Disclosures

DISCLOSURES

Last updated Jul 26, 2026

Investment Advisor Disclosure

eSmeb Inc. (“eSmeb”) is an investment adviser registered with the U.S. Securities and Exchange Commission (“SEC”) (CRD# 152361 / SEC# 801-134951). Registration does not imply a certain level of skill or training. Advisory services are offered only to clients in jurisdictions where eSmeb is registered or exempt from registration. More information about eSmeb is available in its current Form ADV Part 2A Brochure and on the SEC’s Investment Adviser Public Disclosure website.

Client Relationship Summary (Form CRS)

Review the Client Relationship Summary (Form CRS) for more information about eSmeb and its services.

Code of Ethics

Review the Code of Ethics for more information about eSmeb fiduciary standards.

Performance & Risk Disclosure

Past performance does not guarantee future results. Investing involves risk, including the possible loss of principal. Any historical returns, expected returns, or projections may not reflect actual future performance. Certain investments are not suitable for all investors. Before investing, carefully consider your investment objectives, financial situation, and risk tolerance.

Client Advisory Agreement

This is the Client Advisory Agreement that you agree to when you sign up for eSmeb’s services at WaterfallWealth.ai.

Brokerage Disclosure

Brokerage services are provided by Interactive Brokers LLC (“Interactive Brokers”), members FINRA/SIPC. For more information about Interactive Brokers, visit interactivebrokers.com or FINRA’s BrokerCheck.

Solicitor Disclosure

WaterfallWealth LLC (“WaterfallWealth”) provides technology, marketing, and client referral services to eSmeb. WaterfallWealth may receive compensation from eSmeb for referring prospective clients. Such compensation may be based on a percentage of advisory fees received by eSmeb. This creates a conflict of interest because WaterfallWealth has a financial incentive to refer clients to eSmeb. WaterfallWealth is owned in part by principals of eSmeb Inc. WaterfallWealth LLC does not provide investment advice or financial planning services. Clients will not pay higher fees to eSmeb as a result of this arrangement.

Client Referral Program Notice

eSmeb offers a client referral program with non-cash service credits (e.g., platform-fee and/or advisory-fee rebates). Both the client and the referred client receive two months of free service credits if signed up for an annual plan. Credits have no cash value and cannot be exchanged for money. The rebates may not exceed five (5) referrals, or a total value of $1,000 per 12 month period. Clients referring more than five new customers, or seeking value in excess of $1,000, or seeking cash compensation, must enroll in eSmeb’s Promoter Program, which requires a separate written agreement and disclosure process under SEC rules.

A client of eSmeb Inc may have referred you. The client is independent and not affiliated with eSmeb Inc. The client may receive de-minimis non-cash rebates on their service-fees. The client does not provide investment advice.

Promoter Program Notice

eSmeb’s Promoter Program requires a separate written agreement and disclosure process under SEC rules. Non-clients must enroll in the Promoter Program to receive referral compensation. Clients seeking cash compensation in excess of $1,000 must enroll in the Promoter Program. Compensation will be based on the terms of the agreement. Referred clients typically receive 2 months of free service credit if signed up for an annual plan.

A promoter of eSmeb Inc. may have referred you. The promoter is independent and not affiliated with eSmeb Inc. Promoters are compensated by eSmeb for marketing and client-acquisition services but they do not provide investment advice.

Third-Party Links

This website may link to third-party websites. These links are provided for informational purposes only. Neither eSmeb nor Waterfall Wealth endorses nor guarantees the accuracy of information on third-party sites.

Privacy & Terms

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