Paragon Advisors LLC

Item 5 – Fees and Compensation
Investment Supervisory Management
The annual fee for portfolio management services is billed quarterly in arrears and based on the
market value of client assets on the last day of the quarter. Fees will be assessed pro rata in the
event the portfolio management agreement is executed at any time other than the first day of a
calendar quarter. On an annualized basis, Paragon’s standard fees for ongoing investment
services are based on the following schedules:
                            Portfolio Size                     Annualized Fee

                            First $2,000,000                         1.20%
                            $2,000,001 to $5,000,000                 1.00%
                            $5,000,001 to $10,000,000                0.75%
                            Over $10,000,001                         0.50%
A minimum of $1,000,000 of assets under Paragon’s management is required for our services.
Paragon may group certain related client accounts for the purpose of attaining the minimum
Assets Under Management (AUM) and determining the annualized fee. Paragon imposes a
minimum $12,000 annual fee or $3,000 per quarter on portfolios with investable assets valued
under $1,000,000. Paragon reserves the right to lower or remove this minimum at its discretion.
The annual fee for investment management services provided is based upon a percentage (%) of
the market value of the Assets under management in accordance with the fee schedule in the
Agreement signed by the client. Paragon considers cash to be an asset class and part of Assets
under management and subject to the same fee calculation as the client’s non-cash investments.
Please note that we calculate our fees through our portfolio accounting system, Orion, which has
a feed from the custodian. However, the quarter end balance determined by Orion, and which we
calculate our fees, could be different from your balance on your custodial statement due to
timing of corporate actions, accrued interest, and trade settlements.
Payment for investment management fee(s) will be made by the qualified custodian holding the
client’s funds and securities provided the client provides written authorization permitting the
fee(s) to be paid directly from the client’s account(s). Paragon will not have access to client
funds for payment of fee(s) without client consent in writing. Further, the qualified custodian
agrees to deliver a monthly or quarterly account statement directly to the client showing all
disbursements from the account. The client is encouraged to review their account statements for
accuracy. Paragon will have access to a duplicate copy of the statement that was delivered to the
client. Alternatively, Paragon may invoice clients directly for portfolio management fee(s).
When clients are billed directly, payment is due upon receipt of Paragon’s invoice.
We provide an additional service for accounts not directly held by our primary custodian, but
where we do have discretion, and may leverage a third-party platform to facilitate management
of held away assets such as defined contribution plan participant accounts, with discretion. These
are primarily 401(k) accounts, HSAs, and other assets which our primary custodian will not
custody. The platform allows us to avoid being considered to have custody of Client funds since

                         Paragon Financial Advisors | Item 5 – Fees and Compensation 6

             March 6, 2026 FORM ADV PART 2A (“FIRM BROCHURE”)
                           FOR PARAGON FINANCIAL ADVISORS

we do not have direct access to Client log-in credentials to affect trades. We are not affiliated
with the platform in any way and receive no compensation from them for using their platform.
We regularly review the available investment options in these accounts, monitor them, and
rebalance and implement our strategies in the same way we do other accounts, though using
different tools as necessary.

The fee for these directly-managed held-away accounts is determined by the account value at the
end of the quarter. The advisory fee is calculated by assessing the percentage rates using the
predefined levels of assets of the service the client utilizes. As it is impossible to directly debit
the fees from these accounts, those fees will be assigned to the client’s taxable accounts on a pro-
rata basis. If the client does not have a taxable account, those fees will be billed directly to the
client. Accounts initiated or terminated during a calendar quarter will be charged a pro-rated fee
based on the amount of time remaining in the billing period. Since fees are paid in arrears, no
rebate will be needed upon termination of the account.
401(k) and other Qualified Retirement Plans
Paragon’s fee schedule for Plan Sponsor accounts is negotiable and will not exceed 1% annually.
The annual fee shall be prorated and paid quarterly, in arrears, based upon the market value of
the Client assets on the last day of the quarter. Clients may be invoiced directly for fees or may
authorize automatic deduction of fees from their accounts, where available and operationally
feasible.
Paragon serves in multiple advisory capacities with respect to retirement plans. In some cases,
we act as an investment adviser to a retirement plan or plan sponsor and separately act as an
investment adviser to one or more plan participants. When we provide services to both a plan
and a participant, separate agreements apply, and fees are charged independently.
Limited Negotiability of Advisory Fees: Although Paragon has the aforementioned customary
fee schedule, we retain the discretion to negotiate alternative fees on a client-by-client basis. The
client's circumstances and needs will be considered in determining the negotiated fee schedule.
Paragon reserves the option to charge a separate fee for financial planning in addition to the
...

Item 7 – Types of Clients
Paragon Financial Advisors offers personalized investment supervisory services to individuals,
high net worth individuals, pensions, profit-sharing plans, trusts, estates, charitable
organizations, corporations, and business entities. Client relationships vary in scope and length
of service.
Required Minimum Client Accounts
As described in Item 4, a minimum of $1,000,000 of assets under Paragon’s management is
required for our services. Paragon may group certain related client accounts for the purpose of
attaining the minimum Assets Under Management (AUM) and determining the annualized fee.
Paragon imposes a minimum $12,000 annual fee or $3,000 per quarter on portfolios with
investable assets valued under $1,000,000. Paragon reserves the right to lower or remove this
minimum at its discretion. Paragon reserves the option to charge a separate fee for financial
planning in addition to the investment management fee for relationships under $1,000,000 in
AUM.

                                Paragon Financial Advisors | Item 7 – Types of Clients 11

              March 6, 2026 FORM ADV PART 2A (“FIRM BROCHURE”)
                            FOR PARAGON FINANCIAL ADVISORS