Paragon Private Wealth Management offers a variety of advisory services, which include financial planning, consulting, and investment management services. Prior to Paragon Private Wealth Management rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with Paragon Private Wealth Management setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). Paragon Private Wealth Management filed for registration as an investment adviser in March 2021 and is owned by Justin Sherman and Catherine Salsman. While this brochure generally describes the business of Paragon Private Wealth Management, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or other persons who provide investment advice on Paragon Private Wealth Management’s behalf and are subject to the Firm’s supervision or control. Financial Planning and Consulting Services Paragon Private Wealth Management offers, directly or through an affiliate, clients a broad range of financial planning and consulting services, which include any or all of the following functions:
• Business Planning • Bill Paying
• Cash Flow Analysis • Tax Planning
• Trust and Estate Planning
• Investment Reporting on Alternatives
• Insurance Planning • Charitable Contribution Planning
• Retirement Planning • Education Planning While each of these services is available on a stand-alone basis, certain of them can also be rendered in conjunction with investment portfolio management as part of a comprehensive wealth management engagement (described in more detail below). In performing these services, Paragon Private Wealth Management is not required to verify any information received from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to rely on such information. Paragon Private Wealth Management recommends certain clients engage the Firm for additional related services, its Supervised Persons in their individual capacities as insurance agents and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists for the Firm to recommend that clients engage Paragon Private Wealth Management or its affiliates to provide (or continue to provide) additional services for compensation, including investment management services. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by Paragon Private Wealth Management under a financial planning or consulting engagement. Clients are advised that it remains their responsibility to promptly notify the Firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising Paragon Private Wealth Management’s recommendations and/or services. Paragon Private Wealth Management uses a third-party platform to assist in gathering information on client's 401(k) Plans, 529 Plans and annuities. The third-party platform allows Paragon Private Wealth Management to consult on assets not held by our regular custodians. Investment and Wealth Management Services Paragon Private Wealth Management manages client investment portfolios on a discretionary or non-discretionary basis. In addition, Paragon Private Wealth Management primarily provides clients with wealth management services which include a broad range of financial planning and consulting services as well as discretionary and/or nondiscretionary management of investment portfolios. The wealth management services do not include the “Non-Investment Management Services” described below. Types of Investments We offer advice on equity securities, corporate debt securities (other than commercial paper), municipal securities, variable life insurance, variable annuities, options contracts on securities, money market funds, real estate, REITs, structured products and ETFs. Paragon Private Wealth Management may also recommend independent investment managers (“Independent Managers”) in more limited circumstances. Where appropriate, the Firm also provides advice about any type of legacy position or other investment held in client portfolios, but clients should not assume that these assets are being continuously monitored or otherwise advised on by the Firm unless specifically agreed upon. Clients can engage Paragon Private Wealth Management to manage and/or advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, Paragon Private Wealth Management directs or recommends the allocation of client assets among the various investment options available with the product. These assets are generally maintained at the underwriting insurance company or the custodian designated by the product’s provider. Paragon Private Wealth Management tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives. Paragon Private Wealth Management consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify Paragon Private Wealth Management if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients can impose reasonable restrictions or mandates on the management of their accounts if Paragon Private

Wealth Management determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Firm’s management efforts. Use of Independent Managers As mentioned above, Paragon Private Wealth Management selects certain Independent Managers to actively manage a portion of its clients’ assets. The specific terms and conditions under which a client engages an Independent Manager are set forth in a separate written agreement with the designated Independent Manager. That agreement can be between the Firm and the Independent Manager (often called a subadvisor) or the client and the Independent Manager (sometimes called a separate account manager). In addition to this brochure, clients will typically also receive the written disclosure documents of the respective Independent Managers engaged to manage their assets. Paragon Private Wealth Management evaluates a variety of information about Independent Managers, which includes the Independent Managers’ public disclosure documents, materials supplied by the Independent Managers themselves and other third-party analyses it believes are reputable. To the extent possible, the Firm seeks to assess the Independent Managers’ investment strategies, past performance and risk results in relation to its clients’ individual portfolio allocations and risk exposure. Paragon Private Wealth Management also takes into consideration each Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing and research capabilities, among other factors. Paragon Private Wealth Management continues to provide services relative to the discretionary or non-discretionary selection of the Independent Managers. On an ongoing basis, the Firm monitors the performance of those accounts being managed by Independent Managers. Paragon Private Wealth Management seeks to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests. Cash Management and Treasury Paragon Private Wealth Management renders cash management and treasury investment options for state or municipal government entities on a non-discretionary basis. These services will adhere to Kentucky Revised Statutes 66.480 and will be limited to the following:  US Treasury or other US Agency Obligations  Money market or related mutual funds invest in or are collateralized with securities listed in (a)  Bonds issued by the state of Kentucky or its agencies All recommended transactions will be approved in writing by client before execution. These services are provided under a flat fee which is prorated and billed monthly. For more information on fees, see Item 5. Fees and Compensation. Non-Investment Management Services Paragon Private Wealth Management renders non-investment related management services to certain clients. These services include bill paying (including paying and monitoring bills and receivables), concierge services (including relocation, automobile shipping, travel, etc.), major purchase negotiations, banking support, tax management, risk management, and acting as liaison with other professionals provided by Paragon Business Management. These services are provided under a separate agreement with Paragon Business Management. Paragon Business Management is a distinct entity under common ownership and control with Paragon Private Wealth Management. As such, clients are advised that a conflict of interest exists for the Firm to recommend that clients engage Paragon Business Management and affiliates providing certain services to clients of Paragon Business Management (ex. CPAs, attorneys, and etc.). These services are distinct and in addition to any services clients choose to engage through Private Wealth or its affiliates to provide (or continue to provide) additional services for compensation, including investment management services. This conflict is mitigated because clients are not obligated to engage services of Paragon Business Management. IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor (“DOL”) Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL’s Prohibited Transaction Exemption 2020-02 (“PTE 2020-02”) where applicable, Paragon Private Wealth Management is providing the following acknowledgment to you. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. Paragon Private Wealth Management benefits financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest. Assets Under Management As of March 5, 2024, we provide continuous management services for $283,043,282 in client assets on a discretionary basis.