High Probability Advisor (hereinafter “HPA” or “we”) is a fee-based SEC-registered investment
adviser with its principal place of business located in Pittsford, New York. We have been in business
since 2017. Stephen Carl, Michael Jones, and Jeff Coons are the principal owners of the firm, with
Maureen Pilato and Michael Cicero having minority ownership. Bonadio & Co., LLP, an affiliated
accounting firm, and Tom Bonadio have minority ownership stakes in the firm as well.
As of December 31, 2021, we had a total of $542,074,726 of assets under management - $476,158,966
in discretionary assets under management and $65,915,759 in non-discretionary assets under
management.
Portfolio Management Services
Our firm provides continuous advice to a client regarding the investment of client funds based on the
individual needs of the client. Through personal discussions in which goals and objectives based on a
client's particular circumstances are established, we develop a client's personal portfolio allocation and
create and manage a portfolio based on the client’s specific investment objectives. During our data-
gathering process, we determine the client’s individual objectives, time horizons, risk tolerance,
income tax situation and income and liquidity needs. We may also review and discuss a client’s prior
investment history, as well as family composition and background.
We will manage advisory accounts on a discretionary or non-discretionary basis, as agreed with each
client. Account supervision is guided by the stated objectives of the client. Clients may impose
reasonable restrictions on investing in certain securities, types of securities, or industry sectors.
Generally, client portfolios will be comprised of Exchange Traded Funds (ETFs), mutual funds, equity
and fixed-income securities, Real Estate Investment Trusts (REITs), and money market mutual funds
(or other short-term investment vehicles).
Financial Planning Services
HPA also provides financial planning advice. HPA gathers required information through in-depth
personal interviews and may ask clients about their current financial status, future goals and attitudes
towards risk. HPA carefully reviews any appropriate documentation thus provided.
In general, financial planning discussions may address any or all of the following areas that may be of
concern to clients:
Personal: Family records, budgeting, personal liability, estate information, and financial goals;
Education: Education IRA’s, financial aid, state savings plans, grants, and general assistance in
preparing to meet dependents’ continuing educational needs through development of an education
plan;
Tax & Cash Flow: Income tax planning and spending analysis. For example, HPA may illustrate the
impact of various investments on a client’s current income tax and future tax liability;
Death & Disability: Cash needs at death, income needs of surviving dependents, estate planning and
disability income analysis;
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Retirement: Analysis of current strategies and investment
plans to help clients achieve their retirement
goals; and
Investments: Analysis of investment alternatives and their effect on clients’ portfolios.
If a client chooses to implement the recommendations discussed in the financial planning consultation,
HPA suggests that the client work closely with his/her attorney, accountant, insurance agent and/or
stockbroker. Implementation of financial planning recommendations is entirely at a client’s discretion.
HPA’s financial planning recommendations are not limited to any specific product or service offered
by a broker dealer or insurance company. All recommendations are of a generic nature.
HPA does not charge clients any fees for financial planning consultations. However, financial
planning consultations are available only to existing or prospective portfolio management clients.
Receipt of free financial planning consultations is generally contingent on becoming a portfolio
management client of HPA. Item 5- Fees and Compensation – provides additional information
regarding how and when management fees are assessed.
Retirement Advisory Services
Our firm provides advisory services to retirement plans, including serving as a discretionary manager
of plan investments. Our services may include:
•
Advising plan fiduciaries regarding plan design, provider due diligence and plan investment
policies;
• Selecting the investment menu and funds on the menu;
• Managing the Qualified Default Investment Alternative (QDIA) and other risk-based or target
date life cycle investments on the menu; and,
•
Ongoing monitoring of the plan and its investments.
HPA may provide its advisory services via The Logical Retirement Solution®, a Pooled Employer Plan
for which HPA serves as Advisor and 3(38) Manager.
Important Disclosure for Retirement Plan Account and Individual Retirement Account Clients:
When we provide investment advice to you regarding your retirement plan account or individual
retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement
Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing
retirement accounts. The way we make money creates some conflicts with your interests, so we
operate under a special rule that requires us to act in your best interest and not put our interest ahead of
yours. Under this special rule’s provisions, we must:
Meet a professional standard of care when making investment recommendations (give
prudent advice);
Never put our financial interests ahead of yours when making recommendations (give loyal
advice);
Avoid misleading statements about conflicts of interest, fees, and investments;
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Follow policies and procedures designed to ensure that we give advice that is in your best
interest;
Charge no more than is reasonable for our services; and
Give you basic information about conflicts of interest.
Services in General
Our investment recommendations are not limited to any specific product or service offered by a broker
dealer or insurance company.