Disclaimers

Part 1 — Website Disclosure

About the Portfolio Grader

The Portfolio Grader (the “Grader”) is a free, educational tool offered by DASTA, Inc., the parent company of dub Advisors, LLC and dub Financial, LLC. It is provided for general informational and entertainment purposes only.

1. What the Grader does

The Grader applies a deterministic scoring methodology to a portfolio that you choose to share with us, and produces an overall A–F letter grade together with letter sub-grades for up to six components: Performance, Risk, Diversification, Novelty, Efficiency, and, where transaction history is available, Trading. Component scores are derived from observable inputs, including realized returns, holdings concentration, sector and asset-class exposure, an ordinary-least-squares regression of your daily returns against thirteen factor proxies (eleven U.S. sector ETFs, gold, and bitcoin), and reconstructed transaction history when present. After the numerical grade is computed, a third-party large language model writes the user-facing narrative around those scores, subject to a fixed system prompt and a set of deterministic post-generation guardrails. Every grade is logged to an internal audit trail.

2. What the Grader is NOT

The Grader is not investment advice, a recommendation, an endorsement, an opinion as to the appropriateness or suitability of any security or strategy for you, an offer or solicitation to buy or sell any security, an assessment of your individual investment objectives or risk tolerance, a financial plan, a tax or legal opinion, or a substitute for professional advice. Neither the overall grade, the component sub-grades, the narrative explanation, nor any answer the tool provides in follow-up conversation is intended to be relied upon as a basis for any investment decision. The Grader does not consider, and cannot consider, the entirety of your financial situation, tax position, liquidity needs, time horizon, dependents, insurance, debts, or other facts that a financial professional would weigh before recommending any course of action.

3. Educational and entertainment purposes only

The Grader is intended to give you a directional sense of how a portfolio compares against a broad-market benchmark and a set of common diagnostic measures. It is not a verdict. Letter grades necessarily simplify a complex picture: a high grade does not mean a portfolio is appropriate for you, and a low grade does not mean a portfolio is inappropriate for you. You should not use the Grader as the sole or primary basis for any decision to buy, sell, hold, or rebalance any security, or to begin, continue, or end any investment strategy.

4. Methodology limitations and risk areas

The Grader has known limitations that you should understand before relying on any output. These include, without limitation:

• Minimum data thresholds. The Grader requires at least sixty trading days of return data to compute a full grade. Below that threshold, the tool may return only a partial grade or no grade at all.
• Data quality and reconstruction. When transaction history is provided through a CSV upload or reconstructed from a connected brokerage feed, the underlying daily return series is approximated and may differ materially from the actual historical experience of the portfolio. Corporate actions, options assignments, dividends, reinvested distributions, transfers, cost-basis adjustments, partial fills, and similar events may be incompletely captured.
• Asset coverage.Certain asset types, including but not limited to options and other derivatives, futures, private securities, certain mutual funds, and crypto holdings outside a supported universe, may be filtered out, mapped to a generic “unknown” bucket, or otherwise underweighted in the analysis. Portfolios where a meaningful share of the book sits in one of those categories should expect a less reliable grade.
• Brokerage variance. Different brokerages expose different fields, transaction histories, and time windows through the connected data feed. Two portfolios that are economically identical can therefore receive different grades depending on which brokerage they are held at.
• Factor model and benchmark. The thirteen-factor regression and the broad-market benchmark are convenient approximations and are not a comprehensive model of return drivers. Components that depend on the regression: Performance, Risk, Novelty, and Efficiency, should be read as directional only.
• Concentration penalties. Deterministic concentration adjustments may lower the grade on portfolios that are heavily weighted in a single asset class, sector, factor, or in uncategorized holdings. Those penalties are mechanical and may not reflect a deliberate investment thesis you hold.
• Stability and predictive value. The Grader has not been validated for day-to-day stability on the same portfolio over time. High grades have not been shown to predict future outperformance, and low grades have not been shown to predict future underperformance. Past performance reflected in the inputs does not guarantee future results.
• Calibration and change. The Grader is calibrated against an evolving sample of real user data, and the methodology, weights, thresholds, and prompts may be updated at any time without notice. A re-run of the same portfolio at a later date may produce a different grade.

5. AI-generated content

The narrative portion of every grade, and any reply the tool provides in follow-up conversation, is generated by a third-party large language model. DASTA has implemented a fixed system prompt, deterministic post-generation guardrails, an offline review prompt, and a deterministic fallback for cases where the model output cannot be validated. Even with those controls, language models can produce content that is incomplete, inaccurate, internally inconsistent, biased, stale, or otherwise wrong.

If you ask the tool follow-up questions, the AI may, despite our instructions to the contrary, produce content that resembles investment advice, a personalized recommendation, a return forecast, an opinion on suitability, or a guarantee. Any such output is a model error and should be disregarded. DASTA, Inc., dub Advisors, LLC, dub Financial, LLC, and their affiliates expressly disclaim responsibility for any AI-generated statement that purports to provide individualized advice or to predict the future performance of any security, portfolio, or strategy, and you may not rely on any such statement. You should not act on any AI-generated statement without consulting a qualified financial professional.

6. Connecting your accounts and use of your data

If you connect a brokerage account through Plaid or upload a transaction history file, you authorize DASTA to use that information solely to generate a grade for you, render the user interface, maintain an audit record of how the grade was produced, troubleshoot the tool, and improve the methodology over time. The connection is read-only: the Grader does not place trades on your behalf, does not initiate transfers, and has no authority to act on your account. We do not sell your brokerage data. Use of the Grader is also subject to dub's Privacy Policy.

7. Promotional links to dub

Once your grade is produced, you may be offered the option to download the dub mobile app or to provide your email address. The dub app is operated by DASTA, and offers brokerage and advisory services through dub Financial, LLC and dub Advisors, LLC, respectively. Those services are separate from the Grader and are governed by their own account agreements, fees, eligibility requirements, and disclosures, which you should review carefully before opening any account or making any investment. The Grader itself is provided free of charge and DASTA does not charge you a fee for using it; DASTA does benefit indirectly when users who try the Grader subsequently open a dub account, and you should evaluate any promotional content with that potential conflict in mind.

8. No advisory, brokerage, or fiduciary relationship

Use of the Grader does not create an investment advisory, brokerage, agency, fiduciary, or other client relationship between you and DASTA, Inc., dub Advisors, LLC, dub Financial, LLC, or any of their affiliates. dub Advisors, LLC, an SEC-registered investment adviser, and dub Financial, LLC, an SEC-registered broker-dealer, member of FINRA and SIPC, do not provide the Grader, do not adopt its outputs as their own, and do not receive any fee for it. The registrations and memberships of DASTA, Inc., dub Advisors, LLC, dub Financial, LLC, or any of their affiliates do not in any way imply that the SEC, FINRA, SIPC, or any other regulator or self-regulatory organization has reviewed, approved, or endorsed the Grader, its methodology, or any output it produces.

9. Forward-looking statements; investment risk

Any forward-looking content within the Grader's output is hypothetical and not a guarantee of future results. All investing involves risk, including the possible loss of principal. You alone are responsible for any investment decision you make.

10. Eligibility

The Grader is offered to U.S. residents only and is not available outside of the United States. The Grader is not available to officers, directors, employees, contractors, registered persons, or other associated persons of DASTA, Inc., dub Advisors, LLC, dub Financial, LLC, or any of their affiliates.

11. Updates and discontinuation

DASTA may modify, suspend, or discontinue the Grader, the underlying methodology, or any feature of it at any time and without notice. Information presented in the Grader's outputs is subject to change.

12. Contact

Questions about this disclosure or the Grader can be sent to legal@dubapp.com.

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