A. Firm Information Paradigm Wealth Advisory LLC (“Paradigm” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as a limited liability company (“LLC”) under the laws of Delaware. Paradigm was founded in April 2016, and is a wholly owned subsidiary of Paradigm Wealth Management Holdings LLC (“Paradigm Holdings”). David Provinsal (Managing Member) is a majority owner of Paradigm Holdings. The Advisor is operated by David Provinsal (Managing Partner and Chief Compliance Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Paradigm. B. Advisory Services Offered Paradigm offers investment advisory services to individuals, high net worth individuals, families, trusts, estates, charitable organizations and businesses (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. Paradigm’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Investment Management Services Paradigm provides customized investment management solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary investment management and related advisory services. Paradigm works with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create an investment strategy. Paradigm will then construct an investment portfolio, consisting of low-cost, diversified mutual funds and/or exchange-traded funds (“ETFs”) to achieve the Client’s investment goals. The Advisor may also utilize individual stocks, bonds or options contracts to meet the needs of its Clients. The Advisor may retain certain legacy investments based on portfolio fit and/or tax considerations, including legacy engagements with third party money managers. Client portfolios will primarily be constructed using institutional mutual funds, exchange-traded funds (“ETFs”), individual equities, individual bonds, and/or variable annuities. With respect to mutual funds, the Advisor seeks to invest client assets in institutional share classes with the lowest overall expense ratio, where available. Certain Client may have legacy investments in non-institutional mutual fund shares. The Advisor endeavors to sell such legacy non-institutional mutual fund shares when appropriate in accordance with client preferences and tax implications. The Advisor may also utilize other types of investments, as appropriate, to meet the needs of each particular Client. Client portfolios may be fully customized or use one or more of the Advisor’s investment strategies. The Advisor’s investment strategies are comprised of several accounts managed in time-segmented strategies. The Advisor tailors the segments and overall Client strategy to the goals and overall situation of the Client. Clients accumulating wealth for retirement will have accounts that will differ from those accounts[?] in retirement. The Client’s accounts may include the use of variable annuity accounts. In such instances, the Advisor enters into a separate discretionary investment advisory agreement for the management of the variable annuity sub- accounts. There is no additional fee for the management of these accounts. Please see Items 5.E. and 10 below for additional information. Paradigm’s overall investment approach is primarily long-term focused. As detailed above, the Advisor manages various accounts with different investment purposes and time horizons. Certain accounts may have more or less investment activity than other accounts as a result. This approach is designed to optimize the Client’s overall investment strategy. The Advisor may buy, sell or re-allocate positions that have been held less than one year to meet the objectives of the Client or due to market conditions. Paradigm will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. The Advisor monitors Client accounts that hold non-institutional mutual funds to seek appropriate opportunities to convert the funds to an institutional share class, when available. The Paradigm evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Paradigm may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Paradigm may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. Paradigm may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. At no time will Paradigm accept or maintain custody of a Client’s funds or securities. All Client assets will be managed within their designated account[s] at the Custodian,

pursuant to the terms of the advisory agreement. For additional information, please see Item 12 – Brokerage Practices and Item 15 – Custody. Use of Independent Managers – Paradigm Wealth may recommend that certain legacy Clients utilize one or more unaffiliated investment managers or investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment portfolio, based on the Client’s needs and objectives. In such instances, the Client will be required to authorize and enter into an investment management agreement with an Independent Manager that defines the terms in which the Independent Manager will provide its services. The Advisor will perform initial and ongoing oversight and due diligence over each Independent Manager to ensure the Independent Manager’s strategy remains aligned with the Client’s investment objectives and overall best interests. The Advisor will also assist the Client in the development of the initial policy recommendations and managing the ongoing Client relationship. The Client, prior to entering into an agreement with an Independent Manager, will be provided with the Independent Manager's Form ADV Part 2A - Disclosure Brochure (or a brochure that makes the appropriate disclosures). The disclosure will be provided by the Independent Manager. Financial Planning Services Paradigm will typically provide a variety of financial planning services to individuals and families, either as a component of investment management services or pursuant to a written financial planning agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services will involve preparing a financial plan based on the Client’s financial goals and objectives. This planning may encompass one or more areas, including, but not limited to investment planning, retirement planning, personal savings, education savings, insurance needs, and other areas of a Client’s financial situation. A financial plan developed for the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. Paradigm may also refer Clients to an accountant, attorney or another specialist, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of Client’s financial situation, observations, and recommendations. For ad-hoc engagements, the Advisor may not provide a written summary. Plans are typically completed within six (6) months of contract date, assuming all information and documents requested are provided promptly to the Advisor. Financial planning recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. Financial planning services may be included in an overall wealth management engagement or provided as a separate service, pursuant to the terms of the agreement with the Client. C. Client Account Management Prior to engaging Paradigm to provide advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include:
• Establishing an Investment Strategy – Paradigm will work with each Client to develop a custom investment strategy designed in connection with the Client’s investment goals and objectives.
• Asset Allocation – Paradigm will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client.
• Portfolio Construction – Paradigm will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.
• Investment Management and Supervision – Paradigm will provide its discretionary investment management and ongoing oversight of the Client’s investment portfolios, including accounts held at the Custodian (as detailed in Item 12) and any applicable variable annuity sub-accounts. D. Wrap Fee Programs Paradigm will typically include the securities transaction fees together with investment advisory fees to provide the Client with a single, bundled fee structure. Including these fees into a single asset-based is considered a “Wrap Fee Program”. Paradigm customizes its investment management services for Clients. This Wrap Fee Program Brochure is included as Appendix 1 to this Disclosure Brochure solely to discuss the fees and potential conflicts associated with a bundled fee. Please see Appendix 1 – Wrap Fee Program Brochure, which is included with this Disclosure Brochure. E. Assets Under Management As of December 31, 2023, the Advisor manages $356,126,149 in Client assets, all of which are managed on a discretionary basis. Of the total assets under management, $136,238,028 is attributable to variable annuity sub- accounts. Please see item 5.E. and 10 below. Clients may request more current information at any time by contacting the Advisor.