It is unlawful for any person who receives, directly or indirectly, any consideration from another person primarily for advising the other person as to the value of securities or their purchase or sale, whether through the issuance of analyses or reports or otherwise\n(1) to employ any device, scheme, or artifice to defraud the other person, or\n(2) to engage in any act, practice, or course of business which operates or would operate as a fraud or deceit upon the other person.
Massachusetts Legal Code