Michael “Mike” Ayala of Austin, Texas, who markets himself as Mike Ayala, told investors that Wavemark Capital, LLC would buy brand new mobile homes directly from manufacturers, place them in parks owned by his affiliated companies, and pay a guaranteed 12 to 14 percent a year from the sale margins and lot rents. From October 2021 to February 2025, through a vehicle called Wavemark Income Fund, LLC, he raised approximately $9.6 million from nearly 100 investors in at least five states. According to the Securities and Exchange Commission, not one mobile home was ever bought. On September 21, 2026, the SEC sued Ayala and Wavemark in the Western District of Texas.
The complaint charges both with violating Section 17(a) of the Securities Act and Section 10(b) of the Exchange Act and Rule 10b-5, and seeks permanent injunctions, a conduct based injunction against Ayala, disgorgement and a civil penalty. The allegations have not been tested in court. Wavemark, a Wyoming company with an Austin office, was administratively dissolved in December 2023 and kept taking investor money for another fourteen months.
A Game Changing Opportunity With a $50,000 Minimum
Ayala launched the fund in October 2021 as what he called a game changing opportunity, with a minimum investment of $50,000. The pitch was specific. Wavemark would buy new homes for $50,000 to $55,000 each and resell them for $75,000 to $80,000, and the margin plus rent from newly placed homes would fund the returns. A one year note paid 12 percent, a two year note 14 percent. The pitch deck described it as a truly passive income investment, insulated and secure, shielded from market volatility and recession.
The notes were called Secured Promissory Notes, and investors signed a first lien security agreement. At a webinar on July 23, 2024 Ayala told prospective investors the fund obtained a UCC filing against the homes, and in a June 2023 webinar and September 2024 emails investors were told the homes would be secured by certificates of origin identifying each unit’s serial number and manufacturer. There were no homes, so there were no filings and no certificates. The notes were secured by nothing.
Where the $9.6 Million Went
Investors wired money to a fund account Ayala controlled, where it was pooled. It was then moved to other accounts he controlled. According to the SEC, about $8.7 million went to pay debts and operating expenses of his affiliated businesses, including payroll, utilities and distributions to investors in those other businesses. Another $795,485 went back to Wavemark investors as Ponzi-like payments. And although the offering memorandum said no commissions would be paid to anyone soliciting investors, at least one salesperson received $62,000 of investor money in undisclosed commissions.
The complaint does not name the affiliated businesses. Ayala’s own public profiles list him as co-founder of Four Peaks Capital Partners and managing partner and chief executive of Park Place Communities, a mobile home park operator that once claimed 28 communities in 13 states.
Twenty-One Months Without a Missed Payment
From January 2024 the fund began paying late or not at all, and investors began emailing and texting about overdue distributions and unpaid principal. At a July 2024 webinar Ayala told prospective investors the fund had paid returns for 21 consecutive months. The Wavemark website, live until May 2025, claimed 28. Between January and April 2024, salespeople told prospects the fund had never missed a payment. In October 2024 Ayala told a prospective investor that payment problems had only happened during the COVID-19 pandemic and he expected no more.
Behind that, the SEC says, Ayala was deciding which investors to pay based on the money available and on which investors were most upset. It is the same triage described in the case against Mark Hanf and Nam Phan, whose real estate lending funds ranked redemptions by who was most likely to complain. Wavemark stopped operating in June 2025, and most investors lost all or most of their money.
Meanwhile, in Indiana
The affiliated parks were in trouble of their own. In Alexandria, Indiana, the city shut off water and sewage to a 74-lot mobile home park run by Park Place on August 25, 2025, after the operator ran up a $97,000 unpaid water bill. Residents lost service even if they had paid their rent to Park Place. Hartford City sued Ayala, his partner Andrew Lanoie and Park Place in March 2026 over unpaid utilities at another park.
On May 15, 2026, Indiana Attorney General Todd Rokita sued Ayala, Lanoie, Park Place Communities Management and Four Peaks Capital Partners in Madison Circuit Court over what his office called disastrous conditions at four parks in Alexandria, Anderson, Fairmount and Hartford City. Those claims are separate from the SEC case and are also unproven. They sit beside a line in the SEC complaint: investor money that was meant to buy homes went instead to affiliated companies’ expenses, utilities among them.
The Podcast and the Mastermind
Ayala sold himself as the kind of operator people should trust with their savings. On Instagram, where he has around 22,000 followers, he describes himself as a 20 year business owner and real estate investor and a top 100 mobile home park owner. He hosts a podcast called Investing for Freedom and ran a mastermind group for business owner and investor couples. Investor reviews posted online after the collapse describe emails bouncing by August 2025, and complaints filed with the Texas and Arizona securities regulators.
Conclusion
Michael Ayala told nearly 100 people their money would buy new mobile homes, secured by liens and certificates of origin, paying a guaranteed 12 to 14 percent. The SEC says he never bought a single home. About $8.7 million went to his other companies’ bills, $795,485 went back to earlier investors, and a salesman was paid commissions the offering documents said nobody would get. When payments stopped, he told new investors the fund had never missed one, and chose who to pay by who was angriest. Wavemark had already been dissolved as a company for fourteen months of that. In Indiana, a park run by his other business had its water cut off.
