A. Firm Information
Omnia Family Wealth, LLC (“Omnia Family Wealth” or the “Advisor”) is a registered investment advisor with the
U.S. Securities and Exchange Commission. The Advisor is organized as a limited liability company (“LLC”) under
the laws of the State of Florida. Omnia Family Wealth was founded in September 2015, and is owned and
operated by Steven Alan Wagner (Chief Executive Officer), Ivan Orlando Hernandez (Managing Director of
Wealth Structure and Planning and Chief Compliance Officer), and Michael Scott Wagner (Chief Operating
Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and the
advisory services provided by Omnia Family Wealth.
B. Advisory Services Offered
Omnia Family Wealth offers investment advisory services to individuals, high net worth individuals, trusts,
estates, charitable organizations, businesses and pooled investment vehicles (each referred to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary,
the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential
conflicts of interest. Omnia Family Wealth’s fiduciary commitment is further described in the Advisor’s Code of
Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or
Interest in Client Transactions and Personal Trading.
Wealth Management Services
Omnia Family Wealth provides Clients with wealth management services, which generally includes a broad
range of comprehensive financial planning and consulting strategies as well as discretionary and non-
discretionary management of investment portfolios.
Investment Management Services - Omnia Family Wealth works with each Client to identify their investment
goals and objectives as well as risk tolerance and financial situation in order to create a portfolio strategy. In
order to create a comprehensive financial strategy, Omnia Family Wealth will typically provide a variety of
financial planning strategies to Clients that integrate noninvestment related matters such as estate planning, tax
planning, insurance planning, family education, philanthropic planning, and other components of financial
planning (see Financial Planning Services below).
The Advisor will then develop a strategic asset allocation based on the Client’s investment objectives, conducting
due diligence on managers across the spectrum of investment strategies, selecting managers to implement the
allocation internally developed, and providing ongoing monitoring of the investments. Omnia Family Wealth may
utilize one or more unaffiliated investment managers or investment platforms (collectively “Independent
Managers”) to assist in the management of Client assets. For its high net worth Clients, Omnia Family Wealth
may recommend investments in affiliated or unaffiliated private investment vehicles, which may in turn invest in
real estate, private equity or other investments. Under certain conditions, private investments may be
recommended to Clients, but only if the respective investment is appropriate for the Client. Assets in a private
investment are invested in accordance with the respective investment’s offering documents. Clients invested in a
private investment should consult the offering documents for information regarding its investment program,
limitations on withdrawal, and risk factors.
Omnia Family Wealth’s wealth management approach is primarily long-term focused, but the Advisor may buy,
sell or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due
to market conditions. Omnia Family Wealth will construct, implement and monitor the portfolio to ensure it meets
the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the
opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio,
subject to acceptance by the Advisor.
Omnia Family Wealth evaluates and selects investments for inclusion in Client portfolios only after applying its
internal due diligence process. Omnia Family Wealth may recommend, on occasion, redistributing investment
allocations to diversify the portfolio. Omnia Family Wealth may recommend specific positions to increase sector
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or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against
market movement. Omnia Family Wealth may recommend selling positions for reasons that include, but are not
limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of
securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client,
generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance.
Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement
accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the
Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable,
which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will
provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over
the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to
another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based
account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a
new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll
over a retirement account to an account managed by the Advisor.
Use of Independent Managers – When deemed to be in the Client’s best interest, Omnia Family Wealth will
recommend that a Client utilize one or more unaffiliated investment managers or investment platforms
(collectively “Independent Managers”) for all or a portfolio of a Client’s investment portfolio. In such instances, the
Client will then enter into an advisory agreement with the Independent Manager[s] that defines the terms in which
the Independent Manager[s] will provide investment management and related services. Omnia Family Wealth
may also assist in the development of the initial policy recommendations and managing the ongoing Client
relationship. Omnia Family Wealth will perform initial and ongoing oversight and due diligence over the selected
Independent Manager[s] to ensure the Independent Managers’ strategies and target allocations remain aligned
with its clients’ investment objectives and overall best interests. The Client, prior to entering into an agreement
with an Independent Manager, will be provided with the advisor's Form ADV 2A (or a brochure that makes the
appropriate disclosures).
Financial
Planning Services – Omnia Family Wealth will typically provide a variety of financial planning services
to individuals and families either as part of its wealth management services or pursuant to a written financial
planning agreement. Services are offered in several areas of a Client’s financial situation, depending on their
goals and objectives. Generally, such financial planning services will involve preparing a financial plan or
rendering a financial consultation based on the Client’s financial goals and objectives. This planning may
encompass one or more areas of need, including, but not limited to investment planning, retirement planning,
personal savings, education savings, insurance needs, and other areas of a Client’s financial situation.
A financial plan developed for the Client will usually include general recommendations for a course of activity or
specific actions to be taken by the Client. For example, recommendations may be made that the Client start or
revise their investment programs, commence or alter retirement savings, establish education savings and/or
charitable giving programs. Omnia Family Wealth may also refer Clients to an accountant, attorney or other
specialist, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will
provide a written summary of Client’s financial situation, observations, and recommendations. For consulting or
ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically
completed within six months of contract date, assuming all information and documents requested are provided
promptly.
Financial planning recommendations pose a conflict between the interests of the Advisor and the interests of the
Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment
management services or to increase the level of investment assets with the Advisor, as it would increase the
amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made
by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the
recommendations made by the Advisor, the Client is under no obligation to implement the transaction through
the Advisor.
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Private Fund Management Services
The Advisor serves as the general partner and as the investment manager to pooled investment vehicles (each a
“Fund” and collectively the “Funds”). These services are detailed in the offering documents for each Fund, which
include as applicable, operating agreements, private placement memorandum and/or term sheets, subscription
agreements, separate disclosure documents, and all amendments thereto (“Offering Documents”).
The Advisor manages each Fund based on the investment objectives, policies and guidelines as set forth in the
respective Offering Documents and not in accordance with the individual needs or objectives of any particular
investor therein. Each prospective investor interested in investing in a Fund is required to complete a
subscription agreement in which the prospective investor attests as to whether or not such prospective investor
meets the qualifications to invest in the Fund and further acknowledges and accepts the various risk factors
associated with such an investment.
In general, investors in the Funds are not permitted to impose restrictions or limitations. However, the Advisor
may enter into side letter agreements with one or more investors that may alter, modify, or change the terms of
interest held by investors. Certain types of side letters create a conflict of interest between the Advisor and the
investors in the Fund, and/or between investors themselves. Currently, the only side letters in place in the Funds
are for lower or waived fee arrangements.
The Advisor will recommend that certain Clients invest in the Funds. The recommendation to invest in the Funds
poses a conflict between the interests of the Advisor and the interests of the Client, as the Advisor is incentivized
to increase the amount of assets in the Funds in order to increase the revenue generated to the Advisor. This
conflict is mitigated as Clients will only pay the asset-based fee as described above. The Advisor will not receive
additional fees for its management of the Fund. Clients of the Advisor are under no obligation to invest in the
Funds.
For more detailed information on investment objectives, policies and guidelines, please refer to the
respective Fund’s Offering Documents.
Advisory-Only Investment Services
Omnia Family Wealth provides customized advisory-only investment services for certain Clients. In such
instances, the Client will engage Omnia Family Wealth through an advisory-only investment advisory agreement.
The Client will retain all control over implementation of any investment decisions or trade executions, whether on
the Client’s own behalf or via the Client’s third-party investment manager.
Advisory-only investment services may include the following:
• Customized performance reporting (including appropriate benchmark comparisons);
• Quarterly asset allocation reports; and
• Asset location recommendations.
C. Client Account Management
Prior to engaging Omnia Family Wealth to provide investment advisory services, each Client is required to enter
into one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of
the Advisor and the Client. These services may include:
• Establishing an Investment Strategy – Omnia Family Wealth, in connection with the Client, will develop a
strategy that seeks to achieve the Client’s investment goals and objectives.
• Asset Allocation – Omnia Family Wealth will develop a strategic asset allocation that is targeted to meet
the investment objectives, time horizon, financial situation and tolerance for risk for each Client.
• Portfolio Construction – Omnia Family Wealth will develop a portfolio for the Client that is intended to
meet the stated goals and objectives of the Client.
• Investment Management and Supervision – Omnia Family Wealth will provide investment management
and ongoing oversight of the Client’s investment portfolio.
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D. Wrap Fee Programs
Omnia Family Wealth does not manage or place Client assets into a wrap fee program.
E. Assets Under Management
As of December 31, 2023, Omnia Family Wealth had $2,533,723,690 in approximate total combined assets
under management and assets under advisement. The combined assets under management of $759,723,690
includes $640,114,521 which is on a discretionary basis and $119,609,169 on a non-discretionary basis.
Assets under advisement include, but is not limited to, personal property, outside investments and other real
assets of approximately $1,774,000,000. These are non-GAAP accounting assets and values are derived from
information provided by the families we represent and are not verified by Omnia Family Wealth. Clients may
request more current information at any time by contacting the Advisor.