Full Disclosure

Revised January 28, 2026


General Disclosures


Paragon Investing, LLC ("Paragon Investing" or "Paragon") is an SEC-Registered Investment Advisor (RIA) offering advisory services in the United States of America. Paragon Investing and its affiliates operate a website at www.paragoninvesting.com and/or our mobile applications ("our website" (which includes our blog), "Site", "App", or "Paragon"). Registration does not imply a certain level of skill or training. The presence of this website on the Internet shall not be directly or indirectly interpreted as a solicitation of investment advisory services to persons of another jurisdiction unless otherwise permitted by statute. Follow-up or individualized responses to consumers in a particular state by Paragon Investing in the rendering of personalized investment advice for compensation shall not be made without our first complying with jurisdiction requirements or pursuant an applicable state exemption.

Paragon Investing provides investment advisory services to clients, but does not provide personalized estate planning, tax, trusts, or other related services. Nothing on this Site or App should be construed as a solicitation or offer, or recommendation, to buy or sell any security. Advisory services are only provided to investors who become advisory clients of Paragon Investing ("Clients") pursuant to a written & signed Client Advisory Agreement, which investors are urged to read and carefully consider in determining whether such agreement is suitable for their individual facts and circumstances.

PAST PERFORMANCE IS NO GUARANTEE OF FUTURE RESULTS, AND ANY EXPECTED RETURNS OR HYPOTHETICAL PROJECTIONS MAY NOT REFLECT ACTUAL FUTURE PERFORMANCE. FURTHERMORE, PAST RETURNS MAY REFLECT THE PERFORMANCE OF ASSETS FOR A FINITE TIME, OR DURING A PERIOD OF EXTREME MARKET ACTIVITY. ALL INVESTMENTS INVOLVE RISK AND MAY LOSE MONEY.

There can be no assurance that an investment mix or any projected or actual performance shown on the Site or App will lead to the expected results shown or perform in any predictable manner. It should not be assumed that investors will experience returns in the future, if any, comparable to those shown or that any or all Clients actually experienced such returns.

Information presented is for educational purposes only and does not intend to make an offer or solicitation for the sale or purchase of any securities. Past performance is not indicative of future results and investments involve risk and are not guaranteed. Be sure to first consult with a qualified financial advisor and/or tax professional before implementing any strategy discussed here.

The charts and information in this presentation are for illustrative purposes only, and are based upon sources of information that Paragon Investing generally considers reliable, however we cannot guarantee, nor have we verified, the accuracy of such independent market information. The charts and information, and the sources utilized in the compilation thereof, are subjective in nature and open to interpretation.

All investing involves risk, including the possible loss of money you invest, and past performance does not guarantee future performance. Historical returns, expected returns, and probability projections are provided for informational and illustrative purposes, and may not reflect actual future performance.

The information on this site is provided “AS IS” and without warranties of any kind either express or implied. To the fullest extent permissible pursuant to applicable laws, Paragon Investing disclaims all warranties, express or implied, including, but not limited to, implied warranties of merchantability, non-infringement and suitability for a particular purpose. Paragon Investing does not warrant that the information will be free from error. None of the information provided on this website is intended as investment, tax, accounting or legal advice, as an offer or solicitation of an offer to buy or sell, or as an endorsement of any company, security, fund, or other securities or non-securities offering. The information should not be relied upon for purposes of transacting securities or other investments. Your use of the information is at your sole risk. Under no circumstances shall Paragon Investing be liable for any direct, indirect, special or consequential damages that result from the use of, or the inability to use, the materials in this site, even if Paragon Investing or a Paragon Investing authorized representative has been advised of the possibility of such damages. In no event shall Paragon Investing, LLC have any liability to you for damages, losses and causes of action for accessing this site. Information on this website should not be considered a solicitation to buy, an offer to sell, or a recommendation of any security in any jurisdiction where such offer, solicitation, or recommendation would be unlawful or unauthorized.

This website contains the opinions of Paragon Investing, a Registered Investment Advisor. This information should not be relied upon for tax purposes and is based upon sources believed to be reliable. No guarantee is made to the completeness or accuracy of this information. Paragon Investing shall not be responsible for any trading decisions, damages, or other losses resulting from, or related to, the information, data, analyses or opinions contained herein or their use, which do not constitute investment advice, are provided as of the date written, are provided solely for informational purposes, and therefore are not an offer to buy or sell a security. Investments in securities are subject to investment risk, including possible loss of principal. Prices of securities may fluctuate from time to time and may even become valueless. This information has not been tailored to suit any individual.

All written content on this site is for information purposes only. Opinions expressed herein are solely those of Paragon Investing, unless otherwise specifically cited. Material presented is believed to be from reliable sources and no representations are made by our firm as to another parties’ informational accuracy or completeness. All information or ideas provided should be discussed in detail with an advisor, accountant or legal counsel prior to implementation.

All product names, logos, and brands are property of their respective owners. Use of these names, logos, and brands is for identification purposes only, and does not imply endorsement or affiliation.




Performance Disclosures


Asset Class Historical Performance

20-year historical performance metrics per asset class uses the following sources of data, all from the same time period: 12/31/2004 - 12/31/2024.

  1. Public U.S. Stocks: Russell 3000, IWV, daily data.
  2. Private Equity: Cambridge Private Equity Index, quarterly data, inception 1986.
  3. Public U.S. Bonds: Core U.S. Aggregate Bond, AGG, daily data.
  4. Private Debt, Private Credit, and Direct Lending: Cliffwater Direct Lending Index (CDLI)*, quarterly data, inception 9/30/2004.
All sources use the same 20-year time period: 12/31/2004 - 12/31/2024.
Daily, monthly, and quarterly return data for ETFs and mutual funds is pulled from from Koyfin during 2025.
Returns may be rounded to the nearest whole number for simplicity.

Illiquidity return premium is defined as the return outperformance between private asset indexes and their public equivalents, such CDLI* and US Agg Bond, or Cambridge PE and the Russell 3000.

* This is an index of private corporate loans with data since 9/30/2004. The CDLI Index is unlevered, while some current private debt/credit funds use some amount of leverage, up to 1.0x. No fund manager fee is deducted for CDLI, because in practice the fund manager fee is offset by a small amount of fund leverage, increasing the gross return for the fund. On a net basis, the total return from funds is near to the CDLI return.Details here.



Asset Class Max Drawdown Disclosures

Max drawdown figures are quarterly max drawdowns for all asset classes.

  1. Public U.S. Stocks: Russell 3000, IWV, quarterly data.
  2. Private Equity: Cambridge Private Equity Index, quarterly data, inception 1986. CAIA and MAN Group. Cambridge Associates U.S. Buyout sector experienced a -28% peak-to-trough NAV decline during the 2007–2009 global financial crisis. Cambridge Associates U.S. Venture Capital (VC) sector experienced a -17.5% peak-to-trough NAV decline during the 2008–2009 global financial crisis. Making a composite to represent our current investments, based on proportional allocations to US Buyout and US Venture Capital segments of the US Private Equity market: -28% * 75% allocation + -17.5% * 25% allocation = 25.3% (rounded down to -25% max drawdown in 2008-2009.
  3. Public U.S. Bonds: Core U.S. Aggregate Bond, AGG, quarterly data.
  4. Private Debt, Private Credit, and Direct Lending: Cliffwater Direct Lending Index (CDLI) saw a -7.8% max drawdown during 2007-2009, which we typically round to the nearest integer (-8%) during discussions; quarterly data, inception 9/30/2004.



Liquidity Disclosures


Most Private Credit semi-liquid interval funds offer quarterly liquidity (every 91 days) with varying redemption dates.

Most Private Equity funds offer semi-annual redemptions (every 183 days).

In all cases, interval funds are required to follow SEC rules for offering redemptions:

  1. Redemptions may be subject to prorations if total redemption demand exceeds 5% of fund AUM.
  2. Funds are required to grant redemptions up to 5% of fund AUM on the redemption date.
  3. They may optionally go up to 7% of fund AUM without special permission from the SEC, but they are not required to do so.
  4. Funds will be wired to client accounts two business days after the published redemption date.



Fund Minimum Investment Disclosures

Private Equity funds such as CPEFX have a $25M minimum to access their fund.

Private Credit funds such as CCLFX and CELFX have a $10M minimum to access their fund.

Fund minimums are met at the firm level, aggregated across all Paragon clients. Assets are kept in individual client accounts and not pooled.



University Endowment Asset Allocation Disclosure

Historically, large university endowments have invested heavily in the private and alternative asset space, with 80% allocations to private equity, venture capital, private credit, hedge funds, infrastructure, private real estate, real assets, and other alternative investments. Allocations to traditional assets including public stocks, bonds, and cash are typically in the 20% range. Sources: The University of Michigan Endowment has 80% in alternatives, 17% in stocks and bonds, and 3% in cash (as of 6/30/2025). The Harvard Endowment has 79% in Alts, 18% in stocks and bonds, and 3% in cash (as of 6/30/2025). ( Other sources).



Paragon Model Portfolio Disclosures

The Paragon Model Portfolio asset allocation and fund selection has been tracked and updated at each month end since 12/31/2020, since inception of the firm in Q4 2020. It includes a percentage allocation to each investable fund, updated on the last day of the month, applicable for portfolio implementation in the following month.

Results do not represent actual trading, but a majority of client portfolios are traded in accordance with the model, subject to any personal requests, tax implications, or other modifications required on a per-client basis.

Performance shown is net of all fees, including a 0.60% advisory fee, deducted daily. The 0.60% advisor fee is within +/- 5 basis points of our average fee charged to clients between 2020-2025. The results assumes reinvestment of all dividends and distributions received. The Paragon Model Portfolio utilizes stocks, bonds, cash, including ETFs and mutual funds, and also heavily utilizes semi-liquid interval fund investments, some of which require accredited investor status, to gain exposure to private equity and private credit investments.

Investors in interval funds can buy in daily but redemptions are limited to either quarterly or semi-annual redemption dates. Any divestments from these semi-liquid funds in the Model are aligned to the closet month-end update in the Paragon Model Portfolio. This process allows for up to 15 days of discrepancy in returns, as teh interval fund redemption dates are not at month end.

The 'Large Firm 60/40 Blend' includes the following funds: MIBLX (BNY Mellon), FBLAX (Fidelity), FPURX (Fidelity), OAMIX (Invesco), BAGPX (BlackRock), ABALX (American Funds), MDLOX (BlackRock), MXMPX (Empower), GAOAX (JPMorgan), EAAFX (Allspring), BPGLX (UBS).

Historical performance is shown to demonstrate the impact of broad asset allocation adjustments on risk and return. Client portfolio implementation may utilize different managers, and tactical targets may be used to adapt to the current market environment and liquidity considerations.

The Paragon Model Portfolio is for illustrative purposes only, to show the benefit of adding private credit and private equity allocations to portfolios. It is not representative of Paragon Investing's current strategic nor tactical recommendations.

The Paragon Model Portfolio has not been customized or tailored to suit any specific client or group of clients.

The Paragon "60/40" Model Portfolio is intended to match or improve upon the risk statistics of a traditional 60% stock, 40% bond portfolio (commonly referred to as a "60/40" portfolio or "60/40" fund). This is considered to be suitable for clients at retirement, within 5 years of retirement, or having retired within the last 5 years. This assumes average life expectancy and average retirement date(s). Given this risk profile target, and limited to not more than 60% of assets in semi-liquid interval funds, we seek to optimize returns of the "60/40" portfolio.

We believe this Paragon "60/40" Model Portfolio to be relevant for our intended audience and their investment objectives.



Final Disclosure

Paragon Investing is a registered investment adviser. Information presented herein is for educational purposes only and does not intend to make an offer or solicitation for the sale or purchase of any specific securities, investments, or investment strategies. Investments involve risk and are not guaranteed. Past performance is not indicative of future performance.

Readers of the information contained on this site should be aware that any action taken by the viewer/reader based on this information is taken at their own risk. This information does not address individual situations and should not be construed or viewed as any typed of individual or group recommendation. Be sure to first consult with a qualified financial adviser, tax professional, and/or legal counsel before implementing any securities, investments, or investment strategies discussed.

All investing involves risk, including the possible loss of money you invest. Past performance does not guarantee future performance. Historical returns, expected returns, model portfolio returns, and probability projections are provided for informational and illustrative purposes, and may not reflect actual future performance.