Advisory Firm Paragon Capital Management, Inc., dba Paragon Wealth Management (PWM), has been providing investment advisory services since 1993. David A. Young, owner, is the founder and President and has been in the financial services industry since 1987. Advisory Services Paragon Wealth Management offers investment supervisory services and financial planning to individuals and institutions. Investment management is provided on a discretionary and non-discretionary basis. Prospective clients are evaluated to determine each client’s financial circumstances and investment objectives for compatibility to its investment plan. Each client’s investment objectives are identified using a risk profile assessing risk tolerance based upon age, income, cash flow needs, investment goals and emotional tolerance for volatility. Information for the risk profile is collected through interviews and questionnaires after which the Advisor will recommend which investment strategies are suitable for the client’s needs. We construct client portfolios using exchange traded funds (ETFs), individual equities and may also invest in open and closed-end mutual funds, U.S. government securities, convertible securities, corporate and municipal bonds, and other securities when deemed appropriate. We retain broad and flexible investment authority, therefore, except as described above, there are not material limitations on the instruments or markets in which we may purchase or sell. Paragon also manages Paragon Private Strategies Fund, LP, and Paragon Income Fund, LP, which are private investment funds, according to the investment objectives and guidelines

set forth in each of the fund’s offering memorandums. See Item 6 for further information on these funds. Paragon Wealth Management provides financial planning consistent with the individual client's financial and tax status and risk/reward objectives. Planning may be comprehensive or segmented and focus on investments, insurance, taxes, and/or estate plans. Paragon Wealth Management also provides asset allocation strategies based upon its proprietary asset allocation model to investment advisors who provide investment supervisory services. Services are based on the individual needs of the client. An initial interview and data gathering questionnaire is undertaken to determine the client's financial situation and investment objectives and risk tolerance and to give the client the opportunity to impose reasonable restrictions on the management of the account. Clients may call in at any time during normal business hours to discuss the client's account, financial situation, or investment needs. Clients will receive from the custodian/brokerage firm timely confirmations and at least monthly statements containing a description of all transactions and all account activity. The client will retain rights of ownership of all securities and funds in the account to the same extent as if the client held the securities and funds outside the program. In addition to custodial statements, Paragon Wealth Management sends quarterly reports to the client. As of December 31, 2023, Paragon Wealth Management has $146,884,898 of assets under management on a discretionary basis, and $9,530,998 of assets under management on a non-discretionary basis.