Overview
- Headquarters
- Covington, LA
- Total Firm Assets
- $483 million
- Average High-Net-Worth Client Portfolio Size
- $14.3 million
- Minimum Account Size
- $350,000
Fee Structure
Primary Fee Schedule (PARADIEM DISCLOSURE BROCHURE AND SUPPLEMENTS)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $1,000,000 | 1.50% |
| $1,000,001 | $5,000,000 | 1.25% |
| $5,000,001 | $10,000,000 | 1.00% |
| $10,000,001 | $30,000,000 | 0.75% |
| $30,000,001 | and above | 0.50% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $15,000 | 1.50% |
| $5 million | $65,000 | 1.30% |
| $10 million | $115,000 | 1.15% |
| $50 million | $365,000 | 0.73% |
| $100 million | $615,000 | 0.62% |
Clients
- High-Net-Worth Share of Firm Assets
- 88.69%
- Number of High-Net-Worth Clients
- 30
- Total Client Accounts
- 325
- Discretionary Accounts
- 275
- Non-Discretionary Accounts
- 50
Services Offered
Services: Financial Planning, Portfolio Management for Individuals
Regulatory Filings
- SEC CRD Number
- 158200
Additional Brochure: PARADIEM DISCLOSURE BROCHURE AND SUPPLEMENTS (2026-06-11)
View Document Text
Paradiem, LLC
Form ADV Part 2A – Disclosure Brochure
Effective: June 11, 2026
This Form ADV 2A (“Disclosure Brochure”) provides information about the qualifications and business
practices of Paradiem, LLC (herein “Paradiem” or the “Advisor”). If you have any questions about the
contents of this Disclosure Brochure or require information regarding Paradiem, please contact the
Advisor at (985) 727-0770.
Paradiem is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”).
The information in this Disclosure Brochure has not been approved or verified by the SEC or by any state
securities authority. Registration of an investment advisor does not imply any specific level of skill or
training. This Disclosure Brochure provides information about Paradiem to assist you in determining
whether to retain the Advisor.
Additional information about Paradiem and its Advisory Persons is available on the SEC’s website at
www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 158200.
Paradiem, LLC
510 N Jefferson Ave, Covington, LA 70433
Phone: (985) 727-0770
www.paradiem.org
Item 2 – Material Changes
Form ADV 2 is divided into two parts: Part 2A and Part 2B. Part 2A (the “Disclosure Brochure”) provides
information about a variety of topics relating to an Advisor’s business practices and conflicts of interest.
Part 2B (the “Brochure Supplement”) provides information about Advisory Persons of Paradiem. For
convenience, the Advisor has combined these documents into a single disclosure document.
Paradiem believes that communication and transparency are the foundation of its relationship and
continually strive to provide you with complete and accurate information at all times. Paradiem
encourages all current and prospective clients to read this Disclosure Brochure and discuss any
questions you may have with the Advisor.
The Advisor has individuals affiliated with Impact Kingdom Group, LLC. Please see Item 10 for
The Advisor is no longer affiliated with Halcyon Digital Asset Advisors, LLC/Halcyon Digital Asset
The Advisor is no longer affiliated with OxLot Capital.
The Advisor no longer requires a minimum investment management fee of $4,000 per year.
The Advisor has amended Item 17 to reflect the use of Broadridge Investor Communication
Material Changes
The following material changes have been made to this Disclosure Brochure since the annual amendment
filing on 1/30/2025:
●
additional information.
●
Advisors GP
●
●
●
Solutions as a proxy voting vendor.
Future Changes
From time to time the Advisor may amend this Disclosure Brochure to reflect changes in business
practices, changes in regulations or routine annual updates as required by the securities regulators. This
complete Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if
a material change occurs in the business practices of Paradiem.
At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public
Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD#
158200. You may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at
(985) 727-0770.
Paradiem, LLC
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770
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www.paradiem.org
Item 3 – Table of Contents
Item 1 – Cover Page
Item 2 – Material Changes
Item 3 – Table of Contents
Item 4 – Advisory Services
Item 5 – Fees and Compensation
Item 6 – Performance-Based Fees and Side-By-Side Management
Item 7 – Types of Clients
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
Item 9 – Disciplinary Information
Item 10 – Other Financial Industry Activities and Affiliations
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Item 12 – Brokerage Practices
Item 13 – Review of Accounts
Item 14 – Client Referrals and Other Compensation
Item 15 – Custody
Item 16 – Investment Discretion
Item 17 – Voting Client Securities
Item 18 – Financial Information
Appendix 1
ADV2Bs
Privacy Policy
1
2
3
4
10
13
13
13
15
15
15
16
17
18
19
20
20
20
22
29
42
Paradiem, LLC
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770
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www.paradiem.org
Item 4 – Advisory Services
Paradiem, LLC (herein “Paradiem” or the “Advisor”) is a registered investment advisor with the U.S.
Securities and Exchange Commission (“SEC”). The Advisor is organized as a limited liability company
(“LLC”) under the laws of the State of Louisiana. The Advisor was established as a registered investment
advisor in 2011. Effective January 1, 2022 the Adviser became a wholly owned subsidiary of Paradiem
Holding Company, LLC, which is owned by Eric L. Dunavant (President).
This Disclosure Brochure provides information regarding the qualifications, business practices, and the
advisory services provided by Paradiem, including asset management and insurance.
Paradiem offers asset management and financial consulting services to individuals, high net worth
individuals, families, and charitable organizations (each referred to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a
fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to
mitigate potential conflicts of interest. Paradiem’s fiduciary commitment 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.
Personal Financial Planning and Consulting Services
Personal / Family Planning (Family Capital Architecture)
Paradiem offers services to help coordinate the various aspects of your family’s finances along with your
family relationships. Paradiem seeks to serve families in a role similar to that of a Chief Financial Officer.
The following areas are addressed depending on the needs and complexities of each family.
Family Capital Gap Analysis -
Identify Goals: Written goals and intentions.
Charitable Giving: Highlight organizations where you choose to give and identify increased charitable
giving capacity.
Family: Review and provide current family health insight.
Tax Review: Review prior 2 years tax returns and determine tax minimization opportunities.
Estate Review: Review of current legal documents and outline your current estate plan.
Investments: Review holdings and performance, and audit for values-based investments.
Business: Identify organizational opportunities within Leadership, Operations, Personnel, Finance, and
Sales
Family Capital Gap Analysis Presentation: Review and explanation of what you currently have in place
and how your current plan accomplishes your newly documented goals and intentions.
Paradiem, LLC
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770
Page 4
www.paradiem.org
Family Capital Blueprint (ongoing) -
Clarity of Goals: Generational Impact Retreat, Written goals and intentions, annual review and update.
Trusted Advisor: Listening ear, prioritize your needs/desires, quick response to calls/emails, your
advocate.
Charitable Giving: Annual giving optimization, Kingdom Impact Retreat, creation of Your Giving Story,
develop giving strategies, identify giving passions.
Collaboration: Coordinate your team of advisors, discuss planning with advisors, quarterback your
planning team.
Family: Develop family values, develop family motto, facilitate family meetings, create family letters,
include family in charitable giving, improve communication, strengthen relationships, intentional
conversations, family health insight, give children a voice.
Family: Develop family values, develop family motto, create family letters, create a plan to include family
in charitable giving, improve communication, strengthen relationships, intentional conversations, family
health insight, give children a voice.
Events: Exclusive access to Paradiem events and unique access to our Paradiem community.
Tax Planning: Review tax returns (prepared by your CPA), annual tax planning, capital gains minimization.
Estate Planning: Create estate plan, written legal guidelines, review legal documents (prepared by your
Attorney), drive execution of legal documents.
Implementation: Facilitate implementation of plan, accountability with action items, coordinate and
monitor strategies.
Business: Business sale strategies, succession planning, alignment with personal planning.
Investments: Review holdings and performance, align investments with planning, audit for values-based
investments (if desired).
Annual Reviews: Discuss ideal outcomes, implement ideal outcomes, update plan, implement plan
changes, 98-Point Checklist.
Planning or consulting services may also encompass one or more areas of specific need, including but not
limited to, investment planning, retirement planning, personal savings, education savings and other areas
of a Client’s financial situation. The Advisor may provide guidance on any type of security, depending on
the needs, goals, financial situation and current positions held by a Client. The Advisor may also provide
guidance on non-securities investment products, as appropriate.
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 would pose a conflict, as it would increase the amount of advisory fees paid to the Advisor.
This causes a conflict of interest; to mitigate this conflict Clients always have the right to choose to
implement any recommendation with any broker-dealer or insurance agency. Clients always have the
right to decide whether to implement any recommendations made by the Advisor or maintain an ongoing
relationship with the Advisor. If the Client elects to implement on any of the recommendations made by
Paradiem, LLC
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770
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www.paradiem.org
the Advisor, the Client always has the right to execute the transaction through another advisor. The
Investment Advisor Representatives (herein “Advisory Persons”) will typically receive commissions for the
implementation of recommendations for insurance transactions, in their separate capacity as insurance
professionals.
Investment Management Services
Paradiem provides customized investment advisory solutions for its Clients. This is achieved through
continuous personal Client contact and interaction while providing discretionary and non-discretionary
investment management and consulting services. Paradiem works with each Client to identify their
investment goals and objectives as well as risk tolerance and financial situation to create a portfolio
strategy. Paradiem constructs portfolios with individual equity securities, exchange-traded funds
(“ETFs”), individual fixed income securities and mutual funds to achieve the Client’s investment goals. For
certain Clients, the Advisor may recommend investment in Class F-2 shares offered through American
Funds Services (“AFS”), a low cost mutual fund option, which do not include 12(b)-1 fees. Paradiem’s
investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate positions
that have been held less than one year to meet the objectives of the Client or due to market conditions.
Paradiem 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 the
acceptance by the Advisor. The Advisor may retain other types of investments from the Client’s legacy
portfolio due to fit with the overall portfolio strategy, tax-related reasons, or other reasons as identified
between the Advisor and the Client.
Paradiem evaluates and selects ETFs and mutual funds for inclusion in Client portfolios only after
applying their internal due diligence process. Paradiem may recommend, on occasion, redistributing
investment allocations to diversify the portfolio. Paradiem 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. Paradiem 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 Client, generating cash to meet Client needs, or any risk deemed unacceptable for the
Client’s risk tolerance.
Prior to rendering investment advisory services, Paradiem will ascertain, in conjunction with the Client,
the Client’s financial situation, risk tolerance, and investment objective[s]. Paradiem will provide
investment advisory and related services. At no time will Paradiem accept or maintain custody of a
Client’s funds or securities. All Client assets will be managed within their designated account[s] at the
Custodian, pursuant to the Client investment advisory agreement.
Paradiem, LLC
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770
Page 6
www.paradiem.org
Prior to engaging Paradiem to provide investment advisory services, each Client is required to enter into
one or more advisory agreements with the Advisor that define the terms, conditions, authority and
responsibilities of the Advisor and the Client.
At no time will Paradiem 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 advisory agreement. Please see Item 12 –
Brokerage Practices.
These services may include:
§ Establishing an Investment Strategy – Paradiem, in connection with the Client, will develop a
strategy that seeks to achieve the Client’s goals and objectives.
§ Asset Allocation – Paradiem 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 – Paradiem will develop a portfolio for the Client that is intended to meet
§
the stated goals and objectives of the Client.
Investment Management and Supervision – Paradiem will provide investment management and
ongoing oversight of the Client’s investment portfolio.
Retirement Plan Accounts – When deemed to be in the Client’s best interest, the Advisor will recommend
that a Client roll over its retirement plan account into an account managed by the Advisor. In such
instances, the Advisor will serve as an investment fiduciary as that term is defined under The Employee
Retirement Income Security Act of 1974 (“ERISA”). Such a recommendation creates a conflict of interest
as the Advisor will earn a new (or increase its current) advisory fee as a result of the rollover. No client is
under any obligation to roll over retirement plan assets to an account managed by the Advisor.
Paradiem does manage a wrap fee program. For certain Clients, the Advisor will include the securities
transaction fees together with investment advisory fees to provide the Client with a single, bundled fee
structure. Including these fees into a single asset-based fee is considered a “Wrap Fee Program”. The
Advisor customizes its investment management services for its Clients. The Advisor sponsors the
Paradiem Wrap Fee Program solely as a supplemental disclosure regarding the combination of fees.
Depending on the level of trading required for the Client’s account[s] in a particular year, the Client may
pay more or less in total fees than if the Client paid its own transaction fees. Please see Appendix 1 – Wrap
Fee Program Brochure, which is included as a supplement to this Disclosure Brochure.
As of December 31, 2025, the Advisor manages $483,429,554 in Client assets, $476,028,982 of which are
managed on a discretionary basis and $7,400,572 on a non-discretionary basis.
Paradiem, LLC
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770
Page 7
www.paradiem.org
In addition, as of December 31, 2025, the Advisor also has $1,395,108,455 in assets under advisement
(“AUA”), attestable to ongoing consulting services provided to Clients of the Advisor. Clients may request
more current information at any time by contacting the Advisor.
Item 5 – Fees and Compensation
The following paragraphs detail the fee structure and compensation methodology for services provided by
the Advisor. Each Client shall sign one or more agreements that detail the responsibilities of Paradiem
and the Client.
A. Fees for Advisory Services
Planning and Consulting Services
Planning engagements are typically offered on a fixed fee per engagement that is based on the complexity
and duration of the planning services provided. An estimate of the duration and work effort will be
determined prior to establishing the advisory relationship. Planning fees may be negotiable at the sole
discretion of the Advisor.
In certain instances, Clients may be offered an hourly fee for financial planning and consulting services at
a rate of up to $500 per hour.
The Advisor’s fee is exclusive of, and in addition to, transaction fees, and other related costs and
expenses, which may be incurred by the Client. However, the Advisor shall not receive any portion of
these commissions, fees, and costs. The hourly fees are determined after considering many factors, such
as the level and scope of the services.
Paradiem’s Planning and Consulting Services are completed and offered in two levels of service, based on
a fixed, negotiated retainer fee (as listed below). Fees are determined based on the complexity of the
Client’s situation and the anticipated effort and duration associated with the scope of work. All fees will
be presented to the client BEFORE engagement of the relationship to ensure that all parties are in
agreement to the scope of the work.
Monthly Fee Rate
Annual Fee Rate
Personal Financial Planning &
Consulting Services (Family Capital
Architecture)
Family Capital Gap Analysis
N/A
Family Capital Blueprint - Year One
$78,000
5 basis points (.05%) of net worth one
time
(Minimum: $500 / Maximum: $6,500)
20 basis points (.20%) of total net worth
(Billed Monthly) (Minimum monthly fee:
$500 / Maximum monthly fee: $6,500)
Paradiem, LLC
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770
Page 8
www.paradiem.org
Family Capital Blueprint - Year Two +
$54,000
10 basis points (.10%) of total net worth
(Billed Monthly) (Minimum monthly fee:
$350 / Maximum monthly fee: $4,500)
Fees are charged monthly, in advance, or in advance of the engagement, pursuant to the terms of the
agreement.
Investment Management Services
Investment advisory fees are paid in advance of each month, pursuant to the terms of the investment
advisory agreement. Investment advisory fees are based on the market value of assets under
management at the end of the last business day of the preceding month.
Investment advisory fees are based on investment program[s] in which the Client’s account[s] are
invested and are based on the following tiered schedule:
Assets Under Management
Annual Rate (%)
Up to $1,000,000
$1,000,001 to $5,000,000
1.50%
1.25%
$5,000,001 to $10,000,000
$10,000,001 to $30,000,000
1.00%
0.75%
Over $30,000,000
0.50%
The investment advisory fee in the first month of service is prorated to the inception date of the account[s]
to the end of the first month. Fees may be negotiable at the sole discretion of the Advisor. The Client’s
fees will take into consideration the aggregate assets under management with the Advisor. All securities
held in accounts managed by Paradiem will be independently valued by the Custodian. Paradiem will
conduct periodic reviews of the Custodian’s valuations to ensure accurate billing.
Depending on the unique and particular complexities of a Client’s financial situation, the Advisor may also
offer investment management services based on a fixed annual fee arrangement. The total annual fee is
determined on a case-by-case basis. Factors considered in setting the fixed-fee generally include the
complexity of the Client’s financial situation, level of investable assets, and estimated time involved.
Other factors considered include the number of household members, number and type of accounts, life
stage, business interests, real estate ownership, trust arrangements, etc. Fixed fees are intended to be
competitive with what the Client might expect to pay under an “assets under management” (AUM)
approach (assuming all investable assets were managed).
Paradiem, LLC
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770
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www.paradiem.org
B. Fee Billing
Financial Planning and Consulting Services
Financial planning and consulting fees are invoiced by the Advisor and are due in advance of services
rendered. Clients are to pay these fees on a monthly basis. The Advisor will not collect fees that are
greater than $1,200 if the services will be provided six months or more in the future. For annual retainers,
the Advisor will bill in advance for services that will be completed in less than six months. Supplemental
billing may be required during the year pursuant to the terms of the financial planning and consulting
agreement.
Wealth counseling assessment fees are invoiced by the Advisor and are due in advance of services
rendered.
Clients may incur certain fees or charges imposed by third parties, other than Paradiem, in connection
with recommendations made to the Client. The Client is responsible for all such fees.
Investment Management Services
Investment advisory fees are calculated by the Custodian or delegate and deducted from the Client’s
account[s]. The Client shall instruct the Custodian to automatically deduct the investment advisory fee
from the Client’s account[s] for each billing period and pay the investment advisory fee[s] to the Advisor.
The amount due is calculated by applying the quarterly rate (annual rate divided by 365/366) to the total
assets under management with Paradiem at the beginning of each month. Clients will be provided with a
statement, at least quarterly, from the Custodian reflecting deduction of the investment advisory fee. It is
the responsibility of the Client to verify the accuracy of these fees as listed on the Custodian’s brokerage
statement as the Custodian does not assume this responsibility. Clients provide written authorization
permitting advisory fees to be deducted by Paradiem directly from their account[s] held by the Custodian
as part of the investment advisory agreement and separate account forms provided by the Custodian.
C. Other Fees and Expenses
Clients may incur certain fees or charges imposed by third parties in connection with investments made
on behalf of the Client’s account[s]. Paradiem includes securities transactions costs as part of its overall
investment advisory fee through the Paradiem Wrap Fee Program. Securities transaction fees for Client-
directed trades may be charged back to the Client. Please see Item 4.D. above as well as Appendix 1 –
Wrap Fee Program Brochure. The inclusion of securities transaction fees into a single bundled fee may
cost the Client more or less than if paid separately.
In addition, all fees paid to Paradiem for investment advisory services are separate and distinct from the
expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses
are described in each fund’s prospectus. These fees and expenses will generally be used to pay
management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage
Paradiem, LLC
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770
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and account reporting), and a possible distribution fee. A Client may be able to invest in these products
directly, without the services of Paradiem, but would not receive the services provided by Paradiem which
are designed, among other things, to assist the Client in determining which products or services are most
appropriate for each Client’s financial situation and objectives. Accordingly, the Client should review both
the fees charged by the fund[s] and the fees charged by Paradiem to fully understand the total fees to be
paid. Please refer to Item 12 – Brokerage Practices for additional information.
D. Advance Payment of Fees and Termination
Planning and Consulting Services
Either party may terminate a planning or consulting agreement at any time by providing written notice to
the other party. In addition, the Client may also terminate the advisory agreement within five (5) business
days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will
incur charges for bona fide advisory services rendered to the point of termination and such fees will be
due and payable by the Client. Refunds will be given on a pro-rata basis. The agreement for planning
services is effectively terminated upon the presentation of the plan or specific deliverables included in the
agreement.
Investment Management Services
Paradiem is compensated for its services in advance of the month in which investment advisory services
are rendered. Either party may request to terminate the investment advisory agreement with Paradiem, at
any time, by providing advance written notice to the other party. In addition, the Client may also terminate
the investment advisory agreement within five (5) business days of signing the Advisor’s agreement at no
cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services
rendered to the point of termination and such fees will be due and payable by the Client. Upon
termination, the Advisor will refund any unearned, prepaid investment advisory fees from the effective
date of termination to the end of the month. The Client’s investment advisory agreement with the Advisor
is non-transferable without the Client’s prior consent.
E. Compensation for Sales of Securities
Paradiem does not buy or sell securities and does not receive any compensation for securities
transactions in any Client account, other than the investment advisory fees noted above.
Insurance Agency Affiliations
Paradiem is also a licensed insurance agency and certain Advisory Persons are licensed as insurance
professionals. Paradiem will earn commission-based compensation for selling insurance products,
including insurance products sold to Clients. Insurance commissions earned by Paradiem are separate
and in addition to advisory fees. This practice presents a conflict of interest as Advisory Persons and
members of Paradiem’s management have an incentive to recommend insurance products for the
purpose of generating commissions and revenue rather than solely based on Client needs. Paradiem will
Paradiem, LLC
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770
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never earn both a commission and an ongoing advisory fee on the same assets. Additionally, Clients are
under no obligation to purchase insurance products through any Advisory Person or Paradiem. Please see
Item 10 – Other Financial Industry Activities and Affiliations.
Item 6 – Performance-Based Fees and Side-By-Side Management
Paradiem does not charge performance-based fees for its investment advisory services. The fees charged
by Paradiem are as described in Item 5 above and are not based upon the capital appreciation of the
funds or securities held by any Client. Paradiem does not manage any proprietary investment funds or
limited partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to
recommend any particular investment options to its Clients.
Item 7 – Types of Clients
Paradiem offers asset management and financial consulting services to individuals, high net worth
individuals, families, and charitable organizations. Paradiem generally does not impose a minimum
account size for establishing an asset management relationship.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
Paradiem primarily employs a fundamental analysis method in developing investment strategies for its
Clients. Research and analysis from Paradiem is derived from numerous sources, including financial
media companies, third-party research materials, Internet sources, and review of company activities,
including annual reports, prospectuses, press releases and research prepared by others.
Fundamental analysis utilizes economic and business indicators as investment selection criteria. These
criteria are generally ratios and trends that may indicate the overall strength and financial viability of the
entity being analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a
strong investment with a value discounted by the market. While this type of analysis helps the Advisor in
evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets
meeting the investment criteria utilized in the fundamental analysis may lose value and may have negative
investment performance. The Advisor monitors these economic indicators to determine if adjustments to
strategic allocations are appropriate.
As noted above, Paradiem generally employs a long-term investment strategy for its Clients, as consistent
with their financial goals. Paradiem will typically hold all or a portion of a security for more than a year, but
may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of
Clients. At times, Paradiem may also buy and sell positions that are more short-term in nature, depending
on the goals of the Client and/or the fundamentals of the security, sector, or asset class.
Paradiem, LLC
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770
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www.paradiem.org
Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value.
Clients should be prepared to bear the risk of loss. Paradiem will assist Clients in determining an
appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no
guarantee that a Client will meet their investment goals. Fundamental analysis utilizes economic and
business indicators as investment selection criteria. More details on the Advisor’s review process are
included in Item 13.
Each Client engagement will entail a review of the Client's investment goals, financial situation, time
horizon, tolerance for risk and other factors to develop an appropriate strategy for managing a Client's
account. Client participation in this process, including full and accurate disclosure of requested
information, is essential for the analysis of a Client's account[s]. The Advisor shall rely on the financial and
other information provided by the Client or their designees without the duty or obligation to validate the
accuracy and completeness of the provided information. It is the responsibility of the Client to inform the
Advisor of any changes in financial condition, goals or other factors that may affect this analysis.
The risks associated with a particular strategy are provided to each Client in advance of investing Client
accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the
portfolio construction process. Following are some of the risks associated with the Advisor’s investment
approach.
Market Risks
The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as
well as economic, political, or social events in the U.S. and abroad. This risk is linked to the performance
of the overall financial markets.
Equity (Stock) Risks
Common stocks are subject to general stock market fluctuations and to volatile increases and decreases
in value as market confidence and perception of their issuers change. There is also a certain level of
company or industry specific risk that is inherent in each investment. There is the risk that the company
will perform poorly or have its value reduced based on factors specific to the company or its industry,
ETF Risks
The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the
ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs
have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if
the ETFs have a large bid-ask spread and low trading volume. The price of an ETF fluctuates based upon
the market movements and may dissociate from the index being tracked by the ETF or the price of the
underlying investments. An ETF purchased or sold at one point in the day may have a different price than
the same ETF purchased or sold a short time later.
Mutual Fund Risks
The performance of mutual funds is subject to market risk, including the possible loss of principal. The
price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds.
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510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770
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The price of a mutual fund is typically set daily therefore a mutual fund purchased at one point in the day
will typically have the same price as a mutual fund purchased later that same day.
Real Estate Investment Trusts (“REITs”)
Investing in Real Estate Investment Trusts (“REITs”) involves certain distinct risks in addition to those risks
associated with investing in the real estate industry in general. Equity REITs may be affected by changes in
the value of the underlying property owned by the REITs, while mortgage REITs may be affected by the
quality of credit extended. REITs are subject to heavy cash flow dependency, default by borrowers and
self-liquidation. REITs, especially mortgage REITs, are also subject to interest rate risk (i.e., as interest
rates rise, the value of the REIT may decline).
Fixed Income Risks
Fixed Income Securities are subject to specific risks, including the following: (1) interest rate risks, i.e. the
risk that bond prices will fall if interest rates rise, and vice versa, the risk depends on two things, the
bond's time to maturity, and the coupon rate of the bond. (2) reinvestment risk, i.e. the risk that any profit
gained must be reinvested at a lower rate than was previously being earned, (3) inflation risk, i.e. the risk
that the cost of living and inflation increase at a rate that exceeds the income investment thereby
decreasing the investor’s rate of return, (4) credit default risk, i.e. the risk associated with purchasing a
debt instrument which includes the possibility of the company defaulting on its repayment obligation, (5)
rating downgrades, i.e. the risk associated with a rating agency’s downgrade of the company’s rating
which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity Risks,
i.e. the risk that a bond may not be sold as quickly as there is no readily available market for the bond.
Past performance is not a guarantee of future returns. Investing in securities and other investments
involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded
to discuss these risks with the Advisor.
Item 9 – Disciplinary Information
There are no legal, regulatory or disciplinary events involving Paradiem or any of its management
persons. Paradiem and its Supervised Persons value the trust Clients place in the Advisor. The Advisor
encourages Clients to perform the requisite due diligence on any advisor or service provider that the
Client engages. The backgrounds of the Advisor and its Advisory Persons are available on the Investment
Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name
or CRD# 158200.
Item 10 – Other Financial Industry Activities and Affiliations
Insurance Agency Affiliations
Paradiem also serves as a licensed insurance agency, and as such, may offer insurance products on a
commission basis. The Advisor shall generally introduce the Client to an unaffiliated insurance agency to
Paradiem, LLC
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770
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manage the insurance process. The Advisor shall receive a portion of the insurance commission earned
by the unaffiliated insurance agency. No client shall be under any obligation to purchase any insurance
products from the Advisor or such introduced insurance agency. The recommendation by an Advisory
Person that a Client purchase an insurance product presents a conflict of interest, as the receipt of
commissions may provide an incentive to recommend insurance products based on commissions to be
received, rather than based on a particular Client’s need. Clients are reminded that they remain free to
purchase insurance products through other insurance agencies.
Impact Kingdom Group, LLC
The Advisor is affiliated through common control and ownership with Impact Kingdom Group, LLC. Impact
Kingdom Group LLC, through one or more subsidiaries, including the Advisor, acts as manager to Impact
Kingdom Fund. Due to the affiliation between the Advisor and Impact Kingdom Group, LLC, owners of the
Advisor may benefit financially in their individual capacity if Clients invest into Impact Kingdom Fund. As a
result, the Advisor may have an incentive to invest or recommend that Clients invest into Impact Kingdom
Fund.
Certain Clients of the Advisor may invest in Impact Kingdom Fund managed by Impact Kingdom Group,
LLC and/or such other to-be-formed subsidiaries of Impact Kingdom Group, LLC (Affiliated Private Funds).
In these instances, Clients will pay fees in respect of their investments in such Affiliated Private Funds in
accordance with the offering documents of such funds, which will be in addition to the advisory fees
payable to the Advisor. Clients should refer to the offering documents for the fees and expenses paid or
incurred in connection with an investment in any such Affiliated Private Fund. Prior to recommending that
a Client invest in an Affiliated Private Fund, the Advisor is required to evaluate and determinate that such
recommendation aligns with the Client’s investment needs and objectives. [In addition, the Advisor will
provide additional disclosure information to each Client, which will include relevant details regarding
material financial interests and compensation surrounding an investment in Affiliated Private Funds].
There is no requirement for the Advisor to recommend any Affiliated Private Fund to Clients, nor are
Clients obligated to invest in the Affiliated Private Funds.
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Paradiem has implemented a Code of Ethics that defines the Advisor’s fiduciary commitment to each
Client. This Code of Ethics applies to all persons associated with Paradiem (“Supervised Persons”). The
Code of Ethics was developed to provide general ethical guidelines and specific instructions regarding the
Advisor’s duties to the Client. Paradiem and its Supervised Persons owe a duty of loyalty, fairness, and
good faith towards each Client. It is the obligation of Paradiem associates to adhere not only to the
specific provisions of the Code, but also to the general principles that guide the Code. The Code of Ethics
covers a range of topics that address employee ethics and conflicts of interest. To request a copy of the
Code of Ethics, please contact the Advisor at (985) 727-0770.
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510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770
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Paradiem allows Supervised Persons to purchase or sell the same securities that may be recommended
to and purchased on behalf of Clients. Paradiem does not act as principal in any transactions. In addition,
the Advisor does not act as the general partner of a fund, or advise an investment company. Paradiem
does not have a material interest in any securities traded in Client accounts.
Paradiem allows Supervised Persons to purchase or sell the same securities that may be recommended
to and purchased on behalf of Clients. Owning the same securities that are recommended (purchase or
sell) to Clients presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and
mitigated through policies and procedures. As noted above, the Advisor has adopted the Code to address
insider trading (material non-public information controls); gifts and entertainment; outside business
activities and personal securities reporting. When trading for personal accounts, Supervised Persons have
a conflict of interest when trading in the same securities. The fiduciary duty to act in the best interest of its
Clients can be violated if personal trades are made with more advantageous terms than Client trades, or
by trading based on material non-public information. This risk is mitigated by Paradiem requiring reporting
of personal securities trades in order to determine that the Advisory Persons is not putting the Client into a
disadvantage and adhering to the policies and procedures by its Supervised Persons for review by the
CCO, pursuant to its Code of Ethics. The Advisor has also adopted written policies and procedures to
detect the misuse of material, non-public information. In addition, the Code of Ethics governs Gifts and
Entertainment given by and provided to the Advisor, outside employment activities of employees,
Employee reporting, sanctions for violations of the Code of Ethics, and records retention requirements for
various aspects of the Code of Ethics.
Paradiem allows Supervised Persons to purchase or sell the same securities that may be recommended
to and purchased on behalf of Clients. The Advisor and its affiliated persons often trade alongside its
Clients and will often include trades for the accounts of affiliated persons at the same time as its Clients.
At no time, will Paradiem or any Supervised Persons of Paradiem, transact in any security to the
detriment of any Client.
Item 12 – Brokerage Practices
Paradiem does not have discretionary authority to select the broker-dealer/custodian for custody and
execution services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to
safeguard Client assets and authorize Paradiem to direct trades to the Custodian as agreed upon in the
wealth management agreement.
The Advisor typically recommends that Clients establish their account[s] at Charles Schwab & Co., Inc.
(“Schwab”), a FINRA-registered broker-dealer and member SIPC. Clients are not obligated to use the
recommended Custodian and will not incur any extra fee or cost from the Advisor associated with using a
custodian not recommended by Paradiem. Schwab will serve as the Client’s “qualified custodian”.
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510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770
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Paradiem maintains an institutional relationship with Schwab, whereby the Advisor receives economic
benefits. Please see Item 14 – Client Referrals and Other Compensation below.
Paradiem may also recommend that Clients establish their account[s] at Mutual Securities, Inc. (“Mutual
Securities”), a FINRA-registered broker-dealer and member SIPC. Clients are not obligated to use the
recommended Custodian and will not incur any extra fee or cost from the Advisor associated with using a
custodian not recommended by Paradiem. Mutual Securities will serve as the Client’s “qualified
custodian”. Paradiem maintains an institutional relationship with Mutual Securities, whereby the Advisor
receives economic benefits from Mutual Securities. Please see Item 14 below.
In addition, the Advisor may recommend that a Client establish their account[s] directly with a mutual
fund company. For Client accounts established to invest in AFS Fund Class F-2 shares, American Funds
Services will act as the transfer agent for the fund.
Following are additional details regarding the brokerage practices of the Advisor:
1. Soft Dollars - Soft dollars are programs offered by broker-dealers/custodians whereby an advisor
enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research
and other services. Paradiem receives soft dollar economic benefits from Schwab (Please see Item 14).
Clients should be aware that the receipt of economic benefits from a Custodian creates a conflict of
interest since these benefits may influence the Advisor's recommendation of the Custodian over one that
does not furnish similar software, systems support, or services. To mitigate this conflict of interest the
benefits received by the Advisor or its Advisory Persons through participation in the program do not
depend on the amount of brokerage transactions directed to the Custodian. As part of its fiduciary duties
to clients, the Advisor at all times puts the interests of its Clients first.
2. Brokerage Referrals - Paradiem does not receive any compensation from any third party in connection
with the recommendation for establishing an account.
3. Directed Brokerage - The Advisor does not utilize directed brokerage and the Client has the ability to
choose whom they utilize for a Custodian. If a client engages a Custodian other than Schwab the Advisor’s
ability to aggregate a trade may be negated.
The primary objective in placing orders for the purchase and sale of securities for Client accounts is to
obtain the most favorable net results taking into account such factors as 1) price, 2) size of the order, 3)
difficulty of execution, 4) confidentiality and 5) skill required of the Custodian.
Paradiem will execute its transactions through the Custodian as authorized by the Client. Paradiem may
aggregate orders in a block trade or trades when securities are purchased or sold through the Custodian
for multiple (discretionary) accounts. If a block trade cannot be executed in full at the same price or time,
the securities actually purchased or sold by the close of each business day must be allocated in a manner
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510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770
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that is consistent with the initial pre-allocation or other written statement. This must be done in a way that
does not consistently advantage or disadvantage particular Client accounts.
Item 13 – Review of Accounts
Securities in Client accounts are monitored regular and continuous basis, at least monthly by Eric
Dunavant, President of the Advisor. Formal reviews are generally conducted at least annually.
In addition to the investment monitoring each Client account shall be internally reviewed at least
annually. Reviews may be conducted more or less frequently at the Client’s request. Accounts may be
reviewed as a result of major changes in economic conditions, known changes in the Client’s financial
situation, and/or large deposits or withdrawals in the Client’s account[s]. The Client is encouraged to
notify Paradiem if changes occur in his/her personal financial situation that might adversely affect his/her
investment plan. Additional reviews may be triggered by material market, economic or political events.
The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage
statements are sent directly from the Custodian to the Client. The Client may also establish electronic
access to the Custodian’s website so that the Client may view these reports and their account activity.
Client brokerage statements will include all positions, transactions and fees relating to the Client’s
account[s]. The Advisor or the Custodian may also provide Clients with periodic reports regarding their
holdings, allocations, and performance.
Item 14 – Client Referrals and Other Compensation
Paradiem may refer Clients to various unaffiliated, non-advisory professionals (e.g. attorneys,
accountants, estate planners) to provide certain financial services necessary to meet the goals of its
Clients. Paradiem does not receive compensation for these referrals. Likewise, Paradiem may receive
non-compensated referrals of new Clients from various third-parties.
Participation in Institutional Advisor Platform
As disclosed under Item 12, above, the Advisor has established an institutional relationship with Schwab
through its “Schwab Advisor Services” unit, a division of Schwab dedicated to serving independent
advisory firms like Paradiem. As a registered investment advisor participating on the Schwab Advisor
Services platform, Paradiem receives access to software and related support without cost because the
Advisor renders investment management services to Clients that maintain assets at Schwab. Services
provided by Schwab Advisor Services benefit the Advisor and many, but not all services provided by
Schwab will benefit Clients. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put
the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits
from a custodian creates a conflict of interest since these benefits can influence the Advisor's
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510 N Jefferson, Covington, LA 70433
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recommendation of Schwab over a custodian that does not furnish similar software, systems support, or
services.
Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad
range of investment products, execution of securities transactions, and custody of Client’s funds and
securities. Through Schwab, the Advisor may be able to access certain investments and asset classes
that the Client would not be able to obtain directly or through other sources. Further, the Advisor may be
able to invest in certain mutual funds and other investments without having to adhere to investment
minimums that might be required if the Client were to directly access the investments.
Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to
technology, research, discounts and other services. In addition, the Advisor receives duplicate
statements for Client accounts, the ability to deduct advisory fees, trading tools, and back-office support
services as part of its relationship with Schwab. These services are intended to assist the Advisor in
effectively managing accounts for its Clients but may not directly benefit all Clients.
Services that May Only Benefit the Advisor – Schwab also offers other services and financial support to
Paradiem that may not benefit the Client, including: educational conferences and events, financial start-
up support, consulting services and discounts for various service providers. Additionally, Schwab has
agreed to pay for certain services rendered by third parties for which the Advisor would otherwise have to
pay. This amount is covered once the value of Client assets in accounts at Schwab reaches a certain size.
Clients do not pay more for assets maintained at Schwab as a result of these arrangements. However, the
Advisor does benefit from the arrangement because the cost of these services would otherwise be borne
directly by the Advisor. Access to these services and financial support creates a financial incentive for the
Advisor to recommend Schwab, which results in a conflict of interest. Paradiem believes, however, that
the selection of Schwab as Custodian is in the best interests of its Clients. Clients should consider these
conflicts of interest when selecting a custodian.
Participation in Institutional Advisor Platform
Paradiem has established an institutional relationship with Mutual Securities (“Custodian”) to assist the
Advisor in managing Client account[s]. Access to the Mutual Securities platform is provided at no charge
to the Advisor. The Advisor receives access to software and related support without cost because the
Advisor renders investment management services to Clients that maintain assets at Mutual Securities.
The software and related systems support may benefit the Advisor, but not its Clients directly. In fulfilling
its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients
should be aware, however, that the receipt of economic benefits from a Custodian creates a potential
conflict of interest since these benefits may influence the Advisor's recommendation of this Custodian
over one that does not furnish similar software, systems support, or services.
Insurance Company
Paradiem, LLC
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770
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As noted in Item 10, Paradiem also serves as an insurance company, where the Advisor may recommend
to Clients the purchase of certain insurance products. Paradiem will benefit from any revenue generated
from the sale of a recommended insurance product.
Compensation for Client Referrals
Certain Clients may be referred to Paradiem by either an affiliated or unaffiliated party (herein "Promoter")
and receive, directly or indirectly, compensation for the Client referral. In such instances, Paradiem will
compensate the Promoter a fee in accordance with Rule 206(4)-1 of the Advisers Act and any
corresponding state securities requirements. Any such compensation shall be paid solely from the
investment advisory fees earned by Paradiem, and shall not result in any additional charge to the Client.
Item 15 – Custody
The Advisor is authorized to deduct its advisory fees from the Clients account[s] at the custodian. The
Client must place their assets with a "qualified custodian." The Client is required to engage the to retain
all funds and securities and direct Paradiem to utilize that Custodian for securities transactions in the
account[s]. The Client should review statements provided by the Custodian, as the Custodian does not
perform this review. For more information about custodians and brokerage practices, see Item 12 –
Brokerage Practices.
If the Client gives Paradiem the authority to move money from one account to another account, Paradiem
may have custody of those assets. In order to avoid additional regulatory requirements, the Custodian
and Paradiem have adopted safeguards to ensure that all money movements are completed in
accordance with the Client’s instructions.
Item 16 – Investment Discretion
Paradiem typically has discretion over the selection and amount of securities to be bought or sold in
Client accounts without obtaining prior consent or approval from the Client. These purchases or sales are
subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and
agreed to by Paradiem. Discretionary authority will only be authorized upon full disclosure to the Client.
The granting of such authority will be evidenced by the Client's execution of an investment advisory
agreement containing all applicable limitations to such authority. All discretionary trades made by
Paradiem will be in accordance with each Client's investment objectives and goals.
Paradiem, LLC
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770
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Item 17 – Voting Client Securities
Paradiem accepts proxy-voting responsibility for securities held in Client accounts when provided by the
Client. The advisory agreement between Paradiem and the Client will generally specify whether or not
Paradiem has the authority to vote proxies on behalf of a particular Client.
Paradiem has engaged Broadridge Investor Communication Solutions, Inc (“Broadridge”), a third-party,
independent proxy advisory firm, to vote proxies in order to mitigate risks involved with any conflicts of
interest that might otherwise arise in the voting of Client proxies. Although Paradiem expects to vote
proxies according to Broadridge’s recommendations, certain issues may need to be considered on a
case-by-case basis due to the diverse and continually evolving nature of corporate governance issues. If
such cases should arise, then Paradiem will devote appropriate time and resources to consider those
issues.
Proxy Voting Policy and Procedures
Paradiem shall vote proxies in the best interest of its Clients and shall not subrogate the Client’s interest
to its own. Paradiem monitors corporate actions through the Custodian. Paradiem receives notice of
upcoming proxy votes, meeting and record dates, and other information on upcoming corporate actions
by companies in which Paradiem Clients are shareholders. Clients may request a copy of Paradiem’s
proxy voting records free of charge by contacting Paradiem.
Conflicts of Interest in the Voting Process
On occasion, a conflict of interest may exist between the Advisor and the client regarding the outcome of
certain proxy votes. In such cases, the Advisor is committed to resolving the conflict in the best interest of
the Clients before voting for the proxy in question.
Client Direction of Voting
Although most of Paradiem’s Clients for whom the Advisor votes proxies authorize Paradiem to vote in
accordance with its proxy voting policy, a Client may request that the Advisor votes its proxies in
accordance with a different policy. The Advisor will try to accommodate such requests.
In addition, a Client may direct Paradiem to votes its securities in a particular way on a particular
proposal, and the Advisor will seek to do so, assuming timely receipt of the instruction.
Item 18 – Financial Information
Neither Paradiem, nor its management, have any adverse financial situations that would reasonably impair
the ability of Paradiem to meet all obligations to its Clients. Neither Paradiem, nor any of its Advisory
Persons, have been subject to a bankruptcy or financial compromise. Paradiem is not required to deliver a
balance sheet along with this Disclosure Brochure as the Advisor does not collect fees of $1,200 for
services to be performed six months or more in advance.
Paradiem, LLC
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770
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Paradiem, LLC
Form ADV Part 2A – Appendix 1
(“Wrap
Fee Program Brochure”)
Effective: June 11, 2026
This Form ADV2A - Appendix 1 (“Wrap Fee Program Brochure”) provides information about the
qualifications and business practices for Paradiem, LLC (“Paradiem” or the “Advisor”) services when
offering services pursuant to a wrap program. This Wrap Fee Program Brochure shall always be
accompanied by the Paradiem Disclosure Brochure, which provides complete details on the business
practices of the Advisor. If you did not receive the complete Paradiem Disclosure Brochure or you have
any questions about the contents of this Wrap Fee Program Brochure or the Paradiem Disclosure
Brochure, please contact the Advisor at (985) 727-0770.
Paradiem is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”).
The information in this Wrap Fee Program Brochure has not been approved or verified by the SEC or by any
state securities authority. Registration of an investment advisor does not imply any specific level of skill or
training. This Wrap Fee Program Brochure provides information about Paradiem to assist you in
determining whether to retain the Advisor.
Additional information about Paradiem and its Advisory Persons is available on the SEC’s website at
www.adviserinfo.sec.gov by searching with our firm name or our CRD# 158200.
Paradiem, LLC
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Item 2 – Material Changes
Form ADV 2 – Appendix 1 provides information about a variety of topics relating to an Advisor’s business
practices and conflicts of interest. In particular, this Wrap Fee Program Brochure discusses wrap fee
programs offering by the Advisor.
Material Changes
The following material changes have been made to this Disclosure Brochure since the annual amendment
filing on 1/30/2025:
● The Advisor has individuals affiliated with Impact Kingdom Group, LLC. Please see Item 10 for
additional information.
● The Advisor is no longer affiliated with Halcyon Digital Asset Advisors, LLC/Halcyon Digital Asset
Advisors GP
● The Advisor is no longer affiliated with OxLot Capital.
● The Advisor no longer requires a minimum investment management fee of $4,000 per year.
● The Advisor has amended Item 17 to reflect the use of Broadridge Investor Communication
Solutions as a proxy voting vendor.
Future Changes
From time to time, the Advisor may amend this Wrap Fee Program Brochure to reflect changes in business
practices, changes in regulations or routine annual updates as required by the securities regulators. This
complete Wrap Fee Program Brochure (along with the complete Paradiem Disclosure Brochure) or a
Summary of Material Changes shall be provided to you annually and if a material change occurs in the
business practices of Paradiem.
At any time, you may view this Wrap Fee Program Brochure and the current Disclosure Brochure on-line at
the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the
Advisor’s firm name or CRD# 158200. You may also request a copy of this Disclosure Brochure at any
time, by contacting the Advisor at (985) 727-0770.
Item 3 – Services Fees and Compensation
Paradiem, LLC (“Paradiem” or the “Advisor”) provides customized investment advisory services for its
Clients. This Wrap Fee Program Brochure is provided as a supplement to the Paradiem Disclosure
Brochure (Form ADV 2A). This Wrap Fee Program Brochure is provided along with the complete Disclosure
Brochure to provide full details of the business practices and fees when selecting Paradiem as your
investment advisor.
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Phone: (985) 727-0770
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As part of the investment advisory fees noted in Item 5 – Fees and Compensation of the Disclosure
Brochure, Paradiem includes normal securities transaction fees as part of the overall investment advisory
fee. Securities regulations often refer to this combined fee structure as a “Wrap Fee Program”. The
Advisor’s recommended Custodian does not charge securities transaction fees for ETF and equity trades
in a Client’s account, provided that the account meets the terms and conditions of the Custodian’s
brokerage requirements. However, the Custodian typically charges for mutual funds and other types of
investments. The Advisor sponsors the Paradiem Wrap Fee Program.
The sole purpose of this Wrap Fee Program Brochure is to provide additional disclosure relating the
combination of securities transaction fees into the single “bundled” investment advisory fee. This Wrap
Fee Program Brochure references back to the Paradiem Disclosure Brochure in which this Wrap Fee
Program Brochure serves as an Appendix. Please see Item 4 – Advisory Services of the Disclosure
Brochure for details on Paradiem’s investment philosophy and related services.
Advisory services provided by Paradiem are offered in a wrap fee structure whereby normal securities
transaction costs are included in the overall investment advisory fee paid to Paradiem. As the level of
trading in a Client’s account[s] may vary from year to year, the annual cost to the Client may be more or
less than engaging for advisory services where the transactions costs are borne separately by the Client.
The cost of the Wrap Fee Program varies depending on services to be provided to each Client, however,
the Client is not charged more if there is higher trading activity in the Client’s account[s] or to utilize
securities that do not have transaction fees. As noted above, the Advisor’s recommended Custodian does
not charge securities transaction fees for ETF and equity trades in a Client’s account, provided that the
account meets the terms and conditions of the Custodian’s brokerage requirements. However, the
Custodian typically charges for mutual funds and other types of investments such, the Advisor is
incentivized to utilize ETFs and other equity securities to limit the overall cost to the Advisor. The Advisor
will only place Client assets into a Wrap Fee Program when it is believed to be in the Client’s best interest.
Please see Item 5 – Fees and Compensation of the Disclosure Brochure for complete details on fees.
Investment advisory fees are paid quarterly or monthly (herein the “Billing Period”), in advance of each
Billing Period, pursuant to the terms of the investment advisory agreement. Investment advisory fees are
based on the market value of assets under management at the end of the last business day of the
preceding Billing Period.
Assets Under Management
Annual Rate (%)
Up to $1,000,000
1.50%
$1,000,001 to $5,000,000
$5,000,001 to $10,000,000
$10,000,001 to $30,000,000
Over $30,000,000
1.25%
1.00%
0.75%
0.50%
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510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770
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The investment advisory fee in the first quarter of service is prorated from the inception date of the
account[s] to the end of the first Billing Period. Fees may be negotiable at the sole discretion of the
Advisor. The Client’s fees will take into consideration the aggregate assets under management with
Advisor. All securities held in accounts managed by Paradiem will be independently valued by the
Custodian. Paradiem will conduct periodic reviews of the Custodian’s valuations.
As noted above, the Wrap Fee Program includes normal securities trading costs incurred in connection
with the discretionary investment management services provided by Paradiem. Securities transaction
fees for Client-directed trades may be charged back to the Client.
Clients may incur certain fees or charges imposed by third parties in connection with investments made
on behalf of the Client’s account[s]. Under this Wrap Fee Program, Paradiem includes securities
transactions costs as part of its overall investment advisory fee.
In addition, all fees paid to Paradiem for investment advisory services or part of the Wrap Fee Program are
separate and distinct from the expenses charged by mutual funds and exchange-traded funds to their
shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees
and expenses will generally be used to pay management fees for the funds, other fund expenses, account
administration (e.g., custody, brokerage and account reporting), and a possible distribution fee.
Additionally, account activity fees, such as electronic funds and wire transfers fees, certificate delivery
fees, markups and markdowns, bid-ask spreads, selling concessions, and other miscellaneous fees and
expenses as outlined in the account opening paperwork executed with the Custodian, are generally
charged to the Client. Clients are encouraged to refer to the account opening paperwork executed with
the Custodian for an outline of all third-party fees not covered under this Wrap Fee Program.
Paradiem is the sponsor and portfolio manager of this Wrap Fee Program. Paradiem receives investment
advisory fees paid by Clients for participating in the Wrap Fee Program and pays the Custodian for the
costs associated with the management of the Client’s account[s].
Item 4 – Account Requirements and Types of Clients
Paradiem offers investment advisory services to individuals, families and charitable organizations.
Paradiem has a minimum relationship size of $350,000 per household, this minimum may be waived at
the sole discretion of the Advisor. Please see Item 7 – Types of Clients in the Disclosure Brochure for
additional information.
Item 5 – Portfolio Manager Selection and Evaluation
Paradiem, LLC
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770
Page 25
www.paradiem.org
Portfolio Manager Selection
Paradiem serves as sponsor and as portfolio manager for the services under this Wrap Fee Program.
Related Persons
Paradiem personnel serve as portfolio managers for this Wrap Fee Program. Paradiem does not serve as a
portfolio manager for any third-party wrap fee programs.
Performance-Based Fees
Paradiem does not charge performance-based fees.
Supervised Persons
Paradiem Advisory Persons serve as portfolio managers for all accounts, including the services described
in this Wrap Fee Program Brochure. Details of the advisory services provided are included in Item 4.A. of
the Disclosure Brochure.
Methods of Analysis
Please see Item 8 of the Disclosure Brochure (included with this Wrap Fee Program Brochure) for details
on the research and analysis methods employed by the Advisor.
Risk of Loss
Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value.
Clients should be prepared to bear the potential risk of loss. Paradiem will assist Clients in determining an
appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no
guarantee that a Client will meet their investment goals.
Each Client engagement will entail a review of the Client’s investment goals, financial situation, time
horizon, tolerance for risk and other factors to develop an appropriate strategy for managing a Client’s
account[s]. Client participation in this process, including full and accurate disclosure of requested
information, is essential for the analysis of a Client’s account[s]. The Advisor shall rely on the financial
and other information provided by the Client or their designees without the duty or obligation to validate
the accuracy and completeness of the provided information. It is the responsibility of the Client to inform
the Advisor of any changes in financial condition, goals or other factors that may affect this analysis.
Past performance is not a guarantee of future returns. Investing in securities and other investments
involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded
to discuss these risks with the Advisor. Please see Item 8.B. – Risk of Loss in the Disclosure
Brochure for details on investment risks.
Proxy Voting
Paradiem, LLC
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770
Page 26
www.paradiem.org
Paradiem accepts proxy-voting responsibility for securities held in Client accounts when provided by the
Client. The advisory agreement between Paradiem and the Client will generally specify whether or not
Paradiem has the authority to vote proxies on behalf of a particular Client.
Paradiem has engaged Broadridge Investor Communication Solutions, Inc (“Broadridge”), a third-party,
independent proxy advisory firm, to vote proxies in order to mitigate risks involved with any conflicts of
interest that might otherwise arise in the voting of Client proxies. Although Paradiem expects to vote
proxies according to Broadridge’s recommendations, certain issues may need to be considered on a
case-by-case basis due to the diverse and continually evolving nature of corporate governance issues. If
such cases should arise, then Paradiem will devote appropriate time and resources to consider those
issues.
Proxy Voting Policy and Procedures
Paradiem shall vote proxies in the best interest of its Clients and shall not subrogate the Client’s interest
to its own. Paradiem monitors corporate actions through the Custodian. Paradiem receives notice of
upcoming proxy votes, meeting and record dates, and other information on upcoming corporate actions
by companies in which Paradiem Clients are shareholders. Clients may request a copy of Paradiem’s
proxy voting records free of charge by contacting Paradiem.
Conflicts of Interest in the Voting Process
On occasion, a conflict of interest may exist between the Advisor and the client regarding the outcome of
certain proxy votes. In such cases, the Advisor is committed to resolving the conflict in the best interest of
the Clients before voting for the proxy in question.
Client Direction of Voting
Although most of Paradiem’s Clients for whom the Advisor votes proxies authorize Paradiem to vote in
accordance with its proxy voting policy, a Client may request that the Advisor votes its proxies in
accordance with a different policy. The Advisor will try to accommodate such requests.
In addition, a Client may direct Paradiem to votes its securities in a particular way on a particular
proposal, and the Advisor will seek to do so, assuming timely receipt of the instruction.
Item 6 – Client Information Provided to Portfolio Managers
Paradiem is the sponsor and sole portfolio manager for the Program. The Advisor does not share Client
information with other portfolio managers because it is the sole portfolio manager for this Wrap Fee
Program. Please also see the Paradiem Privacy Policy (included after this Wrap Fee Program Brochure).
Item 7 – Client Contact with Portfolio Managers
Paradiem is a full-service investment management advisory firm. Clients always have direct access to the
Portfolio Managers at Paradiem.
Item 8 – Additional Information
Paradiem, LLC
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770
Page 27
www.paradiem.org
Paradiem values the trust Clients place in the Advisor. The Advisor encourages Clients to perform the
requisite due diligence on any advisor or service provider that the Client engages. The backgrounds of the
Advisor and its Advisor Persons are on the Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching for the Advisor’s firm name or CRD# 158200. Please see Item 9 of
the Paradiem Disclosure Brochure as well as Item 3 of each Advisory Person’s Brochure Supplement
(included with this Wrap Fee Program Brochure) for additional information on how to research the
background of the Advisor and its Advisory Persons.
Other Financial Activities and Affiliations
Please see Item 10 – Other Financial Industry Activities and Affiliations and Item 14 – Client Referrals and
Other Compensation of the Form ADV Part 2A – Disclosure Brochure (included with this Wrap Fee
Program Brochure).
Paradiem has implemented a Code of Ethics that defines our fiduciary commitment to each Client. This
Code of Ethics applies to all persons subject to Paradiem’s compliance program (“Supervised Persons”).
Complete details on the Paradiem Code of Ethics can be found under Item 11 – Code of Ethics,
Participation in Client Transactions and Personal Trading in the Disclosure Brochure (included with this
Wrap Fee Program Brochure).
Review of Accounts
Investments in Client accounts are monitored on a regular and continuous basis by Advisory Persons of
Paradiem under the supervision of the Chief Compliance Officer (“CCO”). Details of the review policies
and practices are provided in Item 13 – Review of Accounts of the Form ADV Part 2A – Disclosure
Brochure.
Other Compensation
Participation in Institutional Advisor Platform
The Advisor has established an institutional relationship with Schwab through its “Schwab Advisor
Services” unit, a division of Schwab dedicated to serving independent advisory firms like Paradiem. As a
registered investment advisor participating on the Schwab Advisor Services platform, Paradiem receives
access to software and related support without cost because the Advisor renders investment
management services to Clients that maintain assets at Schwab. Services provided by Schwab Advisor
Services benefit the Advisor and many, but not all services provided by Schwab will benefit Clients. In
fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first.
Clients should be aware, however, that the receipt of economic benefits from a custodian creates a
conflict of interest since these benefits can influence the Advisor’s recommendation of Schwab over a
custodian that does not furnish similar software, systems support, or services.
Paradiem, LLC
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770
Page 28
www.paradiem.org
Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad
range of investment products, execution of securities transactions, and custody of Client’s funds and
securities. Through Schwab, the Advisor may be able to access certain investments and asset classes
that the Client would not be able to obtain directly or through other sources. Further, the Advisor may be
able to invest in certain mutual funds and other investments without having to adhere to investment
minimums that might be required if the Client were to directly access the investments.
Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to
technology, research, discounts and other services. In addition, the Advisor receives duplicate
statements for Client accounts, the ability to deduct advisory fees, trading tools, and back-office support
services as part of its relationship with Schwab. These services are intended to assist the Advisor in
effectively managing accounts for its Clients but may not directly benefit all Clients.
Services that May Only Benefit the Advisor – Schwab also offers other services and financial support to
Paradiem that may not benefit the Client, including: educational conferences and events, financial start-
up support, consulting services and discounts for various service providers. Additionally, Schwab has
agreed to pay for certain services rendered by third parties for which the Advisor would otherwise have to
pay. This amount is covered once the value of Client assets in accounts at Schwab reaches a certain size.
Clients do not pay more for assets maintained at Schwab as a result of these arrangements. However, the
Advisor does benefit from the arrangement because the cost of these services would otherwise be borne
directly by the Advisor. Access to these services and financial support creates a financial incentive for the
Advisor to recommend Schwab, which results in a conflict of interest. Paradiem believes, however, that
the selection of Schwab as Custodian is in the best interests of its Clients. Clients should consider these
conflicts of interest when selecting a custodian.
Compensation for Client Referrals
Certain Clients may be referred to Paradiem by either an affiliated or unaffiliated party (herein “Promoter”)
and receive, directly or indirectly, compensation for the Client referral. In such instances, Paradiem will
compensate the Promoter a fee in accordance with Rule 206(4)-1 of the Advisers Act and any
corresponding state securities requirements. Any such compensation shall be paid solely from the
investment advisory fees earned by Paradiem, and shall not result in any additional charge to the Client.
Financial Information
Neither Paradiem, nor its management have any adverse financial situations that would reasonably
impair the ability of Paradiem to meet all obligations to its Clients. Neither Paradiem, nor any of its
Advisory Persons, has been subject to a bankruptcy or financial compromise. Paradiem is not required to
deliver a balance sheet along with this Disclosure Brochure, as the firm does not collect advance fees of
$1,200 or more for services to be performed six months or more in advance. Please see Item 18 of the
Form ADV Part 2A – Disclosure Brochure.
Paradiem, LLC
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770
Page 29
www.paradiem.org
Form ADV Part 2B – Brochure Supplement
for
Eric L. Dunavant
Founder & President
Effective: June 11, 2026
This Form ADV 2B (“Brochure Supplement”) provides information about the background and
qualifications of Eric L. Dunavant (CRD# 3255295) in addition to the information contained in the
Paradiem, LLC (“Paradiem” or the “Advisor”) Disclosure Brochure (contained herein). If you have not
received a copy of this Brochure Supplement or if you have any questions about the contents of this
Brochure Supplement or Paradiem’s Disclosure Brochure, please contact the Advisor at (985) 727-0770.
Additional information about Eric L. Dunavant is available on the SEC’s Investment Adviser Public
Disclosure website at www.adviserinfo.sec.gov.
Paradiem, LLC
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770
Page 30
www.paradiem.org
Item 2 – Educational Background and Business Experience
The President of Paradiem is Eric L. Dunavant. Mr. Dunavant, born in 1973. Mr. Dunavant earned a B.S. -
Agribusiness from Texas A&M University in College Station, TX in 1996. Additional information regarding
Mr. Dunavant’s employment history is included below.
Employment History:
Paradiem, LLC
-
-
Founder & President
President and Chief Compliance Officer
Registered Representative, LPL Financial LLC
Investment Advisor Representative, LPL Financial LLC
Registered Representative, Charles Schwab & Co, Inc.
09/2019 to Present
06/2011 to 09/2019
11/2007 to 05/2017
11/2007 to 10/2011
06/1999 to 11/2007
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Dunavant. Mr. Dunavant has
never been involved in any regulatory, civil or criminal action. There have been no Client complaints,
lawsuits, arbitration claims or administrative proceedings against Mr. Dunavant. Securities laws require
an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a
legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud;
false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there
are no legal, civil or disciplinary events to disclose regarding Mr. Dunavant. However, we do
encourage you to independently view the background of Mr. Dunavant on the Investment Adviser Public
Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his CRD# 3255295.
Item 4 – Other Business Activities
Insurance Agency Affiliations
Mr. Dunavant is also a licensed insurance professional through Paradiem. These services are separate
and distinct from the advisory services offered to Clients. Paradiem may include these as part of its
overall investment process. However, these are provided as a separate service and fee, which is based on
the unique needs of each Client. As an insurance professional, Mr. Dunavant will receive customary
commissions and other related revenues from the insurance companies whose products are sold. Mr.
Dunavant is not required to offer the products of any particular insurance company. Commissions
generated by insurance sales do not offset regular advisory fees. This practice presents a conflict of
interest in recommending certain products of the insurance companies. Clients always have the right to
choose whether to implement any recommendations made by Mr. Dunavant or the Advisor.
Paradiem, LLC
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770
Page 31
www.paradiem.org
IC4 Coaching and Consulting LLC d/b/a Kingdom ROI Coaching and Consulting
Mr. Dunavant is the owner of IC4 Coaching and Consulting LLC d/b/a Kingdom ROI Coaching and
Consulting (“IC4”). IC4 offers coaching and consulting services in an effort to create life and generational
impact through wisdom and communication. Mr. Dunavant serves as the Kingdom ROI Strategist for IC4.
Clients of Paradiem may be engaged for these services outside the scope of their asset management
agreement with Paradiem. This presents a conflict of interest, as Mr. Dunavant may be incentivized to
recommend to Clients of Paradiem that they engage with IC4 for an additional fee.
Odyssey
Mr. Dunavant is a part owner and board member of Odyssey, an organization with the mission “to train
and lead men”. For his role in the firm, Mr. Dunavant assists in sales, service, and training. Mr. Dunavant
spends 5 hours per month in this capacity and is not currently compensated for his position.
Kingdom Signet
Mr. Dunavant is a part owner, insurance agent, and CEO of Kingdom Signet, a life insurance company.
For his role in the firm, Mr. Dunavant oversees the organization and sells insurance. Mr. Dunavant spends
10 hours per month in this capacity and receives compensation for his position through commission on
personal insurance sales and company sales.
Eric L. Dunavant, Author
Mr. Dunavant, has published multiple books titled “What If We’ve Been Doing It All Wrong?”, “I Crashed in
Backwardsville”, and “At The Bistro With Bob”. The books talk about concepts and ideas of investing but
are all provided for general education and informational purposes. The information found in these books
are not tailored to a consumer’s individual financial circumstances, goals, investment objectives, risk
tolerance, or other relevant factors. The consumer should not use the books as the basis for making any
financial decisions and should instead consult a financial, tax, or legal professional to determine the
applicability of the information to their unique situation. The Advisor receives compensation from the
book sales, which are separate and distinct from advisory fees.
Impact Kingdom Group, LLC
Mr. Dunavant is also a Fund Manager for Impact Kingdom Fund, LLC, which is owned and managed by
Impact Kingdom Group, LLC. For his role in the fund, Mr. Dunavant oversees operations of the initial set
up and compliance of the fund. Mr. Dunavant spends 15 hours per month is this capacity and is not
currently compensated but could receive additional compensation in the future through profit sharing.
Item 5 – Additional Compensation
Mr. Dunavant has additional business activities where compensation is received, which are detailed in
Item 4 above.
Paradiem, LLC
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770
Page 32
www.paradiem.org
Item 6 – Supervision
Mr. Dunavant serves as the Founder & President of Paradiem and is supervised by Ray Marie Fenger, the
Chief Compliance Officer. Ms. Fenger can be reached at (985) 727-0770.
Paradiem has implemented a Code of Ethics, an internal compliance document that guides each
Supervised Person in meeting their fiduciary obligations to Clients of Paradiem. Further, Paradiem is
subject to regulatory oversight by various agencies. These agencies require registration by Paradiem and
its Supervised Persons. As a registered entity, Paradiem is subject to examinations by regulators, which
may be announced or unannounced. Paradiem is required to periodically update the information provided
to these agencies and to provide various reports regarding the business activities and assets of the
Advisor.
Paradiem, LLC
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770
Page 33
www.paradiem.org
Form ADV Part 2B – Brochure Supplement
for
Carl W. Drury
Senior Planning Strategist
Effective: June 11, 2026
This Form ADV 2B (“Brochure Supplement”) provides information about the background and
qualifications of Carl W. Drury (CRD# 6063550) in addition to the information contained in the Paradiem,
LLC (“Paradiem” or the “Advisor”) (CRD # 158200) Disclosure Brochure. If you have not received a copy of
the Disclosure Brochure or if you have any questions about the contents of the Paradiem Disclosure
Brochure or this Brochure Supplement, please contact the Advisor at (985) 727-0770.
Additional information about Mr. Drury is available on the SEC’s Investment Adviser Public Disclosure
website at www.adviserinfo.sec.gov.
Paradiem, LLC
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770
Page 34
www.paradiem.org
Item 2 – Educational Background and Business Experience
Carl W. Drury is the Senior Planning Strategist for Paradiem. Mr. Drury, born in 1964, is dedicated to
advising Clients of Paradiem. Mr. Drury earned a Bachelor of Science Mechanical Engineering from
Purdue University in 1989. Additional information regarding Mr. Drury’s employment history is included
below.
Employment History:
Paradiem, LLC
-
-
-
Senior Planning Strategist
President of Transformation
Vice President of Planning
VP & COO, Kardia, Inc.
General Manager Filament Bearings, Rexnord
03/2025 to Present
09/2018 to 03/2025
07/2014 to 09/2018
04/2007 to 07/2014
09/1989 to 04/2007
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Drury. Mr. Drury has never
been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits,
arbitration claims or administrative proceedings against Mr. Drury. Securities laws require an advisor to
disclose any instances where the advisor or its advisory persons have been found liable in a legal,
regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud; false
statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there
are no legal, civil or disciplinary events to disclose regarding Mr. Drury. However, we do encourage
you to independently view the background of Mr. Drury on the Investment Adviser Public Disclosure
website at www.adviserinfo.sec.gov by searching with his full name or his CRD# 6063550.
Item 4 – Other Business Activities
Impact Kingdom Group, LLC
Mr. Drury is also a Fund Manager and Chief Compliance Officer for the Impact Kingdom Fund, LLC which
is owned and managed by Impact Kingdom Group, LLC. For his role in the fund, Mr. Drury oversees
operations of the initial set up and compliance of the fund. Mr. Drury spends 15 hours per month is this
capacity and is not currently compensated but could receive additional compensation in the future
through profit sharing.
Kingdom Signet, LLC
Mr. Drury is also a Senior Planning Strategist for Kingdom Signet, LLC, a life insurance company. As a
Senior Planning Strategist, Mr. Drury assists with creating insurance strategies to meet client needs and
Paradiem, LLC
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770
Page 35
www.paradiem.org
implement strategies for them. Mr. Drury spends 6 hours per month in this capacity and does not receive
any additional compensation at this time
Item 5 – Additional Compensation
Mr. Drury has additional business activities where compensation is received, which are detailed in Item 4
above.
Item 6 – Supervision
Mr. Drury serves as the Senior Planning Strategist of Paradiem and is supervised by Ray Marie Fenger, the
Chief Compliance Officer. Ms. Fenger can be reached at (985) 727-0770.
Paradiem has implemented a Code of Ethics and internal compliance that guide each Supervised Person
in meeting their fiduciary obligations to Clients of Paradiem. Further, Paradiem is subject to regulatory
oversight by various agencies. These agencies require registration by Paradiem and its Supervised
Persons. As a registered entity, Paradiem is subject to examinations by regulators, which may be
announced or unannounced. Paradiem is required to periodically update the information provided to
these agencies and to provide various reports regarding the business activities and assets of the Advisor.
Paradiem, LLC
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770
Page 36
www.paradiem.org
Form ADV Part 2B – Brochure Supplement
for
Danielle R. Wauchope
Chief Planning Strategist
Effective: June 11, 2026
This Form ADV 2B (“Brochure Supplement”) provides information about the background and
qualifications of Danielle R. Wauchope (CRD# 6362274) in addition to the information contained in the
Paradiem, LLC (“Paradiem” or the “Advisor”) (CRD # 158200) Disclosure Brochure. If you have not
received a copy of the Disclosure Brochure or if you have any questions about the contents of the
Paradiem Disclosure Brochure or this Brochure Supplement, please contact the Advisor at (985) 727-
0770.
Additional information about Mrs. Wauchope is available on the SEC’s Investment Adviser Public
Disclosure website at www.adviserinfo.sec.gov.
Paradiem, LLC
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770
Page 37
www.paradiem.org
Item 2 – Educational Background and Business Experience
Danielle R. Wauchope is the Chief Planning Strategist with Paradiem. Mrs. Wauchope, born in 1985, is
dedicated to advising Clients of Paradiem. Mrs. Wauchope earned a Bachelor of Science in Management
and Business Administration from Indiana Wesleyan University in 2007. Additional information regarding
Mrs. Wauchope’s employment history is included below.
Employment History:
Paradiem, LLC
-
-
-
Chief Planning Strategist
Vice President of Financial Transformation
Financial Planner
Financial Planner, Kardia, Inc.
Swing Manager, McDonalds
01/2025 to Present
09/2018 to 01/2025
07/2014 to 09/2018
1/2008 to 07/2014
12/1999 to 12/2007
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mrs. Wauchope. Mrs. Wauchope
has never been involved in any regulatory, civil or criminal action. There have been no client complaints,
lawsuits, arbitration claims or administrative proceedings against Mrs. Wauchope. Securities laws require
an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a
legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud;
false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there
are no legal, civil or disciplinary events to disclose regarding Mrs. Wauchope. However, we do
encourage you to independently view the background of Mrs. Wauchope on the Investment Adviser Public
Disclosure website at www.adviserinfo.sec.gov by searching her full name or her CRD# 6362274.
Item 4 – Other Business Activities
Mrs. Wauchope is dedicated to her church and is heavily active in the church community. This is a
volunteer position and is not compensated for her work.
Item 5 – Additional Compensation
Mrs. Wauchope has additional business activities where no compensation is received, which are detailed
in Item 4 above.
Paradiem, LLC
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770
Page 38
www.paradiem.org
Item 6 – Supervision
Mrs. Wauchope serves as the Chief Planning Strategist and is supervised is supervised by Ray Marie
Fenger, the Chief Compliance Officer. Ms. Fenger can be reached at (985) 727-0770.
Paradiem has implemented a Code of Ethics, and internal compliance document that guide each
Supervised Person in meeting their fiduciary obligations to Clients of Paradiem. Further, Paradiem is
subject to regulatory oversight by various agencies. These agencies require registration by Paradiem and
its Supervised Persons. As a registered entity, Paradiem is subject to examinations by regulators, which
may be announced or unannounced. Paradiem is required to periodically update the information provided
to these agencies and to provide various reports regarding the business activities and assets of the
Advisor.
Paradiem, LLC
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770
Page 39
www.paradiem.org
Form ADV Part 2B – Brochure Supplement
for
Matthew B. Sullivan
Associate Advisor
Effective: June 11, 2026
This Form ADV 2B (“Brochure Supplement”) provides information about the background and
qualifications of Matthew B. Sullivan (CRD# 8030136) in addition to the information contained in the
Paradiem, LLC (“Paradiem” or the “Advisor”, CRD# 158200) Disclosure Brochure. If you have not received
a copy of the Disclosure Brochure or if you have any questions about the contents of the Paradiem
Disclosure Brochure or this Brochure Supplement, please contact us at (985) 727-0770.
Additional information about Mr. Sullivan is available on the SEC’s Investment Adviser Public Disclosure
website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 8030136.
Paradiem, LLC
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770
Page 40
www.paradiem.org
Item 2 – Educational Background and Business Experience
Matthew B. Sullivan, born in 1999, is dedicated to advising Clients of Paradiem as an Associate Advisor .
Mr. Sullivan earned his Bachelor's Degree from Southeastern Louisiana University in 2022. Additional
information regarding Mr. Sullivan’s employment history is included below.
Employment History:
Associate Advisor , Paradiem, LLC
Account Relations, First Guaranty Bank
01/2025 to Present
11/2021 to 01/2025
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Sullivan. Mr. Sullivan has
never been involved in any regulatory, civil or criminal action. There have been no client complaints,
lawsuits, arbitration claims or administrative proceedings against Mr. Sullivan.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have
been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and
other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property;
bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously
noted, there are no legal, civil or disciplinary events to disclose regarding Mr. Sullivan.
However, we do encourage you to independently view the background of Mr. Sullivan on the Investment
Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his
Individual CRD# 8030136.
Item 4 – Other Business Activities
Mr. Sullivan is dedicated to the investment advisory activities of Paradiem’s Clients. Mr. Sullivan does not
have any other business activities.
Item 5 – Additional Compensation
Mr. Sullivan is dedicated to the investment advisory activities of Paradiem’s Clients. Mr. Sullivan does not
receive any additional forms of compensation.
Item 6 – Supervision
Mr. Sullivan serves as an Associate Advisor of Paradiem and is supervised by Ray Marie Fenger, the Chief
Compliance Officer. Ms. Fenger can be reached at (985) 727-0770.
Paradiem has implemented a Code of Ethics, an internal compliance document that guides each
Supervised Person in meeting their fiduciary obligations to Clients of Paradiem. Further, Paradiem is
subject to regulatory oversight by various agencies. These agencies require registration by Paradiem and
its Supervised Persons. As a registered entity, Paradiem is subject to examinations by regulators, which
may be announced or unannounced. Paradiem is required to periodically update the information provided
to these agencies and to provide various reports regarding the business activities and assets of the
Advisor.
Paradiem, LLC
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770
Page 41
www.paradiem.org
Form ADV Part 2B – Brochure Supplement
for
Caleb W. Kelso
Financial Planning Advisor
Effective: June 11, 2026
This Form ADV 2B (“Brochure Supplement”) provides information about the background and
qualifications of Caleb W. Kelso (CRD# 8076928) in addition to the information contained in the Paradiem,
LLC (“Paradiem” or the “Advisor”, CRD# 158200) Disclosure Brochure. If you have not received a copy of
the Disclosure Brochure or if you have any questions about the contents of the Paradiem Disclosure
Brochure or this Brochure Supplement, please contact us at (985) 727-0770 or by email at.
Additional information about Mr. Kelso is available on the SEC’s Investment Adviser Public Disclosure
website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 8076928.
Paradiem, LLC
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770
Page 42
www.paradiem.org
Item 2 – Educational Background and Business Experience
Caleb W. Kelso, born in 1999, is dedicated to advising Clients of Paradiem as a Financial Planning Advisor.
Mr. Kelso earned a Bachelor of Science in Finance from the University of Arkansas - Fayetteville in 2022.
Additional information regarding Mr. Kelso’s employment history is included below.
Employment History:
Financial Planning Advisor, Paradiem, LLC
OPEX Coordinator, Next Level Blending
04/2025 to Present
07/2022 to 04/2025
Treasury Intern, Tyson Foods
Student, University of Arkansas- Fayetteville
01/2021 to 05/2022
08/2018 to 05/2022
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Kelso. Mr. Kelso has never
been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits,
arbitration claims or administrative proceedings against Mr. Kelso.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have
been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and
other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property;
bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously
noted, there are no legal, civil or disciplinary events to disclose regarding Mr. Kelso.
However, we do encourage you to independently view the background of Mr. Kelso on the Investment
Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his
Individual CRD# 8076928.
Item 4 – Other Business Activities
Mr. Kelso is dedicated to the investment advisory activities of Paradiem’s Clients. Mr. Kelso does not have
any other business activities.
Item 5 – Additional Compensation
Mr. Kelso is dedicated to the investment advisory activities of Paradiem’s Clients. Mr. Kelso does not
receive any additional forms of compensation.
Paradiem, LLC
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770
Page 43
www.paradiem.org
Item 6 – Supervision
Mr. Kelso serves as a Financial Planning Advisor of Paradiem and is supervised by Ray Marie Fenger, the
Chief Compliance Officer. Ms. Fenger can be reached at (985) 727-0770.
Paradiem has implemented a Code of Ethics, an internal compliance document that guides each
Supervised Person in meeting their fiduciary obligations to Clients of Paradiem. Further, Paradiem is
subject to regulatory oversight by various agencies. These agencies require registration by Paradiem and
its Supervised Persons. As a registered entity, Paradiem is subject to examinations by regulators, which
may be announced or unannounced. Paradiem is required to periodically update the information provided
to these agencies and to provide various reports regarding the business activities and assets of the
Advisor.
Paradiem, LLC
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770
Page 44
www.paradiem.org
Form ADV Part 2B – Brochure Supplement
for
Carson A. Rich
Senior Research & Trading Associate
Effective: June xx, 2026
This Form ADV 2B (“Brochure Supplement”) provides information about the background and
qualifications of Carson A. Rich (CRD# 8248860) in addition to the information contained in the Paradiem,
LLC (“Paradiem” or the “Advisor”, CRD# 158200) Disclosure Brochure. If you have not received a copy of
the Disclosure Brochure or if you have any questions about the contents of the Paradiem Disclosure
Brochure or this Brochure Supplement, please contact us at (985) 727-0770.
Additional information about Mr. Rich is available on the SEC’s Investment Adviser Public Disclosure
website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 8248860.
Paradiem, LLC
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770
Page 45
www.paradiem.org
Item 2 – Educational Background and Business Experience
Carson A. Rich, born in 2000, is dedicated to advising Clients of Paradiem as a Senior Research & Trading
Associate. Mr. Rich earned a High School Diploma from Mandeville High School in 2018. Additional
information regarding Mr. Rich’s employment history is included below.
04/2026 to Present
01/2025 to 04/2026
Employment History:
Paradiem, LLC
-
-
Senior Research & Trading Associate
Research Associate I
Real Estate Agent, Living in South Louisiana DBA CR Holdings, LLC
Barista, PJ's Coffee
03/2021 to Present
01/2018 to 01/2021
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Rich. Mr. Rich has never been
involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits,
arbitration claims or administrative proceedings against Mr. Rich.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have
been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and
other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property;
bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously
noted, there are no legal, civil or disciplinary events to disclose regarding Mr. Rich.
However, we do encourage you to independently view the background of Mr. Rich on the Investment
Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his
Individual CRD# 8248860.
Item 4 – Other Business Activities
Living in South Louisiana DBA CR Holdings, LLC
Mr. Rich is also a Real Estate Agent of Living in South Louisiana DBA CR Holdings, LLC. Mr. Rich is
compensated for this activity and spends approximately 5% of his time per month in this capacity.
Item 5 – Additional Compensation
Mr. Rich has additional business activities where compensation is received that are detailed in Item 4
above.
Paradiem, LLC
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770
Page 46
www.paradiem.org
Item 6 – Supervision
Mr. Rich serves as a Senior Research & Trading Associate of Paradiem and is supervised by Ray Marie
Fenger, the Chief Compliance Officer. Ms. Fenger can be reached at (985) 727-0770.
Paradiem has implemented a Code of Ethics, an internal compliance document that guides each
Supervised Person in meeting their fiduciary obligations to Clients of Paradiem. Further, Paradiem is
subject to regulatory oversight by various agencies. These agencies require registration by Paradiem and
its Supervised Persons. As a registered entity, Paradiem is subject to examinations by regulators, which
may be announced or unannounced. Paradiem is required to periodically update the information provided
to these agencies and to provide various reports regarding the business activities and assets of the
Advisor.
Paradiem, LLC
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770
Page 47
www.paradiem.org
Privacy Policy
Effective: June 11, 2026
Our Commitment to You
Paradiem, LLC (“Paradiem” or the “Advisor”) is committed to safeguarding the use of your personal
information that we have as your Investment Advisor. Paradiem (referred to as "we", "our" and "us")
protects the security and confidentiality of the personal information we have and make efforts to ensure
that such information is used for proper business purposes in connection with the management or
servicing of your account. Our relationship with you is our most important asset. We understand that you
have entrusted us with your private information, and we do everything we can to maintain that trust.
We do not sell your non-public personal information to anyone. Nor does Paradiem provide such
information to others except for discrete and proper business purposes in connection with the servicing
and management of your account as discussed below.
Details of our approach to privacy and how your personal non-public information is collected and used
are set forth in this privacy policy.
The Information We Collect About You
You typically provide personal information when you complete the paperwork required to become our
Client. This information may include your:
• Name and address
• E-mail address[es]
• Assets
• Income
• Phone number[s]
• Social security or taxpayer identification number
• Account balance
• Investment activity
• Accounts at other institutions
In addition, we may collect non-public information about you from the following sources:
Information we receive on Brokerage Agreements, Managed Account Agreements and other
Information we receive in the course of establishing a customer relationship including, but not
Information about your transactions with us or others
●
Subscription and Account Opening Documents;
●
limited to, applications, forms, and questionnaires;
●
Information About You That Paradiem Shares
Paradiem works to provide products and services that benefit our customers. We may share non-public
personal information with non-affiliated third parties (such as brokers and custodians) as necessary for us
Paradiem, LLC
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770
Page 48
www.paradiem.org
to provide agreed services and products to you consistent with applicable law. We may also disclose non-
public personal information to other financial institutions with whom we have joint business
arrangements for proper business purposes in connection with the management or servicing of your
account. In addition, your non-public personal information may also be disclosed to you, persons we
believe to be your authorized agent or representative, regulators in order to satisfy Paradiem’s regulatory
obligations, and is otherwise required or permitted by law. Lastly, we may disclose your non-public
personal information to companies we hire to help administrate our business. Companies we hire to
provide services of this kind are not allowed to use your personal information for their own purposes and
are contractually obligated to maintain strict confidentiality. We limit their use of your personal
information to the performance of the specific service we have requested.
To repeat, we do not sell your non-public personal information to anyone.
Information About Former Clients
Paradiem does not disclose, and does not intend to disclose, non-public personal information to non-
affiliated third parties with respect to persons who are no longer our clients.
Confidentiality and Security
Our employees are advised about the firm's need to respect the confidentiality of our customers' non-
public personal information. Additionally, we maintain physical, procedural and electronic safeguards in
an effort to protect the information from access by unauthorized parties.
We'll Keep You Informed
We will send you notice of our privacy policy annually for as long as you maintain an ongoing relationship
with us. Periodically we may revise our privacy policy and will provide you with a revised policy if the
changes materially alter the previous privacy policy. We will not, however, revise our privacy policy to
permit the sharing of non-public personal information other than as described in this notice unless we
first notify you and provide you with an opportunity to prevent the information sharing. You may obtain a
copy of our current privacy policy by contacting us at (985) 727-0770.
Paradiem, LLC
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770
Page 49
www.paradiem.org