HNDL / Strategy Shares - Strategy Shares NASDAQ 7 HANDL Index ETF - تصريحات هيئة الأوراق المالية والبورصات، التقرير السنوي، بيان الوكيل

أسهم الإستراتيجية - أسهم الإستراتيجية NASDAQ 7 HANDL Index ETF
US ˙ NasdaqGM ˙ US86280R5063

الإحصائيات الأساسية
CIK 1506213
SEC Filings
All companies that sell securities in the United States must register with the Securities and Exchange Commission (SEC) and file reports on a regular basis. These reports include company annual reports (10K, 10Q), news updates (8K), investor presentations (found in 8Ks), insider trades (form 4), ownership reports (13D, and 13G), and reports related to the specific securities sold, such as registration statements and prospectus. This page shows recent SEC filings related to Strategy Shares - Strategy Shares NASDAQ 7 HANDL Index ETF
SEC Filings (Chronological Order)
توفر هذه الصفحة قائمة كاملة ومرتبة ترتيبًا زمنيًا لتصريحات هيئة الأوراق المالية والبورصات، باستثناء تصريحات الملكية التي نقدمها في مكان آخر.
July 8, 2025 DEFA14A

Day Hagan Smart Sector® ETF

36 North New York Avenue Huntington, NY 11743 YOUR RESPONSE IS REQUESTED Day Hagan Smart Sector® ETF Dear Shareholder: We have been trying to contact you about an important matter related to your investment.

May 23, 2025 DEF 14A

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 14A (Rule 14a-101) INFORMATION REQUIRED IN PROXY STATEMENT SCHEDULE 14A INFORMATION Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 (Ame

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 14A (Rule 14a-101) INFORMATION REQUIRED IN PROXY STATEMENT SCHEDULE 14A INFORMATION Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 (Amendment No. ) Filed by the Registrant ☒ Filed by a Party other than the Registrant ☐ Check the appropriate box: ☐ Preliminary Proxy Statement ☐ Confide

May 13, 2025 8-A12B

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR 12(g) OF THE SECURITIES EXCHANGE ACT OF 1934

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR 12(g) OF THE SECURITIES EXCHANGE ACT OF 1934 Strategy Shares (Exact name of registrant as specified in its charter) Delaware See Below (State of incorporation or organization) (I.

May 9, 2025 PRE 14A

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 14A (Rule 14a-101) INFORMATION REQUIRED IN PROXY STATEMENT SCHEDULE 14A INFORMATION Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 (Ame

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 14A (Rule 14a-101) INFORMATION REQUIRED IN PROXY STATEMENT SCHEDULE 14A INFORMATION Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 (Amendment No. ) Filed by the Registrant ☒ Filed by a Party other than the Registrant ☐ Check the appropriate box: ☒ Preliminary Proxy Statement ☐ Confide

February 12, 2025 8-A12B

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR 12(g) OF THE SECURITIES EXCHANGE ACT OF 1934

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR 12(g) OF THE SECURITIES EXCHANGE ACT OF 1934 Strategy Shares (Exact name of registrant as specified in its charter) Delaware See Below (State of incorporation or organization) (I.

December 13, 2024 8-A12B

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR 12(g) OF THE SECURITIES EXCHANGE ACT OF 1934 Strategy Shares (Exact name of registrant as sp

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR 12(g) OF THE SECURITIES EXCHANGE ACT OF 1934 Strategy Shares (Exact name of registrant as specified in its charter) Delaware See Below (State of incorporation or organization) (I.

December 3, 2024 CORRESP

* * *

Stradley Ronon Stevens & Young, LLP 2005 Market Street, Suite 2600 Philadelphia, PA 19103 215.

November 22, 2024 CORRESP

November 22, 2024

Stradley Ronon Stevens & Young, LLP 2005 Market Street, Suite 2600 Philadelphia, PA 19103 215.

September 19, 2024 8-A12B

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR 12(g) OF THE SECURITIES EXCHANGE ACT OF 1934

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR 12(g) OF THE SECURITIES EXCHANGE ACT OF 1934 Strategy Shares (Exact name of registrant as specified in its charter) Delaware See Below (State of incorporation or organization) (I.

August 21, 2024 CORRESP

August 21, 2024

Stradley Ronon Stevens & Young, LLP 2005 Market Street, Suite 2600 Philadelphia, PA 19103 215.

October 25, 2023 CORRESP

October 25, 2023

Stradley Ronon Stevens & Young, LLP 2005 Market Street, Suite 2600 Philadelphia, PA 19103 215.

January 25, 2023 AW

STRATEGY SHARES 36 North New York Avenue Huntington, NY 11743

STRATEGY SHARES 36 North New York Avenue Huntington, NY 11743 January 25, 2023 VIA EDGAR Public Filing Desk Securities and Exchange Commission 100 F Street, N.

November 2, 2022 CORRESP

November 1, 2022

Stradley Ronon Stevens & Young, LLP 2005 Market Street, Suite 2600 Philadelphia, PA 19103 215.

September 28, 2022 NPORT-EX

Fair Value

Day Hagan/Ned Davis Research Smart Sector ETF (SSUS) July 31, 2022 (Unaudited) Portfolio of Investments Summary Table Percentage of Fair Value Exchange-Traded Funds 100.

September 28, 2022 NPORT-EX

Fair Value

Day Hagan/Ned Davis Research Smart Sector ETF (SSUS) July 31, 2022 (Unaudited) Portfolio of Investments Summary Table Percentage of Fair Value Exchange-Traded Funds 100.

September 28, 2022 NPORT-EX

Fair Value

Day Hagan/Ned Davis Research Smart Sector ETF (SSUS) July 31, 2022 (Unaudited) Portfolio of Investments Summary Table Percentage of Fair Value Exchange-Traded Funds 100.

September 28, 2022 NPORT-EX

Fair Value

Day Hagan/Ned Davis Research Smart Sector ETF (SSUS) July 31, 2022 (Unaudited) Portfolio of Investments Summary Table Percentage of Fair Value Exchange-Traded Funds 100.

September 28, 2022 NPORT-EX

Fair Value

Day Hagan/Ned Davis Research Smart Sector ETF (SSUS) July 31, 2022 (Unaudited) Portfolio of Investments Summary Table Percentage of Fair Value Exchange-Traded Funds 100.

September 28, 2022 NPORT-EX

Fair Value

Day Hagan/Ned Davis Research Smart Sector ETF (SSUS) July 31, 2022 (Unaudited) Portfolio of Investments Summary Table Percentage of Fair Value Exchange-Traded Funds 100.

September 28, 2022 NPORT-EX

Fair Value

Day Hagan/Ned Davis Research Smart Sector ETF (SSUS) July 31, 2022 (Unaudited) Portfolio of Investments Summary Table Percentage of Fair Value Exchange-Traded Funds 100.

September 28, 2022 NPORT-EX

Fair Value

Day Hagan/Ned Davis Research Smart Sector ETF (SSUS) July 31, 2022 (Unaudited) Portfolio of Investments Summary Table Percentage of Fair Value Exchange-Traded Funds 100.

June 30, 2022 8-A12B

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR 12(g) OF THE SECURITIES EXCHANGE ACT OF 1934

8-A12B 1 dayhagan8a12b.htm 8-A12B UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR 12(g) OF THE SECURITIES EXCHANGE ACT OF 1934 Strategy Shares (Exact name of registrant as specified in its charter) Delaware See Below (State of incorporation or organization) (I.R.S. Employer Identification

June 17, 2022 CORRESP

June 17, 2022

Stradley Ronon Stevens & Young, LLP 2005 Market Street, Suite 2600 Philadelphia, PA 19103 215.

March 31, 2022 NPORT-EX

Fair Value

Strategy Shares Nasdaq 5HANDLTM Index ETF (FIVR) January 31, 2022 (Unaudited) Portfolio of Investments Summary Table Percentage of Fair Value Exchange-Traded Funds 100.

March 31, 2022 NPORT-EX

Fair Value

Strategy Shares Nasdaq 5HANDLTM Index ETF (FIVR) January 31, 2022 (Unaudited) Portfolio of Investments Summary Table Percentage of Fair Value Exchange-Traded Funds 100.

March 31, 2022 NPORT-EX

Fair Value

Strategy Shares Nasdaq 5HANDLTM Index ETF (FIVR) January 31, 2022 (Unaudited) Portfolio of Investments Summary Table Percentage of Fair Value Exchange-Traded Funds 100.

March 31, 2022 NPORT-EX

Fair Value

Strategy Shares Nasdaq 5HANDLTM Index ETF (FIVR) January 31, 2022 (Unaudited) Portfolio of Investments Summary Table Percentage of Fair Value Exchange-Traded Funds 100.

March 31, 2022 NPORT-EX

Fair Value

Strategy Shares Nasdaq 5HANDLTM Index ETF (FIVR) January 31, 2022 (Unaudited) Portfolio of Investments Summary Table Percentage of Fair Value Exchange-Traded Funds 100.

March 31, 2022 NPORT-EX

Fair Value

Strategy Shares Nasdaq 5HANDLTM Index ETF (FIVR) January 31, 2022 (Unaudited) Portfolio of Investments Summary Table Percentage of Fair Value Exchange-Traded Funds 100.

March 31, 2022 NPORT-EX

Fair Value

Strategy Shares Nasdaq 5HANDLTM Index ETF (FIVR) January 31, 2022 (Unaudited) Portfolio of Investments Summary Table Percentage of Fair Value Exchange-Traded Funds 100.

January 7, 2022 8-A12B

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR 12(g) OF THE SECURITIES EXCHANGE ACT OF 1934

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR 12(g) OF THE SECURITIES EXCHANGE ACT OF 1934 Strategy Shares (Exact name of registrant as specified in its charter) Delaware See Below (State of incorporation or organization) (I.

December 29, 2021 CORRESP

December 29, 2021

Stradley Ronon Stevens & Young, LLP 2005 Market Street, Suite 2600 Philadelphia, PA 19103 215.

December 28, 2021 8-A12B

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR 12(g) OF THE SECURITIES EXCHANGE ACT OF 1934

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR 12(g) OF THE SECURITIES EXCHANGE ACT OF 1934 Strategy Shares (Exact name of registrant as specified in its charter) Delaware See Below (State of incorporation or organization) (I.

December 27, 2021 CORRESP

December 23, 2021

Stradley Ronon Stevens & Young, LLP 2005 Market Street, Suite 2600 Philadelphia, PA 19103 215.

December 9, 2021 CORRESP

December 9, 2021

CORRESP 1 filename1.htm Stradley Ronon Stevens & Young, LLP 2005 Market Street, Suite 2600 Philadelphia, PA 19103 215.564.8000 www.stradley.com Michael P. O’Hare (215) 564-8198 [email protected] December 9, 2021 VIA EDGAR U.S. Securities and Exchange Commission Division of Investment Management 100 F Street, N.E. Washington, D.C. 20549-9303 Attention: Elisabeth Bentzinger Re: Strategy Shares (“R

December 2, 2021 AW

STRATEGY SHARES 36 North New York Avenue Huntington, NY 11743

AW 1 ssaw.htm AW STRATEGY SHARES 36 North New York Avenue Huntington, NY 11743 December 2, 2021 VIA EDGAR Public Filing Desk Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: Strategy Shares (File Nos. 333-170750 and 811-22497) Request for Withdrawal of Amendments to Registration Statement on Form N-1A Dear Sir or Madam: Strategy Shares (the “Trust”) has determined t

October 19, 2021 CORRESP

October 19, 2021

Stradley Ronon Stevens & Young, LLP 2005 Market Street, Suite 2600 Philadelphia, PA 19103 Telephone 215.

September 28, 2021 NPORT-EX

Portfolio of Investments Summary Table

Strategy Shares Nasdaq 7HANDLTM Index ETF (HNDL) July 31, 2021 (Unaudited) Portfolio of Investments Summary Table Percentage of Fair Value Exchange-Traded Funds 100.

September 28, 2021 8-A12B

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR 12(g) OF THE SECURITIES EXCHANGE ACT OF 1934

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR 12(g) OF THE SECURITIES EXCHANGE ACT OF 1934 Strategy Shares (Exact name of registrant as specified in its charter) Delaware See Below (State of incorporation or organization) (I.

September 28, 2021 NPORT-EX

Portfolio of Investments Summary Table

Strategy Shares Nasdaq 7HANDLTM Index ETF (HNDL) July 31, 2021 (Unaudited) Portfolio of Investments Summary Table Percentage of Fair Value Exchange-Traded Funds 100.

September 28, 2021 NPORT-EX

Portfolio of Investments Summary Table

Strategy Shares Nasdaq 7HANDLTM Index ETF (HNDL) July 31, 2021 (Unaudited) Portfolio of Investments Summary Table Percentage of Fair Value Exchange-Traded Funds 100.

September 28, 2021 NPORT-EX

Portfolio of Investments Summary Table

Strategy Shares Nasdaq 7HANDLTM Index ETF (HNDL) July 31, 2021 (Unaudited) Portfolio of Investments Summary Table Percentage of Fair Value Exchange-Traded Funds 100.

September 22, 2021 CORRESP

September 22, 2021

CORRESP 1 filename1.htm Stradley Ronon Stevens & Young, LLP 2005 Market Street, Suite 2600 Philadelphia, PA 19103 215.564.8000 www.stradley.com Michael P. O’Hare (215) 564-8198 [email protected] September 22, 2021 VIA EDGAR U.S. Securities and Exchange Commission Division of Investment Management 100 F Street, N.E. Washington, D.C. 20549-9303 Attention: Elisabeth Bentzinger Re: Strategy Shares (

July 26, 2021 CORRESP

July 26, 2021

Stradley Ronon Stevens & Young, LLP 2005 Market Street, Suite 2600 Philadelphia, PA 19103 Telephone 215.

July 14, 2021 CORRESP

July 14, 2021

\ Stradley Ronon Stevens & Young, LLP 2005 Market Street, Suite 2600 Philadelphia, PA 19103 Telephone 215.

April 27, 2021 8-A12B

- 8-A12B

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR 12(g) OF THE SECURITIES EXCHANGE ACT OF 1934 Strategy Shares (Exact name of registrant as specified in its charter) Delaware See Below (State of incorporation or organization) (I.

March 30, 2021 NPORT-EX

Fair Value

Strategy Shares Nasdaq 7HANDLTM Index ETF (HNDL) January 31, 2021 Portfolio of Investments Summary Table Percentage of Fair Value Exchange-Traded Funds 100.

March 30, 2021 NPORT-EX

Fair Value

Strategy Shares Nasdaq 7HANDLTM Index ETF (HNDL) January 31, 2021 Portfolio of Investments Summary Table Percentage of Fair Value Exchange-Traded Funds 100.

March 30, 2021 NPORT-EX

Fair Value

Strategy Shares Nasdaq 7HANDLTM Index ETF (HNDL) January 31, 2021 Portfolio of Investments Summary Table Percentage of Fair Value Exchange-Traded Funds 100.

February 10, 2021 CORRESP

February 9, 2021

Stradley Ronon Stevens & Young, LLP 2005 Market Street, Suite 2600 Philadelphia, PA 19103 215.

January 15, 2021 CORRESP

January 15, 2021

Stradley Ronon Stevens & Young, LLP 2005 Market Street, Suite 2600 Philadelphia, PA 19103 215.

October 9, 2020 CORRESP

October 9, 2020

Stradley Ronon Stevens & Young, LLP 2005 Market Street, Suite 2600 Philadelphia, PA 19103 Telephone 215.

September 24, 2020 NPORT-EX

Fair Value

Strategy Shares Nasdaq 7HANDLTM Index ETF (HNDL) July 31, 2020 (Unaudited) Portfolio of Investments Summary Table Percentage of Fair Value Exchange-Traded Funds 100.

September 24, 2020 NPORT-EX

Fair Value

Strategy Shares Nasdaq 7HANDLTM Index ETF (HNDL) July 31, 2020 (Unaudited) Portfolio of Investments Summary Table Percentage of Fair Value Exchange-Traded Funds 100.

September 24, 2020 NPORT-EX

Fair Value

Strategy Shares Nasdaq 7HANDLTM Index ETF (HNDL) July 31, 2020 (Unaudited) Portfolio of Investments Summary Table Percentage of Fair Value Exchange-Traded Funds 100.

April 24, 2020 EX-99.25

EX-99.25

NOTIFICATION OF THE REMOVAL FROM LISTING AND REGISTRATION OF THE STATED SECURITIES NYSE Arca hereby notifies the SEC of its intention to remove the entire class of the stated securities from listing and registration on the Exchange at the opening of business on May 05, 2020, pursuant to the provisions of Rule 12d2-2 (a).

April 24, 2020 EX-99.25

EX-99.25

NOTIFICATION OF THE REMOVAL FROM LISTING AND REGISTRATION OF THE STATED SECURITIES NYSE Arca hereby notifies the SEC of its intention to remove the entire class of the stated securities from listing and registration on the Exchange at the opening of business on May 05, 2020, pursuant to the provisions of Rule 12d2-2 (a).

March 18, 2020 N-Q

HUSE / Strategy Shares US Market Rotation Strategy ETF N-Q - Quarterly Schedule of Portfolio Holdings - N-Q

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number: 811-22497 Strategy Shares (Exact name of registrant as specified in charter) 36 North New York Avenue, Huntington, NY 11743 (Address of principal executive offices) (Zip code) Citi Fund Services Ohio, Inc.

March 18, 2020 N-Q

SSUS / Day Hagan/Ned Davis Research Smart Sector ETF N-Q - Quarterly Schedule of Portfolio Holdings - N-Q

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number: 811-22497 Strategy Shares (Exact name of registrant as specified in charter) 36 North New York Avenue, Huntington, NY 11743 (Address of principal executive offices) (Zip code) Citi Fund Services Ohio, Inc.

March 18, 2020 EX-99.CERT

Certifications pursuant to Rule 30a-2(a) are attached hereto

CERTIFICATIONS I, Jerry Szilagyi, certify that: 1. I have reviewed this report on Form N-Q of Strategy Shares (the “registrant”); 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the

March 18, 2020 EX-99.CERT

Certifications pursuant to Rule 30a-2(a) are attached hereto

CERTIFICATIONS I, Jerry Szilagyi, certify that: 1. I have reviewed this report on Form N-Q of Strategy Shares (the “registrant”); 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the

January 14, 2020 8-A12B

HUSE / Strategy Shares US Market Rotation Strategy ETF 8-A12B - - 8-A12B

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR 12(g) OF THE SECURITIES EXCHANGE ACT OF 1934 Strategy Shares (Exact name of registrant as specified in its charter) Delaware See Below (State of incorporation or organization) (I.

December 23, 2019 CORRESP

HNDL / Strategy Shares Nasdaq 7 HANDL(TM) Index ETF CORRESP - -

Stradley Ronon Stevens & Young, LLP 2005 Market Street, Suite 2600 Philadelphia, PA 19103 215.

October 30, 2019 8-A12B

Strategy Shares 8-A12B - - 8-A12B

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR 12(g) OF THE SECURITIES EXCHANGE ACT OF 1934 Strategy Shares (Exact name of registrant as specified in its charter) Delaware See Below (State of incorporation or organization) (I.

October 25, 2019 CORRESP

Strategy Shares CORRESP - -

Stradley Ronon Stevens & Young, LLP 2005 Market Street, Suite 2600 Philadelphia, PA 19103 215.

September 20, 2019 N-Q

Strategy Shares N-Q - Quarterly Schedule of Portfolio Holdings - N-Q

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number: 811-22497 Strategy Shares (Exact name of registrant as specified in charter) 36 North New York Avenue, Huntington, NY 11743 (Address of principal executive offices) (Zip code) Citi Fund Services Ohio, Inc.

September 20, 2019 EX-99.CERT

Certifications pursuant to Rule 30a-2(a) are attached hereto.

CERTIFICATIONS I, Jerry Szilagyi, certify that: 1. I have reviewed this report on Form N-Q of Strategy Shares (the “registrant”); 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the

August 13, 2019 CORRESP

August 13, 2019

Stradley Ronon Stevens & Young, LLP 2005 Market Street, Suite 2600 Philadelphia, PA 19103 Telephone 215.

August 2, 2019 CORRESP

August 2, 2019

Stradley Ronon Stevens & Young, LLP 2005 Market Street, Suite 2600 Philadelphia, PA 19103 Telephone 215.

March 20, 2019 N-Q

Strategy Shares N-Q (Quarterly Schedule of Portfolio Holdings)

N-Q 1 strategysharesnq.htm N-Q UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number: 811-22497 Strategy Shares (Exact name of registrant as specified in charter) 36 North New York Avenue, Huntington, NY 11743 (Address of principal executive offices) (Zip

March 20, 2019 EX-99.CERT

I, Jerry Szilagyi, certify that:

EX-99.CERT 2 cert1.htm CERTIFICATIONS I, Jerry Szilagyi, certify that: 1. I have reviewed this report on Form N-Q of Strategy Shares (the “registrant”); 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not mislead

December 7, 2018 CORRESP

Strategy Shares CORRESP

December 6, 2018 VIA EDGAR Elisabeth M. Bentzinger Senior Counsel U.S. Securities and Exchange Commission Division of Investment Management, Disclosure Review Office 100 F Street NE Washington DC 20549 Re: Strategy Shares, File Nos. 333-170750, 811-22497 Dear Ms. Bentzinger: On September 27, 2018, Strategy Shares (the "Registrant"), on behalf of its series, the Strategy Shares Drawbridge Dynamic A

September 27, 2018 CORRESP

VIA ELECTRONIC TRANSMISSION

September 27, 2018 VIA ELECTRONIC TRANSMISSION Attn: Filing Desk U.S. Securities & Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: Strategy Shares, File Nos. 333-170750 and 811-22497 Dear Sir/Madam: On behalf of Strategy Shares (the “Trust”), a registered investment company, we hereby submit, via electronic filing, Post-Effective Amendment No. 47 to the Trust’s Registration State

September 25, 2018 EX-99.CERT

I, James Szilagyi, certify that:

CERTIFICATIONS I, James Szilagyi, certify that: 1. I have reviewed this report on Form N-Q of Strategy Shares (the “registrant”); 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the

September 25, 2018 EX-99.CERT

I, Jerry Szilagyi, certify that:

CERTIFICATIONS I, Jerry Szilagyi, certify that: 1. I have reviewed this report on Form N-Q of Strategy Shares (the “registrant”); 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the

September 25, 2018 N-Q

Strategy Shares N-Q (Quarterly Schedule of Portfolio Holdings)

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number: 811-22497 Strategy Shares (Exact name of registrant as specified in charter) 36 North New York Avenue, Huntington, NY 11743 (Address of principal executive offices) (Zip code) Citi Fund Services Ohio, Inc.

September 21, 2018 DEF 14C

Strategy Shares DEF 14C

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, DC 20549 SCHEDULE 14C (RULE 14c-101) SCHEDULE 14C INFORMATION Information Statement Pursuant to Section 14(c) of the Securities Exchange Act of 1934 Check the appropriate box: £ Preliminary information statement £ Confidential, for use of the Commission only (as permitted by Rule 14c-5(d)(2)) R Definitive information statement STRATEGY SHARES (Name of Registrant as Specified in Its Charter) Payment of Filing Fee (Check the appropriate box): R No Fee required.

September 7, 2018 CORRESP

Strategy Shares CORRESP

CORRESP 1 filename1.htm September 7, 2018 VIA EDGAR Elisabeth M. Bentzinger Senior Counsel U.S. Securities and Exchange Commission Division of Investment Management, Disclosure Review Office 100 F Street NE Washington DC 20549 Re: Strategy Shares, File Nos. 333-170750, 811-22497 Dear Ms. Bentzinger: On June 28, 2018, Strategy Shares (the "Registrant"), on behalf of its series, the Strategy Shares

August 23, 2018 CORRESP

Strategy Shares CORRESP

August 22, 2018 VIA EDGAR Elisabeth M. Bentzinger Senior Counsel U.S. Securities and Exchange Commission Division of Investment Management, Disclosure Review Office 100 F Street NE Washington DC 20549 Re: Strategy Shares, File Nos. 333-170750, 811-22497 Dear Ms. Bentzinger: On June 29, 2018, Strategy Shares (the "Registrant"), on behalf of its series, the Strategy Shares Nasdaq 7 HANDL Index ETF (

August 23, 2018 CORRESP

Strategy Shares CORRESP

August 22, 2018 VIA EDGAR Elisabeth M. Bentzinger Senior Counsel U.S. Securities and Exchange Commission Division of Investment Management, Disclosure Review Office 100 F Street NE Washington DC 20549 Re: Strategy Shares, File Nos. 333-170750, 811-22497 Dear Ms. Bentzinger: On July 2, 2018, Strategy Shares (the "Registrant"), on behalf of its series, the Strategy Shares US Market Rotation Strategy

July 2, 2018 CORRESP

July 2, 2018

July 2, 2018 VIA ELECTRONIC TRANSMISSION Attn: Filing Desk U.S. Securities & Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: Strategy Shares, File Nos. 333-170750 and 811-22497 Dear Sir/Madam: On behalf of Strategy Shares (the “Trust”), a registered investment company, we hereby submit, via electronic filing, Post-Effective Amendment No. 40 to the Trust’s Registration Statement (

June 28, 2018 CORRESP

VIA ELECTRONIC TRANSMISSION

June 28, 2018 VIA ELECTRONIC TRANSMISSION Attn: Filing Desk U.S. Securities & Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: Strategy Shares, File Nos. 333-170750 and 811-22497 Dear Sir/Madam: On behalf of Strategy Shares (the “Trust”), a registered investment company, we hereby submit, via electronic filing, Post-Effective Amendment No. 38 to the Trust’s Registration Statement

March 29, 2018 N-Q

Strategy Shares N-Q (Quarterly Schedule of Portfolio Holdings)

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number: 811-22497 Strategy Shares (Exact name of registrant as specified in charter) 36 North New York Avenue, Huntington, NY 11743 (Address of principal executive offices) (Zip code) Citi Fund Services Ohio, Inc.

March 29, 2018 EX-99.CERT

I, Jerry Szilagyi, certify that:

CERTIFICATIONS I, Jerry Szilagyi, certify that: 1. I have reviewed this report on Form N-Q of Strategy Shares (the “registrant”); 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the

January 12, 2018 EX-99.H OTH MAT CONT

Sub-License Agreement between Nasdaq, Inc. and Rational Advisors, Inc. with respect to Strategy Shares 7HANDL Index ETF – Incorporated herein by reference to Registrant’s Post-Effective Amendment No. 36 filed on January 12, 2018.

Sublicense Agreement Nasdaq 7HANDL Index This agreement (?Agreement?), is made by and between Rational Advisors, Inc.

January 12, 2018 POS EX

SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-1A REGISTRATION STATEMENT

SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-1A REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 Pre-Effective Amendment No.

January 11, 2018 8-A12B

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR 12(g) OF THE SECURITIES EXCHANGE ACT OF 1934

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR 12(g) OF THE SECURITIES EXCHANGE ACT OF 1934 Strategy Shares (Exact name of registrant as specified in its charter) Delaware See Below (State of incorporation or organization) (I.

December 22, 2017 CORRESP

Strategy Shares ESP

Blu Giant, LLC December 22, 2017 VIA EDGAR David Orlic Office of Disclosure and Review Division of Investment Management U.

September 28, 2017 N-Q

Strategy Shares - N-Q

N-Q 1 strategysharesnq.htm N-Q UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number: 811-22497 Strategy Shares (Exact name of registrant as specified in charter) 36 North New York Avenue, Huntington, NY 11743 (Address of principal executive offices) (Zip

September 28, 2017 EX-99.CERT

I, Jerry Szilagyi, certify that:

CERTIFICATIONS I, Jerry Szilagyi, certify that: 1. I have reviewed this report on Form N-Q of Strategy Shares (the “registrant”); 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the

September 15, 2017 CORRESP

VIA ELECTRONIC TRANSMISSION

September 14, 2017 VIA ELECTRONIC TRANSMISSION Attn: Filing Desk U.S. Securities & Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: Strategy Shares, File Nos. 333-170750 and 811-22497 Dear Sir/Madam: On behalf of Strategy Shares (the “Trust”), a registered investment company, we hereby submit, via electronic filing, Post-Effective Amendment No. 31 to the Trust’s Registration State

March 29, 2017 EX-99.CERT

I, Jerry Szilagyi, certify that:

CERTIFICATIONS I, Jerry Szilagyi, certify that: 1. I have reviewed this report on Form N-Q of Strategy Shares (the “registrant”); 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the

March 29, 2017 N-Q

Strategy Shares - N-Q

N-Q 1 strategysharesnq.htm N-Q UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number: 811-22497 Strategy Shares (Exact name of registrant as specified in charter) 36 North New York Avenue, Huntington, NY 11743 (Address of principal executive offices) (Zip

March 21, 2017 8-A12B

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR 12(g) OF THE SECURITIES EXCHANGE ACT OF 1934

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR 12(g) OF THE SECURITIES EXCHANGE ACT OF 1934 Strategy Shares (Exact name of registrant as specified in its charter) Delaware See Below (State of incorporation or organization) (I.

December 1, 2016 CORRESP

December 1, 2016

December 1, 2016 VIA EDGAR Elisabeth Bentzinger Office of Disclosure and Review Division of Investment Management U.

September 29, 2016 EX-99.CERT

I, Jerry Szilagyi, certify that:

Blu Giant, LLC CERTIFICATIONS I, Jerry Szilagyi, certify that: 1. I have reviewed this report on Form N-Q of Strategy Shares (the “registrant”); 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with

September 29, 2016 N-Q

Strategy Shares - N-Q

Blu Giant, LLC UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number: 811-22497 Strategy Shares (Exact name of registrant as specified in charter) 36 North New York Avenue, Huntington, NY 11743 (Address of principal executive offices) (Zip code) Citi Fund Services Ohio, Inc.

September 21, 2016 CORRESP

* * * * *

September 21, 2016 Elisabeth Bentzinger Office of Disclosure and Review Division of Investment Management U.

September 16, 2016 AW

Ladies and Gentleman:

September 16, 2016 Securities and Exchange Commission Public Filing Desk 100 F Street, N.

August 26, 2016 DEF 14C

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, DC 20549 SCHEDULE 14C (RULE 14c-101) SCHEDULE 14C INFORMATION Information Statement Pursuant to Section 14(c) of the Securities Exchange Act of 1934

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, DC 20549 SCHEDULE 14C (RULE 14c-101) SCHEDULE 14C INFORMATION Information Statement Pursuant to Section 14(c) of the Securities Exchange Act of 1934 Check the appropriate box: ? Preliminary information statement ? Confidential, for use of the Commission only (as permitted by Rule 14c-5(d)(2)) R Definitive information statement Strategy Shares (Name of Registrant as Specified in Its Charter) Payment of Filing Fee (Check the appropriate box): R No Fee required.

August 26, 2016 DEF 14C

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, DC 20549 SCHEDULE 14C (RULE 14c-101) SCHEDULE 14C INFORMATION Information Statement Pursuant to Section 14(c) of the Securities Exchange Act of 1934

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, DC 20549 SCHEDULE 14C (RULE 14c-101) SCHEDULE 14C INFORMATION Information Statement Pursuant to Section 14(c) of the Securities Exchange Act of 1934 Check the appropriate box: ? Preliminary information statement ? Confidential, for use of the Commission only (as permitted by Rule 14c-5(d)(2)) R Definitive information statement Strategy Shares (Name of Registrant as Specified in Its Charter) Payment of Filing Fee (Check the appropriate box): R No Fee required.

August 15, 2016 CORRESP

* * * * *

August 15, 2016 Elizabeth Bentzinger Office of Disclosure and Review Division of Investment Management U.

August 9, 2016 CORRESP

Compensation from the Fund Complex*

August 9, 2016 Elizabeth Bentzinger Office of Disclosure and Review Division of Investment Management U.

July 6, 2016 CORRESP

VIA ELECTRONIC TRANSMISSION

Blu Giant, LLC July 6, 2016 VIA ELECTRONIC TRANSMISSION Attn: Filing Desk U.S. Securities & Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: Strategy Shares, File Nos. 333-170750 and 811-22497 Dear Sir/Madam: On behalf of Strategy Shares (the “Trust”), a registered investment company, we hereby submit, via electronic filing, Post-Effective Amendment No. 10 to the Trust’s Registrat

June 28, 2016 CORRESP

VIA ELECTRONIC TRANSMISSION

June 27, 2016 VIA ELECTRONIC TRANSMISSION Attn: Filing Desk U.S. Securities & Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: Strategy Shares, File Nos. 333-170750 and 811-22497 Dear Sir/Madam: On behalf of Strategy Shares (the “Trust”), a registered investment company, we hereby submit, via electronic filing, Post-Effective Amendment No. 9 to the Trust’s Registration Statement (

June 8, 2016 CORRESP

VIA ELECTRONIC TRANSMISSION

June 7, 2016 VIA ELECTRONIC TRANSMISSION Attn: Filing Desk U.S. Securities & Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: Strategy Shares, File Nos. 333-170750 and 811-22497 Dear Sir/Madam: On behalf of Strategy Shares (the ?Trust?), a registered investment company, we hereby submit, via electronic filing, Post-Effective Amendment No. 8 to the Trust?s Registration Statement (t

March 18, 2016 N-Q

Strategy Shares - N-Q

Blu Giant, LLC UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number: 811-22497 Strategy Shares (Exact name of registrant as specified in charter) 2960 North Meridian Street, Suite 300, Indianapolis, IN 46208 (Address of principal executive offices) (Zip code) Citi Fund Services Ohio, Inc.

March 18, 2016 EX-99.CERT

I, Lisa K. Householder, certify that:

CERTIFICATIONS I, Lisa K. Householder, certify that: 1. I have reviewed this report on Form N-Q of Strategy Shares (the “registrant”); 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect t

December 18, 2015 DEFR14A

2960 North Meridian Street, Indianapolis, IN 46208

NOTICE OF MEETING ADJOURNMENT December 18, 2015 We are almost there, but we still need your help.

November 13, 2015 DEF 14A

SCHEDULE 14A INFORMATION Proxy Statement Pursuant to Section 14 (a) of the Securities Exchange Act of 1934 (Amendment No. )

SCHEDULE 14A INFORMATION Proxy Statement Pursuant to Section 14 (a) of the Securities Exchange Act of 1934 (Amendment No.

November 12, 2015 CORRESP

Huntington Strategy Shares CIK 0001506213 (File No. 811-22497)

November 12, 2015 VIA EDGAR EDGAR Operations Branch Division of Investment Management Securities and Exchange Commission 100 F Street, N.

October 29, 2015 PRE 14A

SCHEDULE 14A INFORMATION Proxy Statement Pursuant to Section 14 (a) of the Securities Exchange Act of 1934 (Amendment No. )

PRE 14A 1 d56236dpre14a.htm HUNTINGTON STRATEGY SHARES SCHEDULE 14A INFORMATION Proxy Statement Pursuant to Section 14 (a) of the Securities Exchange Act of 1934 (Amendment No. ) Filed by the Registrant x Filed by a Party other than the Registrant ¨ Check the appropriate box: x Preliminary Proxy Statement ¨ Confidential, for Use of the Commission Only (as permitted by Rule 14a-6(e)(2)) ¨ Definitiv

October 29, 2015 COVER

Huntington Strategy Shares CIK 0001506213 (File No. 811-22497)

SEC Cover Letter October 29, 2015 VIA EDGAR EDGAR Operations Branch Division of Investment Management Securities and Exchange Commission 100 F Street, N.

September 24, 2015 EX-99.CERT

I Daniel Brewer, certify that:

CERTIFICATIONS PURSUANT TO SECTION 302 CERTIFICATIONS I Daniel Brewer, certify that: 1.

September 24, 2015 N-Q

Strategy Shares - HUNTINGTON STRATEGY SHARES

Huntington Strategy Shares UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number: 811-22497 Huntington Strategy Shares (Exact name of registrant as specified in charter) 2960 North Meridian Street, Suite 300, Indianapolis, IN 46208 (Address of principal executive offices) (Zip code) Citi Fund Services Ohio, Inc.

September 10, 2015 CORRESP

August 26, 2015

Huntington Asset Services, Inc. 2960 N. Meridian St. Ste. 300 Indianapolis, IN 46208 August 26, 2015 VIA EDGAR EDGAR Operations Branch Division of Investment Management Securities and Exchange Commission 100 F Street, N.E. Washington, DC 20549 Attention: Ms. Laura Hatch Huntington Strategy Shares SEC File No. 811-22497 Dear Ms. Hatch: Below please find our responses to your comments with respect t

March 31, 2015 EX-99.CERT

I R. Jeffrey Young, certify that:

CERTIFICATIONS I R. Jeffrey Young, certify that: 1. I have reviewed this report on Form N-Q of Huntington Strategy Shares (the “registrant”); 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with re

March 31, 2015 N-Q

Strategy Shares - HUNTINGTON STRATEGY SHARES

Huntington Strategy Shares UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number: 811-22497 Huntington Strategy Shares (Exact name of registrant as specified in charter) 2960 North Meridian Street, Suite 300, Indianapolis, IN 46208 (Address of principal executive offices) (Zip code) Citi Fund Services Ohio, Inc.

September 26, 2014 EX-99.CERT

I R. Jeffrey Young, certify that:

CERTIFICATIONS I R. Jeffrey Young, certify that: 1. I have reviewed this report on Form N-Q of Huntington Strategy Shares (the “registrant”); 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with re

September 26, 2014 N-Q

Strategy Shares - HUNTINGTON STRATEGY SHARES

Huntington Strategy Shares UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number: 811-22497 HUNTINGTON STRATEGY SHARES (Exact name of registrant as specified in charter) 2960 NORTH MERIDIAN STREET, SUITE 300, INDIANAPOLIS, IN 46208 (Address of principal executive offices) (Zip code) CITI FUND SERVICES OHIO, INC.

March 28, 2014 EX-99.CERT

I, R. Jeffrey Young, certify that:

CERTIFICATIONS I, R. Jeffrey Young, certify that: 1. I have reviewed this report on Form N-Q of Huntington Strategy Shares (the “registrant”); 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with r

March 28, 2014 N-Q

Quarterly Schedule of Portfolio Holdings - HUNTINGTON STRATEGY SHARES

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number 811-22497 Huntington Strategy Shares (Exact name of registrant as specified in charter) 2960 North Meridian Street, Suite 300 Indianapolis, IN 46208 (Address of principal executive offices) (Zip Code) Citi Fund Services Ohio, Inc.

September 27, 2013 N-Q

Quarterly Schedule of Portfolio Holdings - HUNTINGTON STRATEGY SHARES

Huntington Strategy Shares UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number 811-22497 Huntington Strategy Shares (Exact name of registrant as specified in charter) 2960 North Meridian Street, Suite 300 Indianapolis, IN 46208 (Address of principal executive offices) (Zip Code) Citi Fund Services Ohio, Inc.

September 27, 2013 EX-99.CERT

I, R. Jeffrey Young

CERTIFICATIONS I, R. Jeffrey Young, certify that: 1. I have reviewed this report on Form N-Q of Huntington Strategy Shares (the “registrant”); 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with r

March 25, 2013 EX-99.CERT

I, R. Jeffrey Young, certify that:

Certifications pursuant to Rule 30a-2(a) CERTIFICATIONS I, R. Jeffrey Young, certify that: 1. I have reviewed this report on Form N-Q of Huntington Strategy Shares (the “registrant”); 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such st

March 25, 2013 N-Q

Quarterly Schedule of Portfolio Holdings - FORM N-Q

Form N-Q UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number 811-22497 Huntington Strategy Shares (Exact name of registrant as specified in charter) 2960 North Meridian Street, Suite 300 Indianapolis, IN 46208 (Address of principal executive offices) (Zip Code) Citi Fund Services Ohio, Inc.

September 27, 2012 EX-99.CERT

R. Jeffrey Young,

Certification CERTIFICATIONS I, R. Jeffrey Young, certify that: 1. I have reviewed this report on Form N-Q of Huntington Strategy Shares (the “registrant”); 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not mis

September 27, 2012 N-Q

Quarterly Schedule of Portfolio Holdings - HUNTINGTON STRATEGY SHARES FORM N-Q

Huntington Strategy Shares Form N-Q UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number 811-22497 Huntington Strategy Shares (Exact name of registrant as specified in charter) 2960 North Meridian St, Suite 300 Indianapolis, IN 46208 (Address of principal executive offices) (Zip Code) R.

June 4, 2012 8-A12B

- FORM 8-A12B

Form 8-A12B UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) or (g) OF THE SECURITIES EXCHANGE ACT OF 1934 Huntington Strategy Shares (Exact name of registrant as specified in its charter) Delaware See Below (State of incorporation or organization) (IRS Employer Identification No.) c/o Hunti

June 1, 2012 EX-99.D.1

HUNTINGTON STRATEGY SHARES INVESTMENT ADVISORY AGREEMENT

Form of Advisory Agreement HUNTINGTON STRATEGY SHARES INVESTMENT ADVISORY AGREEMENT This Agreement is made as of the 11th day of May, 2012, between HUNTINGTON STRATEGY SHARES, a statutory trust organized under the laws of the State of Delaware (herein called the “Trust”) and HUNTINGTON ASSET ADVISORS, INC.

June 1, 2012 EX-99.M

HUNTINGTON STRATEGY SHARES DISTRIBUTION PLAN

Distribution Plan HUNTINGTON STRATEGY SHARES DISTRIBUTION PLAN This Plan constitutes the Distribution Plan (“Plan”) of HUNTINGTON STRATEGY SHARES, a Delaware statutory trust (the “Trust”), with respect to shares (“Shares”) of those certain series of the Trust (the “Funds”) set forth in an exhibit hereto.

June 1, 2012 EX-99.I

June 1

Opinion and Consent of Counsel June 1, 2012 Huntington Strategy Shares 2960 North Meridian Street, Suite 300 Indianapolis, IN 46208 Ladies and Gentlemen: We have acted as counsel to Huntington Strategy Shares, a Delaware statutory trust (the “Trust”), in connection with the filing with the Securities and Exchange Commission (“SEC”) of the Trust’s registration statement on Form N-1A (File Nos.

June 1, 2012 EX-99.G.2

Fee Schedule for Custodial and Services Agreement between Registrant and Citi Fund Services Ohio, Inc. (“Citi”) – Incorporated herein by reference to Registrant’s Pre-Effective Amendment No. 3 filed on June 1, 2012.

Fee Schedule for Custodian and Services Agreement Fee Schedule For Huntington Strategy Shares This Fee Schedule is effective as of April 23, 2012 and supplements the Custodian and Agency Services Agreement between Huntington Strategy Shares and Citibank, N.

June 1, 2012 N-1A/A

- PRE-EFFECTIVE AMENDMENT NO 3

Pre-Effective Amendment No 3 Table of Contents AS FILED WITH THE U.S. SECURITIES AND EXCHANGE COMMISSION ON June 1, 2012 File No.: 333-170750 File No.: 811-22497 U.S. SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-1A REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 x PRE-EFFECTIVE AMENDMENT NO. 3 ¨ POST-EFFECTIVE AMENDMENT NO. ¨ REGISTRATION STATEMENT UNDER THE INVESTMENT

June 1, 2012 EX-99.P.2

HUNTINGTON ASSET ADVISORS, INC. CODE OF ETHICS

Code of Ethics of Huntington HUNTINGTON ASSET ADVISORS, INC. CODE OF ETHICS This Code of Ethics (“Code”) is adopted in compliance with Federal Securities Laws and the requirements of Rule 204A-1 under the Investment Advisers Act of 1940, as amended (“Advisers Act”) and Rule 17j-1 under the Investment Company Act of 1940, as amended (“Company Act”). In accordance with these rules, Huntington Asset

June 1, 2012 EX-99.H.3

EXCHANGE-TRADED FUND SERVICES AGREEMENT Administrative Support Services HUNTINGTON STRATEGY SHARES HUNTINGTON ASSET SERVICES, INC. May 15, 2012

Form of Exchange-Traded Fund Services Agreement EXCHANGE-TRADED FUND SERVICES AGREEMENT Administrative Support Services between HUNTINGTON STRATEGY SHARES and HUNTINGTON ASSET SERVICES, INC.

June 1, 2012 EX-99.E.1

DISTRIBUTION AGREEMENT

Form of Distribution Agreement DISTRIBUTION AGREEMENT THIS DISTRIBUTION AGREEMENT (this “Agreement”) is made as of this 1st day of May, 2012, by and between Huntington Strategy Shares (the “Trust”), a Delaware statutory trust on behalf of its separate portfolios of securities listed on Schedule A, and SEI Investments Distribution Co.

June 1, 2012 CORRESP

-

Acceleration Request HUNTINGTON STRATEGY SHARES 2960 N. Meridian Street, Suite 300 Indianapolis, IN 46208 June 1, 2012 Via EDGAR Mary Cole Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 RE: Huntington Strategy Shares (File Nos. 333-170750; 811-22497) Dear Ms. Cole: On November 22, 2010, Huntington Strategy Shares (the “Registrant

June 1, 2012 COVER

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Leslie K. Klenk 207 228-7295 direct [email protected] June 1, 2012 VIA EDGAR TRANSMISSION Ms. Mary A. Cole United States Securities and Exchange Commission Division of Investment Management 100 F Street, N.E. Washington, D.C. 20549 Re: Huntington Strategy Shares (“Trust”) File Nos.: 333-170750; 811-22497 Dear Ms. Cole: Enclosed please find Pre-Effective Amendment No. 3 to the Trust’s regist

June 1, 2012 EX-99.H.1

SERVICES AGREEMENT HUNTINGTON STRATEGY SHARES CITI FUND SERVICES OHIO, INC. EFT Combined Services V.7.1.11 TABLE OF CONTENTS 1. DEFINITIONS 2. SERVICES AND RELATED TERMS AND CONDITIONS 3. INSTRUCTIONS 4. COMPLIANCE WITH LAWS; ADVICE 5. COMMUNICATIONS

Form of Citi Services Agreement SERVICES AGREEMENT HUNTINGTON STRATEGY SHARES and CITI FUND SERVICES OHIO, INC.

June 1, 2012 EX-99.G.1

Custodial and Agency Services Agreement between the Registrant and Citibank, N.A. (“Custody Agreement”) – Incorporated herein by reference to Registrant’s Pre-Effective Amendment No. 3 filed on June 1, 2012.

Form of Custodian and Agency Services Agreement CUSTODIAL AND AGENCY SERVICES AGREEMENT HUNTINGTON STRATEGY SHARES ETF GCSA - V.

June 1, 2012 EX-99.H.2

LETTER AGREEMENT Huntington Asset Advisors, Inc. 41 South High Street Columbus, OH 43287

Form of Expense Limitation Agreement LETTER AGREEMENT Huntington Asset Advisors, Inc.

June 1, 2012 EX-99.L

Subscription Agreement between the Registrant and The Huntington National Bank – Incorporated herein by reference to Registrant’s Pre-Effective Amendment No. 3 filed on June 1, 2012.

Subscription Agreement May 10, 2012 Huntington Strategy Shares 2960 North Meridian Street, Suite 300 Indianapolis, IN 46208 Re: Seed Capital Subscription Agreement Ladies and Gentlemen: I propose to acquire shares of beneficial interest (the “Shares”) of Huntington Strategy Shares (the “Trust”) for an aggregate price of $100,000, as follows: Fund Number of Shares Price per Share Aggregate Price Huntington EcoLogical Strategy ETF 3,999 $ 25.

June 1, 2012 EX-99.P.3

SEI INVESTMENTS DISTRIBUTION CO. RULE 17j-1 CODE OF ETHICS A copy of this Code may be accessed on the SEI intranet site under the Corporate Governance section. This is an important document. You should take the time to read it thoroughly before you s

Code of Ethics of SEI Investments Distribution Co. SEI INVESTMENTS DISTRIBUTION CO. RULE 17j-1 CODE OF ETHICS A copy of this Code may be accessed on the SEI intranet site under the Corporate Governance section. This is an important document. You should take the time to read it thoroughly before you submit the required annual certification. Any questions regarding this Code of Ethics should be refe

June 1, 2012 EX-99.E.2

Huntington Strategy Shares AUTHORIZED PARTICIPANT AGREEMENT

Form of Authorized participant Agreement Huntington Strategy Shares AUTHORIZED PARTICIPANT AGREEMENT This Authorized Participant Agreement (this “Agreement”) is entered into as of this day of 2012 (the “Effective Date”) by and between (the “Participant”) and SEI Investments Distribution Co.

June 1, 2012 EX-99.J

CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

Consent of independent registered public accountants CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM We consent to the references to our firm under the captions “Other Service Providers” in the Prospectus and “Independent Registered Public Accounting Firm” in the Statement of Additional Information and to the inclusion of our report dated May 29, 2012 on the May 14, 2012 financial statements of Huntington Strategy Shares in the Statement of Additional Information, in the Pre-Effective Amendment Number 3 to the Registration Statement (Form N-1A, No.

June 1, 2012 EX-99.P.1

HUNTINGTON STRATEGY SHARES CODE OF ETHICS

HUNTINGTON STRATEGY SHARES CODE OF ETHICS 1. Statement of General Fiduciary Principles This Code of Ethics is based on the principles that (i) Access Persons (as such term is hereinafter defined) owe a fiduciary duty to, among others, the shareholders of the Trust (as such term is hereinafter defined) to conduct their personal transactions in Covered Securities (as such term is hereinafter defined

April 6, 2012 COVER

-

Cover Letter Leslie K. Klenk 207 228-7295 direct [email protected] April 6, 2012 VIA EDGAR TRANSMISSION Ms. Mary A. Cole United States Securities and Exchange Commission Division of Investment Management 100 F Street, N.E. Washington, D.C. 20549 Re: Huntington Strategy Shares (“Trust”) File Nos.: 333-170750; 811-22497 Dear Ms. Cole: Enclosed please find Pre-Effective Amendment No. 2 to the

April 6, 2012 N-1A/A

- AMENDMENT NO 2

Amendment No 2 Table of Contents AS FILED WITH THE U.S. SECURITIES AND EXCHANGE COMMISSION ON April 6, 2012 File No.: 333-170750 File No.: 811-22497 U.S. SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-1A REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 x PRE-EFFECTIVE AMENDMENT NO. 2 ¨ POST-EFFECTIVE AMENDMENT NO. ¨ and/or REGISTRATION STATEMENT UNDER THE INVESTMENT COMPAN

April 11, 2011 CORRESP

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207 774-1200 main 207 774-1127 facsimile bernsteinshur.com B E R N S T E I N S H U R C O U N S E L O R S A T L A W 100 Middle Street PO Box 9729 Portland, ME 04104-5029 Leslie K. Klenk 207 228-7295 direct [email protected] April 11, 2011 VIA EDGAR TRANSMISSION Ms. Mary A. Cole United States Securities and Exchange Commission Division of Investment Management 100 F Street, N.E. Washington, D

April 11, 2011 N-1A/A

List of Exhibits

AS FILED WITH THE U.S. SECURITIES AND EXCHANGE COMMISSION ON April 11, 2011 File No. 333-170750 File No.: 811-22497 U.S. SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-1A REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 x PRE-EFFECTIVE AMENDMENT NO. 1 ¨ POST-EFFECTIVE AMENDMENT NO. ¨ and/or REGISTRATION STATEMENT UNDER THE INVESTMENT COMPANY ACT OF 1940 x AMENDMENT NO. 1 ¨

April 11, 2011 EX-99.16 PWR OF ATTY

HUNTINGTON STRATEGY SHARES POWER OF ATTORNEY

HUNTINGTON STRATEGY SHARES POWER OF ATTORNEY Each person whose signature appears below hereby constitutes and appoints the Secretary and Assistant Secretaries of THE HUNTINGTON STRATEGY SHARES and each of them, their true and lawful attorneys-in-fact and agents, with full power of substitution and resubstitution for them and in their names, place and stead, in any and all capacities, to sign any a

April 11, 2011 CORRESP

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207 774-1200 main 207 774-1127 facsimile bernsteinshur.com B E R N S T E I N S H U R C O U N S E L O R S A T L A W 100 Middle Street PO Box 9729 Portland, ME 04104-5029 Leslie K. Klenk 207 228-7295 direct [email protected] VIA E-MAIL AND EDGAR April 11, 2011 Ms. Mary A. Cole U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 RE: Huntington Strategy Shares File Nos

November 22, 2010 N-1A

AS FILED WITH THE U.S. SECURITIES AND EXCHANGE COMMISSION ON NOVEMBER19, 2010

AS FILED WITH THE U.S. SECURITIES AND EXCHANGE COMMISSION ON NOVEMBER19, 2010 File No. 333- File No.: 811-22497 U.S. SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-1A REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 x PRE-EFFECTIVE AMENDMENT NO. ? POST-EFFECTIVE AMENDMENT NO. ? and/or REGISTRATION STATEMENT UNDER THE INVESTMENT COMPANY ACT OF 1940 x AMENDMENT NO. ? Hunting

November 22, 2010 EX-99.16 PWR OF ATTY

HUNTINGTON STRATEGY SHARES POWER OF ATTORNEY

HUNTINGTON STRATEGY SHARES POWER OF ATTORNEY Each person whose signature appears below hereby constitutes and appoints the Secretary and Assistant Secretaries of THE HUNTINGTON STRATEGY SHARES and each of them, their true and lawful attorneys-in-fact and agents, with full power of substitution and resubstitution for them and in their names, place and stead, in any and all capacities, to sign any a

November 22, 2010 EX-99.16 PWR OF ATTY

HUNTINGTON STRATEGY SHARES POWER OF ATTORNEY

HUNTINGTON STRATEGY SHARES POWER OF ATTORNEY Each person whose signature appears below hereby constitutes and appoints the Secretary and Assistant Secretaries of THE HUNTINGTON STRATEGY SHARES and each of them, their true and lawful attorneys-in-fact and agents, with full power of substitution and resubstitution for them and in their names, place and stead, in any and all capacities, to sign any a

November 22, 2010 EX-99.1 CHARTER

Certificate of Trust of Huntington Strategy Shares (now known as Strategy Shares) (the “Trust” or the “Registrant”) – Incorporated herein by reference to Registrant’s Initial Registration Statement on Form N-1A filed on November 22, 2010.

CERTIFICATE OF TRUST OF HUNTINGTON STRATEGY SHARES a Delaware Statutory Trust This Certificate of Trust of Huntington Strategy Shares (the ?Trust?) is being duly executed and filed on behalf of the Trust by the undersigned, as initial sole trustee, in order to form a statutory trust pursuant to the Delaware Statutory Trust Act (the ?Act?), Del.

November 22, 2010 EX-99.16 PWR OF ATTY

HUNTINGTON STRATEGY SHARES POWER OF ATTORNEY

HUNTINGTON STRATEGY SHARES POWER OF ATTORNEY Each person whose signature appears below hereby constitutes and appoints the Secretary and Assistant Secretaries of THE HUNTINGTON STRATEGY SHARES and each of them, their true and lawful attorneys-in-fact and agents, with full power of substitution and resubstitution for them and in their names, place and stead, in any and all capacities, to sign any a

November 22, 2010 EX-99.16 PWR OF ATTY

HUNTINGTON STRATEGY SHARES POWER OF ATTORNEY

HUNTINGTON STRATEGY SHARES POWER OF ATTORNEY Each person whose signature appears below hereby constitutes and appoints the Secretary and Assistant Secretaries of THE HUNTINGTON STRATEGY SHARES and each of them, their true and lawful attorneys-in-fact and agents, with full power of substitution and resubstitution for them and in their names, place and stead, in any and all capacities, to sign any a

November 22, 2010 EX-99.16 PWR OF ATTY

HUNTINGTON STRATEGY SHARES POWER OF ATTORNEY

HUNTINGTON STRATEGY SHARES POWER OF ATTORNEY Each person whose signature appears below hereby constitutes and appoints the Secretary and Assistant Secretaries of THE HUNTINGTON STRATEGY SHARES and each of them, their true and lawful attorneys-in-fact and agents, with full power of substitution and resubstitution for them and in their names, place and stead, in any and all capacities, to sign any a

November 22, 2010 EX-99.16 PWR OF ATTY

HUNTINGTON STRATEGY SHARES POWER OF ATTORNEY

HUNTINGTON STRATEGY SHARES POWER OF ATTORNEY Each person whose signature appears below hereby constitutes and appoints the Secretary and Assistant Secretaries of THE HUNTINGTON STRATEGY SHARES and each of them, their true and lawful attorneys-in-fact and agents, with full power of substitution and resubstitution for them and in their names, place and stead, in any and all capacities, to sign any a

November 22, 2010 EX-99.2 BYLAWS

Registrant’s By-Laws – Incorporated herein by reference to Registrant’s Initial Registration Statement on Form N-1A filed on November 22, 2010.

BY-LAWS of Huntington Strategy Shares A Delaware Statutory Trust Dated as of September 1, 2010 < /p> INTRODUCTION A.

November 22, 2010 EX-99.1 CHARTER

Registrant’s Agreement and Declaration of Trust – Incorporated herein by reference to Registrant’s Initial Registration Statement on Form N-1A filed on November 22, 2010.

AGREEMENT AND DECLARATION OF TRUST of HUNTINGTON STRATEGY SHARES a Delaware Statutory Trust ARTICLE I.

November 22, 2010 EX-99.16 PWR OF ATTY

HUNTINGTON STRATEGY SHARES POWER OF ATTORNEY

HUNTINGTON STRATEGY SHARES POWER OF ATTORNEY Each person whose signature appears below hereby constitutes and appoints the Secretary and Assistant Secretaries of THE HUNTINGTON STRATEGY SHARES and each of them, their true and lawful attorneys-in-fact and agents, with full power of substitution and resubstitution for them and in their names, place and stead, in any and all capacities, to sign any a

November 22, 2010 EX-99.16 PWR OF ATTY

HUNTINGTON STRATEGY SHARES POWER OF ATTORNEY

HUNTINGTON STRATEGY SHARES POWER OF ATTORNEY Each person whose signature appears below hereby constitutes and appoints the Secretary and Assistant Secretaries of THE HUNTINGTON STRATEGY SHARES and each of them, their true and lawful attorneys-in-fact and agents, with full power of substitution and resubstitution for them and in their names, place and stead, in any and all capacities, to sign any a

November 22, 2010 EX-99.16 PWR OF ATTY

HUNTINGTON STRATEGY SHARES POWER OF ATTORNEY

HUNTINGTON STRATEGY SHARES POWER OF ATTORNEY Each person whose signature appears below hereby constitutes and appoints the Secretary and Assistant Secretaries of THE HUNTINGTON STRATEGY SHARES and each of them, their true and lawful attorneys-in-fact and agents, with full power of substitution and resubstitution for them and in their names, place and stead, in any and all capacities, to sign any a

November 19, 2010 N-8A

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 FORM N-8A NOTIFICATION OF REGISTRATION FILED PURSUANT TO SECTION 8(a) OF THE INVESTMENT COMPANY ACT OF 1940

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 FORM N-8A NOTIFICATION OF REGISTRATION FILED PURSUANT TO SECTION 8(a) OF THE INVESTMENT COMPANY ACT OF 1940 The undersigned investment company hereby notifies the Securities and Exchange Commission that it registers under and pursuant to the provisions of Section 8(a) of the Investment Company Act of 1940 and in connection wit

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