Vista Wave Investments, LLC

Vista Wave Investments provides discretionary investment management primarily for pooled vehicles and institutional accounts, including retirement plans for which it acknowledges ERISA “investment manager” and fiduciary responsibilities. The firm operates under written Investment Advisory Agreements and implements client-specific Statements of Investment Policy as the basis for portfolio management.

The adviser generally manages accounts with full trading discretion, including the authority to purchase and sell securities, aggregate trades for execution, and rebalance portfolios according to the incorporated SIP; it also performs ongoing monitoring and delivers at least quarterly reports and annual policy reviews. The Agreement contemplates use of custodians (including arrangements for assets held at Interactive Brokers), standard percentage-of-AUM billing, and routine coordination with clients’ other advisors.

Vista Wave’s regulatory disclosures include matters that the firm reports on its Form ADV, and prospective institutional clients are directed to review those disclosure events in the ADV for detail. The advisory agreement also expressly contemplates investments that may involve insurance-type products (for example, references to fees imposed by variable annuity providers) and the firm’s ADV reflects insurance broker/agent activity, features that are less common among investment managers in this category.