Overview
Assets Under Management: $186 million
Headquarters: MIAMI, FL
High-Net-Worth Clients: 25
Average Client Assets: $7 million
Services Offered
Services: Portfolio Management for Individuals
Fee Structure
Primary Fee Schedule (NUMA AMERICAS CORP. BROCHURE)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | and above | 1.00% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $10,000 | 1.00% |
| $5 million | $50,000 | 1.00% |
| $10 million | $100,000 | 1.00% |
| $50 million | $500,000 | 1.00% |
| $100 million | $1,000,000 | 1.00% |
Clients
Number of High-Net-Worth Clients: 25
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 95.51
Average High-Net-Worth Client Assets: $7 million
Total Client Accounts: 204
Discretionary Accounts: 142
Non-Discretionary Accounts: 62
Regulatory Filings
CRD Number: 164602
Last Filing Date: 2025-02-13 00:00:00
Website: https://numaweb.com
Form ADV Documents
Primary Brochure: NUMA AMERICAS CORP. BROCHURE (2025-08-27)
View Document Text
Numa Americas Corp.
1200 Brickell Avenue
Suite 1950
Miami, FL 33131
Telephone: (786) 315-4824
E-mail: rzamora@numaweb.com
Investment Advisor Brochure
(Form ADV – Part 2A/2B) Firm CRD # 164602
This Brochure provides information about the qualifications and business practices of Numa Americas
Corp. If you have any questions about the contents of this Brochure, please contact us at telephone
number (786) 315-4824 and/or by email at rzamora@numaweb.com
The information in this Brochure has not been approved or verified by the United States Securities and
Exchange Commission or by any state securities authority.
Registration of an investment adviser does not imply any level of skill or training. The oral and written
communications received from an adviser provide you with information about which to utilize in
determining to hire or retain an investment adviser.
Additional information about Numa Americas Corp. also is available on the SEC’s website at
www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD
number. The CRD number for Numa Americas Corp. Is 164602.
Revised: December 2024
Item 2 – Material Changes
As required by SEC rules, Numa Americas Corp. (hereinafter “Numa” or the “Adviser”), an investment adviser
registered with the U.S. Securities and Exchange Commission (“SEC”), is required to inform our clients of material
changes to its business that have occurred since the last annual update of the Adviser’s brochure.
You will continue to receive a summary of materials changes, if any, to this and subsequent Brochures within 120
days of the close of our business’ fiscal year. We will further provide you with a new Brochure as necessary
based on changes or new information, at any time, without charge. Currently, our Brochure may be requested by
contacting us at phone number (786) 315-4824 and/or by email at rzamora@numaweb.com
Additional information about Numa is also available via the SEC’s web site www.adviserinfo.sec.gov. The SEC’s
web site also provides information about any persons affiliated with Numa who are registered, or are required to
be registered, as Investment Firm Representatives (“IARs”) of Numa.
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Table of Contents
Table of Contents ...................................................................................................... 3
Item 5 – Fees and Compensation ............................................................................. 5
Item 6 - Performance-Based Fees and side-by-side management ........................... 6
Item 7 - Types of Clients ............................................................................................ 6
Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss ..................... 6
Item 9 - Disciplinary Information ................................................................................ 9
Item 10 - Other Financial Industry Activities and Affiliations ...................................... 9
Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading ...................................................................................................................... 9
Item 12 - Brokerage Practices ................................................................................. 13
Item 13 - Review of Accounts .................................................................................. 13
Item 14 - Client Referrals and Other Compensation ............................................... 14
Item 15 - Custody .................................................................................................... 14
Item 16 - Investment Discretion ............................................................................... 14
Item 17 - Voting Client Securities ............................................................................ 14
Item 18 - Financial Information ................................................................................ 14
Item 19 – Business Continuity and Information Security ......................................... 14
FORM ADV PART 2B BROCHURE SUPPLEMENT ............................................... 16
Rafael Zamora León, Chief Executive Officer, Chief Compliance Officer, Chairman and
Director .................................................................................................................... 17
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Item 4 – Advisory Business
General
Numa offers personalized investment advisory services to high-net-worth individuals, trusts, estates, and
corporations or other business entities. Numa is strictly a fee-only investment management firm. The firm does
not sell annuities, insurance, stocks, bonds, mutual funds, limited partnerships or other commercial products. No
commissions or finder’s fee in any form are accepted.
Numa is a corporation organized in the State of Delaware and registered to do business in New York. Numa is an
indirect wholly owned subsidiary of Numa Asset Management, Ltd. (“NAM’) a privately held BVI company.
Numa offers the following services to advisory clients:
1. Sub-Advising for Third-Party and Affiliate Advisory Programs
Numa offers advisory services to affiliates, specifically NYX Systems SAC (“NYX”) and third-party financial
institutions. The core services offered to these institutions consist of administrative services, asset allocation and
portfolio construction to be used in conjunction with their proprietary advisory programs. In most cases, this
involves the construction of risk-based asset-class and/or investment-specific strategies and on-going monitoring
of such strategies, trade executions. Adviser’s administrative services include, but are not limited to:
§ monitoring the performance of client investments (including any third-party investment products
maintained in client portfolios of investments;
§ monitoring the performance and financial condition; and
§ providing access to proprietary trading software.
NYX Systems SAC, “NYX” offers monitoring, reporting and administrative services to the Adviser, which
includes trade processing and execution services.
2.
Investment Advisory Services
Adviser provides investment advisory services to Adviser’s clients through various types of discretionary and non-
discretionary accounts in accordance with each client’s investment objectives. Investment activities focus on
investments in various kinds of assets and securities in a variety of markets that is intended to fit within the client’s
objectives, strategies and risk profile as described by each client. In addition, Adviser offers several specialized
programs that are described below.
Numa offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and
risk tolerance of each client. These policies are set in a document signed by the client and Advisor named
“Investment Policy Statement” for each client, which outlines the client’s current investment profile (income, tax
levels, and risk tolerance levels) and then constructs a plan (the Investment Policy Statement) to aid in the
selection of a portfolio that matches each client’s specific situation. Investment Supervisory Services include, but
are not limited to, the following:
Investment strategy
§
§ Asset allocation
§ Risk tolerance
§ Personal investment policy
§ Asset selection
§ Regular portfolio monitoring
Numa evaluates the current investments of each client with respect to their risk tolerance levels and time horizon.
Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client.
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3. Family Wealth Services
As an investment adviser, Adviser provides portfolio management and administrative services to client accounts
(the “Accounts”), including investigating, analyzing, structuring and negotiating potential investments, monitoring
the performance of investments and advising the Accounts as to the disposition of investment opportunities.
Adviser provides investment advisory services to Adviser’s clients through the management of investment
portfolios in accordance with the objectives, guidelines and risk profiles of individual clients. Clients provide such
information to Adviser at or before the time they enter into an advisory agreement with Adviser. The Adviser may
provide additional services to clients as negotiated with each client and Adviser may charge a fee that would be
negotiated with the client.
Clients may impose reasonable restrictions on the management of their Accounts, by restricting particular
securities or types of investments. Clients should be aware that performance of restricted accounts may differ
from performance of accounts without such impediments, possibly producing lower overall results.
Additional General Information
Other professionals (e.g., lawyers, accountants, insurance agents, etc.) may be recommended to clients or
engaged directly by the client on an as-needed basis. Conflicts of interest related to recommendations of other
professionals will be disclosed to the client in the event they should occur.
Numa’s Agreements may not be assigned without client consent. Numa does not currently participate in any
Wrap Fee Programs.
Regulatory Assets Under Management
As of December 31, 2024, Adviser had total regulatory assets under management of approximately $186,396,399
out of which $70,722,614 is managed on a non-discretionary basis and $115,673,786 is managed on a
discretionary basis. These numbers include the leverage used with derivatives, basically when we short a put
and do not hold the full notional amount in cash to purchase the underlying security. When we purchase
derivatives and the client’s maximum loss is the premium itself, we use the premium as an asset under
management and do not calculate an implied leverage. Our regulatory assets under management without
leverage is $186,383,747 out of which $113,564,576 is discretionary and $72,819,170 is non-discretionary.
Item 5 – Fees and Compensation
Basic fee schedule
Adviser provides advisory and administrative services for a flat fee (percentage) based upon regulatory assets
under management, which is outlined and established via advisory/administrative services agreement.
The specific manner in which fees are charged by Adviser is established in each client’s written agreement with
Adviser. For investment advisory services, generally and pursuant to contract, fees for the management of
Accounts will be based upon a percentage of the total regulatory assets under management including implied
leverage of the account (including margined assets). Adviser typically receives an annual management fee,
between .30% to 1.00% of this calculated regulatory asset under management of the Account. All fees are
negotiable. Adviser may enter into flat fee arrangements from time to time, typically for administrative services
provided to clients or client Accounts.
Calculation and Deduction of Advisory Fees
With respect to accounts that Adviser manages on a discretionary basis, including the specialized discretionary
programs, generally clients do NOT authorize Adviser to directly debit management fees from client accounts,
instead invoices are sent once services have been performed, usually, quarterly and clients directly pay these
amounts through wire transfers. Fees for Family Wealth Services and other non-discretionary programs are billed
to clients.
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A client may pay more or less fees than similar clients depending on the particular circumstances of the client,
size, additional or differing levels of servicing or as otherwise agreed with specific clients. Clients that negotiate
fees, including a flat fee, may end up paying a higher fee than that set forth above as a result of fluctuations in the
client’s assets under management and account performance.
Additional Fee Information
Clients receive an invoice for fees, in which it may choose to pay Numa directly for its billed fees for the relevant
period.
Adviser’s fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses
which shall be incurred directly by the client. Clients may incur certain charges imposed by custodians, brokers,
and other third parties such as fees charged by fund managers, custodial fees, deferred sales charges, odd-lot
differentials, transfer taxes, wire transfer and electronic funds fees, and other fees and taxes on brokerage
account and securities transactions. Mutual funds and exchange traded funds also charge internal management
fees, which are disclosed in a fund’s prospectus. It is the Adviser’s policy not to accept “kick-backs” or
retrocession fees from any third non-affiliated party providing services to the Adviser’s clients.
Termination of the Agreement
Although an Agreement between Numa and its clients are ongoing agreements and constant adjustments are
required, the length of service to the client is at the client’s discretion. The client or the investment manager may
terminate an Agreement by written notice to the other party with a (30) thirty – day advance notice or as agreed
upon otherwise between the client and the Adviser.
If an agreement is terminated during a period in which the client has already paid Numa its advisory fees in
advance, then the Adviser will reimburse, on a pro-rated basis, the remaining advisory fees collected for any
service not rendered; these fees will be sent to the client’s address of record, unless otherwise directed by the
client, within (30) days of termination of the agreement.
Item 6 - Performance-Based Fees and side-by-side management
Numa may from time to time accept performance-based fees or other fees based on a share of capital gains on or
capital appreciation of the assets of a client.
Item 7 - Types of Clients
Numa provides asset and/or portfolio management services to high-net-worth individuals, corporations and
institutions or other entities. The minimum dollar value for establishing an Account is generally $50,000. Initial
investments of a lesser amount may be accepted at Adviser’s discretion.
Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss
General Investment Strategies and Methods of Analysis
Adviser has arrangements with third party service providers through which Adviser receives general
macroeconomic analyses of economies, currencies, markets and market sectors. Such third parties also provide
research reports on specific securities, sample asset allocations and administrative services. Adviser uses such
information and services as a tool and Adviser also performs its own research and due diligence on advisers and
investment opportunities. Adviser makes investment allocation decisions based on each client’s investment
objectives and risk tolerance, among other factors. Adviser identifies, structures, monitors, invests and liquidates
investments in discretionary accounts. The design and day-to-day management of client portfolios is determined
by Adviser through the assigned portfolio manager. Such third-party service providers do not have access to or
knowledge of information concerning the specific investment decisions and recommendations made to Adviser’s
clients.
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Through Adviser’s global strategy Adviser seeks asset preservation and capital appreciation of clients’ portfolios
by customizing asset allocations and selecting investment vehicles that it believes will align clients’ risk / return
expectations with long term and short-term investment needs and goals. The asset class allocations forecasts
and expectations are analyzed and invested in various financial instruments, typically include equity, fixed
income, options and alternative investments. Adviser will select and monitor the investment vehicles for each
asset class in the portfolios based on their history and prospective risk and return characteristics, and determine
suitability for each client’s needs, as well as, estimated fees and expense.
Material Risks for Significant Investment Strategies
While it is the intention of Adviser to implement strategies, which are designed to minimize potential losses
suffered by its client, there can be no assurance that such strategies will be successful. It is possible that a client
may lose a substantial proportion or all of its assets in connection with investment decisions made by Adviser.
The following is a discussion of typical risks for Adviser’s clients, but it does not purport to be a complete
explanation of the risks involved with Adviser’s investment strategies.
There is no guarantee that in any time period, particularly in the short term, a client’s portfolio will achieve
appreciation in terms of capital growth or that a client’s investment objective will be met by Adviser.
The value of the securities in which Adviser invests on behalf of its clients may be volatile. Price movements may
result from factors affecting individual companies, sectors or industries that may influence certain strategies or the
securities market as a whole. Furthermore, a client will be subject to the risk that inflation, economic recession,
changes in the general level of interest rates or other market conditions over which Adviser will have no control
may adversely affect investment results.
Adviser notes that while Adviser’s management of accounts may not involve direct leveraging, or other risk factors
discussed below, the underlying funds and other investments that comprise client accounts may engage in
practices that can materially impact the performance of such fund or investment, which in turn may materially
impact the value of Adviser’s clients’ portfolios.
Hedging transactions may increase risks of capital losses
Adviser utilizes hedging strategies primarily to protect and preserve capital as well as yield enhancement.
Investment products in which Adviser invests clients’ accounts may utilize a variety of financial instruments, such
as options, for risk management purposes. While hedging transactions may seek to reduce risk, such transactions
may result in a worse overall performance. Certain risks cannot be hedged, such as credit risk, relating both to
particular securities and counterparties. Adviser will not always invest in funds or other investment vehicles that
utilize hedging strategies.
Leverage
Adviser does not utilize direct leverage under its current strategies, i.e borrowing funds. Numa does sell options,
the amount of the initial margin is small relative to the notional value of the options contract, so that transactions
can be viewed as “leveraged” or “geared” but may maintains cash levels in excess of those required by banks and
the exchanges in order to mitigate this risk. Numa reserves the right to engage in leveraged strategies as
explained to clients or when written requests by its client are made in the Investment Policy Statement, (“IPS”).
Liquidity of investment portfolio
The market for some securities in which Adviser invests indirectly on behalf of its clients, may be relatively illiquid.
Liquidity relates to the ability to sell an investment in a timely manner. The market for relatively illiquid securities
tends to be more volatile than the market for more liquid securities. Investments in relatively illiquid securities may
restrict the ability of a fund or portfolio manager to dispose of investments at a price and time that it wishes to do
so. The risk of illiquidity also arises in the case of over-the-counter transactions. There is no regulated market in
such contracts and the bid and offer prices will be established solely by dealers in these contracts. Client
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accounts that are invested in funds or other instruments that contain illiquid investments may be subject to these
risks.
Foreign currency markets
Adviser’s investment strategies may cause a client to be exposed to fluctuations in currency exchange rates
where it invests directly or indirectly in securities denominated in currencies other than U.S. dollars. Adviser does
not engage in direct foreign currency trading, unless specifically asked to do so as a mandate to hedge foreign
exchange risk. However, the underlying funds and other investment vehicles may engage in direct foreign
currency trading. The markets in which foreign exchange transactions are effected are highly volatile, highly
specialized and highly technical. Significant changes, including changes in liquidity and prices, can occur in such
markets within very short periods of time, often within minutes. Foreign exchange trading risks include, but are not
limited to, exchange rate risk, interest rate risk and potential interference by foreign governments through
regulation of local exchange markets, foreign investment, or particular transactions in foreign currency.
Derivatives
Adviser’s investment strategy may cause a client to be exposed to derivatives including instruments and contracts
the value of which is linked to one or more underlying securities, financial benchmarks or indices. Derivatives
allow an investor to hedge or speculate upon the price movements of a particular security, financial benchmark,
index, currency or interest rate at a fraction of the cost of investing in the underlying asset. The value of a
derivative depends largely upon price movements in the underlying asset. Therefore, many of the risks applicable
to trading the underlying asset are also applicable to derivatives trading. However, there are a number of other
risks associated with derivatives trading. For example, because many derivatives provide significantly more
market exposure than the money paid or deposited when the transaction is entered into, a relatively small
adverse market movement can result not only in the loss of the entire investment, but may also expose a client to
the possibility of a loss exceeding the original amount invested.
Settlement risks
Adviser’s investment strategies may expose a client to the credit risk of parties with whom Adviser, on behalf of
the client or the underlying funds, trades and to the risk of settlement default. Market practices in the emerging
markets in relation to the settlement of securities transactions and custody of assets will provide increased risk.
Although the emerging markets have grown rapidly over the last few years, the clearing, settlement and
registration systems available to effect trades on such markets are significantly less developed than those in more
mature world markets which can result in delays and other material difficulties in settling trades and in registering
transfers of securities. Problems of settlement in these markets may affect the net asset value and liquidity of a
client’s portfolio or investments in such portfolios.
Emerging Markets
Adviser’s investment strategies include direct and indirect investments in securities in emerging markets and such
investments involve special considerations and risks. These include a possibility of nationalization, expropriation
or confiscatory taxation, foreign exchange control, political changes, government regulation, social instability or
diplomatic developments which could affect adversely the economies of such countries or the value of a client’s
investments, and the risks of investing in countries with smaller capital markets, such as limited liquidity, price
volatility, restrictions on foreign investment and repatriation of capital, and the risks associated with emerging
economies, including high inflation and interest rates and political and social uncertainties. In addition, it may be
difficult to obtain and enforce a judgment in a court in an emerging country. The economies of many emerging
market countries are still in the early stages of modern development and are subject to abrupt and unexpected
change. In many cases, governments retain a high degree of direct control over the economy and may take
actions having sudden and widespread effects. Investments in products of emerging market may also become
illiquid which may constrain Adviser’s ability to realize some or all of a client’s portfolio holdings. Accounting
standards in emerging market countries may not be as stringent as accounting standards in developed countries.
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Investment Concentration
Most of our client accounts may have a high concentration in a select number of broad indeces (such as the
Standard and Poors 500 index, the Standard and Poors 400 Midcap index, the Russell 2000 small cap index, and
the Nasdaq 100 Index), one sector or sector exchange trades funds (“ETF”), industry, issuer or security that may
subject such accounts to greater risk of loss in the event such investments take an economic downturn.
Material Risks for Particular Types of Securities
The Adviser does not invest primarily in a specific security or type of security. The material risks involved with
investing are described above.
Item 9 - Disciplinary Information
Investment advisers are required to disclose all material facts regarding any legal or Disciplinary events that
would be material to your evaluation of an adviser or the integrity of the adviser’s management. Adviser has no
information applicable to this Item. Please visit www.advisorinfo@sec.gov at any time to view Numa’s registration
information and any applicable disciplinary action.
Item 10 - Other Financial Industry Activities and Affiliations
Broker-Dealer Registration
Adviser is not registered with the Securities and Exchange Commission (SEC) as a broker-dealer. No members of
Numa’s management or associated persons are registered or associated with any broker-dealer.
Commodity Pool Operator, Commodity Trading Adviser, Futures Commission Merchant Registration
Adviser nor its management or associated persons are registered or associated with the Commodity Futures Trading
Commission (“CFTC”) as a futures commission merchant (“FCM”), a commodity pool operator (“CPO”) or a commodity
trading advisor (“CTA”) or an associated person of the foregoing entities.
Affiliates
Numa has relationship with Numa Asset Management Ltd. (NAM) and NYX Systems SAC (“NYX”). These entities
incorporated in British Virgin Islands and Peru respectively offer financial and advisory services. Members of Numa’s
management team are employed by NAC and/or NYX. In addition, the Adviser maintains a sub advisory relationship
with NAM as detailed previously.
Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Code of Ethics and Personal Trading Policies
Adviser has adopted the Code of Ethics pursuant to Rule 204A-l of the Advisers Act in an effort to prevent
violations of federal securities laws. Adviser expects all employees to act with honesty, integrity and
professionalism and to adhere to federal securities laws.
All officers, directors, partners and employees of the Adviser and any other person who provides advice on behalf
of Adviser and is subject to Adviser’s control and supervision (collectively referred to as “Supervised Persons”)
are required to adhere to the Code.
Prevention of Insider Trading
Adviser has adopted policies designed to prevent insider trading that is more fully described in the Code.
Adviser’s policy on insider trading applies to securities trading and information handling by all Supervised Persons
of Adviser (including spouses, minor children and adult members of their households and any other relative of a
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Supervised Person on whose behalf Supervised Person is acting) for their own account or the account of any
client of 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 this manual, 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, a quarterly basis, and an annual basis.
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-l(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). In the event the Chief Compliance Officer
wishes to purchase IPOs or the securities of a private placement for his/her own employee account, the Chief
Compliance Officer must obtain prior written approval from Adviser’s Chief Operating Officer.
Review of Personal Securities Reports
The Chief Compliance Officer (or its 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 Adviser’s
duty to maintain and enforce its Code.
In instances when the Chief Compliance Officer has engaged in personal securities transaction, the Chief
Operating Officer shall review the Chief Compliance Officer’s brokerage statements and trade confirmations.
Outside Business Activities and Private Investments of Employees
Unless otherwise consented by the Chief Compliance Officer, all employees are required to devote their full time
and efforts Adviser’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 Adviser’s interests. Accordingly,
every employee is required to complete a disclosure form and have the form approved by Adviser’s 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 Adviser’s 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.
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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.
Recordkeeping
Adviser maintains the following:
§ Copies of the Code;
§ Records of violations of the Code and actions taken as a result of the violations;
§ Copies of Adviser’s supervised persons’ written acknowledgement of receipt of the Code;
§ Records of Access Persons’ personal trading — Initial Holdings Reports, Annual Holdings Reports, and
Quarterly Transaction Reports, including any information provided under Rule 204A-1(b)(3)(iii) in lieu of
such reports, i.e., brokerage confirmations and transaction reports;
§ A record of the names of Adviser’s “Access Persons”;
§ Records of decisions, and the reasons supporting the decision to approve an Access Person’s acquisition
of securities in initial public offerings or limited offerings; and
§ Records of decisions, and the reasons supporting the decision to approve the Chief Compliance Officer’s
acquisition of securities in initial public offerings or limited offerings.
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.
Training and Education
All Supervised Persons, i.e., all employees, are to receive training on complying with the Code on an annual basis
as part of Adviser’s annual employee compliance review meeting to ensure that all employees fully understand
their duties and obligations and how to comply with the Policy’s procedures.
Copies of Adviser’s Code
A copy of Adviser’s Code is available upon request. For a copy, please contact Adviser at (786) 315 - 4824 or to
rzamora@numaweb.com.
Participation or Interest in Client Transactions and Associated Conflicts of Interest
Adviser may recommend or invest in securities, including funds, issued or managed by its affiliates (or where the
affiliate acts as general partner) in which its affiliates have a material financial interest. Adviser has policies that
require personnel who develop advice and recommendations for clients to render only disinterested and impartial
advice to clients and to comply with other fiduciary obligations, including having an adequate basis in fact for all
recommendations and an obligation to recommend only investments that are suitable for the particular client.
The potential conflicts of interest involved in any such transactions are generally governed by Adviser’s Code.
Pursuant to the stipulations of the Code, Adviser or a related person may buy or sell for itself securities that it also
recommends to clients. The potential conflicts of interest involved in such transactions are governed by the Code,
which establishes sanctions if its requirements are violated and requires that Adviser and employees place the
interests of Adviser’s clients above their own.
Investments in Securities by Adviser and its Personnel
Adviser’s personnel or a related person of Adviser may invest in the same or similar securities and investments as
those recommended to or entered on behalf of Adviser’s clients. The results of the investment activities of
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Adviser’s personnel or related persons for their accounts may differ from the results achieved by or for client
accounts managed by Adviser. The conflicts raised by these circumstances are discussed below.
Adviser 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 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 Adviser’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 Adviser or related persons not pursued a particular
course of action with respect to the issuer of the securities. In addition, in certain instances Adviser’s personnel
may obtain information about the issuer that could limit the ability of such personnel to buy or sell securities of the
issuer on behalf of client accounts.
Transactions undertaken by Adviser’s clients may also adversely impact one or more client accounts. Other
clients of the Adviser may have, as a result of receiving client reports or otherwise, access to information
regarding Adviser’s transactions or views that may affect their transactions outside of accounts controlled by
Adviser, 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.
The results of the investment activities of a client’s account may differ significantly from the results achieved by
Advisers related persons and from the results achieved by Adviser for other client accounts.
As more fully described above, Adviser has adopted a Code of Ethics. Such Code of Ethics together with
Advisers policies and procedures restrict the ability of certain officers and employees of Adviser 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 Advisers
procedures and Code of Ethics minimize or eliminate conflicts of interest.
Trading Alongside by Adviser and its Personnel
Client accounts managed by Adviser may trade in the same or similar securities at or about the same time as
accounts managed or advised by affiliates of the Adviser. Investments by Adviser’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 Adviser’s affiliates. If a portfolio decision or strategy for Adviser’s affiliates’
accounts or the accounts of clients of affiliates is implemented ahead of, or contemporaneously with, similar
portfolio decisions or strategies for Adviser’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 Adviser will generally correct any such
errors that are the fault of the Adviser or an affiliate at no cost to the client, other than costs that the Adviser
deems immaterial. To the extent that the subsequent sale of such securities generates a profit to the Adviser, the
Adviser 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 Adviser will not be responsible for any errors that occur that are not the
fault of the Adviser or any affiliate.
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Privacy Policy
Adviser considers your privacy our utmost concern. Adviser does not share any information of clients with
nonaffiliated third parties, except such information may be disclosed as necessary 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.
When Adviser discloses non-public personal information of clients to a non-affiliated third party that provides
services to Adviser or engages in joint marketing, Adviser shall:
§ notify investors of the possibility of such disclosure; and
§ enter into a contractual agreement with the third party that prohibits the third party from disclosing or
using the investors’ information other than to carry out the purposes for which the information was
disclosed to the third party.
In particular, Adviser may enter, in compliance with the above conditions, into an agreement with a non-affiliated
third party to store the records of Adviser clients and investors including electronic and e-mail records.
For more information about Adviser’s privacy policies or to request a brochure describing Adviser’s privacy
policies contact Adviser at (786) 315-4824 or to rzamora@numaweb.com.
Item 12 - Brokerage Practices
As part of Numa’s relationship with its clients, its Investment Advisory Agreement provides that client may
restrict the discretion and direct brokerage to any broker. The Adviser is authorized in its Investment Advisory
Agreement to select other securities brokers, unless the client directs otherwise in the Agreement.
Typically, Numa considers which broker-dealer will be able to effect the transaction efficiently. Additionally,
the research and services provided by the broker-dealer with respect to the particular type of investment may
be a factor in the selection process. The commissions payable to such broker-dealers may in certain cases
be higher than those attainable from other broker-dealers who do not provide such research and services.
Ordinarily, such research will be used to service all of the Adviser's accounts. Under the Adviser’s standard
Investment Advisory Agreement, the client can revoke the Adviser's authority to select the broker-dealer for
the accounts.
It is Adviser’s policy not to enter into soft dollar arrangements and the Adviser has no formal soft dollar
arrangements. The Adviser does not consider, in selecting or recommending broker-dealers, whether the
Adviser or a related person receives Client referrals from such broker-dealer.
Brokerage for Client Referrals
Adviser does not direct brokerage to particular brokers in consideration for client referrals.
Item 13 - Review of Accounts
Accounts are typically reviewed by the Chief Compliance Officer of the Adviser on a quarterly basis or as needed
due to market conditions or transactional activity. The operations manager typically reviews daily the transactions
entered into for investment advisory clients to determine that correct entries have been made for all client records.
Factors Triggering a Review
There are no specific triggering factors leading to a review.
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Client Reports
Clients of the Adviser with discretionary accounts receive quarterly reports from their qualified Custodian. The
Adviser will also provide a performance report quarterly or as agreed between the Adviser and the client for
accounts managed on a discretionary basis.
Item 14 - Client Referrals and Other Compensation
Numa, from time to time, receives client referrals, and such referrals often come from current clients, attorneys,
accountants, employees, personal friends of employees and other similar sources. Furthermore, Numa does not
currently accept referral fees or any form of remuneration from other professionals when a prospect or client is
referred to them.
Item 15 - Custody
All assets are typically held at qualified custodians, which means the custodians provide account statements
directly to clients at their address of record at least quarterly. Therefore, aside from debiting fees from its clients'
accounts to pay for services rendered, Numa does not maintain custody of its clients’ funds. Clients receive
monthly or quarterly statements from the broker-dealer, bank or other qualified custodian that holds and maintains
the client’s investment assets.
Item 16 - Investment Discretion
Adviser receives discretionary authority from the client at the outset of an advisory relationship to select the
identity and amount of securities to be bought or sold. In all cases, however, such discretion is to be exercised in
a manner consistent with the stated investment objectives for the particular client account.
When selecting securities and determining amounts, Adviser observes the investment policies, limitations and
restrictions of the clients for which it advises. Investment guidelines and restrictions must be provided to Adviser
in writing.
Item 17 - Voting Client Securities
Numa does not vote proxies on securities, thus, clients are expected to vote their own proxies.
Item 18 - Financial Information
The Adviser has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to
clients. Also, Firm has not been the subject of a bankruptcy proceeding.
Item 19 – Business Continuity and Information Security
Business Continuity Plan
Numa has a Business Continuity Plan in place that provides detailed steps to mitigate and recover from the loss
of office space, communications, services or key persons. The Business Continuity Plan covers natural disasters
such as snowstorms, hurricanes, tornados, and flooding. The Plan covers man-made disasters such as loss of
electrical power, loss of water pressure, fire, bomb threat, nuclear emergency, chemical event, biological event, T-
1 communications line outage, Internet outage, railway accident and aircraft accident. Electronic files are backed
up daily and archived offsite.
Alternate offices are identified to support ongoing operations in the event the main office is unavailable. It is our
intention to contact all clients promptly after a disaster that dictates moving our office to an alternate location.
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Privacy and Information Security
Numa maintains an information security program to reduce the risk that your personal and confidential information
may be breached. Furthermore, Numa is committed to maintaining the confidentiality, integrity and security of the
personal information that is entrusted to us.
The categories of nonpublic information that we collect from you may include information about your personal
finances, information about your health to the extent that it is needed for the financial planning process,
information about transactions between you and third parties, and information from consumer reporting agencies,
e.g., credit reports. We use this information to help you meet your personal financial goals.
We maintain a secure office to ensure that your information is not placed at unreasonable risk. We employ a
firewall barrier and use other techniques and authentication procedures in our computer environment. We do not
provide your personal information to mailing list vendors or solicitors. We require strict confidentiality in our
agreements with unaffiliated third parties that require access to your personal information, including financial
service companies, consultants, and auditors. Federal and state securities regulators may review our Company
records and your personal records as permitted by law. Personally identifiable information about you will be
maintained while you are a client, and for the required period thereafter that records are required to be maintained
by federal and state securities laws. After that time, information may be destroyed.
We will notify you in advance if our privacy policy is expected to change. We are required by law to deliver this
Privacy Notice to you annually, in writing.
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FORM ADV PART 2B BROCHURE SUPPLEMENT
December 2024
This brochure supplement provides information about the supervised persons listed below that supplements the
Numa Americas Corp. brochure. You should have received a copy of that brochure. Please contact Rafael
Zamora (rzamora@numaweb.com) if you did not receive Numa Americas Corp’s brochure or if you have any
questions about the contents of this supplement.
List of Supervised Persons
Rafael Zamora León, Director
Numa Americas Corp.
1200 Brickell Avenue
Suite 1950
Miami, FL 33131
Telephone: (786) 315-4824
E-mail: rzamora@numaweb.com
Additional information about the above supervised persons is available on the SEC’s website at
www.adviserinfo.sec.gov.
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Rafael Zamora León, Director
Item 1 - Educational Background and Business Experience
Mr. Zamora has over 30 years’ experience in the structuring of innovative solutions through derivatives and
financial products since joining Bankers Trust in New York in 1992. Currently, Mr. Zamora is Head of
Development for wealth/asset management in Latin America, as well as representative of the subsidiary Nyx
Systems SAC. Previously, Mr. Zamora held positions as Senior Vice President at Banco de Credito del Peru,
Private Banking Division; Atlantic Security Bank, Senior Vice President, Head of Asset Management Division;
Van Eck Global, Managing Director, Latin American Business Development; Bankers Trust, Vice President.
Mr. Zamora holds an MBA from the Wharton School and a bachelor in Engineering from Monterrey Tech,
Mexico. Mr. Zamora was born in 1963.
Item 2 - 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 3 - Other Business Activities
Mr. Zamora is the Chairman and Director of Numa Asset Management (BVI) an affiliated offshore investment
adviser, member of the Board of Directors of Numa Insignia, SPC, Numa Defender Fixed Income Fund, Ltd. and
Numa Brigadier Stratego, Ltd, the latter funds are Cayman Islands exempted limited liability companies (“Numa
Funds”).
Item 4 - Additional Compensation
Mr. Zamora is compensated directly by the Adviser. Additionally, to his fixed annual salary, the board of directors
pays an annual bonus based on Numa´s profits, if any. Mr. Zamora may receive compensation from his outside
business activities.
Item 5 - Supervision
Individual(s) responsible for supervising the activities of Mr. Zamora is the Adviser’s Board Committee.
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