Paragon Financial Partners Inc

Item 5 – Fees and Compensation

  The following paragraphs detail the fee structure and compensation methodology for services provided by the
  Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into one or more
  written agreements with the Advisor that detail the responsibilities of Paragon and the Client.

  A. Fees for Advisory Services
  Wealth Management Services
  Wealth management fees are paid quarterly, in advance of each calendar quarter, pursuant to the terms of the
  wealth management agreement. Wealth management fees are based on the market value of assets under
  management at the end of the prior calendar quarter. Wealth management fees are based on the following
  schedule:

                      Assets Under Management ($)            Annual Rate (%)
                      Up to $1,000,000                            1.25%*
                      $1,000,001 to $3,000,000                    1.00%
                      $3,000,001 to $6,000,000                    0.85%
                      $6,000,001 to $10,000,000                   0.75%
                      Over $10,000,000                            0.65%
                     * The Advisor has a minimum annual fee of $15,000.

  The wealth management fee in the first quarter of service is prorated from the inception date of the account[s] to
  the end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take
  into consideration the aggregate assets under management with the Advisor. All securities held in accounts
  managed by Paragon will be independently valued by the Custodian. Paragon will conduct periodic reviews of the
  Custodian’s valuation to ensure accurate billing.

  The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction and custody fees, and
  other related costs and expenses described in Item 5.C. below, which may be incurred by the Client. However, the
  Advisor shall not receive any portion of these commissions, fees, and costs.

  Fees for trustee services will be charged a flat asset-based fee up to 1%. These fees are in addition to wealth
  management fees described above.

                                                Paragon Financial Partners, Inc.
                                      5850 Canoga Avenue, Suite 400, Woodland Hills, CA 91367
                                            Phone: (310) 557-1515 | Fax: (310) 943-2615
Page 6                                         www.paragonfinancialpartners.com

  Financial Planning and Consulting Services
  Paragon offers standalone financial planning and consulting services either on an hourly basis or for a fixed fee.
  Hourly fees range up to $500. Fixed fees range from $3,500 to $100,000. Fees may be negotiable depending on
  the nature and complexity of each Client’s circumstances and the duration of the engagement. An estimate for total
  hours and/or total costs will be provided to the Client prior to engaging in these services. Based on the financial
  planning and consulting agreement, Clients will be invoiced in advance on a monthly or quarterly basis. The
  financial planning and/or consulting agreement will automatically renew, with the same terms, unless notice of
  termination is given to the Advisor.

  B. Fee Billing
  Wealth Management Services
  Wealth management fees will be calculated by the Advisor or its delegate and deducted from the Client’s
  account[s] at the Custodian. The Advisor or its delegate shall send an invoice to the Custodian indicating the
  amount of the fees to be deducted from the Client’s account[s] at the beginning of each respective quarter. The
  amount due is calculated by applying the quarterly rate (annual rate times days in the quarter divided by days in
  the year) to the total assets under management with Paragon at the end of the prior quarter. Clients will be
  provided with a statement, at least quarterly, from the Custodian reflecting the deduction of the wealth
  management fee. It is the responsibility of the Client to verify the accuracy of these fees as listed on the
  Custodian’s brokerage statement as the Custodian does not assume this responsibility. Clients provide written
  authorization permitting Paragon to be paid directly from their accounts held by the Custodian as part of the
  investment advisory agreement and separate account forms provided by the Custodian.

  Financial Planning and Consulting Services
  Hourly fees are invoiced by the Advisor on a monthly basis, with the final invoice issued in advance of the Client
  receiving the deliverable[s]. Fixed fees are invoiced in advance, either monthly or quarterly, pursuant to the
  financial planning and consulting agreement. Invoices for financial planning and consulting services are due upon
  receipt by the Client.

  C. Other Fees and Expenses
  Clients may incur certain fees or charges imposed by third parties other than Paragon in connection with
  investments made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities
  execution fees charged by the Custodian, as applicable. The Advisor's recommended Custodian does not charge
  securities transaction fees for ETF and equity trades in a Client's account, provided that the account meets the
  terms and conditions of the Custodian's brokerage requirements. However, the Custodian typically charges for
  mutual funds and other types of investments. The investment advisory fee charged by Paragon is separate and
  distinct from these custody and execution fees.

  In addition, all fees paid to Paragon for investment advisory services are separate and distinct from the expenses
  charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in
  each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds,
...

Item 7 – Types of Clients

  Paragon offers investment advisory services to individuals, high net worth individuals, estates, trusts, and
  corporations. The amount of each type of Client is available on Paragon’s Form ADV Part 1. These amounts will
  change over time.

  Paragon generally requires a minimum relationship size of $1,000,000 and a minimum annual fee of $15,000.
  The Advisor may, at its sole discretion, accept accounts with a lower value or charge a lower annual fee.