A. Firm Information
Paradigm Wealth Advisory LLC (“Paradigm” 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 Delaware. Paradigm was founded in April 2016, and is a wholly owned subsidiary of Paradigm
Wealth Management Holdings LLC (“Paradigm Holdings”). David Provinsal (Managing Member) is a majority
owner of Paradigm Holdings.
The Advisor is operated by David Provinsal (Managing Partner and Chief Compliance Officer). This Disclosure
Brochure provides information regarding the qualifications, business practices, and the advisory services
provided by Paradigm.
B. Advisory Services Offered
Paradigm offers investment advisory services to individuals, high net worth individuals, families, trusts, estates,
charitable organizations and businesses (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. Paradigm’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.
Investment Management Services
Paradigm provides customized investment management solutions for its Clients. This is achieved through
continuous personal Client contact and interaction while providing discretionary investment management and
related advisory services. Paradigm works with each Client to identify their investment goals and objectives as
well as risk tolerance and financial situation in order to create an investment strategy. Paradigm will then
construct an investment portfolio, consisting of low-cost, diversified mutual funds and/or exchange-traded funds
(“ETFs”) to achieve the Client’s investment goals. The Advisor may also utilize individual stocks, bonds or options
contracts to meet the needs of its Clients. The Advisor may retain certain legacy investments based on portfolio
fit and/or tax considerations, including legacy engagements with third party money managers.
Client portfolios will primarily be constructed using institutional mutual funds, exchange-traded funds (“ETFs”),
individual equities, individual bonds, and/or variable annuities. With respect to mutual funds, the Advisor seeks
to invest client assets in institutional share classes with the lowest overall expense ratio, where available. Certain
Client may have legacy investments in non-institutional mutual fund shares. The Advisor endeavors to sell such
legacy non-institutional mutual fund shares when appropriate in accordance with client preferences and tax
implications. The Advisor may also utilize other types of investments, as appropriate, to meet the needs of each
particular Client. Client portfolios may be fully customized or use one or more of the Advisor’s investment strategies.
The Advisor’s investment strategies are comprised of several accounts managed in time-segmented strategies.
The Advisor tailors the segments and overall Client strategy to the goals and overall situation of the Client.
Clients accumulating wealth for retirement will have accounts that will differ from those accounts[?] in retirement.
The Client’s accounts may include the use of variable annuity accounts. In such instances, the Advisor enters into
a separate discretionary investment advisory agreement for the management of the variable annuity sub-
accounts. There is no additional fee for the management of these accounts. Please see Items 5.E. and 10 below
for additional information.
Paradigm’s overall investment approach is primarily long-term focused. As detailed above, the Advisor manages
various accounts with different investment purposes and time horizons. Certain accounts may have more or less
investment activity than other accounts as a result. This approach is designed to optimize the Client’s overall
investment strategy. 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. Paradigm will construct, implement and monitor the
portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each
Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their
respective portfolio, subject to acceptance by the Advisor.
The Advisor monitors Client accounts that hold non-institutional mutual funds to seek appropriate opportunities to
convert the funds to an institutional share class, when available. The
Paradigm evaluates and selects investments for inclusion in Client portfolios only after applying its internal due
diligence process. Paradigm may recommend, on occasion, redistributing investment allocations to diversify the
portfolio. Paradigm 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. Paradigm may recommend
selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector
risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the
portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed
unacceptable for the Client’s risk tolerance.
At no time will Paradigm 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 terms of the advisory agreement.
For additional information, please see Item 12 – Brokerage Practices and Item 15 – Custody.
Use of Independent Managers – Paradigm Wealth may recommend that certain legacy Clients utilize one or more
unaffiliated investment managers or investment platforms (collectively “Independent Managers”) for all or a portion
of a Client’s investment portfolio, based on the Client’s needs and objectives. In such instances, the Client will
be required to authorize and enter into an investment management agreement with an Independent Manager
that defines the terms in which the Independent Manager will provide its services. The Advisor will perform initial
and ongoing oversight and due diligence over each Independent Manager to ensure the Independent Manager’s
strategy remains aligned with the Client’s investment objectives and overall best interests. The Advisor will also
assist the Client in the development of the initial policy recommendations and managing the ongoing Client
relationship. The Client, prior to entering into an agreement with an Independent Manager, will be provided with
the Independent Manager's Form ADV Part 2A - Disclosure Brochure (or a brochure that makes the appropriate
disclosures). The disclosure will be provided by the Independent Manager.
Financial Planning Services
Paradigm will typically provide a variety of financial planning services to individuals and families, either as a
component of investment management services or pursuant to a written financial planning agreement. Services
are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally,
such financial planning services will involve preparing a financial plan based on the Client’s financial goals and
objectives. This planning may encompass one or more areas, including, but not limited to investment planning,
retirement planning, personal savings, education savings, insurance needs, and other areas of a Client’s financial
situation.
A financial plan developed for the Client will usually include general recommendations for a course of activity or
specific actions to be taken by the Client. For example, recommendations may be made that the Client start or
revise their investment programs, commence or alter retirement savings, establish education savings and/or
charitable giving programs.
Paradigm may also refer Clients to an accountant, attorney or another specialist, as appropriate for their unique
situation. For certain financial planning engagements, the Advisor will provide a written summary of Client’s
financial situation, observations, and recommendations. For ad-hoc engagements, the Advisor may not provide a
written summary. Plans are typically completed within six (6) months of contract date, assuming all information
and documents requested are provided promptly to the Advisor.
Financial planning recommendations pose a conflict between the interests of the Advisor and the interests of the
Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment
management services or to increase the level of investment assets with the Advisor, as it would increase the amount of
advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the
Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the
recommendations made by the Advisor, the Client is under no obligation to implement the transaction through
the Advisor. Financial planning services may be included in an overall wealth management engagement or
provided as a separate service, pursuant to the terms of the agreement with the Client.
C. Client Account Management
Prior to engaging Paradigm to provide advisory services, each Client is required to enter into one or more
agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and
the Client. These services may include:
• Establishing an Investment Strategy – Paradigm will work with each Client to develop a custom
investment strategy designed in connection with the Client’s investment goals and objectives.
• Asset Allocation – Paradigm 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 – Paradigm will develop a portfolio for the Client that is intended to meet the
stated goals and objectives of the Client.
• Investment Management and Supervision – Paradigm will provide its discretionary investment
management and ongoing oversight of the Client’s investment portfolios, including accounts held at the
Custodian (as detailed in Item 12) and any applicable variable annuity sub-accounts.
D. Wrap Fee Programs
Paradigm will typically 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 is considered a “Wrap
Fee Program”. Paradigm customizes its investment management services for Clients. This Wrap Fee Program
Brochure is included as Appendix 1 to this Disclosure Brochure solely to discuss the fees and potential conflicts
associated with a bundled fee. Please see Appendix 1 – Wrap Fee Program Brochure, which is included with this
Disclosure Brochure.
E. Assets Under Management
As of December 31, 2023, the Advisor manages $356,126,149 in Client assets, all of which are managed on a
discretionary basis. Of the total assets under management, $136,238,028 is attributable to variable annuity sub-
accounts. Please see item 5.E. and 10 below. Clients may request more current information at any time by
contacting the Advisor.