Paragon Capital Management

ITEM 5 - FEES AND COMPENSATION
In addition to the information provided in Item 4 – Advisory Business, this section details our Firm’s services and
each service’s fees and compensation arrangement. The Client and PCM’s Investment Advisory Agreement will
outline and agree upon the exact costs and other terms related to the Client’s Accounts.

INVESTMENT MANAGEMENT FEE

Our Firm offers investment management services for an annual fee based on the amount of assets under
management. Our maximum annual fee is 0.90% based on a blended fee schedule as shown below, and we
have a minimum account size of $1,000,000. We retain the right to waive the minimum account size at our
discretion. Our Firm imposes a minimum annual fee of $7,000.

                        Assets Under Management                    Annual Fee

                              Up to $1,000,000                        0.90%

                          $1,000,001 - $5,000,000                     0.70%

                          $5,000,001 - $10,000,000                    0.50%

                              Over $10,000,000                        0.35%

Our annual fee is reasonable in relation to (1) the services provided and (2) the fees charged by other investment
advisers offering similar services/programs.
Our annual fee is prorated and charged quarterly in arrears based on the value of the Client’s assets under
management as of the close of business on the last business day of the previous quarter. Cash and cash
equivalents, including money market funds, are subject to the agreed-upon advisory fee. Clients should
understand that the advisory fees charged on these balances may exceed the returns provided by cash, cash
equivalents, or money market funds, especially in low-interest rate environments.
Our Firm retains complete discretion to negotiate fees and may waive or impose different fees on any Client.
The investment advisory fees will be deducted from your account and paid directly to our Firm by the qualified

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Custodian(s) of your account. The Client will authorize your account's qualified Custodian(s) to deduct fees from
the account and pay such fees directly to our Firm. All account assets, transactions, and advisory fees will be
shown on the monthly or quarterly statements provided by the Custodian. You should review your account
statements received from the qualified Custodian(s) and verify that appropriate investment advisory fees are
being deducted. The qualified Custodian(s) will not verify the accuracy of the investment advisory fees deducted.
We may aggregate related Client accounts to calculate the advisory fee applicable to the Client. The investment
management agreement will outline the fee charged to a Client and any breakpoints based on the level of assets
managed. The fees are subject to change with prior written notice to the Client.
Our annual investment advisory fee may be higher than that of other investment advisers that offer similar
services and programs. In addition to our compensation, you may incur charges imposed at the mutual fund
level (e.g., advisory fees and other fund expenses).
Accounts initiated or terminated during a calendar quarter will be charged a prorated fee based on the days the
Client account was open during that quarter. Any prepaid, unearned fees will be refunded upon termination of
any account.

LEGACY MANAGEMENT FEE

Managed legacy positions are included within our Firm’s standard investment management fee and are outlined
in the executed investment management agreement.

FINANCIAL PLANNING FEE

Our Firm provides financial planning services under an hourly fee arrangement of $400 per hour.
Fees charged for our financial planning services are not negotiable based upon the type of Client, the services
requested, the investment adviser representative providing advice, the complexity of the Client's situation, the
composition of the Client's account, other advisory services provided, and the relationship of the Client and the
investment adviser representative.
The amount of the fee for your engagement is specified in your financial planning agreement with us. At our
sole discretion, the Client may be required to pay the fee at the time the agreement is executed with our Firm;
however, our Firm does not require or solicit prepayment of more than $1,200 in fees per Client, six months or
more in advance. The fee is considered earned upon delivery of the financial plan, and any unpaid amount is
immediately due.
The Client may pay the fees owed for the financial planning services by submitting payment directly via check
or by deducting the fee from an existing investment account. If the Client elects to pay by automatic deduction
from an existing investment account, they will provide written authorization to our Firm for such a charge.
If the Client terminates the financial planning services after entering into an agreement with our Firm, the Client
will be invoiced and responsible for immediate payment of any hourly financial planning services performed by
us before receiving notice of termination. For financial planning services, our Firm performs under a hourly fee
arrangement, the Client will be responsible for paying a pro-rated fixed fee equivalent to the percentage of work
that our Firm completed. If there is a remaining balance of any fees paid in advance after deducting fees from
the final invoice, those remaining proceeds will be refunded to the Client.

ADDITIONAL FEES & EXPENSES

In addition to the advisory fees paid to our Firm, Clients also incur certain charges imposed by other third parties,
such as broker-dealers, Custodians, trust companies, banks, and other financial institutions. These additional

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charges include securities, transaction fees, custodial fees, fees charged by the SMA, ITPM, and Manager
...

ITEM 7 - TYPES OF CLIENTS
Our Firm provides investment management, investment advice, financial planning, consulting and advisement,
to individuals, high-net-worth individuals and families, trusts, retirement plans, corporations, and charitable
foundations, and pension plans. Our firm requires a minimum account value of $1,000,000 for advisory services.

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Clients have the option to aggregate all household accounts to meet this minimum. Exceptions to the minimum
account requirement may be granted based on the Client's relationship with their representative.
For fee calculation purposes, unless instructed otherwise, we will automatically aggregate related client
accounts, a practice commonly known as "householding" portfolios. Householding may result in lower fees than
if each account were billed separately, as the combined value is used to determine the account size and the
corresponding annualized fee.
Our approach to householding considers the overall family dynamic and relationship. Additionally, if applicable,
and as noted in Appendix B of the Investment Management Agreement, legacy positions may be excluded from
the fee calculation.
Clients must execute a written agreement with our Firm specifying the advisory services to establish a Client
arrangement with us.