Paragon Capital Management, Ltd. is an independent, privately owned SEC-registered investment advisory firm founded in 1990 by Alexander Feick and Henry Lester. Alexander Feick and Henry Lester each own 23.75% of the firm. Current employees own the remaining 52.5% interest. As of the firm's fiscal year-end, December 31, 2023, the firm had approximately $1,134,019,000 of client assets under its management: $1,019,981,900 on a discretionary basis and $114,020,800 on a non-discretionary basis. Philosophy Objective Advice Our fundamental goal is to provide high-quality, objective advice. We do not receive commissions that might influence our recommendations. We do not offer other services that might affect our advice. For example, if we were in the trust management business, we might recommend more trusts. Similarly, we do not receive any fees for referring business to other professionals, which might lead us to recommend those professionals over other providers. Open Platform We strive to find investments that meet our Client's goals and our strategies regardless of how or where they are offered or available. We are not limited by the investments available at any one brokerage firm or custodian. Thus, while most of our client's assets are custodied at Schwab, we buy and sell municipal bonds through several other brokers. Integrated Analysis We consider your whole portfolio in planning and investment decisions. Therefore, we incorporate investments that we do not supervise in our analyses. In addition, we factor in liquidity, time horizon, taxes, regulatory, and legal factors in the process of structuring a portfolio. For example, the time horizon and tax treatment of a trust, a deferred compensation plan, or a retirement account may make an investment compelling in one account and inappropriate in another. Services Paragon Capital Management provides clients with financial planning, investment advice, and investment management services. Financial Planning Financial planning services range from the simple to the complex, from a tax forecast or mortgage analysis to how to manage stock options and concentrated stock positions. Our core financial planning services include the following:  Analysis and planning for retirement  Estate planning, including taxes, trusts, and gifting  Income taxes  Employee benefits, stock options, and compensation contracts  Concentrated stock positions  Life insurance  Asset protection and risk management strategies  Financing  Educational funding Investment Management Clients work with us under the following arrangements: (1) Discretionary – Under a discretionary arrangement, the Client grants Paragon Capital Management discretion and authority under a limited power of attorney to manage and invest their accounts according to established objectives and guidelines. (2) Non-discretionary – Under a non-discretionary arrangement, the Client either implements Paragon Capital Management's advice or Paragon Capital Management makes transactions on behalf of the Client but only on a limited basis or after reviewing recommended transactions with the Client. Non- discretionary clients will generally be unable to participate in trades and opportunities in the same time frame as discretionary clients. For example, municipal bond

opportunities can be fleeting. We customize our investment strategies to our Clients' objectives using individual stocks, bonds, mutual funds, and exchange-traded funds. We also may invest in hedge funds and investment partnerships that pursue various investment strategies. Process In our initial meeting, we determine a client's goals and concerns. We then compile information on their assets, investments, liabilities, income, and expenses. With this information and personal documents, including insurance policies, wills, benefit plans, tax returns, etc., we build a preliminary picture of their financial situation and how we expect assets and income to change over time. We then meet with the Client to review these projections and the underlying assumptions and information. Then, we revise these assumptions and projections as necessary. Next, we develop a plan to achieve goals and invest capital, considering different accounts, taxes, time horizons, and other factors. Finally, an investment policy statement articulates the guidelines for implementing the plan. Retirement Rollover Recommendations 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 of 1974, as amended (“ERISA”) and/or the Internal Revenue Code (the “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. When providing recommendations to retirement plan accounts involving rollover considerations, there are generally four options regarding an existing retirement plan account. An employee may use a combination of those options, such as; (i) leave the funds in the former employer’s plan, if permitted, (ii) roll over the funds to a new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the individual’s age, result in adverse tax consequences). If your designated investment adviser representative recommends that you rollover your retirement plan assets into an account to be managed by our firm, such recommendation creates a conflict of interest insofar as we will earn an advisory fee on the rolled over assets. You are under no obligation to roll over retirement plan assets to an account managed by us. Client Assets Managed As of December 31, 2023, we managed $1,019,981,900 of client assets on a discretionary basis and $114,020,763 on a non-discretionary basis.