Filing 2024 Q1 compared to 2023 Q4 by default. Changes are calculated vs the previous SEC filing.
* Reported Price is the price of the security as of the portfolio date. This value is significant in that it is the last known price at which the security was still held.
An asterisk sign (*) next to the price indicates that the price is likely invalid.
Person Signing this Report on Behalf of Reporting Manager:
Name
Title
City, State
Date
Jeffrey Scott Coons
Chief Compliance Officer
Pittsford, New York
14 Nov 2024
High Probability Advisors, LLC (HPA) failed to make required Form 13F filings from Q4 2020 to Q2 2024 and Form N-PX filings for the period ending 6/30/2024. HPA recently became aware of the Rule 13(f)-1 requirements after reviewing an article on SEC press release 2024-135. HPA has been using a third party compliance consultant since our firm's inception to advise us on regulatory compliance policies, procedures, and practices. Unfortunately, our compliance consultant had not advised us regarding the requirement to file Form 13F, and the compliance issue was not identified in their Annual Compliance Reviews even as HPA's assets under management grew and our investments shifted from primarily mutual funds to Exchange Traded Funds. HPA is making all late filings immediately as part of our self-correction measures. Also, our Chief Compliance Officer has taken steps to update HPA's Compliance Manual to include Rule 13(f)-1, Form 13F, and Form N-PX requirements.
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