About Paragon Financial Advisors Paragon Advisors, LLC is a limited liability corporation formed in 2007 in the state of Texas. In 2011, Paragon Advisors, LLC began doing business as Paragon Financial Advisors. The member owners of the firm are David W. Hailey, Robert C. Calhoun, and Stephen R McGee. As managing members of the firm Mr. Hailey and Mr. Calhoun are tasked with major decisions for the firm that relate to strategic and administrative matters. This narrative brochure provides clients with information regarding Paragon Financial Advisors (Paragon) and the qualifications, business practices, and nature of advisory services that should be considered before becoming an advisory client of Paragon. Prior to engaging Paragon to provide services, clients are generally required to enter into an agreement with Paragon and set the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the portion of the fee due from the client prior to Paragon beginning services. If requested by the client, Paragon may recommend the services of other professionals for implementation purposes. The client is under no obligation to engage the services of any recommended professional. The client retains absolute discretion over all implementation decisions and may accept or reject any recommendation from Paragon. If a client engages a recommended professional, and a dispute arises thereafter relative to the engagement, the client agrees to seek recourse exclusively from and against the engaged professional. It remains the client’s responsibility to promptly notify Paragon if the client’s financial situation or investment objectives change for the purpose of reviewing/evaluation/revising Paragon’s previous recommendations and/or services. Financial Planning and Consulting Services Paragon engages in broad-based financial planning services for its clients, but we do not typically provide a formal written financial plan. Any advice is generally presented in a recap memo, retirement projection report or some combination as agreed to with the client. Paragon’s advice will typically provide a variety of services, principally advisory, to clients regarding management of their financial resources based upon analysis of their individual needs. The process typically begins with an initial complementary consultation. During or after the initial consultation, if the client decides to engage Paragon for financial planning services, pertinent information about the client’s personal and financial circumstances and objectives is collected. Clients may also be required to complete investment related questionnaires and/or risk tolerance assessment as part of the information gathering process. As needed, Paragon will conduct follow-up interviews for the purpose of reviewing and/or collecting financial data. Once such information has been studied and analyzed, a financial plan – designed to achieve the client’s expressed financial goals and objectives – will be produced and presented to the client. To the extent requested by the client, financial planning advice may be rendered and/or limited to areas of business planning, retirement planning, financial planning, personal tax cash flow planning, estate planning, risk management, divorce planning, college planning, and compensation and benefits planning, among others. Paragon Financial Advisors | Item 4 – Advisory Business 2 Financial planning based on the client’s financial situation at the time the information is presented and are based on financial information disclosed by the client to Paragon. Clients are advised that certain assumptions may be made with respect to interest and inflation rates and use of past trends and performance of the market and economy. Past performance in no way indicates future performance. Paragon cannot offer any guarantees or promises that the client’s financial goals and objectives will be met. As the client’s financial situation, goals, objectives, or needs change, the client must notify Paragon promptly. Portfolio Management Services Paragon may provide financial planning when needed, discretionary asset management, and investment supervisory services. Subject to any written guidelines which the client may provide, Paragon will be granted discretion and authority to manage the investments. Accordingly, Paragon is authorized to perform various functions, at the client’s expense, without further approval from the client. Such functions include making all investment decisions on the (a) securities purchased/sold; (b) the amount of securities to be purchased/sold; (c) selection of the broker or dealer to execute the transaction(s), and (d) the commission rates to be paid. Once the portfolio is constructed, Paragon provides ongoing supervision and re-balancing of the portfolio as changes in market conditions and client circumstances may require. After consultation with Paragon, clients may impose reasonable restrictions on investing in certain securities or types of securities. Other restrictions may be imposed by clients with respect to the (average or longest) maturity or credit quality of fixed income investments. In either case, all restrictions must be in writing. Retirement Rollovers-No Obligation/Conflict of Interest A client leaving an employer typically has four options (and may engage in a combination of these options): 1) leave the money in his/her former employer’s plan, if permitted, 2) roll over the assets to his/her new employer’s plan, if one is available and rollovers are permitted, 3) rollover to an Individual Retirement Account (IRA), or 4) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). Paragon may recommend an investor roll over plan assets to an IRA managed by Paragon. As a result, Paragon may earn an asset-based fee; however, a recommendation that a client or prospective client leave their plan assets with their old employer will result in no compensation. Paragon has an economic incentive to encourage an investor to roll plan assets into an IRA that Paragon will manage. There are various factors that Paragon may consider before recommending a rollover, including but not limited to: i) the investment options available in the plan versus the investment options available in an IRA, ii) fees and expenses in the plan versus the fees and expenses in an IRA, iii) the services and responsiveness of the plan’s investment professionals versus those of Paragon, iv) required

minimum distributions and age considerations, and vi) employer stock tax consequences, if any. No client is under any obligation to roll over plan assets to an IRA managed by Paragon. Paragon Financial Advisors | Item 4 – Advisory Business 3 401(k) and other Qualified Retirement Plans An investment advisory service for business owners and trustees of 401(k) plans who want the expertise and experience of an investment advisor who can complete sound due diligence on fund selection, create a menu of options and risk adjusted allocation models in order to ensure peace of mind and reduce fiduciary liability. Retirement Accounts and ERISA 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 interests 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. Selection of Other Advisers (Managed Assets Program) As part of its advisory services, Paragon may offer its clients access to a network of third-party investment advisers (“sub-advisers”) to manage a portion of or their entire portfolio. All sub- advisers to whom Paragon refers its clients must be a registered investment adviser with the Securities and Exchange Commission or other appropriate jurisdiction. After gathering information about a client’s financial situation and investment objectives, a representative of Paragon may assist the client in selecting a particular third-party adviser and/or program. In addition to evaluating and recommending sub-advisers to clients, Paragon will review reports provided to the client by sub-advisers. Paragon also will contact the client periodically to review the client’s financial situation and objectives, communicate information to the sub-adviser as warranted, and assist the client in understanding and evaluating the services provided by the sub-adviser. Clients are reminded to promptly notify Paragon of any material change in their financial situation, investment objectives, or account restrictions. Paragon Financial Advisors | Item 4 – Advisory Business 4 At the time of the referral, Paragon or the sub-adviser(s) will deliver the sub-adviser’s full disclosure that includes detailed information on the services offered and other pertinent disclosures by delivery of a copy of the relevant sub-adviser’s Part 2 of Form ADV or equivalent disclosure documents. In addition, if the investment program recommended to a client is a wrap fee program, the client will also receive from Paragon or the sub-advisor(s) the equivalent wrap fee brochure provided by the sponsor of the program. Paragon will provide each client with all appropriate disclosure statements, including disclosure of fees paid to Paragon, its representatives, and the sub-advisers. Trade Error Policy Should they occur, losses resulting from Paragon’s trade errors shall be reimbursed by either Paragon or the custodian depending on the dollar amount. Any gains will be donated to a charity. Client Obligations In performing its services, Paragon is not required to verify any information received from the client or from the client’s other professionals. Moreover, each client is advised that he or she must promptly notify Paragon if any change occurs in the client’s financial situation or investment objectives during the client engagement. Disclosure Statement A copy of Paragon’s written brochure as set forth on Part 2A of Form ADV shall be provided to each client prior to, or at the same time as, the execution of the any client agreement. Any client who has not received a copy of Paragon’s written Brochure at least 48 hours prior to executing the Advisory Agreement shall have five business days subsequent to executing the agreement to terminate the Paragon’s services without penalty. Non-Participation in Wrap Fee Programs Paragon, as a matter of policy and practice, does not sponsor any wrap fee programs. A wrap fee program is defined as any advisory program under which a specified fee or fees not based directly upon transactions in a client’s account is charged for investment supervisory services (these may include portfolio management or advice concerning the selection of other investment advisers) and the execution of client transactions. Amount of Assets Under Management As of December 31, 2023, Paragon provided advice on approximately $679.7 million in assets, all managed on a discretionary basis, and $901,433 in assets, managed on a non-discretionary basis. Our Policy on Class Action Lawsuits From time to time, securities held in the accounts of clients will be the subject of class action lawsuits. Paragon has no obligation to determine if securities held by the client are subject to a pending or resolved class action lawsuit. It also has no duty to evaluate a client’s eligibility or to submit a claim to participate in the proceeds of a securities class action settlement or verdict. Furthermore, Paragon has no obligation or responsibility to initiate litigation to recover damages Paragon Financial Advisors | Item 4 – Advisory Business 5 on behalf of clients who may have been injured as a result of actions, misconduct, or negligence by corporate management of issuers whose securities are held by clients. Where Paragon receives written or electronic notice of a class action lawsuit, settlement, or verdict affecting securities owned by a client, it will forward all notices, proof of claim forms, and other materials, to the client. Electronic mail is acceptable where appropriate if the client has authorized contact in this manner. Paragon Financial Advisors | Item 5 – Fees and Compensation 6