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Paradiem, LLC
d/b/a Intentional Ownership
Form ADV Part 2A – Disclosure Brochure
Effective: April 7, 2025
This Form ADV 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of
Paradiem, LLC d/b/a Intentional Ownership (herein “Paradiem” or the “Advisor”). If you have any questions about
the contents of this Disclosure Brochure or require information regarding Paradiem,, please contact the Advisor
at (985) 727-0770.
Paradiem is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The
information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities
authority. Registration of an investment advisor does not imply any specific level of skill or training. This
Disclosure Brochure provides information about Paradiem to assist you in determining whether to retain the
Advisor.
Additional information about Paradiem and its Advisory Persons is available on the SEC’s website at
www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 158200.
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson Ave, Covington, LA 70433
Phone: (985) 727-0770 | Fax: (985) 612-7007
www.paradiem.org
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770|Fax: (985) 612-7007
Page 2
www.paradiem.org
Item 2 – Material Changes
Form ADV 2 is divided into two parts: Part 2A and Part 2B. Part 2A (the “Disclosure Brochure”) provides
information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. Part 2B
(the “Brochure Supplement”) provides information about Advisory Persons of Paradiem. For convenience, the
Advisor has combined these documents into a single disclosure document.
Paradiem believes that communication and transparency are the foundation of its relationship and continually
strive to provide you with complete and accurate information at all times. Paradiem encourages all current and
prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Advisor.
Material Changes
The following material changes have been made to this Disclosure Brochure since the annual amendment filing
on 3/25/2024:
●
The Advisor is no longer affiliated with Halcyon Digital Asset Advisors, LLC/Halcyon Digital Asset Advisors
GP
●
The Advisor is affiliated through common ownership with OxLot Capital. Please see item 10 for additional
information.
●
The Advisor no longer requires a minimum investment management fee of $4,000 per year.
Future Changes
From time to time the Advisor may amend this Disclosure Brochure to reflect changes in business practices,
changes in regulations or routine annual updates as required by the securities regulators. This complete
Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if a material
change occurs in the business practices of Paradiem.
At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public
Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 158200. You
may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at (985) 727-0770.
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770|Fax: (985) 612-7007
Page 3
www.paradiem.org
Item 3 – Table of Contents
Item 1 – Cover Page
Item 2 – Material Changes
Item 3 – Table of Contents
Item 4 – Advisory Services
Item 5 – Fees and Compensation
Item 6 – Performance-Based Fees and Side-By-Side Management
Item 7 – Types of Clients
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
Item 9 – Disciplinary Information
Item 10 – Other Financial Industry Activities and Affiliations
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Item 12 – Brokerage Practices
Item 13 – Review of Accounts
Item 14 – Client Referrals and Other Compensation
Item 15 – Custody
Item 16 – Investment Discretion
Item 17 – Voting Client Securities
Item 18 – Financial Information
Appendix 1
ADV2Bs
Privacy Policy
1
2
3
4
10
13
13
13
15
15
15
16
17
18
19
20
20
20
21
37
55
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770|Fax: (985) 612-7007
Page 4
www.paradiem.org
Item 4 – Advisory Services
Paradiem, LLC d/b/a Intentional Ownership (herein “Paradiem” or the “Advisor”) is a registered investment
advisor with the U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as a limited liability
company (“LLC”) under the laws of the State of Louisiana. The Advisor was established as a registered investment
advisor in 2011. Effective January 1, 2022 the Adviser became a wholly owned subsidiary of Paradiem Holding
Company, LLC, which is owned by Eric L. Dunavant (President).
This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory
services provided by Paradiem, including asset management and insurance.
Paradiem offers asset management and financial consulting services to individuals, high net worth individuals,
families, and charitable organizations (each referred to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary,
the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential
conflicts of interest. Paradiem’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For
more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in
Client Transactions and Personal Trading.
Kingdom ROI Blueprint, Kingdom Business ROI Blueprint and Consulting Services
Personal / Family Planning (Kingdom ROI Blueprint)
Paradiem offers services to help coordinate the various aspects of your family’s finances along with your family
relationships. Paradiem seeks to serve families in a role similar to that of a Chief Financial Officer. The following
areas are addressed depending on the needs and complexities of each family.
Year 1
Impact Interview
o Clarity of Goals
▪
▪ Written Goals and Intentions
o Collaboration
▪ Coordinate your team of advisors
▪ Discuss planning with your advisors
▪ Quarterback your planning
o Tax Planning
▪ Review tax returns
▪ Annual tax planning
▪ Capital Gains Minimization
o Cash Flow Planning
▪ Current cash flow
▪ Optimize cash flow
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770|Fax: (985) 612-7007
Page 5
www.paradiem.org
o Estate Planning
▪ Create estate plan
▪ Written legal guidelines
▪ Review legal documents
▪ Drive execution of documents
o Family
▪
Improve communication
▪ Strengthen relationships
▪
Intentional Conversations
▪ Family Health Insight
▪ Give children a voice
o Trusted Advisor
▪ Listening Ear
▪ Prioritizing your needs / desires
▪ Quick response to your calls / emails
▪ Your advocate
o Charitable Giving
▪ Annual Giving Optimization
▪ Generosity Interview
o
Investments
▪ Review holdings and performance
▪ Align Investments with planning
o Business
▪ Business sale strategies
▪ Succession planning
▪ Alignment with personal planning
o
Implementation
▪ Facilitate Implementation of plan
▪ Accountability with action items
▪ Coordinate and monitor strategies
o Events
▪ Exclusive access to events
▪ Unique access to our community
Year 2+
o Clarity of Goals
▪ Annual Update and Review
o Collaboration
▪ Coordinate your team of advisors
▪ Discuss planning with your advisors
▪ Quarterback your planning
o Tax Planning
▪ Review tax returns
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770|Fax: (985) 612-7007
Page 6
www.paradiem.org
▪ Annual tax planning
▪ Capital Gains Minimization
o Cash Flow Planning
▪ Current cash flow
▪ Optimize cash flow
▪ Review cash flow scenarios
o Estate Planning
▪ Monitor changes for updates
o Family
▪ Develop family values
▪ Develop family motto
▪ Facilitate family meetings
▪ Create family letters
▪
Include family in giving
▪
Improve communication
▪ Strengthen relationships
▪
Intentional Conversations
▪ Family Health Insight
▪ Give children a voice
o Trusted Advisor
▪ Listening Ear
▪ Prioritize your needs / desires
▪ Quick response to your calls / emails
▪ Your advocate
▪ Charitable Giving
▪ Annual Giving Optimization
▪ Creation of your giving story
▪ Develop giving strategies
▪
Identify Giving Passions
o
Investments
▪ Audit for obstacles and opportunities
▪ Exclusive access to events
▪ Unique access to our community
o Business
▪ Business sale strategies
▪ Succession planning
▪ Alignment with personal planning
o Annual Reviews
Implement plan changes
▪ Discuss Ideal Outcomes
▪ Update Plan
▪
o Events
▪ Exclusive access to events
▪ Unique access to our community
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770|Fax: (985) 612-7007
Page 7
www.paradiem.org
Business Planning (Kingdom Business ROI Blueprint)
Paradiem offers services to help coordinate the various aspects of your business. Paradiem seeks to serve
businesses in a role similar to that of a business consultant. The following areas are addressed depending on the
needs and complexities of each business.
Year 1
Impact Interview
o Business Operating System Implementation
o Clarity of Goals
▪
▪ Written Goals and Intentions
o Collaboration
▪ Coordinate your team of advisors
▪ Discuss planning with your advisors
▪ Quarterback your planning
o Trusted Advisor
▪ Listening Ear
▪ Prioritize your needs / desires
▪ Quick response to your calls / emails
▪ Your advocate
o Leadership
▪ Define Culture
▪ Formalized Core Values
▪ Documented Vision
▪ Develop purpose
▪ Documented Mission
o Operations
▪ Streamline Key Processes
▪ Develop KPIs
▪ Build Meeting Optimization
o Marketing
Identify Core Customers
▪
▪ Define Differentiators
o Finance
Informal Valuation
▪ Cash Flow Planning
▪ Tax Planning
▪
▪ Growth Analysis
▪ Charitable Giving Strategies
▪ Sale Strategies
o Personnel
▪ Employee Care & Compensation Strategies
▪ Define Organizational Structure
▪ Right People, Right Seats
o Legal
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770|Fax: (985) 612-7007
Page 8
www.paradiem.org
▪ Buy-Sell Agreements
▪ Structure Analysis
▪ Business Continuity
o
Implementation
▪ Facilitate Implementation of Plan
▪ Accountability with Action Items
▪ Coordinate and Monitor Strategies
o Events
▪ Exclusive access to events
▪ Unique access to our community
Year 2+
o Business Operation System
▪ Coordinate Annual and Quarterly Meeting Updates
o Clarify of Goals
▪ Annual Update and Review
o Collaboration
▪ Coordinate your team of advisors
▪ Discuss planning with your advisors
▪ Quarterback your planning
o Trusted Advisor
▪ Listening Ear
▪ Prioritize your needs / desires
▪ Quick response to your calls / emails
▪ Your advocate
o Leadership
▪ Review
o Culture Sustainability
▪ Core Values
▪ Vision
▪ Purpose
▪ Mission
o Operations
▪ Process Review
▪ Annualized KPI Monitoring
▪ Facilitate Meeting Optimization
o Marketing
▪ Monitor Ideal Customer Avatar
▪ Re-visit Market Differentiators
o Finance
▪ Optimize Current Cash Flow
▪ Current & Future State Projections
▪ Tax Planning
▪ Valuation & Growth Analysis
▪ Charitable Giving Strategies
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770|Fax: (985) 612-7007
Page 9
www.paradiem.org
▪ Sale Strategies
o Personal
▪ Employee Care & Compensation Review
▪ Review Organizational Structure
o Legal
▪ Monitor Changes for Updates to:
▪ Buy-Sell Agreements
▪ Structure Analysis
▪ Business Continuity
o Annual Reviews
Implement Ideal Outcomes
Implement Plan Changes
▪ Discuss Ideal Outcomes
▪
▪ Update Plan
▪
o Events
▪ Exclusive access to events
▪ Unique access to our community
Planning or consulting services may also encompass one or more areas of specific need, including but not limited
to, investment planning, retirement planning, personal savings, education savings and other areas of a Client’s
financial situation. The Advisor may provide guidance on any type of security, depending on the needs, goals,
financial situation and current positions held by a Client. The Advisor may also provide guidance on non-
securities investment products, as appropriate.
Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the
interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor
for investment management services or to increase the level of investment assets with the Advisor would pose a
conflict, as it would increase the amount of advisory fees paid to the Advisor. This causes a conflict of interest; to
mitigate this conflict Clients always have the right to choose to implement any recommendation with any broker-
dealer or insurance agency. Clients always have the right to decide whether to implement any recommendations
made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to implement on
any of the recommendations made by the Advisor, the Client always has the right to execute the transaction
through another advisor. The Investment Advisor Representatives (herein “Advisory Persons”) will typically receive
commissions for the implementation of recommendations for insurance transactions, in their separate capacity as
insurance professionals.
Investment Management Services
Paradiem provides customized investment advisory solutions for its Clients. This is achieved through continuous
personal Client contact and interaction while providing discretionary and non-discretionary investment
management and consulting services. Paradiem works with each Client to identify their investment goals and
objectives as well as risk tolerance and financial situation to create a portfolio strategy. Paradiem constructs
portfolios with individual equity securities, exchange-traded funds (“ETFs”), individual fixed income securities and
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770|Fax: (985) 612-7007
Page 10
www.paradiem.org
mutual funds to achieve the Client’s investment goals. For certain Clients, the Advisor may recommend
investment in Class F-2 shares offered through American Funds Services (“AFS”), a low cost mutual fund option,
which do not include 12(b)-1 fees. Paradiem’s investment approach is primarily long-term focused, but the
Advisor may buy, sell or re-allocate positions that have been held less than one year to meet the objectives of the
Client or due to market conditions. Paradiem will construct, implement and monitor the portfolio to ensure it
meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the
opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio,
subject to the acceptance by the Advisor. The Advisor may retain other types of investments from the Client’s
legacy portfolio due to fit with the overall portfolio strategy, tax-related reasons, or other reasons as identified
between the Advisor and the Client.
Paradiem evaluates and selects ETFs and mutual funds for inclusion in Client portfolios only after applying their
internal due diligence process. Paradiem may recommend, on occasion, redistributing investment allocations to
diversify the portfolio. Paradiem may recommend specific positions to increase sector or asset class weightings.
The Advisor may recommend employing cash positions as a possible hedge against market movement. Paradiem
may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or
losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting
of the position[s] in the portfolio, change in risk tolerance of Client, generating cash to meet Client needs, or any
risk deemed unacceptable for the Client’s risk tolerance.
Prior to rendering investment advisory services, Paradiem will ascertain, in conjunction with the Client, the Client’s
financial situation, risk tolerance, and investment objective[s]. Paradiem will provide investment advisory and
related services. At no time will Paradiem accept or maintain custody of a Client’s funds or securities. All Client
assets will be managed within their designated account[s] at the Custodian, pursuant to the Client investment
advisory agreement.
Prior to engaging Paradiem to provide investment advisory services, each Client is required to enter into one or
more advisory agreements with the Advisor that define the terms, conditions, authority and responsibilities of the
Advisor and the Client.
At no time will Paradiem accept or maintain custody of a Client’s funds or securities, except for the limited
authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at
the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices.
These services may include:
▪ Establishing an Investment Strategy – Paradiem, in connection with the Client, will develop a strategy that
seeks to achieve the Client’s goals and objectives.
▪ Asset Allocation – Paradiem will develop a strategic asset allocation that is targeted to meet the
investment objectives, time horizon, financial situation, and tolerance for risk for each Client.
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770|Fax: (985) 612-7007
Page 11
www.paradiem.org
▪ Portfolio Construction – Paradiem will develop a portfolio for the Client that is intended to meet the
▪
stated goals and objectives of the Client.
Investment Management and Supervision – Paradiem will provide investment management and ongoing
oversight of the Client’s investment portfolio.
Retirement Plan Accounts – When deemed to be in the Client’s best interest, the Advisor will recommend that a
Client roll over its retirement plan account into an account managed by the Advisor. In such instances, the
Advisor will serve as an investment fiduciary as that term is defined under The Employee Retirement Income
Security Act of 1974 (“ERISA”). Such a recommendation creates a conflict of interest as the Advisor will earn a new
(or increase its current) advisory fee as a result of the rollover. No client is under any obligation to roll over
retirement plan assets to an account managed by the Advisor.
Paradiem does manage a wrap fee program. For certain Clients, the Advisor will include the securities transaction
fees together with investment advisory fees to provide the Client with a single, bundled fee structure. Including
these fees into a single asset-based fee is considered a “Wrap Fee Program”. The Advisor customizes its
investment management services for its Clients. The Advisor sponsors the Paradiem Wrap Fee Program solely as a
supplemental disclosure regarding the combination of fees. Depending on the level of trading required for the
Client’s account[s] in a particular year, the Client may pay more or less in total fees than if the Client paid its own
transaction fees. Please see Appendix 1 – Wrap Fee Program Brochure, which is included as a supplement to this
Disclosure Brochure.
As of December 31, 2024, the Advisor manages $466,197.031 in Client assets, $455,743,580 of which are
managed on a discretionary basis and $19,453,451 on a non-discretionary basis.
In addition, as of December 31, 2024, the Advisor also has $1,365,965,205 in assets under advisement (“AUA”),
attestable to ongoing consulting services provided to Clients of the Advisor. Clients may request more current
information at any time by contacting the Advisor.
Item 5 – Fees and Compensation
The following paragraphs detail the fee structure and compensation methodology for services provided by the
Advisor. Each Client shall sign one or more agreements that detail the responsibilities of Paradiem and the Client.
A. Fees for Advisory Services
Planning and Consulting Services
Planning engagements are typically offered on a fixed fee per engagement that is based on the complexity and
duration of the planning services provided. An estimate of the duration and work effort will be determined prior
to establishing the advisory relationship. Planning fees may be negotiable at the sole discretion of the Advisor.
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770|Fax: (985) 612-7007
Page 12
www.paradiem.org
In certain instances, Clients may be offered an hourly fee for financial planning and consulting services at a rate of
up to $500 per hour.
The Advisor’s fee is exclusive of, and in addition to, transaction fees, and other related costs and expenses, which
may be incurred by the Client. However, the Advisor shall not receive any portion of these commissions, fees, and
costs. The hourly fees are determined after considering many factors, such as the level and scope of the services.
Paradiem’s Planning and Consulting Services are completed in offered in three levels of service, based on a fixed,
negotiated retainer fee (as listed below). Fees are determined based on the complexity of the Client’s situation
and the anticipated effort and duration associated with the scope of work. All fees will be presented to the client
BEFORE engagement of the relationship to ensure that all parties are in agreement to the scope of the work.
Wealth Counseling Service
Monthly Fee Rate
Annual Fee Rate
Business Planning (Kingdom Business ROI
$5,000
$60,000
Blueprint)
Personal / Family Planning (Kingdom ROI
$5,000
$60,000
Blueprint)
Personal/Business Planning (Kingdom
$8,500
$102,000
Business ROI & Kingdom ROI Blueprints)
Fees are charged monthly, in advance, or in advance of the engagement, pursuant to the terms of the agreement.
Investment Management Services
Investment advisory fees are paid in advance of each month, pursuant to the terms of the investment advisory
agreement. Investment advisory fees are based on the market value of assets under management at the end of
the last business day of the preceding month.
Investment advisory fees are based on investment program[s] in which the Client’s account[s] are invested and
are based on the following tiered schedule:
Assets Under Management
Annual Rate (%)
1.50%
1.25%
1.00%
Up to $1,000,000
$1,000,001 to $5,000,000
$5,000,001 to $10,000,000
$10,000,001 to $30,000,000
0.75%
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770|Fax: (985) 612-7007
Page 13
www.paradiem.org
Over $30,000,000
0.50%
The investment advisory fee in the first month of service is prorated to the inception date of the account[s] to the
end of the first month. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take
into consideration the aggregate assets under management with the Advisor. All securities held in accounts
managed by Paradiem will be independently valued by the Custodian. Paradiem will conduct periodic reviews of
the Custodian’s valuations to ensure accurate billing.
Depending on the unique and particular complexities of a Client’s financial situation, the Advisor may also offer
investment management services based on a fixed annual fee arrangement. The total annual fee is determined on
a case-by-case basis. Factors considered in setting the fixed-fee generally include the complexity of the Client’s
financial situation, level of investable assets, and estimated time involved. Other factors considered include the
number of household members, number and type of accounts, life stage, business interests, real estate
ownership, trust arrangements, etc. Fixed fees are intended to be competitive with what the Client might expect
to pay under an “assets under management” (AUM) approach (assuming all investable assets were managed).
B. Fee Billing
Financial Planning and Consulting Services
Financial planning and consulting fees are invoiced by the Advisor and are due in advance of services rendered.
Clients are to pay these fees on a monthly basis. The Advisor will not collect fees that are greater than $1,200 if
the services will be provided six months or more in the future. For annual retainers, the Advisor will bill in advance
for services that will be completed in less than six months. Supplemental billing may be required during the year
pursuant to the terms of the financial planning and consulting agreement.
Wealth counseling assessment fees are invoiced by the Advisor and are due in advance of services rendered.
Clients may incur certain fees or charges imposed by third parties, other than Paradiem, in connection with
recommendations made to the Client. The Client is responsible for all such fees.
Investment Management Services
Investment advisory fees are calculated by the Custodian or delegate and deducted from the Client’s account[s].
The Client shall instruct the Custodian to automatically deduct the investment advisory fee from the Client’s
account[s] for each billing period and pay the investment advisory fee[s] to the Advisor. The amount due is
calculated by applying the quarterly rate (annual rate divided by 365/366) to the total assets under management
with Paradiem at the beginning of each month. Clients will be provided with a statement, at least quarterly, from
the Custodian reflecting deduction of the investment advisory fee. It is the responsibility of the Client to verify the
accuracy of these fees as listed on the Custodian’s brokerage statement as the Custodian does not assume this
responsibility. Clients provide written authorization permitting advisory fees to be deducted by Paradiem directly
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770|Fax: (985) 612-7007
Page 14
www.paradiem.org
from their account[s] held by the Custodian as part of the investment advisory agreement and separate account
forms provided by the Custodian.
C. Other Fees and Expenses
Clients may incur certain fees or charges imposed by third parties in connection with investments made on behalf
of the Client’s account[s]. Paradiem includes securities transactions costs as part of its overall investment advisory
fee through the Paradiem Wrap Fee Program. Securities transaction fees for Client-directed trades may be
charged back to the Client. Please see Item 4.D. above as well as Appendix 1 – Wrap Fee Program Brochure. The
inclusion of securities transaction fees into a single bundled fee may cost the Client more or less than if paid
separately.
In addition, all fees paid to Paradiem for investment advisory services are separate and distinct from the expenses
charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in
each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds,
other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible
distribution fee. A Client may be able to invest in these products directly, without the services of Paradiem, but
would not receive the services provided by Paradiem which are designed, among other things, to assist the Client
in determining which products or services are most appropriate for each Client’s financial situation and
objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by
Paradiem to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional
information.
D. Advance Payment of Fees and Termination
Planning and Consulting Services
Either party may terminate a planning or consulting agreement at any time by providing written notice to the
other party. In addition, the Client may also terminate the advisory agreement within five (5) business days of
signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for
bona fide advisory services rendered to the point of termination and such fees will be due and payable by the
Client. Refunds will be given on a pro-rata basis. The agreement for planning services is effectively terminated
upon the presentation of the plan or specific deliverables included in the agreement.
Investment Management Services
Paradiem is compensated for its services in advance of the month in which investment advisory services are
rendered. Either party may request to terminate the investment advisory agreement with Paradiem, at any time,
by providing advance written notice to the other party. In addition, the Client may also terminate the investment
advisory agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After
the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of
termination and such fees will be due and payable by the Client. Upon termination, the Advisor will refund any
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770|Fax: (985) 612-7007
Page 15
www.paradiem.org
unearned, prepaid investment advisory fees from the effective date of termination to the end of the month. The
Client’s investment advisory agreement with the Advisor is non-transferable without the Client’s prior consent.
E. Compensation for Sales of Securities
Paradiem does not buy or sell securities and does not receive any compensation for securities transactions in any
Client account, other than the investment advisory fees noted above.
Insurance Agency Affiliations
Paradiem is also a licensed insurance agency and certain Advisory Persons are licensed as insurance
professionals. Paradiem will earn commission-based compensation for selling insurance products, including
insurance products sold to Clients. Insurance commissions earned by Paradiem are separate and in addition to
advisory fees. This practice presents a conflict of interest as Advisory Persons and members of Paradiem’s
management have an incentive to recommend insurance products for the purpose of generating commissions
and revenue rather than solely based on Client needs. Paradiem will never earn both a commission and an
ongoing advisory fee on the same assets. Additionally, Clients are under no obligation to purchase insurance
products through any Advisory Person or Paradiem. Please see Item 10 – Other Financial Industry Activities and
Affiliations.
Item 6 – Performance-Based Fees and Side-By-Side Management
Paradiem does not charge performance-based fees for its investment advisory services. The fees charged by
Paradiem are as described in Item 5 above and are not based upon the capital appreciation of the funds or
securities held by any Client. Paradiem does not manage any proprietary investment funds or limited partnerships
(for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any particular
investment options to its Clients.
Item 7 – Types of Clients
Paradiem offers asset management and financial consulting services to individuals, high net worth individuals,
families, and charitable organizations. Paradiem generally does not impose a minimum account size for
establishing an asset management relationship.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
Paradiem primarily employs a fundamental analysis method in developing investment strategies for its Clients.
Research and analysis from Paradiem is derived from numerous sources, including financial media companies,
third-party research materials, Internet sources, and review of company activities, including annual reports,
prospectuses, press releases and research prepared by others.
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770|Fax: (985) 612-7007
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Fundamental analysis utilizes economic and business indicators as investment selection criteria. These criteria are
generally ratios and trends that may indicate the overall strength and financial viability of the entity being
analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment
with a value discounted by the market. While this type of analysis helps the Advisor in evaluating a potential
investment, it does not guarantee that the investment will increase in value. Assets meeting the investment
criteria utilized in the fundamental analysis may lose value and may have negative investment performance. The
Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate.
As noted above, Paradiem generally employs a long-term investment strategy for its Clients, as consistent with
their financial goals. Paradiem will typically hold all or a portion of a security for more than a year, but may hold
for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times,
Paradiem may also buy and sell positions that are more short-term in nature, depending on the goals of the
Client and/or the fundamentals of the security, sector, or asset class.
Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients
should be prepared to bear the risk of loss. Paradiem will assist Clients in determining an appropriate strategy
based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will
meet their investment goals. Fundamental analysis utilizes economic and business indicators as investment
selection criteria. More details on the Advisor’s review process are included in Item 13.
Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon,
tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client
participation in this process, including full and accurate disclosure of requested information, is essential for the
analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the
Client or their designees without the duty or obligation to validate the accuracy and completeness of the
provided information. It is the responsibility of the Client to inform the Advisor of any changes in financial
condition, goals or other factors that may affect this analysis.
The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts.
The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction
process. Following are some of the risks associated with the Advisor’s investment approach.
Market Risks
The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as
economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall
financial markets.
Equity (Stock) Risks
Common stocks are subject to general stock market fluctuations and to volatile increases and decreases in value
as market confidence and perception of their issuers change. There is also a certain level of company or industry
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770|Fax: (985) 612-7007
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specific risk that is inherent in each investment. There is the risk that the company will perform poorly or have its
value reduced based on factors specific to the company or its industry,
ETF Risks
The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs
will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading
risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs have a large
bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and
may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF
purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short
time later.
Mutual Fund Risks
The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of
the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a
mutual fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the
same price as a mutual fund purchased later that same day.
Real Estate Investment Trusts (“REITs”)
Investing in Real Estate Investment Trusts (“REITs”) involves certain distinct risks in addition to those risks
associated with investing in the real estate industry in general. Equity REITs may be affected by changes in the
value of the underlying property owned by the REITs, while mortgage REITs may be affected by the quality of
credit extended. REITs are subject to heavy cash flow dependency, default by borrowers and self-liquidation.
REITs, especially mortgage REITs, are also subject to interest rate risk (i.e., as interest rates rise, the value of the
REIT may decline).
Past performance is not a guarantee of future returns. Investing in securities and other investments involve a risk
of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with
the Advisor.
Item 9 – Disciplinary Information
There are no legal, regulatory or disciplinary events involving Paradiem or any of its management persons.
Paradiem and its Supervised Persons value the trust Clients place in the Advisor. The Advisor encourages Clients
to perform the requisite due diligence on any advisor or service provider that the Client engages. The
backgrounds of the Advisor and its Advisory Persons are available on the Investment Adviser Public Disclosure
website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 158200.
Item 10 – Other Financial Industry Activities and Affiliations
Insurance Agency Affiliations
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770|Fax: (985) 612-7007
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Paradiem also serves as a licensed insurance agency, and as such, may offer insurance products on a commission
basis. The Advisor shall generally introduce the Client to an unaffiliated insurance agency to manage the
insurance process. The Advisor shall receive a portion of the insurance commission earned by the unaffiliated
insurance agency. No client shall be under any obligation to purchase any insurance products from the Advisor or
such introduced insurance agency. The recommendation by an Advisory Person that a Client purchase an
insurance product presents a conflict of interest, as the receipt of commissions may provide an incentive to
recommend insurance products based on commissions to be received, rather than based on a particular Client’s
need. Clients are reminded that they remain free to purchase insurance products through other insurance
agencies.
OxLot Capital
The Advisor is under common control and ownership with OxLot Capital (“OxLot”). OxLot is currently an inactive
entity.
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Paradiem has implemented a Code of Ethics that defines the Advisor’s fiduciary commitment to each Client. This
Code of Ethics applies to all persons associated with Paradiem (“Supervised Persons”). The Code of Ethics was
developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to the
Client. Paradiem and its Supervised Persons owe a duty of loyalty, fairness, and good faith towards each Client. It
is the obligation of Paradiem associates to adhere not only to the specific provisions of the Code, but also to the
general principles that guide the Code. The Code of Ethics covers a range of topics that address employee ethics
and conflicts of interest. To request a copy of the Code of Ethics, please contact the Advisor at (985) 727-0770.
Paradiem allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients. Paradiem does not act as principal in any transactions. In addition, the Advisor
does not act as the general partner of a fund, or advise an investment company. Paradiem does not have a
material interest in any securities traded in Client accounts.
Paradiem allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients
presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and
procedures. As noted above, the Advisor has adopted the Code to address insider trading (material non-public
information controls); gifts and entertainment; outside business activities and personal securities reporting. When
trading for personal accounts, Supervised Persons have a conflict of interest when trading in the same securities.
The fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more
advantageous terms than Client trades, or by trading based on material non-public information. This risk is
mitigated by Paradiem requiring reporting of personal securities trades in order to determine that the Advisory
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770|Fax: (985) 612-7007
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www.paradiem.org
Persons is not putting the Client into a disadvantage and adhering to the policies and procedures by its
Supervised Persons for review by the CCO, pursuant to its Code of Ethics. The Advisor has also adopted written
policies and procedures to detect the misuse of material, non-public information. In addition, the Code of Ethics
governs Gifts and Entertainment given by and provided to the Advisor, outside employment activities of
employees, Employee reporting, sanctions for violations of the Code of Ethics, and records retention
requirements for various aspects of the Code of Ethics.
Paradiem allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients. The Advisor and its affiliated persons often trade alongside its Clients and will
often include trades for the accounts of affiliated persons at the same time as its Clients. At no time, will
Paradiem or any Supervised Persons of Paradiem, transact in any security to the detriment of any Client.
Item 12 – Brokerage Practices
Paradiem does not have discretionary authority to select the broker-dealer/custodian for custody and execution
services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets
and authorize Paradiem to direct trades to the Custodian as agreed upon in the wealth management agreement.
The Advisor typically recommends that Clients establish their account[s] at Charles Schwab & Co., Inc. (“Schwab”),
a FINRA-registered broker-dealer and member SIPC. Clients are not obligated to use the recommended
Custodian and will not incur any extra fee or cost from the Advisor associated with using a custodian not
recommended by Paradiem. Schwab will serve as the Client’s “qualified custodian”. Paradiem maintains an
institutional relationship with Schwab, whereby the Advisor receives economic benefits. Please see Item 14 –
Client Referrals and Other Compensation below.
Paradiem may also recommend that Clients establish their account[s] at Mutual Securities, Inc. (“Mutual
Securities”), a FINRA-registered broker-dealer and member SIPC. Clients are not obligated to use the
recommended Custodian and will not incur any extra fee or cost from the Advisor associated with using a
custodian not recommended by Paradiem. Mutual Securities will serve as the Client’s “qualified custodian”.
Paradiem maintains an institutional relationship with Mutual Securities, whereby the Advisor receives economic
benefits from Mutual Securities. Please see Item 14 below.
In addition, the Advisor may recommend that a Client establish their account[s] directly with a mutual fund
company. For Client accounts established to invest in AFS Fund Class F-2 shares, American Funds Services will act
as the transfer agent for the fund.
Following are additional details regarding the brokerage practices of the Advisor:
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770|Fax: (985) 612-7007
Page 20
www.paradiem.org
1. Soft Dollars - Soft dollars are programs offered by broker-dealers/custodians whereby an advisor enters into
an agreement to place security trades with a broker-dealer/custodian in exchange for research and other services.
Paradiem receives soft dollar economic benefits from Schwab (Please see Item 14). Clients should be aware that
the receipt of economic benefits from a Custodian creates a conflict of interest since these benefits may influence
the Advisor's recommendation of the Custodian over one that does not furnish similar software, systems support,
or services. To mitigate this conflict of interest the benefits received by the Advisor or its Advisory Persons
through participation in the program do not depend on the amount of brokerage transactions directed to the
Custodian. As part of its fiduciary duties to clients, the Advisor at all times puts the interests of its Clients first.
2. Brokerage Referrals - Paradiem does not receive any compensation from any third party in connection with the
recommendation for establishing an account.
3. Directed Brokerage - The Advisor does not utilize directed brokerage and the Client has the ability to choose
whom they utilize for a Custodian. If a client engages a Custodian other than Schwab the Advisor’s ability to
aggregate a trade may be negated.
The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the
most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of
execution, 4) confidentiality and 5) skill required of the Custodian.
Paradiem will execute its transactions through the Custodian as authorized by the Client. Paradiem may
aggregate orders in a block trade or trades when securities are purchased or sold through the Custodian for
multiple (discretionary) accounts. If a block trade cannot be executed in full at the same price or time, the
securities actually purchased or sold by the close of each business day must be allocated in a manner that is
consistent with the initial pre-allocation or other written statement. This must be done in a way that does not
consistently advantage or disadvantage particular Client accounts.
Item 13 – Review of Accounts
Securities in Client accounts are monitored regular and continuous basis, at least monthly by Eric Dunavant,
President of the Advisor. Formal reviews are generally conducted at least annually.
In addition to the investment monitoring each Client account shall be internally reviewed at least annually.
Reviews may be conducted more or less frequently at the Client’s request. Accounts may be reviewed as a result
of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits
or withdrawals in the Client’s account[s]. The Client is encouraged to notify Paradiem if changes occur in his/her
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770|Fax: (985) 612-7007
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www.paradiem.org
personal financial situation that might adversely affect his/her investment plan. Additional reviews may be
triggered by material market, economic or political events.
The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage
statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to
the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage
statements will include all positions, transactions and fees relating to the Client’s account[s]. The Advisor or the
Custodian may also provide Clients with periodic reports regarding their holdings, allocations, and performance.
Item 14 – Client Referrals and Other Compensation
Paradiem may refer Clients to various unaffiliated, non-advisory professionals (e.g. attorneys, accountants, estate
planners) to provide certain financial services necessary to meet the goals of its Clients. Paradiem does not
receive compensation for these referrals. Likewise, Paradiem may receive non-compensated referrals of new
Clients from various third-parties.
Participation in Institutional Advisor Platform
As disclosed under Item 12, above, the Advisor has established an institutional relationship with Schwab through
its “Schwab Advisor Services” unit, a division of Schwab dedicated to serving independent advisory firms like
Paradiem. As a registered investment advisor participating on the Schwab Advisor Services platform, Paradiem
receives access to software and related support without cost because the Advisor renders investment
management services to Clients that maintain assets at Schwab. Services provided by Schwab Advisor Services
benefit the Advisor and many, but not all services provided by Schwab will benefit Clients. In fulfilling its duties to
its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware,
however, that the receipt of economic benefits from a custodian creates a conflict of interest since these benefits
can influence the Advisor's recommendation of Schwab over a custodian that does not furnish similar software,
systems support, or services.
Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of
investment products, execution of securities transactions, and custody of Client’s funds and securities. Through
Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be
able to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual
funds and other investments without having to adhere to investment minimums that might be required if the
Client were to directly access the investments.
Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to technology,
research, discounts and other services. In addition, the Advisor receives duplicate statements for Client accounts,
the ability to deduct advisory fees, trading tools, and back-office support services as part of its relationship with
Schwab. These services are intended to assist the Advisor in effectively managing accounts for its Clients but may
not directly benefit all Clients.
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770|Fax: (985) 612-7007
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www.paradiem.org
Services that May Only Benefit the Advisor – Schwab also offers other services and financial support to Paradiem
that may not benefit the Client, including: educational conferences and events, financial start-up support,
consulting services and discounts for various service providers. Additionally, Schwab has agreed to pay for certain
services rendered by third parties for which the Advisor would otherwise have to pay. This amount is covered
once the value of Client assets in accounts at Schwab reaches a certain size. Clients do not pay more for assets
maintained at Schwab as a result of these arrangements. However, the Advisor does benefit from the
arrangement because the cost of these services would otherwise be borne directly by the Advisor. Access to
these services and financial support creates a financial incentive for the Advisor to recommend Schwab, which
results in a conflict of interest. Paradiem believes, however, that the selection of Schwab as Custodian is in the
best interests of its Clients. Clients should consider these conflicts of interest when selecting a custodian.
Participation in Institutional Advisor Platform
Paradiem has established an institutional relationship with Mutual Securities (“Custodian”) to assist the Advisor in
managing Client account[s]. Access to the Mutual Securities platform is provided at no charge to the Advisor. The
Advisor receives access to software and related support without cost because the Advisor renders investment
management services to Clients that maintain assets at Mutual Securities. The software and related systems
support may benefit the Advisor, but not its Clients directly. In fulfilling its duties to its Clients, the Advisor
endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of
economic benefits from a Custodian creates a potential conflict of interest since these benefits may influence the
Advisor's recommendation of this Custodian over one that does not furnish similar software, systems support, or
services.
Insurance Company
As noted in Item 10, Paradiem also serves as an insurance company, where the Advisor may recommend to
Clients the purchase of certain insurance products. Paradiem will benefit from any revenue generated from the
sale of a recommended insurance product.
Compensation for Client Referrals
Certain Clients may be referred to Paradiem by either an affiliated or unaffiliated party (herein "Promoter") and
receive, directly or indirectly, compensation for the Client referral. In such instances, Paradiem will compensate
the Promoter a fee in accordance with Rule 206(4)-1 of the Advisers Act and any corresponding state securities
requirements. Any such compensation shall be paid solely from the investment advisory fees earned by Paradiem,
and shall not result in any additional charge to the Client.
Item 15 – Custody
Paradiem does not accept or maintain custody of Client accounts, except for the limited circumstances outlined
below:
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770|Fax: (985) 612-7007
Page 23
www.paradiem.org
Deduction of Advisory Fees - To ensure compliance with regulatory requirements associated with the deduction
of advisory fees, all Clients for whom Paradiem exercises discretionary authority must hold their assets with a
"qualified custodian." Clients are responsible for engaging a “qualified custodian” to safeguard their funds and
securities and must instruct Paradiem to utilize that Custodian for securities transactions on their behalf. Clients
are encouraged to review statements provided by the Custodian and compare to any reports provided by
Paradiem to ensure accuracy, as the Custodian does not perform this review
Money Movement Authorization - For instances where Clients authorize Paradiem to move funds between their
accounts, Paradiem and the Custodian have implemented safeguards to ensure that all money movement
activities are conducted strictly in accordance with the Client’s documented instructions.
Item 16 – Investment Discretion
Paradiem typically has discretion over the selection and amount of securities to be bought or sold in Client
accounts without obtaining prior consent or approval from the Client. These purchases or sales are subject to
specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by
Paradiem. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such
authority will be evidenced by the Client's execution of an investment advisory agreement containing all
applicable limitations to such authority. All discretionary trades made by Paradiem will be in accordance with
each Client's investment objectives and goals.
Item 17 – Voting Client Securities
Paradiem accepts proxy-voting responsibility for securities held in Client accounts when provided by the Client.
The advisory agreement between Paradiem and the Client will generally specify whether or not Paradiem has the
authority to vote proxies on behalf of a particular Client.
Proxy Voting Policy and Procedures
Paradiem shall vote proxies in the best interest of its Clients and shall not subrogate the Client’s interest to its
own. Paradiem monitors corporate actions through the Custodian. Paradiem receives notice of upcoming proxy
votes, meeting and record dates, and other information on upcoming corporate actions by companies in which
Paradiem Clients are shareholders. Clients may request a copy of Paradiem’s proxy voting records free of charge
by contacting Paradiem.
Conflicts of Interest in the Voting Process
On occasion, a conflict of interest may exist between the Advisor and the client regarding the outcome of certain
proxy votes. In such cases, the Advisor is committed to resolving the conflict in the best interest of the Clients
before voting for the proxy in question.
Client Direction of Voting
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770|Fax: (985) 612-7007
Page 24
www.paradiem.org
Although most of Paradiem’s Clients for whom the Advisor votes proxies authorize Paradiem to vote in
accordance with its proxy voting policy, a Client may request that the Advisor votes its proxies in accordance with
a different policy. The Advisor will try to accommodate such requests.
In addition, a Client may direct Paradiem to votes its securities in a particular way on a particular proposal, and
the Advisor will seek to do so, assuming timely receipt of the instruction.
Item 18 – Financial Information
Neither Paradiem, nor its management, have any adverse financial situations that would reasonably impair the
ability of Paradiem to meet all obligations to its Clients. Neither Paradiem, nor any of its Advisory Persons, have
been subject to a bankruptcy or financial compromise. Paradiem is not required to deliver a balance sheet along
with this Disclosure Brochure as the Advisor does not collect fees of $1,200 for services to be performed six months
or more in advance.
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770|Fax: (985) 612-7007
Page 25
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Paradiem, LLC
d/b/a Intentional Ownership
Form ADV Part 2A – Appendix 1
(“Wrap Fee Program Brochure”)
Effective: April 7, 2025
This Form ADV2A - Appendix 1 (“Wrap Fee Program Brochure”) provides information about the qualifications and
business practices for Paradiem, LLC d/b/a Intentional Ownership(“Paradiem” or the “Advisor”) services when
offering services pursuant to a wrap program. This Wrap Fee Program Brochure shall always be accompanied by
the Paradiem Disclosure Brochure, which provides complete details on the business practices of the Advisor. If
you did not receive the complete Paradiem Disclosure Brochure or you have any questions about the contents of
this Wrap Fee Program Brochure or the Paradiem Disclosure Brochure, please contact the Advisor at (985) 727-
0770.
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770|Fax: (985) 612-7007
Page 26
www.paradiem.org
Paradiem is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The
information in this Wrap Fee Program Brochure has not been approved or verified by the SEC or by any state
securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This
Wrap Fee Program Brochure provides information about Paradiem to assist you in determining whether to retain
the Advisor.
Additional information about Paradiem and its Advisory Persons is available on the SEC’s website at
www.adviserinfo.sec.gov by searching with our firm name or our CRD# 158200.
Item 2 – Material Changes
Form ADV 2 – Appendix 1 provides information about a variety of topics relating to an Advisor’s business
practices and conflicts of interest. In particular, this Wrap Fee Program Brochure discusses wrap fee programs
offering by the Advisor.
Material Changes
The following material changes have been made to this Disclosure Brochure since the annual amendment filing
on 3/25/2024:
● The Advisor is no longer affiliated with Halcyon Digital Asset Advisors, LLC/Halcyon Digital Asset Advisors
GP
● The Advisor is affiliated through common ownership with OxLot Capital. Please see item 10 for additional
information.
● The Advisor no longer requires a minimum investment management fee of $4,000 per year.
Future Changes
From time to time, the Advisor may amend this Wrap Fee Program Brochure to reflect changes in business
practices, changes in regulations or routine annual updates as required by the securities regulators. This complete
Wrap Fee Program Brochure (along with the complete Paradiem Disclosure Brochure) or a Summary of Material
Changes shall be provided to you annually and if a material change occurs in the business practices of Paradiem.
At any time, you may view this Wrap Fee Program Brochure and the current Disclosure Brochure on-line at the
SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s
firm name or CRD# 158200. You may also request a copy of this Disclosure Brochure at any time, by contacting
the Advisor at (985) 727-0770.
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770|Fax: (985) 612-7007
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www.paradiem.org
Item 3 – Services Fees and Compensation
Paradiem, LLC d/b/a Intentional Ownership (“Paradiem” or the “Advisor”) provides customized investment
advisory services for its Clients. This Wrap Fee Program Brochure is provided as a supplement to the Paradiem
Disclosure Brochure (Form ADV 2A). This Wrap Fee Program Brochure is provided along with the complete
Disclosure Brochure to provide full details of the business practices and fees when selecting Paradiem as your
investment advisor.
As part of the investment advisory fees noted in Item 5 – Fees and Compensation of the Disclosure Brochure,
Paradiem includes normal securities transaction fees as part of the overall investment advisory fee. Securities
regulations often refer to this combined fee structure as a “Wrap Fee Program”. The Advisor’s recommended
Custodian does not charge securities transaction fees for ETF and equity trades in a Client’s account, provided
that the account meets the terms and conditions of the Custodian’s brokerage requirements. However, the
Custodian typically charges for mutual funds and other types of investments. The Advisor sponsors the Paradiem
Wrap Fee Program.
The sole purpose of this Wrap Fee Program Brochure is to provide additional disclosure relating the combination
of securities transaction fees into the single “bundled” investment advisory fee. This Wrap Fee Program Brochure
references back to the Paradiem Disclosure Brochure in which this Wrap Fee Program Brochure serves as an
Appendix. Please see Item 4 – Advisory Services of the Disclosure Brochure for details on Paradiem’s investment
philosophy and related services.
Advisory services provided by Paradiem are offered in a wrap fee structure whereby normal securities transaction
costs are included in the overall investment advisory fee paid to Paradiem. As the level of trading in a Client’s
account[s] may vary from year to year, the annual cost to the Client may be more or less than engaging for
advisory services where the transactions costs are borne separately by the Client. The cost of the Wrap Fee
Program varies depending on services to be provided to each Client, however, the Client is not charged more if
there is higher trading activity in the Client’s account[s] or to utilize securities that do not have transaction fees.
As noted above, the Advisor’s recommended Custodian does not charge securities transaction fees for ETF and
equity trades in a Client’s account, provided that the account meets the terms and conditions of the Custodian’s
brokerage requirements. However, the Custodian typically charges for mutual funds and other types of
investments such, the Advisor is incentivized to utilize ETFs and other equity securities to limit the overall cost to
the Advisor. The Advisor will only place Client assets into a Wrap Fee Program when it is believed to be in the
Client’s best interest. Please see Item 5 – Fees and Compensation of the Disclosure Brochure for complete details
on fees.
Investment advisory fees are paid quarterly or monthly (herein the “Billing Period”), in advance of each Billing
Period, pursuant to the terms of the investment advisory agreement. Investment advisory fees are based on the
market value of assets under management at the end of the last business day of the preceding Billing Period.
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770|Fax: (985) 612-7007
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www.paradiem.org
Assets Under Management
Annual Rate (%)
Up to $1,000,000
1.50%
$1,000,001 to $5,000,000
1.25%
$5,000,001 to $10,000,000
1.00%
$10,000,001 to $30,000,000
0.75%
Over $30,000,000
0.50%
The investment advisory fee in the first quarter of service is prorated from the inception date of the account[s] to
the end of the first Billing Period. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees
will take into consideration the aggregate assets under management with Advisor. All securities held in accounts
managed by Paradiem will be independently valued by the Custodian. Paradiem will conduct periodic reviews of
the Custodian’s valuations.
As noted above, the Wrap Fee Program includes normal securities trading costs incurred in connection with the
discretionary investment management services provided by Paradiem. Securities transaction fees for Client-
directed trades may be charged back to the Client.
Clients may incur certain fees or charges imposed by third parties in connection with investments made on behalf
of the Client’s account[s]. Under this Wrap Fee Program, Paradiem includes securities transactions costs as part of
its overall investment advisory fee.
In addition, all fees paid to Paradiem for investment advisory services or part of the Wrap Fee Program are
separate and distinct from the expenses charged by mutual funds and exchange-traded funds to their
shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and
expenses will generally be used to pay management fees for the funds, other fund expenses, account
administration (e.g., custody, brokerage and account reporting), and a possible distribution fee. Additionally,
account activity fees, such as electronic funds and wire transfers fees, certificate delivery fees, markups and
markdowns, bid-ask spreads, selling concessions, and other miscellaneous fees and expenses as outlined in the
account opening paperwork executed with the Custodian, are generally charged to the Client. Clients are
encouraged to refer to the account opening paperwork executed with the Custodian for an outline of all third-
party fees not covered under this Wrap Fee Program.
Paradiem is the sponsor and portfolio manager of this Wrap Fee Program. Paradiem receives investment advisory
fees paid by Clients for participating in the Wrap Fee Program and pays the Custodian for the costs associated
with the management of the Client’s account[s].
Item 4 – Account Requirements and Types of Clients
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770|Fax: (985) 612-7007
Page 29
www.paradiem.org
Paradiem offers investment advisory services to individuals, families and charitable organizations. Paradiem has a
minimim relationship size of $350,000 per household, this minimum may be waived at the sole discretion of the
Advisor. Please see Item 7 – Types of Clients in the Disclosure Brochure for additional information.
Item 5 – Portfolio Manager Selection and Evaluation
Portfolio Manager Selection
Paradiem serves as sponsor and as portfolio manager for the services under this Wrap Fee Program.
Related Persons
Paradiem personnel serve as portfolio managers for this Wrap Fee Program. Paradiem does not serve as a
portfolio manager for any third-party wrap fee programs.
Performance-Based Fees
Paradiem does not charge performance-based fees.
Supervised Persons
Paradiem Advisory Persons serve as portfolio managers for all accounts, including the services described in this
Wrap Fee Program Brochure. Details of the advisory services provided are included in Item 4.A. of the Disclosure
Brochure.
Methods of Analysis
Please see Item 8 of the Disclosure Brochure (included with this Wrap Fee Program Brochure) for details on the
research and analysis methods employed by the Advisor.
Risk of Loss
Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients
should be prepared to bear the potential risk of loss. Paradiem will assist Clients in determining an appropriate
strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a
Client will meet their investment goals.
Each Client engagement will entail a review of the Client’s investment goals, financial situation, time horizon,
tolerance for risk and other factors to develop an appropriate strategy for managing a Client’s account[s]. Client
participation in this process, including full and accurate disclosure of requested information, is essential for the
analysis of a Client’s account[s]. The Advisor shall rely on the financial and other information provided by the
Client or their designees without the duty or obligation to validate the accuracy and completeness of the
provided information. It is the responsibility of the Client to inform the Advisor of any changes in financial
condition, goals or other factors that may affect this analysis.
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770|Fax: (985) 612-7007
Page 30
www.paradiem.org
Past performance is not a guarantee of future returns. Investing in securities and other investments involve a risk
of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with
the Advisor. Please see Item 8.B. – Risk of Loss in the Disclosure Brochure for details on investment risks.
Proxy Voting
Paradiem accepts proxy-voting responsibility for securities held in Client accounts when provided by the Client.
The advisory agreement between Paradiem and the Client will generally specify whether or not Paradiem has the
authority to vote proxies on behalf of a particular Client.
Proxy Voting Policy and Procedures
Paradiem shall vote proxies in the best interest of its Clients and shall not subrogate the Client’s interest to its
own. Paradiem monitors corporate actions through the Custodian. Paradiem receives notice of upcoming proxy
votes, meeting and record dates, and other information on upcoming corporate actions by companies in which
Paradiem Clients are shareholders. Clients may request a copy of Paradiem’s proxy voting records free of charge
by contacting Paradiem.
Conflicts of Interest in the Voting Process
On occasion, a conflict of interest may exist between the Advisor and the client regarding the outcome of certain
proxy votes. In such cases, the Advisor is committed to resolving the conflict in the best interest of the Clients
before voting for the proxy in question.
Client Direction of Voting
Although most of Paradiem’s Clients for whom the Advisor votes proxies authorize Paradiem to vote in
accordance with its proxy voting policy, a Client may request that the Advisor votes its proxies in accordance with
a different policy. The Advisor will try to accommodate such requests.
In addition, a Client may direct Paradiem to votes its securities in a particular way on a particular proposal, and
the Advisor will seek to do so, assuming timely receipt of the instruction.
Item 6 – Client Information Provided to Portfolio Managers
Paradiem is the sponsor and sole portfolio manager for the Program. The Advisor does not share Client
information with other portfolio managers because it is the sole portfolio manager for this Wrap Fee Program.
Please also see the Paradiem Privacy Policy (included after this Wrap Fee Program Brochure).
Item 7 – Client Contact with Portfolio Managers
Paradiem is a full-service investment management advisory firm. Clients always have direct access to the Portfolio
Managers at Paradiem.
Item 8 – Additional Information
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770|Fax: (985) 612-7007
Page 31
www.paradiem.org
Paradiem values the trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite
due diligence on any advisor or service provider that the Client engages. The backgrounds of the Advisor and its
Advisor Persons are on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching
for the Advisor’s firm name or CRD# 158200. Please see Item 9 of the Paradiem Disclosure Brochure as well as
Item 3 of each Advisory Person’s Brochure Supplement (included with this Wrap Fee Program Brochure) for
additional information on how to research the background of the Advisor and its Advisory Persons.
Other Financial Activities and Affiliations
Please see Item 10 – Other Financial Industry Activities and Affiliations and Item 14 – Client Referrals and Other
Compensation of the Form ADV Part 2A – Disclosure Brochure (included with this Wrap Fee Program Brochure).
Paradiem has implemented a Code of Ethics that defines our fiduciary commitment to each Client. This Code of
Ethics applies to all persons subject to Paradiem’s compliance program (“Supervised Persons”). Complete details
on the Paradiem Code of Ethics can be found under Item 11 – Code of Ethics, Participation in Client Transactions
and Personal Trading in the Disclosure Brochure (included with this Wrap Fee Program Brochure).
Review of Accounts
Investments in Client accounts are monitored on a regular and continuous basis by Advisory Persons of
Paradiem under the supervision of the Chief Compliance Officer (“CCO”). Details of the review policies and
practices are provided in Item 13 – Review of Accounts of the Form ADV Part 2A – Disclosure Brochure.
Other Compensation
Participation in Institutional Advisor Platform
The Advisor has established an institutional relationship with Schwab through its “Schwab Advisor Services” unit,
a division of Schwab dedicated to serving independent advisory firms like Paradiem. As a registered investment
advisor participating on the Schwab Advisor Services platform, Paradiem receives access to software and related
support without cost because the Advisor renders investment management services to Clients that maintain
assets at Schwab. Services provided by Schwab Advisor Services benefit the Advisor and many, but not all
services provided by Schwab will benefit Clients. In fulfilling its duties to its Clients, the Advisor endeavors at all
times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic
benefits from a custodian creates a conflict of interest since these benefits can influence the Advisor’s
recommendation of Schwab over a custodian that does not furnish similar software, systems support, or services.
Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of
investment products, execution of securities transactions, and custody of Client’s funds and securities. Through
Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be
able to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual
funds and other investments without having to adhere to investment minimums that might be required if the
Client were to directly access the investments.
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770|Fax: (985) 612-7007
Page 32
www.paradiem.org
Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to technology,
research, discounts and other services. In addition, the Advisor receives duplicate statements for Client accounts,
the ability to deduct advisory fees, trading tools, and back-office support services as part of its relationship with
Schwab. These services are intended to assist the Advisor in effectively managing accounts for its Clients but may
not directly benefit all Clients.
Services that May Only Benefit the Advisor – Schwab also offers other services and financial support to Paradiem
that may not benefit the Client, including: educational conferences and events, financial start-up support,
consulting services and discounts for various service providers. Additionally, Schwab has agreed to pay for certain
services rendered by third parties for which the Advisor would otherwise have to pay. This amount is covered
once the value of Client assets in accounts at Schwab reaches a certain size. Clients do not pay more for assets
maintained at Schwab as a result of these arrangements. However, the Advisor does benefit from the
arrangement because the cost of these services would otherwise be borne directly by the Advisor. Access to
these services and financial support creates a financial incentive for the Advisor to recommend Schwab, which
results in a conflict of interest. Paradiem believes, however, that the selection of Schwab as Custodian is in the
best interests of its Clients. Clients should consider these conflicts of interest when selecting a custodian.
Compensation for Client Referrals
Certain Clients may be referred to Paradiem by either an affiliated or unaffiliated party (herein “Promoter”) and
receive, directly or indirectly, compensation for the Client referral. In such instances, Paradiem will compensate
the Promoter a fee in accordance with Rule 206(4)-1 of the Advisers Act and any corresponding state securities
requirements. Any such compensation shall be paid solely from the investment advisory fees earned by Paradiem,
and shall not result in any additional charge to the Client.
Financial Information
Neither Paradiem, nor its management have any adverse financial situations that would reasonably impair the
ability of Paradiem to meet all obligations to its Clients. Neither Paradiem, nor any of its Advisory Persons, has
been subject to a bankruptcy or financial compromise. Paradiem is not required to deliver a balance sheet along
with this Disclosure Brochure, as the firm does not collect advance fees of $1,200 or more for services to be
performed six months or more in advance. Please see Item 18 of the Form ADV Part 2A – Disclosure Brochure.
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770|Fax: (985) 612-7007
Page 33
www.paradiem.org
Form ADV Part 2B – Brochure Supplement
for
Eric L. Dunavant
Founder & President
Effective: April 7, 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Eric
L. Dunavant (CRD# 3255295) in addition to the information contained in the Paradiem, LLC d/b/a Intentional
Ownership (“Paradiem” or the “Advisor”) Disclosure Brochure (contained herein). If you have not received a copy
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770|Fax: (985) 612-7007
Page 34
www.paradiem.org
of this Brochure Supplement or if you have any questions about the contents of this Brochure Supplement or
Paradiem’s Disclosure Brochure, please contact the Advisor at (985) 727-0770.
Additional information about Eric L. Dunavant is available on the SEC’s Investment Adviser Public Disclosure
website at www.adviserinfo.sec.gov.
Item 2 – Educational Background and Business Experience
The President of Paradiem is Eric L. Dunavant. Mr. Dunavant, born in 1973. Mr. Dunavant earned a B.S. -
Agribusiness from Texas A&M University in College Station, TX in 1996. Additional information regarding Mr.
Dunavant’s employment history is included below.
Employment History:
Founder & President
09/2019 to Present
Paradiem, LLC d/b/a Intentional Ownership
-
-
President and Chief Compliance Officer
06/2011 to 09/2019
Registered Representative, LPL Financial LLC
11/2007 to 05/2017
Investment Advisor Representative, LPL Financial LLC
11/2007 to 10/2011
Registered Representative, Charles Schwab & Co, Inc.
06/1999 to 11/2007
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Dunavant. Mr. Dunavant has never been
involved in any regulatory, civil or criminal action. There have been no Client complaints, lawsuits, arbitration
claims or administrative proceedings against Mr. Dunavant. Securities laws require an advisor to disclose any
instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil or
arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions;
theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or
dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or disciplinary events to
disclose regarding Mr. Dunavant. However, we do encourage you to independently view the background of Mr.
Dunavant on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his
full name or his CRD# 3255295.
Item 4 – Other Business Activities
Insurance Agency Affiliations
Mr. Dunavant is also a licensed insurance professional through Paradiem. These services are separate and distinct
from the advisory services offered to Clients. Paradiem may include these as part of its overall investment
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770|Fax: (985) 612-7007
Page 35
www.paradiem.org
process. However, these are provided as a separate service and fee, which is based on the unique needs of each
Client. As an insurance professional, Mr. Dunavant will receive customary commissions and other related
revenues from the insurance companies whose products are sold. Mr. Dunavant is not required to offer the
products of any particular insurance company. Commissions generated by insurance sales do not offset regular
advisory fees. This practice presents a conflict of interest in recommending certain products of the insurance
companies. Clients always have the right to choose whether to implement any recommendations made by Mr.
Dunavant or the Advisor.
IC4 Coaching and Consulting LLC d/b/a Kingdom ROI Coaching and Consulting
Mr. Dunavant is the owner of IC4 Coaching and Consulting LLC d/b/a Kingdom ROI Coaching and Consulting
(“IC4”). IC4 offers coaching and consulting services in an effort to create life and generational impact through
wisdom and communication. Mr. Dunavant serves as the Kingdom ROI Strategist for IC4. Clients of Paradiem may
be engaged for these services outside the scope of their asset management agreement with Paradiem. This
presents a conflict of interest, as Mr. Dunavant may be incentivized to recommend to Clients of Paradiem that
they engage with IC4 for an additional fee.
Paradiem Strategies
Mr. Dunavant also serves as the Co-Owner and President of Paradiem Strategies. Paradiem Strategies provides
coaching, consulting, and strategic planning services directly to businesses. These services are separate and
distinct from the advisory services offered to Clients of Paradiem. Clients of Paradiem may be engaged for these
services outside the scope of their asset management agreement with Paradiem. This presents a conflict of
interest, as Mr. Dunavant may be incentivized to recommend to Clients of Paradiem that they engage with
Paradiem Strategies for an additional fee.
Odyssey
Mr. Dunavant is a part owner and board member of Odyssey, an organization with the mission “to train and lead
men”. For his role in the firm, Mr. Dunavant assists in sales, service, and training. Mr. Dunavant spends 5 hours per
month in this capacity and is not currently compensated for his position.
Kingdom Signet
Mr. Dunavant is a part owner, insurance agent, and CEO of Kingdom Signet, a life insurance company.
For his role in the firm, Mr. Dunavant oversees the organization and sells insurance. Mr. Dunavant spends 10
hours per month in this capacity and receives compensation for his position through commission on personal
insurance sales and company sales.
OxLot Capital
Mr. Dunavant is a part owner of OxLot Capital. OxLot is currently an inactive entity.
Item 5 – Additional Compensation
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770|Fax: (985) 612-7007
Page 36
www.paradiem.org
Mr. Dunavant has additional business activities where compensation is received, which are detailed in Item 4
above.
Item 6 – Supervision
Mr. Dunavant serves as the President of Paradiem and is supervised by Ray Marie Fenger, the Chief Compliance
Officer. Ms. Fenger can be reached at (985) 727-0770.
Paradiem has implemented a Code of Ethics, an internal compliance document that guides each Supervised
Person in meeting their fiduciary obligations to Clients of Paradiem. Further, Paradiem is subject to regulatory
oversight by various agencies. These agencies require registration by Paradiem and its Supervised Persons. As a
registered entity, Paradiem is subject to examinations by regulators, which may be announced or unannounced.
Paradiem is required to periodically update the information provided to these agencies and to provide various
reports regarding the business activities and assets of the Advisor.
Form ADV Part 2B – Brochure Supplement
for
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770|Fax: (985) 612-7007
Page 37
www.paradiem.org
Carl W. Drury
Senior Planning Strategist
Effective: April 7, 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Carl
W. Drury (CRD# 6063550) in addition to the information contained in the Paradiem, LLC d/b/a Intentional
Ownership (“Paradiem” or the “Advisor”) (CRD # 158200) Disclosure Brochure. If you have not received a copy of
the Disclosure Brochure or if you have any questions about the contents of the Paradiem Disclosure Brochure or
this Brochure Supplement, please contact the Advisor at (985) 727-0770.
Additional information about Mr. Drury is available on the SEC’s Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov.
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770|Fax: (985) 612-7007
Page 38
www.paradiem.org
Item 2 – Educational Background and Business Experience
Carl W. Drury is the Senior Planning Strategist for Paradiem. Mr. Drury, born in 1964, is dedicated to advising
Clients of Paradiem. Mr. Drury earned a Bachelor of Science Mechanical Engineering from Purdue University in
1989. Additional information regarding Mr. Drury’s employment history is included below.
Employment History:
Senior Planning Strategist
03/2025 to Present
President of Transformation
09/2018 to 03/2025
Paradiem, LLC d/b/a Intentional Ownership
-
-
-
Vice President of Planning
07/2014 to 09/2018
VP & COO, Kardia, Inc.
04/2007 to 07/2014
General Manager Filament Bearings, Rexnord
09/1989 to 04/2007
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Drury. Mr. Drury has never been involved
in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims or
administrative proceedings against Mr. Drury. Securities laws require an advisor to disclose any instances where
the advisor or its advisory persons have been found liable in a legal, regulatory, civil or arbitration matter that
alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or
wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical
practices. As previously noted, there are no legal, civil or disciplinary events to disclose regarding Mr. Drury.
However, we do encourage you to independently view the background of Mr. Drury on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his CRD# 6063550.
Item 4 – Other Business Activities
Mr. Drury is dedicated to the advisory activities of Paradiem’s Clients. Mr. Drury does not have any other business
activities.
Item 5 – Additional Compensation
Mr. Drury is dedicated to the advisory activities of Paradiem’s Clients. Mr. Drury does not receive any additional
forms of compensation.
Item 6 – Supervision
Mr. Drury serves as the Senior Planning Strategist of Paradiem and is supervised by Ray Marie Fenger, the Chief
Compliance Officer. Ms. Fenger can be reached at (985) 727-0770.
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770|Fax: (985) 612-7007
Page 39
www.paradiem.org
Paradiem has implemented a Code of Ethics and internal compliance that guide each Supervised Person in
meeting their fiduciary obligations to Clients of Paradiem. Further, Paradiem is subject to regulatory oversight by
various agencies. These agencies require registration by Paradiem and its Supervised Persons. As a registered
entity, Paradiem is subject to examinations by regulators, which may be announced or unannounced. Paradiem is
required to periodically update the information provided to these agencies and to provide various reports
regarding the business activities and assets of the Advisor.
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770|Fax: (985) 612-7007
Page 40
www.paradiem.org
Form ADV Part 2B – Brochure Supplement
for
Danielle R. Wauchope
Chief Planning Strategist
Effective: April 7, 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Danielle R. Wauchope (CRD# 6362274) in addition to the information contained in the Paradiem, LLC d/b/a
Intentional Ownership (“Paradiem” or the “Advisor”) (CRD # 158200) Disclosure Brochure. If you have not received
a copy of the Disclosure Brochure or if you have any questions about the contents of the Paradiem Disclosure
Brochure or this Brochure Supplement, please contact the Advisor at (985) 727-0770.
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770|Fax: (985) 612-7007
Page 41
www.paradiem.org
Additional information about Mrs. Wauchope is available on the SEC’s Investment Adviser Public Disclosure
website at www.adviserinfo.sec.gov.
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770|Fax: (985) 612-7007
Page 42
www.paradiem.org
Item 2 – Educational Background and Business Experience
Danielle R. Wauchope is a Vice President of Family Transformation with Paradiem. Mrs. Wauchope, born in 1985,
is dedicated to advising Clients of Paradiem. Mrs. Wauchope earned a Bachelor of Science in Management and
Business Administration from Indiana Wesleyan University in 2007. Additional information regarding Mrs.
Wauchope’s employment history is included below.
Employment History:
Chief Planning Strategist
01/2025 to Present
Vice President of Financial Transformation
09/2018 to 01/2025
Paradiem, LLC d/b/a Intentional Ownership
-
-
-
Financial Planner
07/2014 to 09/2018
Financial Planner, Kardia, Inc.
1/2008 to 07/2014
Swing Manager, McDonalds
12/1999 to 12/2007
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mrs. Wauchope. Mrs. Wauchope has never
been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration
claims or administrative proceedings against Mrs. Wauchope. Securities laws require an advisor to disclose any
instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil or
arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions;
theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or
dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or disciplinary events to
disclose regarding Mrs. Wauchope. However, we do encourage you to independently view the background of
Mrs. Wauchope on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching her
full name or her CRD# 6362274.
Item 4 – Other Business Activities
Mrs. Wauchope is dedicated to her church and is heavily active in the church community. This is a volunteer
position and is not compensated for her work.
Item 5 – Additional Compensation
Mrs. Wauchope has additional business activities where no compensation is received, which are detailed in Item 4
above.
Item 6 – Supervision
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770|Fax: (985) 612-7007
Page 43
www.paradiem.org
Mrs. Wauchope serves as the Vice President, Family Planning and is supervised is supervised by Ray Marie Fenger,
the Chief Compliance Officer. Ms. Fenger can be reached at (985) 727-0770.
Paradiem has implemented a Code of Ethics, and internal compliance document that guide each Supervised
Person in meeting their fiduciary obligations to Clients of Paradiem. Further, Paradiem is subject to regulatory
oversight by various agencies. These agencies require registration by Paradiem and its Supervised Persons. As a
registered entity, Paradiem is subject to examinations by regulators, which may be announced or unannounced.
Paradiem is required to periodically update the information provided to these agencies and to provide various
reports regarding the business activities and assets of the Advisor.
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770|Fax: (985) 612-7007
Page 44
www.paradiem.org
Form ADV Part 2B – Brochure Supplement
for
Russell L. Riggs
Chief Business Strategist
Effective: April 7, 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Russell L. Riggs (CRD# 6733790) in addition to the information contained in the Paradiem, LLC d/b/a Intentional
Ownership (“Paradiem” or the “Advisor”, CRD# 158200) Disclosure Brochure. If you have not received a copy of
the Disclosure Brochure or if you have any questions about the contents of the Paradiem Disclosure Brochure or
this Brochure Supplement, please contact the Advisor at (985) 727-0775.
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770|Fax: (985) 612-7007
Page 45
www.paradiem.org
Additional information about Mr. Riggs is available on the SEC’s Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 6733790.
Item 2 – Educational Background and Business Experience
Russell L. Riggs, born in 1985, is dedicated to advising Clients of Paradiem as the Vice President of Business
Transformation. Mr. Riggs earned a Bachelor of Arts in Business Administration from Southwestern Assemblies of
God University in 2007. Additional information regarding Mr. Riggs’s employment history is included below.
Employment History:
Chief Business Strategist, Paradiem, LLC d/b/a Intentional
12/2016 to Present
Ownership
Insurance Agent, Independent Insurance Producer
10/2015 to Present
District Manager, Avis Budget Group
12/2010 to 10/2015
Corporate Relations Director, D-Tabb Associates
04/2009 to 09/2010
Supervisor, Cole Haan
03/2008 to 04/2009
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Riggs. Mr. Riggs has never been involved
in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims or
administrative proceedings against Mr. Riggs.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no
legal, civil or disciplinary events to disclose regarding Mr. Riggs.
However, we do encourage you to independently view the background of Mr. Riggs on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD#
6733790.
Item 4 – Other Business Activities
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770|Fax: (985) 612-7007
Page 46
www.paradiem.org
Insurance Agency Affiliations
Mr. Riggs is also licensed insurance professional through Paradiem. These services are separate and distinct from
the advisory services offered to Clients. Paradiem may include these as part of its overall investment process.
However, these are provided as a separate service and fee, which is based on the unique needs of each Client. As
an insurance professional, Mr. Riggs will receive customary commissions and other related revenues from the
insurance companies whose products are sold. Mr. Riggs is not required to offer the products of any particular
insurance company. Commissions generated by insurance sales do not offset regular advisory fees. This practice
presents a conflict of interest in recommending certain products of the insurance companies. Clients always have
the right to choose whether to implement any recommendations made by Mr. Riggs or the Advisor.
Paradiem Strategies
Mr. Riggs also serves as the President of Paradiem Strategies. Paradiem Strategies provides coaching, consulting,
and strategic planning services directly to businesses. These services are separate and distinct from the advisory
services offered to Clients of Paradiem. Clients of Paradiem may be engaged for these services outside the scope
of their asset management agreement with Paradiem. This presents a conflict of interest, as Mr. Riggs may be
incentivized to recommend to Clients of Paradiem that they engage with Paradiem Strategies for an additional
fee.
Item 5 – Additional Compensation
Mr. Riggs has additional business activities where compensation is received, which are detailed in Item 4 above.
Item 6 – Supervision
Mr. Riggs serves as Vice President of Business Transformation of Paradiem and is supervised by Ray Marie
Fenger, the Chief Compliance Officer. Ms. Fenger can be reached at (985) 727-0770.
Paradiem has implemented a Code of Ethics, and internal compliance document that guides each Supervised
Person in meeting their fiduciary obligations to Clients of Paradiem. Further, Paradiem is subject to regulatory
oversight by various agencies. These agencies require registration by Paradiem and its Supervised Persons. As a
registered entity, Paradiem is subject to examinations by regulators, which may be announced or unannounced.
Paradiem is required to periodically update the information provided to these agencies and to provide various
reports regarding the business activities and assets of the Advisor.
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770|Fax: (985) 612-7007
Page 47
www.paradiem.org
Form ADV Part
2B – Brochure Supplement
for
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770|Fax: (985) 612-7007
Page 48
www.paradiem.org
Kristina B. Schuler, CRPC®
Chief Advisor
Effective: April 7, 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Kristina B. Schuler, CRPC® (CRD# 5735165) in addition to the information contained in the Paradiem, LLC d/b/a
Intentional Ownership (“Paradiem” or the “Advisor”, CRD# 158200) Disclosure Brochure. If you have not received
a copy of the Disclosure Brochure or if you have any questions about the contents of the Paradiem Disclosure
Brochure or this Brochure Supplement, please contact us at (985) 727-0770.
Additional information about Mrs. Schuler is available on the SEC’s Investment Adviser Public Disclosure website
at www.adviserinfo.sec.gov by searching with her full name or her Individual CRD# 5735165.
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770|Fax: (985) 612-7007
Page 49
www.paradiem.org
Item 2 – Educational Background and Business Experience
Kristina B. Schuler, CRPC®, born in 1985, is dedicated to advising Clients of Paradiem as Chief Investment Officer,
Lead Advisor. Mrs. Schuler earned a Bachelor of Science degree in Finance from University of Phoenix in 2008.
Additional information regarding Mrs. Schuler’s employment history is included below.
Employment History:
Chief Advisor
01/2025 to Present
Chief Investment Officer, Lead Advisor
11/2023 to 01/2025
VP, Investment Strategy, Lead Advisor
08/2022 to 10/2023
Paradiem, LLC d/b/a Intentional Ownership
-
-
-
-
Associate Advisor
04 2021 to 08/2022
Wealth Platform Manager, Hancock Whitney
03/2020 to 03/2021
Client Services Manager, Edelman Financial Engines
06/2014 to 03/2020
Government Insuring Specialist/Appraisal Coordinator, NOLA Lending Group
08/2012 to 06/2013
Deputy Compliance Officer, Pritchard Capital Partners
10/2010 to 06/2012
Chartered Retirement Planning Counselor (“CRPC ®”)
Individuals who hold the CRPC® designation have completed a course of study encompassing pre-and post-
retirement needs, asset management, estate planning and the entire retirement planning process using models
and techniques from real client situations. Additionally, individuals must pass an end-of-course examination that
tests their ability to synthesize complex concepts and apply theoretical concepts to real-life situations. All
designees have agreed to adhere to Standards of Professional Conduct and are subject to a disciplinary process.
Designees renew their designation every two-years by completing 16 hours of continuing education, reaffirming
adherence to the Standards of Professional Conduct and complying with self-disclosure requirements.
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mrs. Schuler. Mrs. Schuler has never been
involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration
claims or administrative proceedings against Mrs. Schuler.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no
legal, civil or disciplinary events to disclose regarding Mrs. Schuler.
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770|Fax: (985) 612-7007
Page 50
www.paradiem.org
However, we do encourage you to independently view the background of Mrs. Schuler on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with her full name or her Individual CRD#
5735165.
Item 4 – Other Business Activities
Mrs. Schuler is dedicated to the investment advisory activities of Paradiem’s Clients. Mrs. Schuler does not have
any other business activities.
Item 5 – Additional Compensation
Mrs. Schuler is dedicated to the investment advisory activities of Paradiem’s Clients. Mrs. Schuler does not receive
any additional forms of compensation.
Item 6 – Supervision
Mrs. Schuler serves as a Chief Investment Officer& Lead Advisor and is supervised by Ray Marie Fenger, the Chief
Compliance Officer. Ms. Fenger can be reached at (985) 727-0770.
Paradiem has implemented a Code of Ethics, an internal compliance document that guides each Supervised
Person in meeting their fiduciary obligations to Clients of Paradiem. Further, Paradiem is subject to regulatory
oversight by various agencies. These agencies require registration by Paradiem and its Supervised Persons. As a
registered entity, Paradiem is subject to examinations by regulators, which may be announced or unannounced.
Paradiem is required to periodically update the information provided to these agencies and to provide various
reports regarding the business activities and assets of the Advisor.
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770|Fax: (985) 612-7007
Page 51
www.paradiem.org
Form ADV Part 2B – Brochure Supplement
for
Stephen L. Mikell
Financial Planning Advisor
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770|Fax: (985) 612-7007
Page 52
www.paradiem.org
Effective: April 7, 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Stephen L. Mikell (CRD# 8017427) in addition to the information contained in the Paradiem, LLC d/b/a Intentional
Ownership (“Paradiem” or the “Advisor”, CRD# 158200) Disclosure Brochure. If you have not received a copy of
the Disclosure Brochure or if you have any questions about the contents of the Paradiem Disclosure Brochure or
this Brochure Supplement, please contact us at (985) 727-0770.
Additional information about Dr. Mikell is available on the SEC’s Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 8017427.
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770|Fax: (985) 612-7007
Page 53
www.paradiem.org
Item 2 – Educational Background and Business Experience
Stephen L. Mikell, born in 1968, is dedicated to advising Clients of Paradiem as a Financial Planning Advisor. Dr.
Mikell earned his M.D. from University of South Florida in 1997. Dr. Mikell also earned his Bachelor of Science
Degree in Industrial and Systems Engineering from University of Florida in 1991. Additional information regarding
Dr. Mikell’s employment history is included below.
Employment History:
Financial Planning Advisor, Paradiem, LLC
12/2024 to Present
Pediatrician, Medstaff National Medical Staffing
08/2023 to 09/2024
Pediatrician, Children's Hospital New Orleans / LCMC
01/2009 to 04/2023
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Dr. Mikell. Dr. Mikell has never been involved
in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims or
administrative proceedings against Dr. Mikell.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no
legal, civil or disciplinary events to disclose regarding Dr. Mikell.
However, we do encourage you to independently view the background of Dr. Mikell on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD#
8017427.
Item 4 – Other Business Activities
Dr. Mikell is dedicated to the investment advisory activities of Paradiem’s Clients. Dr. Mikell does not have any
other business activities.
Item 5 – Additional Compensation
Dr. Mikell is dedicated to the investment advisory activities of Paradiem’s Clients. Dr. Mikell does not receive any
additional forms of compensation.
Item 6 – Supervision
Dr. Mikell serves as a Financial Planning Advisor of Paradiem and is supervised by Ray Marie Fenger, the Chief
Compliance Officer. Ms. Fenger can be reached at (985) 727-0770.
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770|Fax: (985) 612-7007
Page 54
www.paradiem.org
Paradiem has implemented a Code of Ethics, an internal compliance document that guides each Supervised
Person in meeting their fiduciary obligations to Clients of Paradiem. Further, Paradiem is subject to regulatory
oversight by various agencies. These agencies require registration by Paradiem and its Supervised Persons. As a
registered entity, Paradiem is subject to examinations by regulators, which may be announced or unannounced.
Paradiem is required to periodically update the information provided to these agencies and to provide various
reports regarding the business activities and assets of the Advisor
Privacy Policy
Effective: April 7, 2025
Our Commitment to You
Paradiem, LLC d/b/a Intentional Ownership (“Paradiem” or the “Advisor”) is committed to safeguarding the use of
your personal information that we have as your Investment Advisor. Paradiem (referred to as "we", "our" and
"us") protects the security and confidentiality of the personal information we have and make efforts to ensure
that such information is used for proper business purposes in connection with the management or servicing of
your account. Our relationship with you is our most important asset. We understand that you have entrusted us
with your private information, and we do everything we can to maintain that trust.
We do not sell your non-public personal information to anyone. Nor does Paradiem provide such information to
others except for discrete and proper business purposes in connection with the servicing and management of
your account as discussed below.
Details of our approach to privacy and how your personal non-public information is collected and used are set
forth in this privacy policy.
The Information We Collect About You
You typically provide personal information when you complete the paperwork required to become our Client.
This information may include your:
• Name and address
• Assets
• E-mail address[es]
• Income
• Phone number[s]
• Account balance
• Social security or taxpayer identification number
• Investment activity
• Accounts at other institutions
In addition, we may collect non-public information about you from the following sources:
●
Information we receive on Brokerage Agreements, Managed Account Agreements and other Subscription
and Account Opening Documents;
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770|Fax: (985) 612-7007
Page 55
www.paradiem.org
●
Information we receive in the course of establishing a customer relationship including, but not limited to,
applications, forms, and questionnaires;
●
Information about your transactions with us or others
Information About You That Paradiem Shares
Paradiem works to provide products and services that benefit our customers. We may share non-public personal
information with non-affiliated third parties (such as brokers and custodians) as necessary for us to provide
agreed services and products to you consistent with applicable law. We may also disclose non-public personal
information to other financial institutions with whom we have joint business arrangements for proper business
purposes in connection with the management or servicing of your account. In addition, your non-public personal
information may also be disclosed to you, persons we believe to be your authorized agent or representative,
regulators in order to satisfy Paradiem’s regulatory obligations, and is otherwise required or permitted by law.
Lastly, we may disclose your non-public personal information to companies we hire to help administrate our
business. Companies we hire to provide services of this kind are not allowed to use your personal information for
their own purposes and are contractually obligated to maintain strict confidentiality. We limit their use of your
personal information to the performance of the specific service we have requested.
To repeat, we do not sell your non-public personal information to anyone.
Information About Former Clients
Paradiem does not disclose, and does not intend to disclose, non-public personal information to non-affiliated
third parties with respect to persons who are no longer our clients.
Confidentiality and Security
Our employees are advised about the firm's need to respect the confidentiality of our customers' non-public
personal information. Additionally, we maintain physical, procedural and electronic safeguards in an effort to
protect the information from access by unauthorized parties.
We'll Keep You Informed
We will send you notice of our privacy policy annually for as long as you maintain an ongoing relationship with
us. Periodically we may revise our privacy policy and will provide you with a revised policy if the changes
materially alter the previous privacy policy. We will not, however, revise our privacy policy to permit the sharing of
non-public personal information other than as described in this notice unless we first notify you and provide you
with an opportunity to prevent the information sharing. You may obtain a copy of our current privacy policy by
contacting us at (985) 727-0770.
Paradiem, LLC
d/b/a Intentional Ownership
510 N Jefferson, Covington, LA 70433
Phone: (985) 727-0770|Fax: (985) 612-7007
Page 56
www.paradiem.org