Paradigm Capital Management, LLC ("PCM") specializes in Investment Management services. The firm is a Limited Liability Company formed in the State of Nevada. PCM has been in business as an investment adviser since 1996. The firm is owned by Bruce and Mary Harvey.
The following paragraphs describe our services and fees. As used in this brochure, the words "we," "our," and "us" refer to Paradigm Capital Management LLC and the words "you," "your," and "client" refer to you as either a client or prospective client of our firm.
This Brochure discloses potential conflicts of interest associated with investment transactions, compensation and any other matters related to investment decisions made by our firm or its representatives. As a fiduciary, it is our duty to always act in the client's best interest. This is accomplished by knowing our client and working with them to understand their investment objectives, risk tolerance, and time horizon. Investment Management Services We provide individualized investment management services to individuals and high net worth individuals, small businesses, trusts & estates and charitable accounts. We employ continuous security supervision. We customize client accounts using various investment instruments including exchange traded funds ("ETFs") and individual stocks to build portfolios. From time to time, we may recommend individual bonds, mutual funds, and other public investments if client specific circumstances warrant.
Each client can place reasonable restrictions on the types of investments to be held in their portfolio at any time by informing us of those restrictions. Restrictions on investments in certain securities or types of securities may not be possible due to the level of difficulty this would entail in managing the account since we cannot control what investments ETFs and mutual funds may own.
All advisory accounts are managed on a discretionary basis in separate client accounts. The firm emphasizes a patient disciplined approach to investments and risk management. If you participate in our portfolio management services, we require you to grant us discretionary authority to manage your account. Subject to a grant of discretionary authorization, we have the authority and responsibility to formulate investment strategies on your behalf. Discretionary authorization will allow us to determine the specific securitiesand the amount of shares to be purchased or sold for your account without obtaining your approval prior to each transaction. We will also have discretion over the broker or dealer to be used for securities

transactions in your account. Discretionary authority is typically granted by the investment advisory agreement you sign with our firm as well as other new account forms. All investment decisions are made within the firm based on our analysis of each specific investment. Our investment strategy is based primarily on fundamental and statistical analysis. We spend considerable time researching and analyzing each investment in an attempt to minimize risk. This enables us to take more concentrated positions in industries or companies that we have determined have good potential return.
Participation in Wrap Fee Programs Our firm does not offer or participate in any wrap fee programs.
Types of Investments We offer advice on equity securities, mutual funds, ETFs, and fixed income investments.
Additionally, we may advise you on various types of investments 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.
4 Since our investment strategies and advice are based on each client's specific financial situation, the investment advice we provide to you may be different or conflicting with the advice we give to other clients regarding the same security or investment.
IRA Rollover Recommendation When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's provisions, we must:
•Meet a professional standard of care when making investment recommendations (give prudent advice).

•Never put our financial interests ahead of yours when making recommendations (give loyal advice).
•Avoid misleading statements about conflicts of interest, fees, and investments.
•Follow policies and procedures designed to ensure that we give advice that is in your best interest.
•Charge no more than is reasonable for our services; and
•Give you basic information about conflicts of interest. Regulatory Assets Under Management As of December 31, 2023, we provide continuous management services for $142,247,390 in client assets on a discretionary basis.