Overview

Assets Under Management: $117 million
Headquarters: FRISCO, TX
High-Net-Worth Clients: 53
Average Client Assets: $2 million

Services Offered

Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Institutional Clients, Pension Consulting, Investment Advisor Selection

Fee Structure

Primary Fee Schedule (WAVE WEALTH DISCLOSURE BROCHURE, BROCHURE SUPPLEMENTS, AND PRIVACY POLICY)

MinMaxMarginal Fee Rate
$0 $2,000,000 1.00%
$2,000,001 $5,000,000 0.80%
$5,000,001 $10,000,000 0.60%
$10,000,001 and above 0.40%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $10,000 1.00%
$5 million $44,000 0.88%
$10 million $74,000 0.74%
$50 million $234,000 0.47%
$100 million $434,000 0.43%

Clients

Number of High-Net-Worth Clients: 53
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 98.25
Average High-Net-Worth Client Assets: $2 million
Total Client Accounts: 458
Discretionary Accounts: 457
Non-Discretionary Accounts: 1

Regulatory Filings

CRD Number: 285079
Last Filing Date: 2025-02-06 00:00:00
Website: https://wavewealth.com

Form ADV Documents

Additional Brochure: WAVE WEALTH DISCLOSURE BROCHURE, BROCHURE SUPPLEMENTS, AND PRIVACY POLICY (2025-09-17)

View Document Text
Wave Wealth Management, LLC Form ADV Part 2A – Disclosure Brochure Effective: September 17, 2025 This Form ADV 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of Wave Wealth Management, LLC (“Wave Wealth” or the “Advisor”). If you have any questions about the contents of this Disclosure Brochure, please contact the Advisor at (972) 954-4100. Wave Wealth is a registered investment advisor registered with the U.S. Securities and Exchange Commission (“SEC”). The information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure Brochure provides information about Wave Wealth to assist you in determining whether to retain the Advisor. Additional information about Wave Wealth and its Advisory Persons is available on the SEC’s website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 285079. Wave Wealth Management, LLC 7000 Parkwood Blvd. Suite G300 Frisco, TX 75034 Phone: (972) 954-4100 I Fax: (972) 954-4106 www.wavewealth.com Item 2 – Material Changes Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. The Brochure Supplement provides information about Advisory Persons of Wave Wealth. For convenience, the Advisor combined these documents into a single disclosure document. Wave Wealth believes that communication and transparency are the foundation of its relationship with clients and will continually strive to provide you with complete and accurate information at all times. Wave Wealth encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Advisor. Material Changes The following material changes have been made to this Disclosure Brochure since the last annual amendment filing on February 6, 2025: ● The Advisor has added Securities Backed Lending/Lines of Credit as part of its service offering. Please see Item 4 and Item 8 regarding these changes. Future Changes From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in our business practices, changes in regulations, or routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if a material change occurs. At any time, you may view the current Disclosure Brochure online at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 285079. You may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at (972) 954-4100. Page 2 Wave Wealth Management, LLC 7000 Parkwood Blvd. Suite G300 Frisco, TX 75034 Phone: (972) 954-4100 I Fax: (972) 954-4106 www.wavewealth.com Item 3 – Table of Contents Item 1 – Cover Page Item 2 – Material Changes Item 3 – Table of Contents Item 4 – Advisory Services A. Firm Information B. Advisory Services Offered C. Client Account Management D. Wrap Fee Programs E. Assets Under Management Item 5 – Fees and Compensation A. Fees for Advisory Services B. Fee Billing C. Other Fees and Expenses D. Advance Payment of Fees and Termination E. Compensation for Sales of Securities Item 6 – Performance-Based Fees and Side-By-Side Management Item 7 – Types of Clients Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss A. Methods of Analysis B. Risk of Loss A. Code of Ethics B. Personal Trading with Material Interest C. Personal Trading in Same Securities as Clients D. Personal Trading at Same Time as Client Item 12 – Brokerage Practices A. Recommendation of Custodian[s] B. Aggregating and Allocating Trades Item 13 – Review of Accounts A. Frequency of Reviews B. Causes for Reviews C. Review Reports Item 14 – Client Referrals and Other Compensation A. Compensation Received by Wave Wealth B. Compensation for Client Referrals Item 15 – Custody Item 16 – Investment Discretion Item 17 – Voting Client Securities Item 18 – Financial Information Form ADV Part 2B – Brochure Supplement Privacy Policy 1 2 3 4 4 4 6 6 6 6 7 8 8 9 9 10 10 10 10 10 12 Item 9 – Disciplinary Information 12 Item 10 – Other Financial Industry Activities and Affiliations Item 11 – Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading 12 12 13 13 13 13 13 14 14 14 14 14 14 14 15 15 16 16 16 17 21 Page 3 Wave Wealth Management, LLC 7000 Parkwood Blvd. Suite G300 Frisco, TX 75034 Phone: (972) 954-4100 I Fax: (972) 954-4106 www.wavewealth.com Item 4 – Advisory Services A. Firm Information Wave Wealth Management, LLC (“Wave Wealth” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as a Limited Liability Company (“LLC”) under the laws of Texas. Wave Wealth was founded in July 2016 and is owned and operated by Benjamin A. Jones (President, Founder, and Chief Compliance Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and advisory services provided by Wave Wealth. B. Advisory Services Offered Wave Wealth offers investment advisory services to individuals, high-net-worth individuals, trusts, estates, charitable organizations, and retirement plans (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As such, each recommendation made as part of the advisory services is based on the belief that the recommendation is in the Client's best interest. Wave Wealth’s fiduciary commitment to each Client 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. Investment Management Services Wave Wealth provides customized investment management and advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary investment management and related advisory services. Wave Wealth provides a personalized and comprehensive investment portfolio solution by meeting and assessing the Client's unique situation. Then, given this information, Wave Wealth customizes a portfolio and crafts appropriate allocations into one of seven model portfolios for the Client’s portfolio. Internal Investment Management - As stated above, for investment portfolios managed internally, Wave Wealth will either customize a portfolio or craft appropriate allocations into one of ten model portfolios for the Client. The allocation of Client funds within these portfolios is designed to maximize client returns with an acceptable level of volatility based on our estimates of prospective returns to each component. Our ten model portfolios and customized portfolios consist of low-cost, diversified mutual funds and/or exchange-traded funds (“ETFs”) to achieve the Client’s investment goals. The Advisor may also utilize individual stocks, annuities, bonds, structured notes, and real estate investment trusts (“REITs”) to meet the needs of its Clients. The Advisor may retain certain types of investments from the Client’s legacy portfolio due to fit with the overall portfolio strategy, tax-related reasons, or other reasons as identified between the Advisor and the Client. Wave Wealth’s investment 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. Wave 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. Wave Wealth evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Wave Wealth may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Wave Wealth may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. Wave 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, changes in risk tolerance of Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. At no time will Wave Wealth accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within their designated account[s], pursuant to the Client investment management agreement; please see Item 12 – Brokerage Practices. Page 4 Wave Wealth Management, LLC 7000 Parkwood Blvd. Suite G300 Frisco, TX 75034 Phone: (972) 954-4100 I Fax: (972) 954-4106 www.wavewealth.com Retirement Plan 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 the 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 earns a new (or increases 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. Participant Account Management – As part of the Advisor’s investment management services, when appropriate, the Advisor will use a third-party platform to facilitate the management of held-away assets, such as defined contribution plan participant accounts, with investment discretion. The platform allows the Advisor to avoid being considered to have custody of Client funds since the Advisor does not have direct access to Client log-in credentials to affect trades. Wave Wealth is not affiliated with the platform in any way and receives no compensation from them for using their platform. A link will be provided to the Client, allowing the Client to connect an account[s] to the platform. Once the Client’s account[s] is connected to the platform, the Advisor will review the current account allocations. When deemed necessary, the Advisor will rebalance the account considering the Client’s investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account[s] will be reviewed at least quarterly, and allocation changes will be made as deemed necessary. Financial Planning Services Wave Wealth will typically provide a variety of financial planning and consulting services to Clients, either as a component of investment 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 involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting 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 or financial consultation rendered to 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, and establish education savings and/or charitable giving programs. Wave Wealth may also refer Clients to an accountant, attorney, or other specialists as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of the 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 the contract date, assuming all information and documents requested are provided promptly. Financial planning and consulting 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. Retirement Plan Advisory Services Wave Wealth provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include: Page 5 Wave Wealth Management, LLC 7000 Parkwood Blvd. Suite G300 Frisco, TX 75034 Phone: (972) 954-4100 I Fax: (972) 954-4106 www.wavewealth.com ● Vendor Analysis ● Plan Participant Enrollment and Education Tracking ● Investment Management Services (ERISA 3(38)) ● Performance Reporting ● Ongoing Investment Recommendations and Assistance Certain of these services are provided by Wave Wealth, serving in the capacity of a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of Wave Wealth’s fiduciary status, the specific services to be rendered, and all direct and indirect compensation the Advisor reasonably expects under the engagement. Use of Independent Managers Wave Wealth will recommend that Clients utilize one or more unaffiliated investment managers or investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment portfolio, based on the Client’s needs and objectives. In certain instances, the Client may be required to authorize and enter into an investment management agreement with the Independent Manager[s] that defines the terms in which the Independent Manager[s] will provide its services. The Advisor will perform initial and ongoing oversight and due diligence over each Independent Manager to ensure the strategy remains aligned with the Client’s investment objectives and overall best interests. The Advisor will also assist the Client in the development of the initial policy recommendations and managing the ongoing Client relationship. The Client will be provided with the Independent Manager's Form ADV Part 2A - Disclosure Brochure (or a brochure that makes the appropriate disclosures) prior to entering into an agreement with an Independent Manager. Non-Purpose Loans and Lines of Credit The Advisor may introduce certain Clients to US Bank Select, a non-purpose loan program made available through Charles Schwab & Co. Inc. and TriState (“Lending Program”). In such instances, the Client’s assets in their account[s] at the Custodian will be utilized as collateral for a non-purpose loan. The recommendation of a Lending Program presents a conflict of interest as the Advisor will continue to receive investment advisory fees for managing the collateralized assets in the Client’s account[s]. Clients are not obligated to engage the Advisor for the Lending Program. Additionally, the Advisor does not earn compensation on the Lending Program accounts For additional information related to the risks involved non-purpose loans and lines of credit, please see Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss. C. Client Account Management Prior to engaging Wave Wealth to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor that defines the terms, conditions, authority, and responsibilities of the parties. These services may include: ● Establishing an Investment Strategy – Wave Wealth, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives. ● Portfolio Construction/Model Portfolio – Wave Wealth will either develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client or place Client assets in a model portfolio that is targeted to meet the investment objectives, time horizon, financial situation and tolerance of risk for each Client. ● Investment Management and Supervision – Wave Wealth will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs Wave Wealth does not manage or place Client assets into a wrap fee program. E. Assets Under Management As of December 31, 2024, the Advisor manages $116,576,041 in Client assets, $115,763,485 of which are managed on a discretionary basis and $812,556 on a non-discretionary basis. Clients may request more current information at any time by contacting the Advisor. Page 6 Wave Wealth Management, LLC 7000 Parkwood Blvd. Suite G300 Frisco, TX 75034 Phone: (972) 954-4100 I Fax: (972) 954-4106 www.wavewealth.com Item 5 – Fees and Compensation The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into one or more written agreements with the Advisor. A. Fees for Advisory Services Investment Management Services Investment management fees are paid quarterly, in advance of each calendar quarter, pursuant to the terms of the investment management agreement. Investment management fees are based on the market value of assets under management at the end of the prior quarter and in accordance with the following schedule: Assets Under Management ($) Up to $2,000,000 $2,000,001 to $5,000,000 $5,000,001 to $10,000,000 $10,000,001 and Above Annual Rate (%) 1.00% 0.80% 0.60% 0.40% Direct Indexing – For Clients selecting to utilize the Direct Indexing account option, there is an additional 0.50% fee for assets invested within the product. Specific accounts that utilize the Direct Indexing account feature will be further outlined on the Client agreement. In certain cases, the Client’s investment management fees are based on a grandfathered tier schedule, outlined in the Client’s agreement. The investment management fee in the first quarter of service is prorated from the inception date of the account[s] to the end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into consideration the aggregate assets under management with the Advisor. All securities held in accounts managed by Wave Wealth will be independently valued by the Custodian. Wave Wealth will conduct periodic reviews of the Custodian’s valuations. The Advisor’s fee is exclusive of, and in addition to, brokerage fees, transaction fees, and other related costs and expenses which may be incurred by the Client. However, the Advisor shall not receive any portion of these commissions, fees, and costs. Financial Planning Services Wave Wealth offers ongoing, standalone financial planning services for an annual fee ranging up to $10,000 a year. Financial planning fees are determined based on the nature and complexity of the services to be provided and the overall relationship with the Advisor. Fees are negotiable at the Advisor’s sole discretion. Retirement Plan Advisory Services Fees for retirement plan advisory services are charged an annual asset-based fee of up to 1.00%, billed in advance of each calendar quarter, pursuant to the terms of the retirement plan advisory agreement. Retirement plan advisory fees are based on the market value of assets under management at the end of the prior quarter. Fees may be negotiable depending on the size and complexity of the Plan, and certain existing Clients may have fee schedules that differ from the schedule below. Retirement plan advisory fees are generally based on the following schedule: Assets Under Management ($) Up to $2,000,000 $2,000,001 to $5,000,000 $5,000,001 to $10,000,000 $10,000,001 and Above Annual Rate (%) 1.00% 0.80% 0.60% 0.40% Page 7 Wave Wealth Management, LLC 7000 Parkwood Blvd. Suite G300 Frisco, TX 75034 Phone: (972) 954-4100 I Fax: (972) 954-4106 www.wavewealth.com In certain cases, the Client’s fees for retirement plan advisory services are based on a grandfathered tier schedule, outlined in the Client’s agreement. Use of Independent Managers As noted in Item 4, the Advisor will implement all or a portion of a Client’s investment portfolio utilizing one or more Independent Managers. To eliminate any conflict of interest, the Advisor does not earn any compensation from an Independent Manager. The Advisor will only earn its investment advisory fee as described above. Independent Managers typically do not offer any fee discounts but may have a breakpoint schedule that will reduce the fee with an increased level of assets placed under management with an Independent Manager. The terms of such fee arrangements are included in the Independent Manager’s disclosure brochure and applicable contract[s] with the Independent Manager. The total blended fee, including the Advisor’s fee and the Independent Manager’s fee, will not exceed 2.50% annually. B. Fee Billing Investment Management Services Investment advisory fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at the Custodian. The Advisor or its delegate shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s account[s] at the beginning of each quarter. The amount due is calculated by applying the quarterly rate (annual rate/days in a year, multiplied by the days in the quarter) to the total assets under management with Wave Wealth at the end of the prior quarter. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting the deduction of the investment advisory fee. In addition, the Advisor will provide the Client with a report itemizing the fee, including the calculation period covered by the fee, the account value, and the methodology used to calculate the fee. It is the responsibility of the Client to verify the accuracy of these fees as listed on the Custodian’s brokerage statement, as the Custodian does not assume this responsibility. Clients provide written authorization permitting advisory fees to be deducted by Wave Wealth directly from their account[s] held by the Custodian as part of the investment management agreement and separate account forms provided by the Custodian. Financial Planning Services Annual retainer financial planning fees are invoiced by the Advisor either monthly or quarterly, in advance of each month or quarter. Retirement Plan Advisory Services Fees may be directly invoiced to the Plan Sponsor or deducted from the assets of the Plan, depending on the terms of the retirement plan advisory agreement. Use of Independent Managers For Client accounts implemented through an Independent Manager, the Client’s overall fees may include Wave Wealth’s investment advisory fee (as noted above) plus investment management fees and/or platform fees charged by the Independent Manager[s], as applicable. In certain instances, the Independent Manager or the Advisor may assume responsibility for calculating the Client’s fees and deduct all fees from the Client’s account[s]. C. Other Fees and Expenses Clients may incur certain fees or charges imposed by third parties other than Wave Wealth in connection with investments made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities execution fees charged by the Custodian, if applicable. The Advisor's recommended Custodian does not charge securities transaction fees for ETF and equity trades in Client accounts but typically charges for mutual funds and other types of investments. The investment management fee charged by Wave Wealth is separate and distinct from these custody and execution fees. In addition, all fees paid to Wave Wealth for investment advisory services are separate and distinct from the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage, and account reporting), and a possible distribution fee. A Client may be able to invest in these products directly, without the services of Wave Wealth, but would not receive the services provided by Wave Wealth which are designed, among other things, to Page 8 Wave Wealth Management, LLC 7000 Parkwood Blvd. Suite G300 Frisco, TX 75034 Phone: (972) 954-4100 I Fax: (972) 954-4106 www.wavewealth.com assist the Client in determining which products or services are most appropriate for each Client’s financial situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by Wave Wealth to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information. D. Advance Payment of Fees and Termination Investment Management Services Wave Wealth is compensated for its investment management services at the beginning of the quarter before services are rendered. Either party may terminate the investment management agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the investment management agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five- day period, the Client will incur charges for bona fide advisory services rendered to the point of termination, and such fees will be due and payable by the Client. Upon termination, the Advisor will refund any unearned, prepaid investment management fees from the effective date of termination. The Client’s investment management agreement with the Advisor is non-transferable without the Client’s prior consent. Financial Planning Services Wave Wealth requires an advance deposit as described above. For retainer engagements, Wave Wealth is compensated monthly or quarterly in advance. Either party may terminate the financial planning agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the financial planning agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination, and such fees will be due and payable by the Client. In the case of a fixed fee engagement, the percentage of the engagement scope completed by the Advisor. For retainer Clients, the Client will be billed for the portion of the month or quarter in which services were provided. The Advisor will refund any unearned, prepaid planning fees from the effective date of termination. The Client’s financial planning agreement with the Advisor is non- transferable without the Client’s prior consent. Retirement Plan Advisory Services Wave Wealth is compensated for its retirement plan advisory services in advance of the quarter in which services are rendered. Either party may terminate the retirement plan advisory agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the retirement advisory agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination, and such fees will be due and payable by the Client. Upon termination, the Advisor will refund any unearned, prepaid advisory fees from the effective date of termination. The Client’s retirement plan advisory agreement with the Advisor is non- transferable without the Client’s prior consent. Use of Independent Managers In the event that the Advisor has determined that an Independent Manager is no longer in the Client’s best interest, or a Client should wish to terminate their relationship with the Independent Manager, the terms for the termination will be set forth in the respective agreements between the Client or the Advisor and the Independent Manager. Wave Wealth will assist the Client with the termination and transition as appropriate. E. Compensation for Sales of Securities Wave Wealth does not buy or sell securities to earn commissions and does not receive any compensation for securities transactions in any Client account other than the investment advisory fees noted above. Insurance Agency Affiliations Certain Advisory Persons are also licensed as independent insurance professionals. These persons will earn commission-based compensation for selling insurance products, including insurance products they sell to Clients. Insurance commissions earned by these persons are separate and in addition to advisory fees. This practice presents a conflict of interest because persons providing investment advice on behalf of the Advisor, who are insurance agents, have an incentive to recommend insurance products to Clients for the purpose of generating commissions rather than solely based on Client needs. However, Clients are under no obligation, contractually or Page 9 Wave Wealth Management, LLC 7000 Parkwood Blvd. Suite G300 Frisco, TX 75034 Phone: (972) 954-4100 I Fax: (972) 954-4106 www.wavewealth.com otherwise, to purchase insurance products through any person affiliated with the Advisor. Please see Item 10 – Other Financial Industry Activities and Affiliations. Item 6 – Performance-Based Fees and Side-By-Side Management Wave Wealth does not charge performance-based fees for its investment advisory services. The fees charged by Wave Wealth are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by any Client. Wave Wealth does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients. Item 7 – Types of Clients Wave Wealth offers investment advisory services to individuals, high-net-worth individuals, trusts, estates, charitable organizations, and retirement plans. The amount of each type of Client is available on the Advisor’s Form ADV Part 1A. These amounts may change over time and are updated at least annually by the Advisor. Wave Wealth generally does not impose a minimum size for establishing a relationship. Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss A. Methods of Analysis Wave Wealth primarily employs a fundamental analysis method in developing investment strategies for its Clients. In addition, the Advisor may also utilize technical and cyclical analysis methods in developing investment strategies for its Clients. Research and analysis from Wave Wealth are derived from numerous sources, including financial media companies, third-party research materials, Internet sources, and reviews of company activities, including annual reports, prospectuses, press releases, and research prepared by others. Fundamental analysis utilizes economic and business indicators as investment selection criteria. These criteria are generally ratios and trends that may indicate the overall strength and financial viability of the entity being analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with a value discounted by the market. While this type of analysis helps the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the fundamental analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Technical analysis involves the analysis of past market data rather than specific company data in determining the recommendations made to clients. Technical analysis may involve the use of charts to identify market patterns and trends, which may be based on investor sentiment rather than the fundamentals of the company. The primary risk in using technical analysis is that spotting historical trends may not help to predict such trends in the future. Even if the trend will eventually reoccur, there is no guarantee that Wave Wealth will be able to accurately predict such a reoccurrence. Cyclical analysis is similar to technical analysis in that it involves the analysis of market conditions at a macro (entire market/economy) or micro (company specific) level rather than the overall fundamental analysis of the health of the particular company that Wave Wealth is recommending. The risks with cyclical analysis are similar to those of technical analysis. As noted above, Wave Wealth generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. Wave Wealth will typically hold all or a portion of a security for more than a year but may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, Wave Wealth may also buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the fundamentals of the security, sector, or asset class. Page 10 Wave Wealth Management, LLC 7000 Parkwood Blvd. Suite G300 Frisco, TX 75034 Phone: (972) 954-4100 I Fax: (972) 954-4106 www.wavewealth.com B. Risk of Loss Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should be prepared to bear the potential risk of loss. Wave Wealth will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their investment goals. While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon, tolerance for risk, and other factors to develop an appropriate strategy for managing a Client's account. Client participation in this process, including full and accurate disclosure of requested information, is essential for the analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals, or other factors that may affect this analysis. The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process. Following are some of the risks associated with the Advisor’s investment approach: Market Risks The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall financial markets. ETF Risks The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs have a large bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. Options Contracts 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. Bond Risks Bonds are subject to specific risks, including the following: (1) interest rate risks, i.e., the risk that bond prices will fall if interest rates rise, and vice versa; the risk depends on two things, the bond’s time to maturity and the coupon rate of the bond. (2) reinvestment risk, i.e., the risk that any profit gained must be reinvested at a lower rate than was previously being earned, (3) inflation risk, i.e., the risk that the cost of living and inflation increase at a rate that exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e., the risk associated with purchasing a debt instrument which includes the possibility of the company defaulting on its repayment obligation, (5) rating downgrades, i.e., the risk associated with a rating agency’s downgrade of the company’s rating which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity Risks, i.e., the risk that a bond may not be sold as quickly as there is no readily available market for the bond. Page 11 Wave Wealth Management, LLC 7000 Parkwood Blvd. Suite G300 Frisco, TX 75034 Phone: (972) 954-4100 I Fax: (972) 954-4106 www.wavewealth.com Mutual Fund Risks The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual fund is typically set daily; therefore, a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day. Margin Borrowings The use of short-term margin borrowings may result in certain additional risks to a Client. For example, if securities pledged to brokers to secure a Client's margin accounts decline in value, the Client could be subject to a "margin call," pursuant to which it must either deposit additional funds with the broker or be the subject of mandatory liquidation of the pledged securities to compensate for the decline in value. Real Estate Investment Trusts Investing in REITs involves certain distinct risks, in addition to those risks associated with investing in the real estate industry in general. For example, 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 (i.e., as interest rates rise, the value of the REIT may decline). Structured Products Structured notes are not bank deposits and are not insured by the Federal Deposit Insurance Corporation or any other governmental agency. The terms and risks of each structured note vary materially depending on the nature and volatility of the referenced asset, the creditworthiness of the issuer, and the maturity of the instrument, among other factors. The general risks associated with this type of investment include, but are not limited to, non-payment risk (payment of interest and return of principal may be reduced, in whole or in part, due to underperformance of the referenced asset); counter-party risk (for reasons such as bankruptcy, the issuer of the structured note may fail to pay all or a portion of the principal and interest due on the structured note); underperformance risk (the structured note may underperform alternative allocations to traditional bonds, the referenced asset, or a combination of such investments, depending on market conditions). Structured notes are significantly riskier than conventional debt instruments. There is a risk of loss of some or all of the principal at maturity. Non-Purpose Loans and Lines of Credit Non-purpose loans and lines of credit carry a number of 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]. Past performance is not a guarantee of future returns. Investing in securities and other investments involves a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with the Advisor. Item 9 – Disciplinary Information its Advisor Persons are available on the There are no legal, regulatory, or disciplinary events involving Wave Wealth or its owner. Wave Wealth and its Supervised Persons value the trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence on any advisor or service provider The Client engages. The backgrounds of the Advisor and Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 285079. Item 10 – Other Financial Industry Activities and Affiliations Insurance Agency Affiliations As noted in Item 5, Advisory Persons are also licensed insurance professionals. Implementations of insurance recommendations are separate and apart from the advisory services provided by Wave Wealth. As an insurance Page 12 Wave Wealth Management, LLC 7000 Parkwood Blvd. Suite G300 Frisco, TX 75034 Phone: (972) 954-4100 I Fax: (972) 954-4106 www.wavewealth.com professional, the Advisory Person will receive customary commissions and other related revenues from the various insurance companies whose products are sold. Wave Wealth is not required to offer the products of any particular insurance company. Commissions generated by insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in recommending certain products of insurance companies. Clients are under no obligation to implement any recommendations made by Advisory Persons or the Advisor. Wave Wealth also mitigates this by having insurance commissions paid to the firm and not to the individual Advisory Person. Tax Preparation and Bookkeeping Services Wave Wealth also offers tax preparation and bookkeeping services. Clients are advised that these services are separate and distinct from the Advisory services rendered by the Advisor and are provided for an additional fee. This creates a conflict of interest because the Advisor has an incentive to recommend these services to Clients due to the receipt of additional compensation received by the Advisor. However, Clients are not obligated to engage Wave Wealth for these services in order to maintain a relationship with the Advisor. Item 11 – Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading A. Code of Ethics Wave Wealth has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each Client. This Code applies to all persons associated with Wave Wealth (“Supervised Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to the Client. Mr. Jones owes a duty of loyalty, fairness, and good faith towards each Client. It is the obligation of Wave Wealth and its Supervised Persons to adhere not only to the specific provisions of the Code but also to the general principles that guide the Code. The Code covers a range of topics that address employee ethics and conflicts of interest. To request a copy of the Code, please contact the Advisor at (972) 954-4100. B. Personal Trading with Material Interest Wave Wealth allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Wave Wealth does not act as a principal in any transactions. In addition, the Advisor does not act as the general partner of a fund or advise an investment company. Wave Wealth does not have a material interest in any securities traded in Client accounts. C. Personal Trading in Same Securities as Clients Wave Wealth allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities recommended (purchase or sell) to Clients presents a conflict of interest that, as fiduciaries, the Advisor must disclose to Clients and mitigate through policies and procedures. As noted above, the Advisor has adopted the Code to address insider trading (material, nonpublic information controls); gifts and entertainment; outside business activities, and personal securities reporting. When trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more advantageous terms than Client trades or by trading based on material, nonpublic information. This risk is mitigated by the Advisor requiring reporting of personal securities trades by its employees for review by the Chief Compliance Officer (“CCO”). The Advisor has also adopted written policies and procedures to detect the misuse of material, nonpublic information. In addition, the Code governs Gifts and Entertainment given by and provided to the Advisor, outside employment activities of Supervised Persons, Employee reporting, sanctions for violations of the Code and records retention requirements for various aspects of the Code. D. Personal Trading at Same Time as Client Wave Wealth allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterward. At no time will Wave Wealth, or any Supervised Person of Wave Wealth, transact in any security to the detriment of any Client. Page 13 Wave Wealth Management, LLC 7000 Parkwood Blvd. Suite G300 Frisco, TX 75034 Phone: (972) 954-4100 I Fax: (972) 954-4106 www.wavewealth.com Item 12 – Brokerage Practices A. Recommendation of Custodian[s] Wave Wealth does not have discretionary authority to select the broker-dealer/custodian for custody and execution services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets and authorize Wave Wealth to direct trades to the Custodian as agreed upon in the investment management agreement. Further, Wave Wealth does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-by-trade basis. Where Wave Wealth does not exercise discretion over the selection of the Custodian, it may recommend the Custodian to Clients for custody and execution services. Clients are not obligated to use the recommended Custodian and will not incur any extra fee or cost associated with using a custodian not recommended by Wave Wealth. However, if the recommended Custodian is not engaged, Wave Wealth may be limited in the services it can provide. Wave Wealth will generally recommend that Clients establish their account[s] at Charles Schwab & Co., Inc. (“Schwab”), a FINRA-registered broker-dealer and member SIPC. Schwab will serve as the Client’s “qualified custodian”. Wave Wealth maintains an institutional relationship with Schwab, whereby the Advisor receives economic benefits from Schwab (Please see Item 14 below.) 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. 2. Brokerage Referrals – Wave Wealth does not receive any compensation from any third party in connection with the recommendation for establishing an account. 3. Directed Brokerage – All Clients are serviced on a “directed brokerage basis,” where Wave Wealth will place trades within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are traded within their respective account[s]. The Advisor will not engage in any principal transactions (i.e., trade of any security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a security into one Client account from another Client’s account[s]). Wave Wealth 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 Custodian. B. Aggregating and Allocating Trades The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the Custodian. Wave Wealth will execute its transactions through the Custodian as directed by the Client. Wave Wealth may aggregate orders in a block trade or trades when securities are purchased or sold through the Custodian for multiple (discretionary) accounts on the same trading day. If a block trade cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each business day must be allocated in a manner that is consistent with the initial pre-allocation or other written statement. This must be done in a way that does not consistently advantage or disadvantage any particular Client accounts. Item 13 – Review of Accounts A. Frequency of Reviews Securities in Client account[s] are monitored on a regular and continuous basis by Mr. Jones, CCO of Wave Wealth. Formal reviews are generally conducted at least annually or more frequently depending on the needs of the Client. Page 14 Wave Wealth Management, LLC 7000 Parkwood Blvd. Suite G300 Frisco, TX 75034 Phone: (972) 954-4100 I Fax: (972) 954-4106 www.wavewealth.com B. Causes for Reviews In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least annually. Reviews may be conducted more or less frequently at the Client’s request. Accounts may be reviewed as a result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify Wave Wealth if changes occur in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be triggered by material market, economic or political events. C. Review Reports The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage statements will include all positions, transactions, and fees relating to the Client’s account[s]. The Advisor may also provide Clients with periodic reports regarding their holdings, allocations, and performance. Item 14 – Client Referrals and Other Compensation A. Compensation Received by Wave Wealth Wave Wealth does not receive commissions or other compensation from product sponsors, broker-dealers, or any unrelated third party. Wave Wealth may refer Clients to various unaffiliated, non-advisory professionals (e.g., attorneys, accountants, estate planners) to provide certain financial services necessary to meet the goals of its Clients. Likewise, Wave Wealth may receive non-compensated referrals of new Clients from various third parties. Participation in Institutional Advisor Platform Wave Wealth has established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a division of Schwab dedicated to serving independent advisory firms like Wave Wealth. As a registered investment advisor participating on the Schwab Advisor Services platform, Wave Wealth receives access to software and related support without cost because the Advisor renders investment management services to Clients that maintain assets at Schwab. Services provided by Schwab Advisor Services benefit the Advisor and many, but not all services provided by Schwab will benefit Clients. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a custodian creates a potential conflict of interest since these benefits may influence the Advisor's recommendation of this custodian over one that does not furnish similar software, systems support, or services. Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of Client’s funds and securities. Through Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be able to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual funds and other investments without having to adhere to investment minimums that might be required if the Client were to directly access the investments. Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to technology, research, discounts and other services. In addition, the Advisor receives duplicate statements for Client accounts, the ability to deduct advisory fees, trading tools, and back office support services as part of its relationship with Schwab. These services are intended to assist the Advisor in effectively managing accounts for its Clients, but may not directly benefit all Clients. Services that May Only Benefit the Advisor – Schwab also offers other services to Wave Wealth that may not benefit the Client, including: educational conferences and events, financial start-up support, consulting services and discounts for various service providers. Access to these services creates a financial incentive for the Advisor to recommend Schwab, which results in a potential conflict of interest. Wave Wealth believes, however, that the selection of Schwab as Custodian is in the best interests of its Clients. B. Compensation for Client Referrals Page 15 Wave Wealth Management, LLC 7000 Parkwood Blvd. Suite G300 Frisco, TX 75034 Phone: (972) 954-4100 I Fax: (972) 954-4106 www.wavewealth.com Wave Wealth does not compensate, either directly or indirectly, any persons who are not supervised persons for Client referrals. Item 15 – Custody Wave Wealth does not accept or maintain custody of any Client accounts except for the limited circumstances outlined below: Deduction of Advisory Fees - To ensure compliance with regulatory requirements associated with the deduction of advisory fees, all Clients for whom Wave Wealth exercises discretionary authority must hold their assets with a "qualified custodian." Clients are responsible for engaging a “qualified custodian” to safeguard their funds and securities and must instruct Wave Wealth to utilize that Custodian for securities transactions on their behalf. Clients are encouraged to review statements provided by the Custodian and compare to any reports provided by Wave Wealth to ensure accuracy, as the Custodian does not perform this review. For more information about custodians and brokerage practices, see Item 12 – Brokerage Practices. Money Movement Authorization - For instances where Clients authorize Wave Wealth to move funds between their accounts, Wave Wealth and the Custodian have implemented safeguards to ensure that all money movement activities are conducted strictly in accordance with the Client’s documented instructions. Item 16 – Investment Discretion Wave Wealth generally has discretion over the selection and amount of securities to be bought or sold in Client accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by Wave Wealth. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will be evidenced by the Client's execution of an investment management agreement containing all applicable limitations to such authority. All discretionary trades made by Wave Wealth will be in accordance with each Client's investment objectives and goals. Item 17 – Voting Client Securities Wave Wealth does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the Custodian. The Advisor will assist in answering questions relating to proxies; however, the Client retains the sole responsibility for proxy decisions and voting. Item 18 – Financial Information Neither Wave Wealth nor Mr. Jones has any adverse financial situations that would reasonably impair the ability of Wave Wealth to meet all obligations to its Clients. Neither Wave Wealth nor any of its Advisory Persons have been subject to a bankruptcy or financial compromise. Wave Wealth is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect fees of $ 1,2 00 or more for services to be performed six months or more in advance. Page 16 Wave Wealth Management, LLC 7000 Parkwood Blvd. Suite G300 Frisco, TX 75034 Phone: (972) 954-4100 I Fax: (972) 954-4106 www.wavewealth.com Form ADV Part 2B – Brochure Supplement for Benjamin A. Jones, CFP®, CIMA®, CPWA®, EA President, Founder, and Chief Compliance Officer Effective: September 17, 2025 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Benjamin A. Jones, CFP®, CIMA®, CPWA®, EA (CRD# 5091560), in addition to the information contained in the Wave Wealth Management, LLC (“Wave Wealth” or the “Advisor,” CRD # 285079) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the Wave Wealth Disclosure Brochure or this Brochure Supplement, please contact the Advisor at (972) 954-4100. Additional information about Mr. Jones is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or CRD# 5091560. Page 17 Wave Wealth Management, LLC 7000 Parkwood Blvd. Suite G300 Frisco, TX 75034 Phone: (972) 954-4100 I Fax: (972) 954-4106 www.wavewealth.com Item 2 – Educational Background and Business Experience Benjamin A. Jones, CFP®, CIMA®, CPWA®, EA, born in 1984, is dedicated to advising Clients of Wave Wealth as the President, Founder, and Chief Compliance Officer. Mr. Jones earned a Bachelor of Science degree in Financial Planning from Texas Tech University in 2004. Additional information regarding Mr. Jones’ employment history is included below. Employment History: President, Founder, and Chief Compliance Officer, Wave Wealth Management, LLC Financial Advisor, Ameriprise Financial Services Financial Advisor, VSR Advisory Services, Inc. Financial Advisor, VSR Financial Services, Inc. Financial Advisor, Vision Wealth Management, Inc. 07/2016 to Present 03/2012 to 09/2016 04/2008 to 03/2012 01/2008 to 03/2012 07/2006 to 03/2012 Certified Financial Planner ("CFP®") The CERTIFIED FINANCIAL PLANNER™, CFP®, and federally registered CFP® marks (collectively, the “CFP® marks”) are professional certification marks granted in the United States by the Certified Financial Planner Board of Standards, Inc. (“CFP® Board”). The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial planners to hold CFP® certification. It is recognized in the United States and a number of other countries for its (1) high standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical requirements that govern professional engagements with clients. Currently, more than 95,000 individuals have obtained CFP® certification in the United States. To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements: ● Education – Complete an advanced college-level course of study addressing the financial planning subject areas that CFP® Board’s studies have determined as necessary for the competent and professional delivery of financial planning services, and attain a Bachelor’s Degree from a regionally accredited United States college or university (or its equivalent from a foreign university). CFP® Board’s financial planning subject areas include insurance planning and risk management, employee benefits planning, investment planning, income tax planning, retirement planning, and estate planning; ● Examination – Pass the comprehensive CFP® Certification Examination. The examination, administered in 10 hours over a two-day period, includes case studies and client scenarios designed to test one’s ability to correctly diagnose financial planning issues and apply one’s knowledge of financial planning to real- world circumstances; ● Experience – Complete at least three years of full-time financial planning-related experience (or the equivalent, measured as 2,000 hours per year); and ● Ethics – Agree to be bound by the CFP® Board’s Standards of Professional Conduct, a set of documents outlining the ethical and practice standards for CFP® professionals. Individuals who become certified must complete the following ongoing education and ethics requirements in order to maintain the right to continue to use the CFP® marks: ● Continuing Education – Complete 30 hours of continuing education hours every two years, including two hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain competence and keep up with developments in the financial planning field; and ● Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The Standards prominently require that CFP® professionals provide financial planning services at a fiduciary standard of care. This means CFP® professionals must provide financial planning services in the best interests of their clients. CFP® professionals who fail to comply with the above standards and requirements may be subject to the CFP® Board’s enforcement process, which could result in suspension or permanent revocation of their CFP® certification. Page 18 Wave Wealth Management, LLC 7000 Parkwood Blvd. Suite G300 Frisco, TX 75034 Phone: (972) 954-4100 I Fax: (972) 954-4106 www.wavewealth.com Certified Investment Management AnalystSM (CIMA®) The CIMA® certification signifies that an individual has met initial ongoing experience, ethical, education, and examination requirements for investment management consulting, including advanced investment management theory and application. Prerequisites for the CIMA® certification are three years of financial services experience and an acceptable regulatory history. To obtain the CIMA® certification, candidates must pass an online Qualification Examination, successfully complete a one-week classroom education program provided by a Registered Education Provider at an AACSB-accredited university business school, pass an online Certification Examination, and have an acceptable regulatory history as evidenced by FINRA Form U-4 or other regulatory requirements. CIMA® designees are required to adhere to IMCA’s Code of Professional Responsibility, Standards of Practice, and Rules and Guidelines for the use of the Marks. CIMA® designees must report 40 hours of continuing education credits, including two ethics hours, every two years to maintain the certification. The designation is administered through Investment Management Consultants Association (IMCA). The CIMA® certification has earned ANSI® (American National Standards Institute) accreditation under the personnel certification program. The American National Standards Institute, or ANSI®, is a private non-profit organization that facilitates standardization and conformity assessment activities in the United States. CIMA® is the first financial services credential to meet this international standard for personnel certification. Certified Private Wealth Advisor® (CPWA®) The CPWA® designation signifies that an individual has met initial and ongoing experience, ethical, education, and examination requirements for the professional designation, which is centered on private wealth management topics and strategies for high-net-worth clients. Prerequisites for the CPWA® designation are a Bachelor’s degree from an accredited college or university or one of the following designations or licenses: CIMA®, CIMC®, CFA®, CFP®, ChFC®, or CPA license; have an acceptable regulatory history as evidenced by FINRA Form U-4 or other regulatory requirements and five years of professional client-centered experience in financial services or a related industry. CPWA® designees have completed a rigorous educational process that includes self-study requirements, an in-class education component, and successful completion of a comprehensive examination. CPWA® designees are required to adhere to IMCA’s Code of Professional Responsibility and Rules and Guidelines for the use of the Marks. CPWA® designees must report 40 hours of continuing education credits, including two ethics hours, every two years to maintain the certification. The designation is administered through Investment Management Consultants Association (IMCA). Enrolled Agent (EA) An enrolled agent (EA) is a federally-authorized tax practitioner who has technical expertise in the field of taxation and who is empowered by the U.S. Department of the Treasury to represent taxpayers before all administrative levels—examination, collection, and appeals—of the Internal Revenue Service. In addition to taxpayer representation, enrolled agents often provide tax consultation services and prepare a wide range of federal and state tax returns. Item 3 – Disciplinary Information There are no legal, civil, or disciplinary events to disclose regarding Mr. Jones. Mr. Jones 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. Jones. Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil, or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil, or disciplinary events to disclose regarding Mr. Jones. However, the Advisor encourages Clients to independently view the background of Mr. Jones on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or individual CRD# 5091560. Page 19 Wave Wealth Management, LLC 7000 Parkwood Blvd. Suite G300 Frisco, TX 75034 Phone: (972) 954-4100 I Fax: (972) 954-4106 www.wavewealth.com Item 4 – Other Business Activities Insurance Agency Affiliations Mr. Jones is also a licensed insurance professional. Implementations of insurance recommendations are separate and apart from Mr. Jones’ role with Wave Wealth. As an insurance professional, Mr. Jones will receive customary commissions and other related revenues from the various insurance companies whose products are sold. Mr. Jones is not required to offer the products of any particular insurance company. Commissions generated by insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in recommending certain products of insurance companies. Clients are under no obligation to implement any recommendations made by Mr. Jones or the Advisor. Item 5 – Additional Compensation Mr. Jones has additional business activities where compensation is received that are detailed in Item 4 above. Item 6 – Supervision Mr. Jones serves as the President, Founder, and Chief Compliance Officer of Wave Wealth. Mr. Jones can be reached at (972) 954-4100. Wave Wealth has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of Wave Wealth. Further, Wave Wealth is subject to regulatory oversight by various agencies. These agencies require registration by Wave Wealth and its Supervised Persons. As a registered entity, Wave Wealth is subject to examinations by regulators, which may be announced or unannounced. Wave Wealth is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor. Page 20 Wave Wealth Management, LLC 7000 Parkwood Blvd. Suite G300 Frisco, TX 75034 Phone: (972) 954-4100 I Fax: (972) 954-4106 www.wavewealth.com Form ADV Part 2B – Brochure Supplement for Matthew D. Madison, RFC® Associate Wealth Manager Effective: September 17, 2025 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Matthew D. Madison, RFC®, (CRD# 7564492) in addition to the information contained in the Wave Wealth Management, LLC (“Wave Wealth” or the “Advisor”, CRD# 285079) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the Wave Wealth Disclosure Brochure or this Brochure Supplement, please contact us at (972) 954-4100. Additional information about Mr. Madison 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# 7564492. Page 21 Wave Wealth Management, LLC 7000 Parkwood Blvd. Suite G300 Frisco, TX 75034 Phone: (972) 954-4100 I Fax: (972) 954-4106 www.wavewealth.com Item 2 – Educational Background and Business Experience Matthew D. Madison, RFC®, born in 1998, is dedicated to advising Clients of Wave Wealth as an Associate Wealth Manager Mr. Madison earned a Masters of Education, Curriculum and Instruction from Texas A&M University in 2022. Mr. Madison also earned a Bachelor of Arts in English from Texas A&M University in 2020. Additional information regarding Mr. Madison’s employment history is included below. Employment History: Associate Wealth Manager, Wave Wealth Management, LLC Registered Representative, Ameriprise Financial Services, LLC Registered Representative, NYLIFE Securities LLC Agent, New York Life Insurance Company Teacher, Cy-Fair Highschool 09/2025 to Present 09/2022 to 08/2025 08/2022 to 08/2022 07/2022 to 08/2022 08/2021 to 05/2022 Registered Financial Consultant™ ("RFC®") Registered Financial Consultant™ ("RFC®") is a professional designation awarded by the International Association of Registered Financial Consultants™ ("IARFC®") to those financial advisors who meet specific standards of education, experience, and integrity. Prerequisites for the RFC® designation are; a baccalaureate or graduate degree in financial planning or services with strong emphasis on subjects relating to economics, accounting, business, statistics, finance, and similar studies; or have earned one of the following professional degrees or designations: AMS, CFA®, CFP®, ChFC®, CLU®, CPA®, EA®, JD®, or completed an IARFC® or CFP®, approved curriculum at an accredited college or university; must meet local licensing requirements securities, life, and health insurance; or operate as a fee-only planner, have no suspension or revocation of any professional license; subscribe and adhere to the RFC® Code of Ethics; must agree to devote a minimum of 40 hours per year of professional continuing education in the field of personal finance and professional practice management; and annually attest to the continued compliance and operation of the RFC® Code of Ethics. Item 3 – Disciplinary Information There are no legal, civil or disciplinary events to disclose regarding Mr. Madison. Mr. Madison 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. Madison. Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or disciplinary events to disclose regarding Mr. Madison. However, we do encourage you to independently view the background of Mr. Madison on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 7564492. Item 4 – Other Business Activities Insurance Agency Affiliations Mr. Madison is also a licensed insurance professional. Implementations of insurance recommendations are separate and apart from Mr. Madison’s role with Wave Wealth. As an insurance professional, Mr. Madison will receive customary commissions and other related revenues from the various insurance companies whose products are sold. Mr. Madison is not required to offer the products of any particular insurance company. Commissions generated by insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in recommending certain products of the insurance companies. Clients are under no obligation to implement any recommendations made by Mr. Madison or the Advisor. Mr. Madison spends less than 5% of his time per month in this capacity. Page 22 Wave Wealth Management, LLC 7000 Parkwood Blvd. Suite G300 Frisco, TX 75034 Phone: (972) 954-4100 I Fax: (972) 954-4106 www.wavewealth.com Item 5 – Additional Compensation Mr. Madison has an additional business activity where compensation is received that is detailed in Item 4 above. Item 6 – Supervision Mr. Madison serves as an Associate Wealth Manager of Wave Wealth and is supervised by Benjamin Jones, the Chief Compliance Officer. Mr. Jones can be reached at (972) 954-4100. Wave Wealth has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of Wave Wealth. Further, Wave Wealth is subject to regulatory oversight by various agencies. These agencies require registration by Wave Wealth and its Supervised Persons. As a registered entity, Wave Wealth is subject to examinations by regulators, which may be announced or unannounced. Wave Wealth is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor. Page 23 Wave Wealth Management, LLC 7000 Parkwood Blvd. Suite G300 Frisco, TX 75034 Phone: (972) 954-4100 I Fax: (972) 954-4106 www.wavewealth.com Privacy Policy Effective Date: September 17, 2025 Our Commitment to You Wave Wealth Management, LLC (“Wave Wealth” or the “Advisor”) is committed to safeguarding the use of personal information of our Client’s (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in our Privacy Policy (“Policy”). Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. Wave Wealth (also referred to as "we," "our," and "us”) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you. Wave Wealth does not sell your nonpublic personal information to anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below. Details of our approach to privacy and how your personal nonpublic information is collected and used are set forth in this Policy. Why you need to know? Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information. What information do we collect from you? Social security or taxpayer identification number Assets and liabilities Name, address, and phone number[s] Income and expenses Email address[es] Investment activity Account information (including other institutions) Investment experience and goals What Information do we collect from other sources? Custody, brokerage, and advisory agreements questionnaires and suitability Other advisory agreements and legal documents Transactional information with us or others Account applications and forms Investment documents Other information needed to service the account How do we protect your information? To safeguard your personal information from unauthorized access and use, we maintain physical, procedural, and electronic security measures. These include such safeguards as secure passwords, encrypted file storage, and a secure office environment. Our technology vendors provide security and access control over personal information and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Clients’ personal information. We require third parties that assist in providing our services to you to protect the personal information they receive from us. Page 24 Wave Wealth Management, LLC 7000 Parkwood Blvd. Suite G300 Frisco, TX 75034 Phone: (972) 954-4100 I Fax: (972) 954-4106 www.wavewealth.com How do we share your information? An RIA shares Clients’ personal information to effectively implement its services. In the section below, we list some reasons we may share your personal information. Basis For Sharing Do we share? Can you limit? Servicing our Clients We may share nonpublic personal information with non-affiliated third parties (such as brokers, custodians, regulators, credit agencies, and other financial institutions) as necessary for us to provide agreed services to you consistent with applicable law, including but not limited to: Yes No ● Processing transactions; ● General account maintenance; ● Responding to regulators or legal investigations; and ● Credit reporting, etc. No Not Shared Marketing Purposes Wave Wealth does not disclose and does not intend to disclose,= personal information with non-affiliated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where Wave Wealth or the client has a formal agreement with the financial institution. We will only share information for purposes of servicing your accounts, not for marketing purposes. Yes Yes Authorized Users Your nonpublic personal information may be disclosed to you and persons that we believe to be your authorized agent[s] or representative[s]. No Not Shared Information About Former Clients Wave Wealth does not disclose and does not intend to disclose nonpublic personal information to non-affiliated third parties with respect to persons who are no longer our Clients. Changes to our Privacy Policy We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us. Periodically we may revise this Policy and will provide you with a revised policy if the changes materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of nonpublic personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing. Any Questions? You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting us at (972) 954-4100. Page 25 Wave Wealth Management, LLC 7000 Parkwood Blvd. Suite G300 Frisco, TX 75034 Phone: (972) 954-4100 I Fax: (972) 954-4106 www.wavewealth.com