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Disclosures

Paragon Financial Services is registered with the Securities and Exchange Commission as an investment adviser and, as such, we provide advisory services rather than brokerage services. Brokerage and investment advisory services and fees differ and it is important for you, our client, to understand the differences.

Additionally, free and simple tools are available to research firms and financial professionals at www.investor.gov/CRS, which also provides educational materials about broker-dealers, investment advisers, and investing.

This page is a summary of the services and fees we offer to “retail” investors, which are natural persons who seek or receive services primarily for personal, family, or household purposes.

Investment Services and Advice We Provide

We offer the following investment advisory services to retail investors:

  • Financial Planning Services
  • Portfolio Management Services
  • Pension Consulting Services
  • Educational seminars/workshops
  • Asset Allocation Services
  • Advisory Consulting Services
  • Sponsor and Manager of Wrap Fee Program(s)

Detailed information regarding our services, fees and other disclosures can be found in our Form ADV Part 2A Items 4, 7, and 8 and Form ADV Part 2 Appendix 1 Brochures Items 4 and 5 here.

Account Monitoring

If you open an investment account with our firm, as part of our standard service we will monitor.

Investment Authority

We manage investment accounts on a discretionary basis whereby will decide investments to buy or sell for your account. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased or sold for your account) by providing our firm with your restrictions and guidelines in writing.

We also offer non-discretionary investment management services whereby we will provide advice, but you will ultimately decide which investments to buy and sell for your account. You have an unrestricted right to decline to implement any advice provided by our firm on a non-discretionary basis.

Investment Offerings

We primarily offer advice on equity securities, mutual funds, exchange traded funds, annuities, corporate debt securities, municipal securities, investment company securities, US Government securities, optionscontracts on securities, and interest in partnerships investing in real estate, oiland gas interests, and others. Our servicesare not limited to a specific type of investment or product.

Account Minimums and Requirements

In general, we require a minimum of $25,000 to open and maintain an advisory account. At our discretion, we may waive this minimum account size. If you do not maintain at least $250,000 in our account, you would not be eligible for the Wrap Fee Program and would not incur transaction costs.

What Fees You Will Pay

The following summarizes the principal fees and costs associated with engaging our firm for investment advisory services. For detailed information, refer to our Form ADV Part 2A, Items 5 and 6 and Form ADV Part 2 Appendix 1 Brochures by clicking here.

  • Asset Based Fees: Payable quarterly in advance. Since the fees we receive are asset-based (i.e. based on the value of your account), we have an incentive to increase your account value which creates a conflict especially for those accounts holding illiquid or hard-to-value assets;
  • Hourly Fees: Payable Other;
  • Wrap Program Fees: Payable quarterly in advance, based on the balance at end of billing period. Asset-based fees associated with a wrap fee program generally include most transaction costs and fees to a broker-dealer or bank that has custody of the assets; therefore, the asset-based fee is higher than a typical asset-based advisory fee. Since our firm pays the transaction costs associated with securities transactions in your account, we have an incentive to minimize the trading in your account;
    • Clients pay the following addition fees and/or expenses: If you do not maintain at least $250,000 in your account, you would not be eligible for the Wrap Fee Program and would incur transaction costs.

Examples of the most common fees and costs applicable to our clients are: Custodian fees;

  • Account maintenance fees;
  • Fees related to mutual funds and exchange-traded funds;
  • Transaction charges when purchasing or selling securities; and
  • Other product-level fees associated with your investments

You will pay fees and costs whether you make or lose money on your investments. Fees and costs will reduce any amount of money you make on your investments over time. Please make sure you understand what fees and costs you are paying.

Our Legal Obligations to You As Your Investment Adviser

When we act as your investment adviser we have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. You should understand and ask us about these conflicts because they can affect the investment advice we provide you.

How Else We Make Money and Possible Conflicts of Interest

Third-Party Payments: Persons providing advice on behalf of our firm are registered representatives with a broker-dealer and licensed as independent insurance agents. These persons receive compensation in connection with the purchase and sale of securities or other investment products and commission-based compensation for selling insurance products.

Compensation and insurance commissions earned by these persons is separate and in addition to our advisory fees. This practice presents a conflict of interest because they have an incentive to recommend investment products or insurance products based on the compensation or commission received rather than solely based on your needs.

Refer to our Form ADV Part 2A and Form ADV Part 2 Appendix 1 Brochures here.

How Our Financial Professionals Make Money

The financial professionals servicing your account(s) are compensated under our management. Financial professionals’ compensation is based on the following factors: A base monthly salary in the following ways: Salary; Fee for assets under our management. Financial professionals’ compensation is based on the following factors: A base monthly salary based on the amount of client assets they service.

Legal or Disciplinary History

Our firm and our financial professionals currently do not have any legal or disciplinary history to disclose. Visit www.investor.gov.CRS for a free and simple research tool.

Key Questions to Ask Your Financial Professional

  • Given my financial situation, should I choose an investment advisory service? Why or why not?
  • How will you choose investments to recommend to me?
  • What is your relevant experience, including your licenses, education and other qualifications?
  • What do these qualifications mean?
  • Help me understand how your fees and costs might affect my investments. If I give you $10,000 to invest, how much will go to fees and costs, and how much will be invested for me?
  • How might your conflicts of interest affect me, and how will you address them?
  • As a financial professional, do you have any disciplinary history? For what type of conduct?
  • Who is my primary contact person?
  • Is he or she a representative of an investment adviser or a broker-dealer?
  • Who can I talk to if I have concerns about how this person is treating me?
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