Paragon Outcomes Management is an investment adviser with its principal place of business in New York, New York. Paragon Outcomes Management is organized as a limited liability company under the laws of the State of Delaware. The Adviser commenced operations in January 2009. The managing member of Paragon Outcomes Management is Paragon Outcomes Management, LP (“POM LP”). The general partner of POM LP is Paragon Outcomes Management GP, LLC (“POM GP”). Frank Tripoli is the principal owner of both POM GP and POM LP. Paragon Outcomes Management and its affiliates provide investment advisory services on both a discretionary and nondiscretionary basis. As part of its investment advisory business, the Adviser (i) manages portfolios of pooled investment vehicles (the “Funds”); and (ii) provides management, advisory and monitoring services to privately-owned corporations (the “Accounts”). The Funds are investment vehicles that Paragon manages on a discretionary basis. The Funds are intended for sophisticated investors that aim to invest in a broad range of private investments. Examples of these may include equity or debt investments in real estate and other asset backed operating businesses; preferred equity interest in private or public companies; and direct lending. The Funds have historically invested, and may continue to invest, in mutual funds, hedge funds, private equity funds and other investments; provided, however, that the Adviser has the flexibility to invest in any security and in any sector of the market.

For its investments in operating companies and private equity, Paragon generally invests alongside joint venture partners who have specific expertise that Paragon believes may enhance the value or availability of such investments. To control any risks that may be associated with joint venture partner arrangements, Paragon often retains certain control rights where the Adviser may be able terminate its relationship with the joint venture partner or effect other changes regarding the investment in its sole discretion. The Adviser also advises Accounts on a nondiscretionary basis. The services provided to the Accounts may range from recommendations on asset allocation, meeting with investment or management teams and monitoring their ongoing performance. The Funds and/or the Accounts may be collectively or individually referred to as the “Clients” in this Part 2A of Form ADV. Paragon Outcomes Management tailors its advisory services to the individual needs of its Clients based upon its understanding of each Client’s financial situation, goals and objectives. Clients may impose restrictions on investment in certain securities or types of securities. The Adviser does not participate in wrap fee programs. As of December 31, 2022, Paragon Outcomes Management had net assets under management of approximately $216.9 million on a discretionary basis and approximately $1.38 million on a nondiscretionary basis. Please note that these numbers are a good faith estimate, unaudited and subject to change upon audit.