A. Firm Information Paragon Financial Partners, Inc. (“Paragon” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). Paragon is organized as a Corporation under the laws of the State of California. Paragon was founded in May 2011 and is owned and operated by President and Chief Compliance Officer Evan F. Shorten. This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Paragon. B. Advisory Services Offered Paragon offers investment advisory services to individuals, high net worth individuals, estates, trusts, corporations, and businesses (each referred to as a “Client”). The Advisor acts as a fiduciary to Clients, as defined under applicable laws and regulations. As such, each recommendation made as part of the advisory services is based on the belief that the recommendation is in the Client's best interest. Paragon’s fiduciary commitment to each Client 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. Wealth Management Services Paragon provides Clients with wealth management services, which generally include comprehensive financial planning and consulting strategies as well as discretionary management of investment portfolios. Investment Management Services – Paragon provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing both discretionary and non-discretionary investment management and consulting services. Paragon works with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio strategy. Paragon will then construct a portfolio, consisting of exchange-listed securities and exchange- traded funds (“ETFs”), over-the-counter securities, foreign securities, corporate debt securities, mutual funds, CDs, options, margin, variable annuities, municipal securities, United States government securities, government agency securities, including municipal and government securities that are a part of mutual funds, and interests in partnerships investing in real estate and oil and gas interests to accomplish this objective. The Advisor may retain certain legacy investments based on portfolio fit and/or tax considerations. Paragon’s investment approach is primarily long-term focused, but the Advisor may buy, sell, or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. Paragon 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. Paragon evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Paragon may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Paragon 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. Paragon 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. Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA or recommend a similar transaction including rollovers from one ERISA sponsored Plan to www.paragonfinancialpartners.com Page 5 another, one IRA to another IRA, or from one type of account to another account (e.g., commission-based account to fee-based account). Such a recommendation

creates a conflict of interest if the Advisor earns a new (or increases its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. At no time will Paragon accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the agreement; please see Item 12 – Brokerage Practices. Financial Planning and Consulting Services – Paragon will typically provide a variety of financial planning and consulting services to individuals, families, and businesses either as a component of its wealth management services or pursuant to a written financial planning and consulting agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Paragon also provides specialized planning and negotiation services, including divorce financial planning, negotiation of significant assets, and contract negotiations. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation or business consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including, but not limited to investment planning, retirement planning, estate planning, personal savings, insurance needs, education savings, financial coaching including general and personalized financial advice, and other areas of a Client’s financial situation. A financial plan developed for, or financial consultation rendered to 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. Paragon 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 the Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six (6) months of the contract date, assuming all information and documents requested are provided promptly. Financial planning and consulting 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. C. Client Account Management Prior to engaging Paragon to provide investment 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 – Paragon, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives.
• Asset Allocation – Paragon 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 – Paragon will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.
• Investment Management and Supervision – Paragon will provide investment management and ongoing oversight of the Client’s investment portfolio. www.paragonfinancialpartners.com Page 6 D. Wrap Fee Programs Paragon does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by Paragon. E. Assets Under Management As of December 31, 2023, Paragon manages $280,943,409 in Client assets, $188,813,645 of which are managed on a discretionary basis and $92,129,764 on a non-discretionary basis. Clients may request more current information at any time by contacting the Advisor.