PARAGON ADV PART 2A

Part 2A of Form ADV: Firm Brochure Form ADV, Part 2A, Item 1 Cover Page Paragon Investing, LLC 1744 Michigan Avenue Detroit, MI 48216 www.ParagonInvesting.com Tel: (734) 649-6710 October 26, 2026 FORM ADV PART 2 FIRM BROCHURE This brochure provides information about the qualifications and business practices of Paragon Investing, LLC. If you have any questions about the contents of this brochure, please contact us at (734) 649-6710. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Paragon Investing, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for Paragon Investing, LLC is 310897. Paragon Investing, LLC is a Registered Investment Adviser. Registration with the United States Securities and Exchange Commission or any state securities authority does not imply a certain level of skill or training. 1  Form ADV, Part 2A, Item 2 Material Changes Annual Update The Material Changes section of this brochure will be updated annually or when material changes occur since the previous release of the Firm Brochure. Each year, we will ensure that you receive a summary of any material changes to this and subsequent brochures by April 30th. We will further provide you with our most recent brochure at any time at your request, without charge. You may request a brochure by contacting us at (734) 649-6710. Material Changes since the Last Update Paragon Investing, LLC was established as a new Registered Investment Advisor domiciled the State of Michigan in October 2020. In 2026, they became registered with the Securities and Exchange Commission (“SEC”), under the rules and regulations of the US Investment Advisers Act of 1940, as amended (the "Advisers Act"). The following material changes have been made since the last annual update filed on March 3, 2026. • The Firm has moved from 718 North Gainsborough Avenue, Royal Oak, MI 48067 to 1744 Michigan Avenue, Detroit, MI 48216. • The Firm has updated their fee schedule as found in Item 5: Fees and Compensation. 2  Form ADV, Part 2A, Item 3 Table of Contents Item 4 - Advisory Business………………………………………………… 4 Item 5 - Fees and Compensation………………………………………….. 5 Item 6 - Performance-Based Fees and Side-By-Side Management…. 7 Item 7 - Types of Clients……………………………………………………. 8 Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss……… ..... 8 Item 9 - Disciplinary Information…………………………………………….. 11 Item 10 - Other Financial Industry Activities and Affiliations…………. 12 Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading……………………………………………………………… 12 Item 12 - Brokerage Practices………………………………………………. 13 Item 13 - Review of Accounts……………………………………………….. 14 Item 14 - Client Referrals and Other Compensation……………………. 15 Item 15 - Custody……………………………………………………………… 15 Item 16 - Investment Discretion…………………………………………….. 15 Item 17 - Voting Client Securities………………………………………… 16 Item 18 - Financial Information…………………………………………… 16 Item 19 - Requirements for State-Registered Advisers………………… 16 3  Form ADV Part 2A, Item 4 Advisory Business Paragon Investing, LLC (hereinafter called “Paragon”) is a Registered Investment Adviser based in Royal Oak, Michigan, and incorporated under the laws of the State of Michigan. Paragon is owned by Jonathan Carender, Corey Wangler and DBP Ventures LLC. Paragon is registered with the U.S. Securities and Exchange Commission (SEC) and is subject to the rules and regulations of the US Advisers Act. Founded in October 2020, Paragon provides investment advisory services, which may include, but are not limited to, the review of client investment objectives and goals, recommending asset allocation strategies of managed and unmanaged assets among investment products such as cash, stocks, mutual funds and bonds, annuities, and/or preparing written investment strategies. Our investment advice is tailored to meet our clients’ needs and investment objectives. Clients may impose restrictions on investing in certain securities or types of securities (such as a product type, specific companies, specific sectors, etc.) by providing a signed and dated written notification, of which an e-mail is also an acceptable form of notification. Paragon also provides financial planning consulting services including, but not limited to, risk assessment/management, investment planning, estate planning, financial organization, or financial decision making/negotiation. Paragon provides investment advisory and other financial services through its Investment Advisory Representatives ("IAR") to accounts opened with Paragon. Managed Accounts are available to individuals, high net worth individuals and businesses. Paragon provides discretionary and non-discretionary investment advisory services to some of its clients through various managed account programs. Paragon will assist clients in determining the suitability of the Managed Account Programs for the client. The IAR is compensated through a comprehensive single fee and the account may be assessed other charges associated with conducting a brokerage business. Paragon and its IAR, as appropriate, will be responsible for the following: • Performing due diligence • Recommending strategic asset and style allocations • Providing research on investment product options, as needed • Providing client risk profile questionnaire • Obtaining investment advisory contract from client with required financial, risk tolerance, suitability and investment vehicle selection information for each new account • Performing client suitability check on account documentation, review the investment objectives and evaluate the investment vehicle selections • Providing Firm Brochure (this document) The firm, as of January 16, 2026, has $82,900,000 Discretionary assets under management and $55,300,000 Non-Discretionary assets under management. 4  Paragon does not participate in a Wrap fee program. Form ADV, Part 2A, Item 5 Fees and Compensation The following types of fees will be assessed: Asset Management – Managed Accounts are available to individuals, high net worth individuals and businesses. Fees are charged quarterly in arrears and are based primarily on asset size and the level of complexity of the services provided. In individual cases, Paragon has the sole discretion to negotiate fees that are lower than the standard fee shown or to waive fees. Fees are not based on the share of capital gains or capital appreciation of the funds or any portion of the funds. Comparable services for lower fees may be available from other sources. Fees for the initial quarter will be prorated based upon the number of calendar days in the calendar quarter that the advisory agreement is in effect. Fees are based on the average daily balance of the assets in Client’s accounts over the quarter. Annual fees are a maximum of 1.40%. Financial planning services may be included with portfolio management services. Paragon Investing, LLC also provides Advisory Services for assets for which management is not preferred or available. Annual fees range up to 1.40%, depending on the amount of assets under advisement (“AUA”) – See charts below. Assets Under Advisement Annual Fee Rate First $100,000 1.40% Next $150,000 1.30% Next $250,000 1.20% Next $250,000 1.10% Next $250,000 1.00% Next $2,000,000 1.00% Next $2,000,000 0.90% Next $5,000,000 0.80% Next $10,000,000 0.70% Next $10,000,000 0.60% Next $20,000,000 0.50% Next $50,000,000 0.35% Over $100,000,000 0.20% As authorized in the client agreement, the account custodian withdraws Paragon Investing, LLC’s advisory fees directly from the clients’ accounts according to the custodian’s policies, practices, and procedures. The custodial statement includes the amount of any fees paid to Paragon for advisory services. You should carefully review the statement from your 5  custodian/broker-dealer’s statement and verify the calculation of fees. Your custodian/broker- dealer does not verify the accuracy of fee calculations. Fees are charged in arrears on a quarterly basis, meaning that advisory fees for a quarter are charged on the first day of the following quarter. Clients may terminate investment advisory services obtained from Paragon at any time with thirty (30) days written notice. If terminated by either party, the Client will pay a prorated fee for that quarter, assessed on the day of termination, or closest business day. The day of termination is thirty (30) days after written notice is given or the next business day thereafter. If termination of the agreement is within five (5) business days from the date set forth in this agreement, all fees paid in advance will be refunded to the Client in full. All funds under management shall be liquidated or transferred at market value as of the date of liquidation or transfer. Termination may be delayed until after the last restricted-access fund is redeemed (interval funds, tender offer funds, and other semi-liquid funds). This may delay termination by 3-6 months, or longer if redemptions are gated (partial redemption granted). After 30 days, Paragon agrees to not charge advisory fees on the restricted-access assets that are waiting to be redeemed. Paragon is providing access to funds at terms that the client and some advisors cannot access otherwise, and the recommended allocations are deemed intellectual property of Paragon. If the client terminates its relationship with Paragon, they are indicating they no longer desire to be invested in the restricted access funds and they shall be redeemed upon the next redemption date. Financial Planning – Financial planning services may be offered as a standalone service and are charged in arrears through a fixed fee or hourly arrangement as agreed upon between the client and Paragon Investing, LLC. There will never be an instance where $1,200 or more in fees is charged six or more months in advance. Hourly fees are generally charged when the scope of services cannot be determined or if the services are limited to one meeting. Fixed fees are generally quoted to the client for longer term consulting projects. Fees are negotiable and vary depending upon the complexity of the client situation and services to be provided. Hourly fees range from $100 - $250 per hour, depending on what is negotiated between Paragon and the client. Similar financial planning services may be available elsewhere for a lower cost to the client. Fixed fees for longer-term consulting projects range from $1,000 to $10,000 per project. An estimate for total hours and charges is determined at the start of the advisory relationship. Typically, clients will be invoiced monthly for all time spent by Paragon as agreed upon by client or upon completion of the services if less than a month. Paragon accepts check, ACH and direct account debit when possible, for the payment for services. Clients who wish to terminate the planning process prior to completion may do so with written notice. Upon receipt of written notification, any earned fee will immediately become due and payable. A client may terminate an advisory agreement without being assessed any fees or expenses within five (5) days of its signing. Additional Fees and Expenses In addition to advisory fees paid to Paragon as explained above, clients may pay custodial service, account maintenance, transaction, and other fees associated with maintaining the account. These fees vary by broker and/or custodian. Clients should ask Paragon for details on 6  transaction fees or other custodial fees specific to their account, as these fees are not included in the annual advisory fee. Paragon does not share any portion of such fees. Additionally, for any mutual funds purchased, the client may pay their proportionate share of the funds’ distribution, internal management, investment advisory and administrative fees. Such fees are not shared with Paragon and are compensation to the fund manager. Clients are urged to read the mutual fund prospectus prior to investing. Neither Paragon nor any of our supervised persons accepts compensation for the sale of securities or other investment products. Mutual fund companies impose internal fees and expenses on clients. These fees are in addition to the costs associated with the investment advisory services as described above. Complete details of such internal expenses are specified and disclosed in each mutual fund company’s prospectus. Clients are strongly advised to review the prospectus(es) prior to investing in such securities. Mutual funds purchased or sold in broker-dealer accounts may generate transaction fees that would not exist if the purchase or sale were made directly with the mutual fund company. Mutual funds held in broker-dealer accounts also charge management fees. These mutual fund management fees may be more or less than the mutual fund management fees charged if the client held the mutual fund directly with the mutual fund company. Clients may purchase shares of mutual funds directly from the mutual fund issuer, its principal underwriter, or a distributor without purchasing the services of Paragon or paying the advisory fee on such shares (but subject to any applicable sales charges). Certain mutual funds are offered to the public without a sales charge. In the case of mutual funds offered with a sales charge, the prevailing sales charge (as described in the mutual fund prospectus) may be more or less than the applicable advisory fee. However, clients would not receive Paragon’s assistance in developing an investment strategy, selecting securities, monitoring performance of the account, and making changes as necessary. Please refer to Item 12 “Brokerage Practices” of this brochure for additional information. Form ADV, Part 2A, Item 6 Performance-Based Fees and Side-By-Side Management Paragon Investing, LLC does not charge performance-based fees or participate in side-by-side management. Side-by-side management refers to the practice of managing accounts that are charged performance-based fees while at the same time managing accounts that are not charged performance-based fees. Performance-based fees are fees that are based on a share of capital gains or appreciation of the assets of a client. Our fees are calculated as described in Fees and Compensation section above, and are not charged on the basis of performance of your advisory account. 7  Form ADV, Part 2A, Item 7 Types of Clients Paragon offers investment advisory services to individuals, high net worth individuals, other investment advisers and businesses. There is a $100,000.00 minimum account size to open and maintain an access only advisory account and a $300,000.00 minimum account size to open and maintain a full service account. Form ADV, Part 2A, Item 8 Methods of Analysis, Investment Strategies, and Risk of Loss Paragon’s methods of analysis and investment strategies incorporate the client’s needs and investment objectives, time horizon, and risk tolerance. Paragon is not bound to a specific investment strategy for the management of investment portfolios, but rather consider the risk tolerance levels pre-determined gathered at the account opening, as well as on an on-going basis. Examples of methodologies that our investment strategies may incorporate include: Asset Allocation – Asset Allocation is a broad term used to define the process of selecting a mix of asset classes and the efficient allocation of capital to those assets by matching rates of return to a specified and quantifiable tolerance for risk. Dollar-Cost Averaging – Dollar-cost averaging is the technique of buying a fixed dollar amount of securities at regularly scheduled intervals, regardless of the price per share. This will gradually, over time, decrease the average share price of the security. Dollar-cost averaging lessens the risk of investing a large amount in a single investment at the wrong time. Technical Analysis – Involves studying past price patterns and trends in the financial markets to predict the direction of both the overall market and specific stocks. The risk of market timing based on technical analysis is that it may not accurately predict future price movements. Current prices of securities may reflect all information known about the security and day to day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Fundamental Analysis - We attempt to measure the intrinsic value of a security by looking at economic and financial factors (including the overall economy, industry conditions, and the financial condition and management of the company itself) to determine if the company is underpriced (indicating it is a good time to buy) or overpriced (indicating it is time to sell). Fundamental analysis does not attempt to anticipate market movements. This presents a potential risk, as the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the stock. Mutual Fund, Interval Fund and/or ETF Analysis - We look at the experience and track record of the manager of the mutual fund or ETF in an attempt to determine if that manager has demonstrated an ability to invest over a period of time and in different economic conditions. We 8  also look at the underlying assets in a mutual fund or ETF in an attempt to determine if there is significant overlap in the underlying investments held in other fund(s) in the client’s portfolio. We also monitor the funds or ETFs in an attempt to determine if they are continuing to follow their stated investment strategy. A risk of mutual fund and/or ETF analysis is that, as in all securities investments, past performance does not guarantee future results. A manager who has been successful will not necessarily be able to replicate that success in the future. In addition, as we do not control the underlying investments in a fund or ETF, managers of different funds held by the client may purchase the same security, increasing the risk to the client if that security were to fall in value. There is also a risk that a manager can deviate from the stated investment mandate or strategy of the fund or ETF, which could make the holding(s) less suitable for the client’s portfolio. Long-Term Purchases – securities purchased with the expectation that the value of those securities will grow over a relatively long period of time, generally greater than one year. Short-Term Purchases – securities purchased with the expectation that they will be sold within a relatively short period of time, generally less than one year, to take advantage of the securities’ short term price fluctuations. Our strategies and investments may have unique and significant tax implications. Regardless of your account size or other factors, we strongly recommend that you continuously consult with a tax professional prior to and throughout the investing of your assets. Investing in securities involves risk of loss that clients should be prepared to bear. Although we manage your portfolio with strategies and in a manner consistent with your risk tolerances, there can be no guarantee that our efforts will be successful. You should be prepared to bear the risk of loss. All investments involve the risk of loss, including (among other things) loss of principal, a reduction in earnings (including interest, dividends, and other distributions), and the loss of future earnings. These risks include market risk, interest rate risk, issuer risk, and general economic risk. Regardless of the methods of analysis or strategies suggested for your particular investment goals, you should carefully consider these risks, as they all bear risks. Paragon’s primary goal for investing is to help the client maintain purchasing power over the long term. This may result in short term variability and loss of principal. Time horizon and risk tolerance are key determinates of the proper asset allocation. Paragon’s approach focuses on taking appropriate risks for which clients are compensated (i.e. market risk) and seeking to limit or eliminate risks that do not provide compensation over the long term (i.e. individual stock risk or lack of portfolio risk). Below are some more specific risks of investing: Market Risk. The prices of securities in which clients invest may decline in response to certain events taking place around the world, including those directly involving the companies whose securities are owned by the client or an underlying fund; conditions affecting the general 9  economy; overall market changes; local, regional or global political, social or economic instability; and currency, interest rate and commodity price fluctuations. Investors should have a long-term perspective and be able to tolerate potentially sharp declines in market value. Management Risk. Paragon’s investment approach may fail to produce the intended results. If our perception of the performance of a specific asset class or underlying fund is not realized in the expected time frame, the overall performance of client’s portfolio may suffer. Equity Risk. Equity securities tend to be more volatile than other investment choices. The value of an individual mutual fund or ETF can be more volatile than the market as a whole. This volatility affects the value of the client’s overall portfolio. Small- and mid-cap companies are subject to additional risks. Smaller companies may experience greater volatility, higher failure rates, more limited markets, product lines, financial resources, and less management experience than larger companies. Smaller companies may also have a lower trading volume, which may disproportionately affect their market price, tending to make them fall more in response to selling pressure than is the case with larger companies. Fixed Income Risk. The issuer of a fixed income security may not be able to make interest and principal payments when due. Generally, the lower the credit rating of a security, the greater the risk that the issuer will default on its obligation. If a rating agency gives a debt security a lower rating, the value of the debt security will decline because investors will demand a higher rate of return. As nominal interest rates rise, the value of fixed income securities is likely to decrease. A nominal interest rate is the sum of a real interest rate and an expected inflation rate. Municipal Securities Risk. The value of municipal obligations can fluctuate over time, and may be affected by adverse political, legislative and tax changes, as well as by financial developments that affect the municipal issuers. Because many municipal obligations are issued to finance similar projects by municipalities (e.g., housing, healthcare, water and sewer projects, etc.), conditions in the sector related to the project can affect the overall municipal market. Payment of municipal obligations may depend on an issuer’s general unrestricted revenues, revenue generated by a specific project, the operator of the project, or government appropriation or aid. There is a greater risk if investors can look only to the revenue generated by the project. In addition, municipal bonds generally are traded in the “over-the-counter” market among dealers and other large institutional investors. From time to time, liquidity in the municipal bond market (the ability to buy and sell bonds readily) may be reduced in response to overall economic conditions and credit tightening. Investment Companies Risk. When a client invests in open end mutual funds or ETFs, the client indirectly bears its proportionate share of any fees and expenses payable directly by those funds. Therefore, the client will incur higher expenses, many of which may be duplicative. In addition, the client’s overall portfolio may be affected by losses of an underlying fund and the level of risk arising from the investment practices of an underlying fund (such as the use of derivatives). ETFs are also subject to the following risks: (i) an ETF’s shares may trade at a market price that is above or below their net asset value; (ii) the ETF may employ an investment strategy that utilizes high leverage ratios; or (iii) trading of an ETF’s shares may be halted if the listing exchange’s officials deem such action appropriate, the shares are de-listed from the exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases 10  in stock prices) halts stock trading generally. Paragon has no control over the risks taken by the underlying funds. Interval Fund Risk. Where appropriate, Paragon may recommend certain funds structured as non-diversified, closed-end management investment companies, registered under the Investment Company Act of 1940 (“interval fund”). Investments in an interval fund involve additional risk, including lack of liquidity and restrictions on withdrawals. During any time periods outside of the specified repurchase offer window(s), investors will be unable to sell their shares of the interval fund. There is no assurance that an investor will be able to tender shares when or in the amount desired and the fund can suspend or postpone repurchases. Additionally, in limited circumstances, an interval fund may have a limited amount of capacity and may not be able to fulfill all purchase orders. While an interval fund periodically offers to repurchase a portion of its securities, there is no guarantee that investors may sell their shares at any given time or in the desired amount. As interval funds may expose investors to liquidity risk, investors should consider interval fund shares to be an illiquid investment. Typically, the interval funds are not listed on any securities exchange and are not publicly traded. Thus, there is no secondary market for the fund’s shares. Clients should carefully review the fund’s prospectus to more fully understand the interval fund structure and the corresponding liquidity risks. Because these types of investments involve certain additional risk, these funds will only be utilized when consistent with a client’s investment objectives, individual situation, suitability, tolerance for risk and liquidity needs. Investment should be avoided where an investor has a short-term investing horizon and/or cannot bear the loss of some or all of the investment. Artificial Intelligence and Machine Learning Risk. Certain service providers utilized by the Firm to service client accounts have artificial intelligence components. The use of artificial intelligence and machine learning includes increased risk of data inaccuracies and security vulnerabilities. Due to the rapid advancement of machine learning technologies, future risks related to artificial intelligence are unpredictable. As a measure to mitigate these risks to our clients, the Firm performs periodic due diligence of our service providers for assurance that the service providers have appropriate controls in place to protect our clients’ information and to limit data inaccuracies when artificial intelligence is used by the service provider. Form ADV, Part 2A, Item 9 Disciplinary Information Paragon Investing, LLC or its Principal Executive Officers have not had any reportable disclosable events in the past ten years. 11  Form ADV, Part 2A, Item 10 Other Financial Industry Activities and Affiliations Jonathan Carender and Corey Wangler, owners of Paragon, are not currently registered or have an application pending to register, as a broker-dealer or a registered representative of a broker- dealer. Neither Paragon nor its representatives are registered, or have an application pending to register, as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor. Paragon does not recommend or select other investment advisers for our clients. Mr. Wangler is on the investment committee of Sunpointe LLC, a Securities and Exchange Commission Registered Investment Advisor. This does not create a conflict of interest as Paragon does not share clients with this Registered Investment Advisor. Form ADV, Part 2A, Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Paragon’s Code of Ethics includes guidelines for professional standards of conduct for our Associated Persons. Our goal is to protect client interests at all times and to demonstrate our commitment to fiduciary duties of honesty, good faith, and fair dealing. All of Paragon’s Associated Persons are expected to strictly adhere to these guidelines. Persons associated with Paragon Investing, LLC are also required to report any violations to the Code of Ethics. Additionally, the firm maintains and enforces written policies reasonably designed to prevent the misuse or dissemination of material, non-public information about our clients or client accounts by persons associated with our firm. Paragon and its employees may buy or sell securities that are also held by clients. It is the expressed policy of the advisor that no person employed by our firm purchase or sell any security prior to the transaction being implemented for an advisory account; therefore, preventing such employees from benefiting from transactions placed on behalf of the advisory clients. The advisor does not have, nor plans to have, an interest or position in a security which is then also recommended to the client. As these situations may present a conflict of interest, the advisor has established the following restrictions in order to ensure its fiduciary responsibilities should this issue ever arise: 1. A director, officer or employee of the advisor shall not buy or sell a security for their personal portfolio(s) where their decision is substantially derived, in whole or part, by reason of his or her employment, unless the information is also available to the investing public. No owner/employee of Paragon shall prefer their own interest to that of the client. 12  2. The advisor maintains a list of all securities held by the company and all directors, officers, and employees. These holdings are reviewed on a quarterly basis by the principal of the firm. 3. The advisor requires that all employees must act in accordance with all applicable Federal and State regulations governing registered investment advisors. 4. The advisor may block personal trades with those of clients but will ensure that clients are not at a disadvantage. Paragon’s Code of Ethics is available to you upon request. You may obtain a copy of our Code of Ethics by contacting Corey Wangler at (734) 649-6710. Form ADV, Part 2A, Item 12 Brokerage Practices In order for Paragon to provide asset management services, we request you utilize the brokerage and custodial services of Charles Schwab & Co., Inc. (“Schwab”), for which we have an existing relationship. Paragon and Schwab are not affiliated companies. In considering which independent qualified custodian will be the best fit for Paragon’s business model, we are evaluating the following factors, which is not an all-inclusive list: ➢ Financial strength ➢ Reputation ➢ Reporting capabilities ➢ Execution capabilities ➢ Pricing, and ➢ Types and quality of research Paragon does not select or recommend broker-dealers based on whether the Firm or a related person receives client referrals from that broker-dealer. While you are free to choose any broker- dealer or other service provider, we recommend that you establish an account with a brokerage firm with which we have an existing relationship. Such relationships may include benefits provided to our firm, including, but not limited to research, market information, and administrative services that help our firm manage your account(s). We believe that recommended broker-dealers provide quality execution services for our clients at competitive prices. Price is not the sole factor we consider in evaluating best execution. We also consider the quality of the brokerage services provided by the recommended broker-dealers, including the value of research provided, the firm’s reputation, execution capabilities, commission rates, and responsiveness to our clients and our firm. You may direct us in writing to use a particular broker-dealer to execute some or all of the transactions for your account. If you do so, you are responsible for negotiating the terms and arrangements for the account with that broker-dealer. We may not be able to negotiate commissions, obtain volume discounts, or best execution. In addition, under these circumstances a difference in commission charges may exist between the commissions charged to clients who 13  direct us to use a particular broker or dealer and other clients who do not direct us to use a particular broker or dealer. Paragon does not receive client referrals from broker-dealers in exchange for cash or other compensation, such as brokerage services or research. Paragon does not have any formal soft dollar arrangements. When Paragon buys or sells the same security for two or more clients (including our personal accounts), we may place concurrent orders to be executed together as a single “block” in order to facilitate orderly and efficient execution. Each client account will be charged or credited with the average price per unit. We receive no additional compensation or remuneration of any kind because we aggregate client transactions. No client is favored over any other client. If an order is not completely filled, it is allocated pro-rata based on an allocation statement prepared by Paragon prior to placing the order. Because of an order’s aggregation, some clients may pay higher transaction costs, or greater spreads, or receive less favorable net prices on transactions than would otherwise be the case if the order had not been aggregated. Form ADV, Part 2A, Item 13 Review of Accounts Client accounts are reviewed at least quarterly by Corey Wangler, Principal Executive Officer of the firm. Corey Wangler reviews clients’ accounts with regards to their investment policies and risk tolerance levels. All accounts at Paragon are assigned to this reviewer. All financial planning accounts are reviewed upon financial plan creation and plan delivery by Corey Wangler, Principal Executive Officer of the firm. There is only one level of review and that is the total review conducted to create the financial plan. Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). Each client will receive at least quarterly a written report that details the clients’ account which may come from the custodian. Clients are provided a one-time financial plan concerning their financial situation. After the presentation of the plan, there are no further reports. Clients may request additional plans or reports for a fee. 14  Form ADV, Part 2A, Item 14 Client Referrals and Other Compensation Paragon does not compensate any individual or firm for client referrals. In addition, Paragon does not receive compensation for referring clients to other professional service providers. Form ADV, Part 2A, Item 15 Custody Paragon does not have physical custody of any client funds and/or securities, and does not take custody of client accounts at any time. Client funds and securities will be held with a bank, broker dealer, or other independent qualified custodian. However, by granting Paragon written authorization to automatically deduct fees from client accounts, Paragon is deemed to have limited custody. You will receive account statements from the independent, qualified custodian holding your funds at least quarterly. The account statement from your custodian will indicate the amount of advisory fees deducted from your account(s) each billing cycle. Clients should carefully review statements received from the custodian. Paragon also sends quarterly invoices detailing the manner and amount of advisory fees to all clients. Some clients may execute limited powers of attorney or other standing letters of authorization that permit the firm to transfer money from their account with the client’s independent qualified Custodian to third-parties. This authorization to direct the Custodian may be deemed to cause our firm to exercise limited custody over your funds or securities and for regulatory reporting purposes, we are required to keep track of the number of clients and accounts for which we may have this ability. We do not have physical custody of any of your funds and/or securities. Your funds and securities will be held with a bank, broker-dealer, or other independent, qualified custodian. You will receive account statements from the independent, qualified custodian(s) holding your funds and securities at least quarterly. The account statements from your custodian(s) will indicate any transfers that may have taken place within your account(s) each billing period. You should carefully review account statements for accuracy. Form ADV, Part 2A, Item 16 Investment Discretion Before Paragon can buy or sell securities on your behalf, you must first sign our discretionary management agreement, a limited power of attorney, and/or trading authorization forms. By choosing to do so, you may grant the firm discretion over the selection and amount of securities to be purchased or sold for your account(s) without obtaining your consent or approval prior to each transaction. Clients may impose limitations on discretionary authority for investing in certain securities or types of securities (such as a product type, specific companies, specific sectors, etc.), as well as other limitations as expressed by the client. Limitations on discretionary authority are required to be provided to the IAR in writing. Please refer to the “Advisory 15  Business” section of this Brochure for more information on our discretionary management services. Form ADV, Part 2A, Item 17 Voting Client Securities We do not vote proxies on behalf of your advisory accounts. At your request, we may offer you advice regarding corporate actions and the exercise of your proxy voting rights. Contact Corey Wangler at (734) 649-6710 with any questions. If you own shares of common stock or mutual funds, you are responsible for exercising your right to vote as a shareholder. In most cases, you will receive proxy materials directly from the account custodian. However, in the event we were to receive any written or electronic proxy materials, we would forward them directly to you by mail, unless you have authorized our firm to contact you by electronic mail, in which case, we would forward any electronic solicitation to vote proxies. Form ADV, Part 2A, Item 18 Financial Information Paragon is not required to provide financial information to our clients because we do not require or solicit the prepayment of more than $1,200 six or more months in advance. Paragon does not have any financial condition that is reasonably likely to impair your ability to meet contractual commitments to clients. Neither Paragon nor its representatives have been the subject of a bankruptcy petition at any time during the past ten years. Form ADV, Part 2A, Item 19 Requirements for State-Registered Advisers This section is not applicable because the firm is registered with the U.S. Securities and Exchange Commission. 16