All US holdings of this investor are reported in this report. The Form 13F report requires disclosure of the manager that files the report, the name and class of the security, the CUSIP code, the number of shares as
of the end of the calendar quarter for which the report is filed, and the total market value. The market value
column should not be used as a substitute for Assets Under Management (AUM), as it does not include cash held in
accounts.
* 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
11/14/2024
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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