Governance · Corporate discipline
The institutional discipline of a regulated utility.
- Entity
- Wavestar Holdings LLC
- Formation
- Wyoming · 2026
- Committees
- Audit · Risk · Comp
- Docs posture
- Public-by-default
Corporate structure
One holding company. Module-level operating discipline.
Corporate facts
- Legal entity
- Wavestar Holdings LLC
- Jurisdiction
- Wyoming, United States
- Formation year
- 2026
- Registered agent
- Per public filings · on request
- Operating modules
- ORCH · Terminal · Market · Attest
Currently operated under the holding company. ORCH separates to its own chartered CCP entity on CFTC DCO registration.
- Shared registry
- did:orbit: namespace
The identity registry is operated as shared infrastructure across all four modules.
- Annual audit
- Top-tier external auditor
Auditor appointment disclosed publicly on seating. First audit cycle covers FY2026.
- Foundation
- Orbital Interchange Foundation (OIF)
501(c)(6) membership body forming ~month 18. Protocol governance transfers to OIF on incorporation.
The governance suite
Documents that govern the company.
- 01
Charter
The foundational document. Corporate purpose, member classes, board composition, amendment procedure. Published publicly; modified only by Board supermajority with member notice. - 02
Code of Ethics
The binding conduct document for every employee, director, and advisor. Covers personal trading, gifts, political activity, outside activities, and the ethics hotline. Enforced by the Audit Committee. - 03
Audit Committee Charter
The written charter for the Audit Committee — membership, independence requirements, scope, meeting cadence, external-auditor relationship, whistleblower oversight. Approved by the Board and re-reviewed annually. - 04
Risk Committee Charter
The written charter for the Risk Committee — membership, scope over default-fund and margin framework, escalation paths during member default, stress-testing cadence, and the relationship with the Chief Risk Officer once appointed. - 05
Compensation Committee Charter
The written charter for the Compensation Committee — scope over executive and director compensation, the equity plan, and performance-linked components. Aligned with prevailing governance standards for regulated institutions. - 06
Clearing Member Rulebook
The governing document for member conduct, published in the Regulatory section. Amendments require member notice-and-comment before taking effect, except in declared emergency-resolution scenarios. - 07
Conflict of Interest policy
Specific conflict-of-interest policy binding on all directors, executives, and advisors. Maintains the public register of disclosures and recusals. - 08
Dispute Resolution policy
The framework for member-to-member disputes, member-to-Wavestar disputes, and regulator-directed inquiries. Covers mediation, binding arbitration, and appeal paths.
Operating principles
How decisions actually get made.
- 01
Written decisions
Every consequential technical decision ships with a numbered Architectural Decision Record in docs/decisions/. Every consequential institutional decision ships with a board resolution. Both are searchable, dated, and attributable. - 02
Reversibility preferred
Where the decision is reversible, we move fast. Where it is not — anything touching the member rulebook, the default fund, or the registry contract — we move carefully, with member consultation and board approval. - 03
Escalation paths are named
For every class of decision, the escalation path is documented. Rulebook amendment? Member notice then board vote. Default declaration? Risk Committee within two hours. Regulatory comment letter? General Counsel with CEO sign-off. Nothing important has a vague owner. - 04
Public disclosure is the default
If a document affects a member firm, a counterparty, or the regulator, it is public unless there is a specific reason not to make it public. The reasoning lives on the company's public filings page.
Dispute resolution
The framework, in one paragraph.
Member-to-member disputes over a cleared trade are resolved first at the clearing-house level — Wavestar acts as the neutral counterparty and the member rulebook governs the outcome. Escalated disputes go to binding arbitration under AAA commercial rules, seated in New York, with the right of appeal to a New York court only on narrow grounds of arbitrator misconduct.
Disputes between a member and Wavestar itself are held to a higher procedural standard: the member may elect between binding arbitration and New York state court. Regulator- directed inquiries are handled under the procedures defined in each regulatory framework — no contractual carve-out displaces a legitimate regulatory process.
The full dispute-resolution policy is in the public legal suite. The substance is deliberately boring — which is the point.
The institutional test of a clearing house is not how well it handles the easy cases. It is how predictably it handles the hard ones.
Related
The Board sits above the governance suite.
Governance is the common law. The Board is the constitution. The composition of the Board, the seats we have open, and the committee matrix are all laid out on the next page.