# Paragon Capital Management

> Paragon Capital Management is an SEC-registered investment advisory firm in Denver, CO, registered since 1990, reporting $1 billion to $5 billion in regulatory assets under management in its Form ADV filing dated March 24, 2026.

- CRD: 105147
- Filed as: PARAGON CAPITAL MANAGEMENT
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: Denver, CO
- Filing period: October 2026
- Form ADV filing dated: March 24, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/105147
- AdvisorCensus page: https://advisorcensus.com/firm/paragon-capital-management-denver-co-105147

## Quick answers

**How is Paragon Capital Management compensated?**
On its Form ADV (Item 5.E, October 2026), Paragon Capital Management reports these compensation arrangements: a percentage of assets under its management; hourly charges; fixed fees (other than subscription fees).

**How much does Paragon Capital Management charge?**
Its Form ADV Part 2A brochure dated March 24, 2026 states: Hourly rate: $400 an hour (financial planning services). Fees can differ by service and may be negotiable; the brochure is the complete statement.

**Where is Paragon Capital Management located?**
Paragon Capital Management's principal office is in Denver, CO, according to its Form ADV.

**Is Paragon Capital Management registered with the SEC or a state?**
Paragon Capital Management is an SEC-registered investment advisory firm, registered since 1990. Status as filed: Approved. CRD 105147.

**How much does Paragon Capital Management manage?**
Paragon Capital Management reports $1,316,232,312 in regulatory assets under management in its Form ADV filing dated March 24, 2026 (89% discretionary).

**How have Paragon Capital Management's assets and staff changed since 2021?**
In the Form ADV data for Paragon Capital Management: Regulatory assets under management: $1,115,930,463 in the October 2021 data and $1,316,232,312 in the October 2026 data, up 18%. Total employees: 6 in October 2021 and 6 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does Paragon Capital Management serve?**
By number of clients on Form ADV Item 5.D: high net worth individuals (140); individuals (other than high net worth individuals) (47); charitable organizations (1).

**Which custodians does Paragon Capital Management use?**
Paragon Capital Management's most recent Form ADV filing (Schedule D, Section 5.K(3)) lists Charles Schwab & Co., Inc. as a custodian holding 10% or more of its separately managed account assets.

**Does Paragon Capital Management report any disciplinary disclosures?**
Reports no disclosure items on Form ADV Item 11. The detail of any item is on the firm's SEC record: https://adviserinfo.sec.gov/firm/summary/105147

**Does Paragon Capital Management state an account minimum?**
Its Form ADV Part 2A brochure dated March 24, 2026 says: "Our Firm typically requires a minimum account size of $1,000,000 for advisory accounts. However, sometimes, at our sole discretion, we may accept smaller accounts based on various criteria, such as anticipated future assets, related accounts, and other individual Client circumstances."

**What changed in Paragon Capital Management's recent Form ADV filings?**
In the April 2026 filing data: Employees performing advisory functions went from 4 to 5.

## From the Form ADV filing

### Compensation (Item 5.E)
- A percentage of assets under your management
- Hourly charges
- Fixed fees (other than subscription fees)

### Fees and minimums (Form ADV Part 2A brochure dated March 24, 2026)

- Account minimum: $1,000,000 (the brochure says it may be waived or negotiated)

> Our Firm typically requires a minimum account size of $1,000,000 for advisory accounts. However, sometimes, at our sole discretion, we may accept smaller accounts based on various criteria, such as anticipated future assets, related accounts, and other individual Client circumstances.

- Minimum annual fee: $7,000

> Our Firm imposes a minimum annual fee of $7,000.

- Hourly rate: $400 an hour (financial planning services)

> Our Firm provides financial planning services under an hourly fee arrangement of $400 per hour.

As stated in the firm's brochure. Fees can differ by service and may be negotiable.

### Custodians (Schedule D, Section 5.K(3))
- Charles Schwab & Co., Inc.

Custodians holding 10% or more of the firm's separately managed account assets, as filed on Form ADV (Schedule D, Section 5.K(3)). A custodian holds client assets; it does not endorse or supervise the firm. AdvisorCensus has no relationship with any custodian.

### Regulatory assets under management (Item 5.F)
- Total: $1,316,232,312
- Discretionary: $1,171,622,801
- Non-discretionary: $144,609,511

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Individuals (other than high net worth individuals) | 47 | $23,817,405 |
| High net worth individuals | 140 | $1,290,384,572 |
| Charitable organizations | 1 | $2,030,335 |

### Advisory services (Item 5.G)
- Financial planning services
- Portfolio management for individuals and/or small businesses
- Selection of other advisers (including private fund managers)

### Firm details
- Registered since: 1990 (36 years)
- Employees: 6 total, 5 performing advisory functions
- Wrap fee program participation: No
- States registered or notice-filed: AZ, CA, CO, FL, NE, NH, TX, VA, WA
- Disclosures (Item 11): Reports no disclosure items on Form ADV Item 11.

### Websites listed on Form ADV (Item 1.I)
- paragoncapitalco.com

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $1,115,930,463 | 6 | July 20, 2021 |
| October 2022 | $1,423,044,284 | 6 | March 14, 2022 |
| October 2023 | $1,002,796,080 | 6 | June 22, 2023 |
| October 2024 | $1,134,002,663 | 6 | March 12, 2024 |
| October 2025 | $1,249,154,038 | 5 | July 23, 2025 |
| October 2026 | $1,316,232,312 | 6 | March 24, 2026 |

Regulatory assets under management: $1,115,930,463 in the October 2021 data and $1,316,232,312 in the October 2026 data, up 18%.
Total employees: 6 in October 2021 and 6 in October 2026.

## Changes in the filing (last 12 months)

### April 2026
- Employees performing advisory functions went from 4 to 5.

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Paragon Capital Management (CRD 105147): Form ADV filing data as of October 2026.