Paragon Investing LLC

Fees and Compensation

The following types of fees will be assessed:

Asset Management – Managed Accounts are available to individuals, high net worth individuals
and businesses. Fees are charged quarterly in arrears and are based primarily on asset size and
the level of complexity of the services provided. In individual cases, Paragon has the sole
discretion to negotiate fees that are lower than the standard fee shown or to waive fees. Fees are
not based on the share of capital gains or capital appreciation of the funds or any portion of the
funds. Comparable services for lower fees may be available from other sources. Fees for the
initial quarter will be prorated based upon the number of calendar days in the calendar quarter
that the advisory agreement is in effect. Fees are based on the average daily balance of the assets
in Client’s accounts over the quarter. Annual fees are a maximum of 1.00%. Financial planning
services may be included with portfolio management services.

Paragon Investing, LLC also provides Advisory Services for assets for which management is not
preferred or available. Annual fees range up to 1.00%, depending on the amount of assets under
advisement (“AUA”) – See charts below.

   Assets Under Advisement                                 Annual Fee Rate
      First $1,000,000                                          1.00%
      Next $1,000,000                                           0.90%
      Next $1,000,000                                           0.80%
      Next $1,000,000                                           0.70%
      Next $1,000,000                                           0.60%
      Next $5,000,000                                           0.50%
      Next $15,000,000                                          0.40%
      Next $25,000,000                                          0.30%
      Next $50,000,000                                          0.20%
      Over $100,000,000                                         0.10%

As authorized in the client agreement, the account custodian withdraws Paragon Investing,
LLC’s advisory fees directly from the clients’ accounts according to the custodian’s policies,
practices, and procedures. The custodial statement includes the amount of any fees paid to
Paragon for advisory services. You should carefully review the statement from your
custodian/broker-dealer’s statement and verify the calculation of fees. Your custodian/broker-
dealer does not verify the accuracy of fee calculations.

Fees are charged in arrears on a quarterly basis, meaning that advisory fees for a quarter are
charged on the first day of the following quarter. Clients may terminate investment advisory

services obtained from Paragon at any time with thirty (30) days written notice. If terminated by
either party, the Client will pay a prorated fee for that quarter, assessed on the day of termination,
or closest business day. The day of termination is thirty (30) days after written notice is given or
the next business day thereafter. If termination of the agreement is within five (5) business days
from the date set forth in this agreement, all fees paid in advance will be refunded to the Client in
full. All funds under management shall be liquidated or transferred at market value as of the date
of liquidation or transfer.

Termination may be delayed until after the last restricted-access fund is redeemed (interval funds,
tender offer funds, and other semi-liquid funds). This may delay termination by 3-6 months, or
longer if redemptions are gated (partial redemption granted). After 30 days, Paragon agrees to not
charge advisory fees on the restricted-access assets that are waiting to be redeemed. Paragon is
providing access to funds at terms that the client and some advisors cannot access otherwise, and
the recommended allocations are deemed intellectual property of Paragon. If the client terminates
its relationship with Paragon, they are indicating they no longer desire to be invested in the
restricted access funds and they shall be redeemed upon the next redemption date.

Financial Planning – Financial planning services may be offered as a standalone service and are
charged in arrears through a fixed fee or hourly arrangement as agreed upon between the client
and Paragon Investing, LLC. There will never be an instance where $1,200 or more in fees is
charged six or more months in advance. Hourly fees are generally charged when the scope of
services cannot be determined or if the services are limited to one meeting. Fixed fees are
generally quoted to the client for longer term consulting projects. Fees are negotiable and vary
depending upon the complexity of the client situation and services to be provided. Hourly fees
range from $100 - $250 per hour, depending on what is negotiated between Paragon and the
client. Similar financial planning services may be available elsewhere for a lower cost to the
client. Fixed fees for longer-term consulting projects range from $1,000 to $10,000 per project.
An estimate for total hours and charges is determined at the start of the advisory relationship.

Typically, clients will be invoiced monthly for all time spent by Paragon as agreed upon by
client or upon completion of the services if less than a month. Paragon accepts check, ACH and
direct account debit when possible, for the payment for services. Clients who wish to terminate
the planning process prior to completion may do so with written notice. Upon receipt of written
notification, any earned fee will immediately become due and payable. A client may terminate
an advisory agreement without being assessed any fees or expenses within five (5) days of its
signing.

Additional Fees and Expenses

In addition to advisory fees paid to Paragon as explained above, clients may pay custodial
service, account maintenance, transaction, and other fees associated with maintaining the
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Types of Clients

Paragon offers investment advisory services to individuals, high net worth individuals, other
investment advisers and businesses. There is a $100,000.00 minimum account size to open and

maintain an access only advisory account and a $300,000.00 minimum account size to open and
maintain a full service account.

Form ADV, Part 2A, Item 8

       Methods of Analysis, Investment Strategies, and Risk of Loss

Paragon’s methods of analysis and investment strategies incorporate the client’s needs and
investment objectives, time horizon, and risk tolerance. Paragon is not bound to a specific
investment strategy for the management of investment portfolios, but rather consider the risk
tolerance levels pre-determined gathered at the account opening, as well as on an on-going basis.
Examples of methodologies that our investment strategies may incorporate include:

Asset Allocation – Asset Allocation is a broad term used to define the process of selecting a mix
of asset classes and the efficient allocation of capital to those assets by matching rates of return
to a specified and quantifiable tolerance for risk.

Dollar-Cost Averaging – Dollar-cost averaging is the technique of buying a fixed dollar amount
of securities at regularly scheduled intervals, regardless of the price per share. This will
gradually, over time, decrease the average share price of the security. Dollar-cost averaging
lessens the risk of investing a large amount in a single investment at the wrong time.

Technical Analysis – Involves studying past price patterns and trends in the financial markets to
predict the direction of both the overall market and specific stocks. The risk of market timing
based on technical analysis is that it may not accurately predict future price movements. Current
prices of securities may reflect all information known about the security and day to day changes
in market prices of securities may follow random patterns and may not be predictable with any
reliable degree of accuracy.

Fundamental Analysis - We attempt to measure the intrinsic value of a security by looking at
economic and financial factors (including the overall economy, industry conditions, and the
financial condition and management of the company itself) to determine if the company is
underpriced (indicating it is a good time to buy) or overpriced (indicating it is time to sell).
Fundamental analysis does not attempt to anticipate market movements. This presents a potential
risk, as the price of a security can move up or down along with the overall market regardless of
the economic and financial factors considered in evaluating the stock.

Mutual Fund, Interval Fund and/or ETF Analysis - We look at the experience and track record of
the manager of the mutual fund or ETF in an attempt to determine if that manager has
demonstrated an ability to invest over a period of time and in different economic conditions. We
also look at the underlying assets in a mutual fund or ETF in an attempt to determine if there is
significant overlap in the underlying investments held in other fund(s) in the client’s portfolio.
We also monitor the funds or ETFs in an attempt to determine if they are continuing to follow
their stated investment strategy.

A risk of mutual fund and/or ETF analysis is that, as in all securities investments, past
performance does not guarantee future results. A manager who has been successful will not
necessarily be able to replicate that success in the future. In addition, as we do not control the
underlying investments in a fund or ETF, managers of different funds held by the client may
purchase the same security, increasing the risk to the client if that security were to fall in value.
There is also a risk that a manager can deviate from the stated investment mandate or strategy of
the fund or ETF, which could make the holding(s) less suitable for the client’s portfolio.

Long-Term Purchases – securities purchased with the expectation that the value of those
securities will grow over a relatively long period of time, generally greater than one year.

Short-Term Purchases – securities purchased with the expectation that they will be sold within a
relatively short period of time, generally less than one year, to take advantage of the securities’
short term price fluctuations.

Our strategies and investments may have unique and significant tax implications. Regardless of
your account size or other factors, we strongly recommend that you continuously consult with a
tax professional prior to and throughout the investing of your assets.

Investing in securities involves risk of loss that clients should be prepared to bear. Although we
manage your portfolio with strategies and in a manner consistent with your risk tolerances, there
can be no guarantee that our efforts will be successful. You should be prepared to bear the risk
of loss.

All investments involve the risk of loss, including (among other things) loss of principal, a
reduction in earnings (including interest, dividends, and other distributions), and the loss of
future earnings. These risks include market risk, interest rate risk, issuer risk, and general
economic risk. Regardless of the methods of analysis or strategies suggested for your particular
investment goals, you should carefully consider these risks, as they all bear risks.

Paragon’s primary goal for investing is to help the client maintain purchasing power over the
long term. This may result in short term variability and loss of principal. Time horizon and risk
tolerance are key determinates of the proper asset allocation. Paragon’s approach focuses on
taking appropriate risks for which clients are compensated (i.e. market risk) and seeking to limit
or eliminate risks that do not provide compensation over the long term (i.e. individual stock risk
or lack of portfolio risk).

Below are some more specific risks of investing:
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