Mobile Home Scam: $9.6M Raised, ZERO Homes Bought!

SEC v. Michael Ayala; Wavemark Capital, LLC — U.S. Securities and Exchange Commission Litigation Release No. 26643, dated September 21, 2026.

Wavemark Capital and its CEO, Michael Ayala, have been charged by the SEC for allegedly orchestrating a $9.6 million fraudulent offering. They promised investors high, guaranteed returns on mobile home investments but instead used the funds for Ponzi-like payments, commissions, and personal expenses.

In Plain English

Imagine someone promised you a great return on a business, saying they'd use your money to buy and rent out mobile homes. But instead of buying homes, they used new investors' money to pay off earlier investors, like a game of financial musical chairs. They also spent the money on other things, not what they promised.

Disclaimer: all facts are drawn from the SEC's own filings; the claims described are allegations unless and until a court rules or the parties settle, and some cases end in dismissal.

How the Alleged Scheme Worked

1. The Promise Wavemark Capital, LLC, led by Michael Ayala, offered investors promissory notes, promising to use the money to buy mobile homes and place them in parks owned by Ayala's affiliates. Investors were promised guaranteed annualized returns between 12% and 14% from rental payments and mobile home sales.
2. The Reality Contrary to their promises, the defendants allegedly did not purchase any mobile homes. Instead, investor funds were used to make Ponzi-like payments to earlier investors.
3. Misappropriation of Funds Investor money was also allegedly misappropriated to pay sales commissions, cover debts, and fund operational expenses related to Ayala's affiliate entities, diverting funds from the promised mobile home investments.
4. Raising Capital From October 2021 through February 2025, Wavemark Capital and Ayala raised approximately $9.6 million from nearly 100 investors through the Wavemark Income Fund, LLC.

The Enforcement Action

On September 21, 2026, the SEC filed settled charges against Wavemark Capital, LLC and its founder and CEO, Michael Ayala, in the U.S. District Court for the Western District of Texas. The defendants allegedly operated a $9.6 million fraudulent offering involving mobile home investments. Without admitting the allegations, the defendants consented to final judgments permanently enjoining them from violating securities laws, ordering disgorgement of $8,817,909 plus $736,725 in prejudgment interest on a joint and several basis. As to Ayala, the judgment also includes a conduct-based injunction and a civil penalty of $236,451.

Named in this action: Wavemark Capital, LLC, Michael Ayala.

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