Firm Information
The firm was organized in 1998 as an LLC in the state of Kansas to help individuals and business owners pursue their financial
goals. The entity registered as an investment advisor with the SEC in 1998.
Once a client’s goals have been established, the firm can customize appropriate investments strategies consistent with a client’s
investment objective and risk profile utilizing the following products and services:
This disclosure brochure provides information regarding the qualifications, business practices and details of the advisory services
and the applicable fees.
Principal Owner
Paragon Capital Management, LLC is owned and operated by Craig Novorr (CRD No. 5204893).
Advisory Services Offered
Paragon Capital Management, LLC provides regular and continuous management and supervision of assets as well as financial
planning primarily to individuals, high net worth individuals, foundations, trusts and estates. Assets are managed on a
discretionary basis, as selected on the written asset management agreement.
Discretionary Authority – Client grants Advisor ongoing and continuous discretionary authority to execute its investment
recommendations without the Client's prior approval of each specific transaction. Under this authority, Client shall allow
Advisor to purchase and sell securities and instruments in this Account(s), arrange for delivery and payment in connection
with the foregoing, select and retain sub-advisors, and act on behalf of the Client in all matters necessary or incidental.
Asset management focuses on investment goals, objectives, risk tolerance consistent with a client’s financial situation.
Investment portfolios consist primarily of individual stocks, exchange traded funds, mutual funds, US government, municipal, or
corporate bonds, preferred stock, structured notes, and money market funds. Paragon may invest client accounts in other types of
securities based on the client’s goals and risk tolerance. Clients may impose reasonable restrictions on investing in certain types
of securities. If a client should choose to hold an investment in their account that we do not monitor, it would be held in the
account as an unsupervised asset.
At no time will the firm accept or maintain direct custody of funds or securities. All client assets will be managed within the
designated brokerage account[s] held at a qualified custodian, according to the terms of the account opening documents.
Financial Planning Retirement Strategies Asset Allocation
Investments Estate Planning
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If a client does not receive this disclosure brochure at least 48 hours prior to entering into an investment advisory agreement,
they have a right to terminate the contract, without penalty, within five business days.
Investment Advisor Representatives are restricted to providing services and charging fees based in accordance with the
descriptions detailed in this document and the account agreement. However, the exact service and fees charged to a particular
Client are dependent upon the Investment Advisor Representative that is working with the Client. Investment Advisor
Representatives will consider the individual needs of each Client when providing investment advice. Investment strategies and
recommendations are tailored to the individual needs of each Client but generally consist of an asset allocation consistent with:
1. Income with Capital Preservation. Designed
as a longer-term accumulation account, this investment objective is
considered generally the most conservative. Emphasis is placed on generation of current income with minimal risk
of capital loss. Lowering the risk generally means lowering the potential income and overall return.
2. Income with Moderate Growth. This investment objective emphasizes generation of current income with a
secondary focus on moderate capital growth.
3. Growth with Income. This investment objective emphasizes modest capital growth with some focus on generation
of current income.
4. Growth. This investment objective emphasizes achieving high long-term growth and capital appreciation. There is
little focus on generation of current income.
5. Aggressive Growth. This investment objective emphasizes aggressive growth and maximum capital appreciation,
with no focus on generation of current income. This objective has a very high level of risk and is for investors with a
longer timer horizon.
Retirement Plan Rollovers
Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases
to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where
applicable, we are providing the following acknowledgment to you.
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.
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Client Account Management
Prior to engaging Paragon Capital Management, LLC to provide investment advisory services, each Client is required to enter into
an investment advisory agreement with that defines the terms, conditions, authority, and responsibilities.
Sub-Advisory Service
Paragon acts as a sub-advisor to unaffiliated Private Advisors who participate in the Schwab Advisor Marketplace. We are
compensated by the Client in the network for services rendered. Paragon’s compensation is in addition to the Primary Advisor’s
advisory fee and is charged directly to the client. Client signs fee schedule (based on Paragon’s normal fee schedule which could
be negotiable) and Investment Guidelines with Paragon separate from Primary Advisor’s fees. The terms and conditions under
which the client shall engage us shall generally be set forth in separate written agreements between the client and our firm and
the client and the Primary Adviser.
Assets Under Management
Assets under management as of December 31,
2023 are as follows: