’s “Offering Documents”).
Investment restrictions for a Fund Client, if any, are established in its organizational and/or
Offering Documents, Advisory Agreements and/or any side letter agreements negotiated
with Investors in such Fund Client. In addition, Lumida may be engaged to provide sub-
advisory services to private funds sponsored and offered by unaffiliated or affiliated, third-
party advisory firms.
FAMILY OFFICE SERVICES – Lumida provides Family Office Services and will obtain
from the Separate Account Client information to determine each Separate Account Client’s
financial situation, investment objectives, and risk tolerance (“Family Office clients”).
Advisor shall craft a specific investment strategy for each Family Office client, focusing on
the Family Office client’s specific goals, objectives,
risk tolerance, liquidity needs, and
special considerations, if any, to develop an asset allocation for the Assets under
Advisement and Assets under Management.
For Family Office clients, Lumida will be available to prepare a written financial plan for
each Family Office client and/or advise on topics mutually agreed upon by the Family
Office client and the Firm. Topics may include cash flow analysis, tax planning, estate
planning, debt analysis, charitable planning, real estate analysis, or other non-investment
related topics. It is expressly understood that Lumida will not provide accounting or legal
advice, nor prepare any accounting or legal documents. Family Office Services will be
provided in conjunction with services of attorneys, accountants, and/or other outside
specialists as deemed appropriate by each Family Office client to potentially assist in the
implementation of the Firm’s financial planning recommendations. Family Office clients
will be responsible for paying all fees associated with such third-party services.
Family Office clients understand that it will be incumbent upon each client to identify to
Lumida those particular financial planning issues for which client is requesting advice or
consultation, and Family Office clients and the Firm must mutually agree that Lumida will
provide consultations in response to such request or issues raised by the Family Office
client. When providing financial planning services, the Family Office client will provide
Lumida with the necessary information requested by the Firm, including, but not limited to
the client’s current financial status, future goals, and attitudes towards risk.
Separate Account Clients who will not be engaging Lumida for Family Office Services are
advised and afforded the opportunity to seek the advice and counsel of the Client’s own
tax, financial, and legal advisers.
Lumida will not be responsible for withholding any tax penalties that may apply to Separate
Account Clients’ custodial accounts or for any state or federal income tax withholding,
except as may otherwise be required by applicable law.
INVESTMENT CONSULTING SERVICES – In addition, Lumida may provide Investment
Consulting Services designed to provide Separate Account Clients with periodic portfolio
reviews and investment recommendations for Assets under Advisement. Each Separate
Account Client will be solely responsible for implementing (e.g., placing trades with the
qualified custodian) any advice provided by Lumida for the Assets under Advisement and
any recommendations made by Lumida will be based on the Separate Account Client’s
financial situation, investment objectives, and risk tolerance.
The frequency of review and assets considered “Assets Under Advisement” and any
potential restrictions on investment advice and recommendations made by Lumida will be
identified within the service agreement with each Separate Account Client. Lumida will
review and provide reports on portfolio performance of Assets under Advisement against
applicable benchmarks and will be reasonably available to consult with each client
regarding such reports. If a client determines not to implement an investment
recommendation of Lumida related to Assets under Advisement, the client will be
responsible for notifying the Firm. Lumida will not have any discretionary authority to make
or implement investment decisions related to Assets under Advisement.
C. Client Tailored Services and Client Imposed Restrictions
Advisory services provided to Separate Account Clients are tailored to achieve their
investment objectives. Lumida will gather information on each Separate Account Client
during onboarding to determine the Client’s risk tolerance, investment objectives, and
investment constraints or restrictions, which will be considered in making investment
decisions on behalf of the Separate Account Client and/or making recommendations to
such Separate Account Client.
With respect to Fund Clients, Lumida has the authority to select which and how many
securities and other instruments to buy or sell without consultation with Fund Client or its
Investors who do not have the ability to impose restrictions on investment decisions made
on behalf of Fund Clients.
D. Wrap Fee Programs
Lumida does not participate in wrap fee programs.
E. Amounts Under Management
As of the date of this Brochure, Lumida managed approximately $124,909,010 in
regulatory assets management, $26,288,009 of which is managed on a discretionary basis
and $98,621,001 on a non-discretionary basis.