Paragon Capital Management LLC

Item 5 – Fees and Compensation
Investment Management
The fee calculation is based on the fair market value of the account(s) as of the end of each quarter. Fees paid to us for
management services are paid in arrears quarterly and not in advance of services, and they are deducted directly from our
client’s account(s) unless other arrangements have been made. Our fee calculation is based on assets under management in each
client account. The Adviser calculates the advisory fee based on the prior quarter end value, multiplied by the advisory fee
divided by 360 and then multiplied by the actual number of days in the quarter. The fee is deducted based on a separate written
authorization between the custodian and the Client.

Fees may be negotiated for larger accounts or accounts affiliated with existing clients but are charged a maximum annual
fee of 1.00%.

The minimum annual fee per Household is $2,500.

        Clients will receive quarterly statements from the Custodian that provides details of the advisory fees.

        The investment advisory fee in the first period of service is pro-rated from the inception date of the account[s] to
        the end of the first quarter.

        Asset management fees are exclusive of and in addition to, brokerage fees, transaction fees, and other related costs
        and expenses.

        The firm will not have the authority or responsibility to value portfolio securities.

ADV 2A – Firm Disclosure Brochure                               Page 6 of 20

Financial Planning
Financial planning is not billed separately but within the scope of the larger advisory relationship.

Mutual Fund Share Class Disclosures
Paragon Capital Management, LLC strives to select the lowest cost share class available; however, certain mutual fund share
classes charge a 12b-1 fee that generally amounts to an additional .25% expense ratio or more. The purpose of 12b-1 fees, as
approved by the SEC, are to cover marketing expenses and shareholder services such as support services and “other expenses”
such as legal, accounting and the administrative functions of the custodian. When selecting a mutual fund, Investment Advisor
Representatives have a fiduciary duty to choose the share class that helps manage the overall fee structure of the account. The
entire fee structure includes such fees as the asset management fee, the expense ratio and ticket charges.

        Mutual funds typically offer multiple share classes, including lower-cost share classes that do not charge 12b-1 fees
        and are therefore usually less expensive.

        Investment Advisor Representatives will consider investing Client funds in 12b-1 fee-paying share classes even
        when a lower-cost share class is available as appropriate to account for the overall fee structure and tax
        considerations as well as attributes of a fund not available for lesser fees.

Compensation for Sales of Securities
Paragon Capital Management, LLC does not receive commission compensation for advisory services.

Other Fees and Expenses
Clients will incur transaction charges for trades executed in their accounts. These transaction fees are separate from asset
management fees. Clients will also pay the following separately incurred expenses, which we do not receive any part of: charges
imposed directly by a mutual fund, index fund, or exchange traded fund which shall be disclosed in the fund’s prospectus (i.e.,
fund management fees and other fund expenses).

If a Client’s assets are invested in mutual funds or other pooled investment products, Clients should be aware that there will be
two layers of advisory fees and expenses for those assets. Client will pay an advisory fee to the fund manager and other
expenses as a shareholder of the fund. Client will also pay Advisor the advisory fee with respect to those assets. Most of the
mutual funds available in the program may be purchased directly. Therefore, Clients could generally avoid the second layer of
fees by not using the management services of Paragon Capital Management, LLC and by making their own investment decisions.
Further information regarding fees assessed by a mutual fund is available in the appropriate prospectus.

Fees for Serving as Investment Advisor on Certain Trusts
We may also serve as investment advisor on certain trusts requiring a corporate trustee. Fees may differ from our fee schedule
based on factors such as the size of account and the corporate trustee selected to administer the trust.

Fees for Third-Party Sub-Advisors
Third-party sub-advisors shall be paid a fee, separate and distinct from that payable to Paragon. Mutual fund and exchange
traded funds also charge internal management fees, which are disclosed in a fund's prospectus. Such charges, fees, and
commissions are exclusive of and in addition to our fee, and we shall not receive any portion of these commissions, fees, and
costs.

ADV 2A – Firm Disclosure Brochure                             Page 7 of 20

Termination
A contract between Paragon Capital Management, LLC and a Client may at any time be terminated by the Client without the
payment of any penalty. This Agreement may be terminated by the Adviser on two weeks' written notice to the Client. This
Agreement may be amended at any time by mutual written consent of the parties. Clients will be given this brochure form ADV
Part 2A, forty-eight hours in advance of signing an agreement or they will have five business days to unconditionally cancel
the agreement.

Item 7 – Types of Clients
The advisory services offered by Paragon Capital Management, LLC are generally provided to individuals, high net worth
individuals, foundations, trusts, and estates.

Clients can also set up foundations that will be managed towards meeting their goals for current and future charitable
contributions. Our account minimum is $500,000 but smaller accounts may be accepted based on several factors including the
client relationship.