DASTA Investments LLC (“DASTA”) is an investment adviser with its principal place of business in New
York, New York. DASTA is a wholly owned subsidiary of DASTA Incorporated, a Delaware corporation.
Steven Wang is the principal control person of DASTA Incorporated.
DASTA is eligible to register as an investment adviser with the SEC as an internet adviser pursuant to Rule
203A-2(e) of the Investment Advisers Act of 1940, as amended, due to its advisory business being
conducted exclusively through a mobile application owned by DASTA Incorporated (collectively, the “dub
App”).
Advisory Services
DASTA exclusively provides investment advisory and discretionary portfolio management services through
the dub App to individual users (“DASTA Users”), who are natural persons. Within the dub App, DASTA
Users can employ filtering and search tools to discover and invest in proprietary investment strategies
managed by DASTA (“Premium Portfolios”), or other DASTA User portfolios.
It’s important to emphasize that when a DASTA User allocates assets to mirror the trading activity of another
DASTA User's portfolio, DASTA Incorporated employs its proprietary technology. This technology enables
a self-directed trade through the Firm’s introducing broker dealer, DASTA Financial, LLC (“Introducing
Firm”), effectively replicating (or “Copy” / “Copying”) the DASTA User's chosen portfolio in their own
account. DASTA Users maintain complete control and discretion when it comes to deciding whether to
replicate one or more portfolios within the dub App.
DASTA does not provide financial planning services or give tax or legal advice. DASTA Users are urged to
consult with his or her own advisors with respect to the legal, tax, regulatory, financial, and accounting
consequences of an investment in any Premium Portfolio.
User Profiles and Risk Scoring
The dub App also gathers and evaluates information provided by each DASTA User, encompassing details
such as age, income, investment objectives, investment horizon, risk tolerance, and other pertinent
information utilized by DASTA to construct a comprehensive user profile, referred to as the "User Profile."
This User Profile may incorporate a risk tolerance score, which is exclusively determined based on
responses provided by DASTA Users during the creation of their profile.
It's important to note that DASTA Users are initially restricted from investing in Premium Portfolios that
DASTA deems to have a higher risk rating than the DASTA User's risk tolerance score, creating what we
term a "risk mismatch." Whenever a risk mismatch occurs, DASTA Users are promptly notified, preventing
them from Copying the corresponding Premium Portfolio, unless such DASTA User acknowledges such
risk mismatch and affirmatively agrees to continue with making an investment toward that Premium
Portfolio.
In addition, DASTA Users hold the flexibility to update their User Profile at their discretion. Such updates
may or may not result in a modification to the DASTA User's risk tolerance score. In all instances, DASTA
Users bear sole responsibility for notifying DASTA of any alterations to their financial situation, investment
objectives, risk tolerance, or investment constraints.
General Considerations
The dub App is a mobile and online investment and trading platform, designed to be a marketplace of
investment ideas and provide access to DASTA Users to a wide variety of investment strategies. DASTA
provides its advisory services primarily online, however DASTA customer support is available for telephone
consultation as needed to provide a complete advisory experience to DASTA Users.
DASTA Users should be familiar with investing online and comfortable communicating with DASTA through
electronic means. When DASTA Users agree to the terms of the dub App, they agree to receive all
communications and documents electronically
(via email or directly through the dub App). The dub App is
not suitable for DASTA Users if they have limited access to internet or don’t have the physical technology
required to run the dub App.
It's important for DASTA Users to keep in mind that the dub App and any Premium Portfolios a DASTA
User may invest in is only one component of their investment strategy. The dub App is not designed to
provide financial planning services and is limited by the information a DASTA User provides during
onboarding. Investing is inherently risky and may result in a total loss of your investment.
Copy Mechanics
When a DASTA User Copies a Premium Portfolio, DASTA sends corresponding automated trades
reflecting the Premium Portfolio holdings directly to the Introducing Firm, who clears through third-party
broker-dealer, Apex Clearing Corporation (“Third Party Broker”). If a Premium Portfolio that a DASTA User
Copies changes, DASTA sends corresponding automated trade instructions to the Introducing Firm
reflecting the Premium Portfolio changes. DASTA does not always reflect the trading activity in a Premium
Portfolio. For instance, a DASTA User’s may impose reasonable restrictions on investing in certain
securities or types of securities. In those instances, DASTA will allocate the remaining weight pro-rata
across all holdings in the Premium Portfolio.
When multiple DASTA Users Copy a Premium Portfolio, DASTA may, but is not required to, aggregate
orders for the purchase and sale of securities to reflect the Premium Portfolio. In such instances, each
DASTA User will receive their pro-rata allocation with the average price per unit.
Each DASTA User opens a brokerage account (“Brokerage Account”) with the Introducing Firm who utilizes
the Third Party Broker for execution, custodial and clearing services.
Premium Portfolio Availability
There are multiple instances where DASTA may cease the availability of a particular Premium Portfolio.
For instance, DASTA seeks to make available only those Premium Portfolios that meet the diligence and
performance requirements of DASTA. To the extent these requirements are not met, as determined by
DASTA, DASTA may decide to remove the Premium Portfolio from the dub App. Where this is the case,
DASTA will seek to provide DASTA Users with as much notice as reasonably practical prior to removing
the Premium Portfolio from the dub App. Other reasons for removal of a Premium Portfolio from the dub
App include death or incapacity or retirement of a supervised person. DASTA cannot guarantee the
availability of any Premium Portfolio on the dub App.
The availability of a Premium Portfolio should not be considered by a DASTA User to be an
endorsement or recommendation of its Premium Portfolio. Investing in securities involves inherent
risks, and you should be prepared for the potential of losing money when you invest in securities.
Premium Portfolio Evaluation
Prior to a Premium Portfolio’s availability on the dub App, DASTA conducts due diligence on each Premium
Portfolio, both from a qualitative and quantitative perspective. DASTA’s review includes but is not limited to
the following:
• Strategy Evaluation: Review of a strategies exposure, constraints, case studies, risk-return profile,
risk controls, and RIA decision making
• Quantitative Assessment: Performance History (vs Benchmark), risk adjusted returns,
upside/downside capture, back testing, and other performance metrics
DASTA Users must rely on their own examination of the Premium Portfolio, including the merits
and risks involved, before Copying any Premium Portfolio. DASTA does not endorse or recommend
any Premium Portfolio for investment by a DASTA User. There is no guarantee that the objective of
any or all Premium Portfolios will be achieved.