Description of Services and Fees Paragon Financial Services ("PFS") is a registered investment adviser primarily based in Richmond, Virginia. We are organized as a corporation under the laws of the State of Virginia. We have been providing investment advisory services since 2012. Simon Woon and Vickie Woon are our principal owners. Currently, we offer the following investment advisory services, which are personalized to each individual client:
•Portfolio Management Services
•Financial Planning Services
•Pension Consulting Services
•Advisory Consulting Services
•Sub-Advisory Services The following paragraphs describe our services and fees. Please refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to your individual needs. As used in this brochure, the words "we", "our" and "us" refer to Paragon Financial Services and the words "you", "your" and "client" refer to you as either a client or prospective client of our firm.
Portfolio Management Services We offer discretionary and non-discretionary portfolio management services. Our investment advice is tailored to meet our clients' needs and investment objectives. If you retain our firm for portfolio management services, we will meet with you to determine your investment objectives, risk tolerance, and other relevant information at the beginning of our advisory relationship. We will use the information we gather to develop a strategy that enables our firm to give you continuous and focused investment advice and/or to make investments on your behalf. As part of our portfolio management services, we will customize an investment portfolio for you according to your risk tolerance and investing objectives. We may also invest your assets using a predefined strategy, or we may invest your assets according to one or more model portfolios developed by our firm. Once we construct an investment portfolio for you, or select a model portfolio, we will monitor your portfolio's performance on an ongoing basis, and will rebalance the portfolio as required by changes in market conditions and in your financial circumstances.
If you participate in our discretionary portfolio management services, we require you to grant our firm discretionary authority to manage your account. Discretionary authorization will allow us to determine the specific securities, and the amount of securities, to be purchased or sold for your account without your approval prior to each transaction. Discretionary authority is typically granted by the investment advisory agreement you sign with our firm and the appropriate trading authorization forms. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased or sold for your account) by providing our firm with your restrictions and guidelines in writing. If you enter into non-discretionary arrangements with our firm, we must obtain your approval prior to executing any transactions on behalf of your account.
Financial Planning Services We offer financial planning services which typically involve providing a variety of advisory services to clients regarding the management of their financial resources based upon an analysis of their individual needs. These services can range from broad, comprehensive, financial planning to consultative or single subject planning. If you retain our firm for financial planning services, we will meet with you to gather information about your financial circumstances and objectives. We may also use financial planning software to determine your current financial position and to define and quantify 4 your long-term goals and objectives. Once we specify those long-term objectives (both financial and non-financial), we will develop shorter-term, targeted objectives. Once we review and analyze the information you provide to our firm and the data derived from our financial planning software, we will deliver a written plan to you, designed to help you achieve your stated financial goals and objectives.
Financial plans are based on your financial situation at the time we present the plan to you, and on the financial information you provide to us. You must promptly notify our firm if your financial situation, goals, objectives, or needs change.
You are under no obligation to act on our financial planning recommendations. Should you choose to act on any of our recommendations, you are not obligated to implement the financial plan through any of our other investment advisory services. Moreover, you may act on our recommendations by placing securities transactions with any brokerage firm.
Estate and Tax Planning Coordination Services Paragon offers estate planning coordination services to its financial planning clients in need of basic estate planning assistance. In order to provide the estate planning coordination services, Paragon has contracted with Encore Estate Plans. Encore Estate Plans provides an online platform to help coordinate the creation of estate planning documents based on information provided by you via a comprehensive questionnaire which may be completed on paper or online. Once complete, the estate plan will be returned by Encore Estate Plans to Paragon for delivery to you. In addition, Paragon offers its financial planning clients tax preparation and tax planning coordination services to clients in need of basic or complex tax preparation or planning assistance through its affiliate Paragon Tax Strategy. Paragon Tax Strategy, through its relationship with United Cloud Partners Services, provides Paragon clients access to individuals who have obtained the Certified Professional Accountant ("CPA") designation and are in good standing with the American Institute of CPAs. Paragon Financial Services will help coordinate with the CPA during the creation of tax preparation and / or tax planning documents based on information provided by you. Once complete, Paragon Financial Services will coordinate with Paragon Tax Strategy for the documents and planning recommendations for delivery to you. As part of these coordination services, Paragon does not provide tax advice, legal advice or legal services, but only facilitates the coordination and interpretation of tax planning or estate planning documents based on the information provided by you. You may be referred / recommended to a local tax or estate planning attorney for deeper examination / review of your tax preparation and / or planning documents. Please see Item 5 Fees and Compensation, Item 10 Other Financial Industry Activities and Affiliations, and Item 14 Client Referrals and Other Compensation of this brochure for additional information regarding our relationship with Encore Estate Plans or our affiliation with Paragon Tax Strategy.
Pension Consulting Services We offer pension consulting services to employee benefit plans and their fiduciaries based upon the needs of the plan and the services requested by the plan sponsor or named fiduciary. In general, these services may include an existing plan review and analysis, plan-level advice regarding fund selection and investment options, education services to plan participants, investment performance monitoring, and/or ongoing consulting. These pension consulting services will generally be non-discretionary and advisory in nature. The ultimate decision to act on behalf of the plan shall remain with the plan sponsor or other named fiduciary.
5 We may also assist with participant enrollment meetings and provide investment-related educational seminars to plan participants on such topics

as:
•Diversification
•Asset allocation
•Risk tolerance
•Time horizon Our educational seminars may include other investment-related topics specific to the particular plan.
We may also provide additional types of pension consulting services to plans on an individually negotiated basis. All services, whether discussed above or customized for the plan based upon requirements from the plan fiduciaries (which may include additional plan-level or participant-level services) shall be detailed in a written agreement and be consistent with the parameters set forth in the plan documents.
Either party to the pension consulting agreement may terminate the agreement upon 30-days' written notice to the other party. The pension consulting fees will be prorated for the quarter in which the termination notice is given and any unearned fees will be refunded to the client.

•Advisory Services to Retirement Plans As disclosed above, we offer various levels of advisory and consulting services to employee benefit plans ("Plan") and to the participants of such plans ("Participants"). The services are designed to assist plan sponsors in meeting their management and fiduciary obligations to Participants under the Employee Retirement Income Securities Act ("ERISA"). Pursuant to adopted regulations of the U.S. Department of Labor under ERISA Section 408(b)(2), we are required to provide the Plan's responsible plan fiduciary (the person who has the authority to engage us as an investment adviser to the Plan) with a written statement of the services we provide to the Plan, the compensation we receive for providing those services, and our status (which is described below). The services we provide to your Plan are described above, and in the service agreement that you have previously signed with our firm. Our compensation for these services is described below, at Item 5, and also in the service agreement. We may, with consent of the Plan, and in accordance with Plan documents, bill out-of-pocket expenses (such as overnight mailings, messenger, translation fees, etc.) at cost. We do not reasonably expect to receive any other compensation, direct or indirect, for the services we provide to the Plan or Participants. Nonetheless, since Associated Persons of our firm are registered representative and/or licensed insurance agents, these individuals may receive 12b-1 fees, revenue sharing or other forms of indirect compensation in connection with mutual fund investments allowable under applicable authority through LPL Financial, LLC (refer to Items 5, 12, and 14 for additional disclosures). If we receive any other compensation for such services, we will (i) offset the compensation against our stated fees, and (ii) we will promptly disclose the amount of such compensation, the services rendered for such compensation and the payer of such compensation to you. In providing services to the Plan and Participants, our status is that of an investment adviser registered with the States of Virginia and New Jersey and we are not subject to any disqualifications under Section 411 of ERISA. In performing fiduciary services, we are acting as a non-discretionary fiduciary of the Plan as defined in Section 3(21), only. We do not act as a discretionary "investment manager" of the Plan as defined in Section 3(38) under ERISA. 6 Advisory Consulting Services We also provide consulting services to our advisory clients. Such services generally relate to providing general and specific advice on investment selection for qualified retirement plan accounts.
Sub-Advisory Services We offer sub-advisory services to unaffiliated third party money managers (the "Primary Investment Adviser"). As part of these services, we will provide model portfolios, which the Primary Investment Adviser selects for their clients. We will not directly manage the Primary Investment Adviser's individual client accounts. The Primary Investment Adviser will be responsible for selecting the appropriate model for its clients Wrap Fee Program(s) We are a portfolio manager to a wrap fee program, which is a type of investment program that provides clients with access to several money managers or mutual fund asset allocation models for a single fee that includes administrative fees, management fees, and commissions. If you participate in our wrap fee program, you will pay our firm a single fee, which includes our money management fees, certain transaction costs, and custodial and administrative costs. We receive a portion of the wrap fee for our services. The overall cost you will incur if you participate in our wrap fee program may be higher or lower than you might incur by separately purchasing the types of securities available in the program.
If you do not maintain at least $250,000 in your account, you would not be eligible for the Wrap Fee Program and would incur transaction costs. However, in our sole discretion, we may combine the account values of family members living in the same household to determine the applicable account balance and/or advisory fee. For example, we may combine account values for you, your spouse, joint accounts with your spouse, your minor children, and other types of related accounts. Combining account values may increase the asset total, which may make you eligible to participate in the Program and may also result in paying a reduced advisory fee.
Transactions for your account must be executed by LPL Financial, LLC, a securities broker-dealer and a member of the Financial Industry Regulatory Authority and the Securities Investor Protection Corporation. To compare the cost of the wrap fee program with non-wrap fee portfolio management services, you should consider the frequency of trading activity associated with our investment Strategy and the brokerage commissions charged by LPL Financial, LLC or other broker-dealers, and the advisory fees charged by investment advisers. For more information concerning the Wrap Fee Program, please see Appendix 1 to this Brochure.
Types of Investments We primarily offer advice on equity securities, mutual funds, exchange traded funds, annuities, corporate debt securities, municipal securities, investment company securities, US Government securities, options contracts on securities, and interest in partnerships investing in real estate, oil and gas interests, and others.
Additionally, we may advise you on any type of investment that we deem appropriate based on your stated goals and objectives. We may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship.
In general, we manage wrap fee accounts on a discretionary basis based on a long-term investment strategy. However, we manage non-wrap fee accounts on either a discretionary or a non-discretionary basis, and may include a short-term investment strategy in managing this type of account. A long-term investment strategy will typically involve investing in securities that are anticipated to grow in value 7 over a relatively long period of time. On the other hand, a short-term investment strategy will typically involve purchasing and selling securities within a relatively short period of time based on these securities' short-term price fluctuations.
If you participate in our wrap fee program, we will provide you with a separate Wrap Fee Program Brochure explaining the program and costs associated with the program.
Assets Under Management As of December 31, 2023, we provide continuous management services for $280,905,882 in client assets on a discretionary basis.