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On March 30, 2026, the Massachusetts Securities Division entered an order (the “Order”) against Dub Advisors, LLC, a New York-based, SEC-registered investment adviser (“Dub Advisors”), for violating the Massachusetts Uniform Securities Act, specifically for failing to reasonably supervise its agents and employees to ensure its advertising contained full and fair disclosures of all material information. Dub Advisors settled with the Massachusetts Securities Division, admitting the facts alleged though neither admitting nor denying the violations of law set forth in the Order. The firm was censured, fined $500,000, and ordered to make payments of restitution to identified affected Massachusetts citizens.

Dub Advisors operates through its mobile and online investment and trading application, the “dub app,” and offers “copy trading” or “copy trade” portfolios allowing users to replicate investment portfolios of politicians and public figures (e.g., U.S. Congresswoman Nancy Pelosi and her husband), hedge fund managers, other dub app users, and others.

To promote the dub app, between December 2024 and March 2025, Dub Advisors ran social media advertisements that had been created for it by a third party and then reviewed and approved by Dub Advisors’ compliance team. Those advertisements highlighted the purportedly strong performance of one of Dub Advisors’ “copy trade” portfolios. Among other things, the advertisements showed intraday portfolio performance metrics that were not reflective of the corresponding portfolio market closing values. Moreover, Dub Advisors’ disclosures, which were included as a comment under the social media post, failed to identify that the returns were not based on a standard market close or limited to a specific time period.

Dub Advisors’ Chief Compliance Officer eventually directed it to cease using the advertisements. Even then, however, the firm did not pull its advertisements for at least eleven days following the Chief Compliance Officer’s directive.

Requirements for Advertising Policies

The Massachusetts Securities Division found that Dub Advisors, through its acts and policies, “failed to reasonably supervise [its] agents, investment adviser representatives or other employees to assure compliance” with Massachusetts securities law. As part of the settlement, Dub Advisors was required to revise and enhance its compliance policies to ensure that all future advertisements, whether produced internally or by a third party, (a) contain prominent required disclosure and, when containing performance data, the beginning and end date of the calculation period, and (b) do not include intraday or other short-term price movements.

The Massachusetts Securities Division also required that Dub Advisors compliance policies be revised to ensure that prominent disclosure is “tailored to the advertising medium.” The Massachusetts Securities Division specifically disapproved of Dub Advisors’ use of disclosure in the comments section of an Instagram advertisement where users had to affirmatively click into the comments section to see the required disclosure.

Further Observations

We also note the following:

  • Notwithstanding news headlines such as “[Secretary of the Commonwealth William] Galvin fines online poster who promised to trade stocks like Pelosi, [Warren] Buffett” (Masslive.com, March 30, 2026), the Order does not address the legality of Dub Advisors’ practice of offering investors “copy trade” portfolios. 
  • The Order expressly states that it is not intended to form the basis of any disqualification or sanctions under the federal securities laws, such as any “bad boy” provisions under the Investment Advisers Act of 1940 (the “Advisers Act”), or Rule 506(d) of Regulation D under the Securities Act of 1933.
  • The Order only covers Massachusetts law and investors. We are not aware of any concurrent action being taken by the U.S. Securities and Exchange Commission relating to potential violations of the federal securities laws, especially violations of Rule 206(4)-1 (i.e., the “advertising rule”) under the Advisers Act.

For More Information

This Client Alert has been prepared by John Hunt, a Partner, and Bailey Travers, an Associate, in the Investment Management and Private Funds practice groups of the international law firm of Sullivan & Worcester LLP. For more information, Mr. Hunt may be reached in our Boston office by calling +1 (617) 338-2961 or our London office by calling +44 (0)20 7448 1000, or by email at jhunt@sullivanlaw.com; Mr. Travers may be reached in our Boston office by calling +1 (617) 338-2895 or by email at btravers@sullivanlaw.com.

This Client Alert is provided for general informational purposes only and does not constitute legal advice.