EMPOWER ANNUITY INSURANCE COMPANY

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Participation or late rest in Clio m Transactions _. Aff flaw E'FSJ effects Securities Transaction forAdvisory Clients Registered representatives of EFSI may provide wholesaling, direct sales, enrollment, and/or communication services to retirement plans and their participants for which EAG may also provide Its services. In return, EFSI may ... recelve fees from elther the plan or the investment prodder (fund famllles): All securities transactions which occur -' as aresult of EAG's services, as described in this Brochure, are executed by EFSI: EFSI may receive compensation In the form of 12b-1 fees or other compensation from mutual fund companies or from the other Investments that may be available as plan Investment options. In all instances, EAG's affllfation with these entities is disclosed. Allocations In the Investment options are solely determined and based on Morningstar Investment Management's software and notdetermiriations made by EAG. The compensation paid by EAC to Morningstar Investment Managementfor Morningstar Investment Management's proprietary safiwore advise program does not vary based on the .. allocations made or recommended by Morningstar Investment Management'. Because Morningstar Investment Management Isunaffiliatedwith EAG and FPSI, EAG does not believe there is a conflictof Interest, Affiliate EAlCor"INV proprietary lnustmeitts +r Investment options Into which partidpantor accountholder assets maybe allocated, pursuantto the CA or the MA __ .. services may be through a fixed and variable deferred annuity issued by EAIC or ELAINY. Because Morningstar Investment Management is unaffiliated with EAG, EAIC, EIAINY andtheiraffliates, EAG does not believe there Is a conflict of Interest. However, In all Instances, EAG's afRllation with EAIC and/or EAIC's affiliates, as applicable, will be. disclosed, Item 12- Brukorase Practices Brokerage Selection; Bast Execution - For retirement plans, the plan sponsor or Its agent selects the broker -dealer used by the retirement plan and ... determines the reasonableness of the compensation. EAG does not select or recommend broker -dealers for stock transactions or self -directed brokerage accounts and does not determine the reasonableness of broker -dealer's compensatioia. Transactions recommended by Morningstar Investment Managementfc r the Service are processed by EAG's affiliated recordkeepeq Empower, and generally executed through EFSI. Soft Dollar Practices As a matter of polity, EAG does not itillre research or other products or,oIces from third parties in connection with client securltrm transactions on a soft -dollar commission basis. Directed Brokerage The plan sponsor may elect in offer brokerage services to participants in the retirement plan. EAG does not participate in such decisions and does not provide recommended portfolios or investment recommendations on assets held Ina brokerage account under the retirement plan - Trade Aggregation • 1 - - - - EAG does not bunch orders or engage in block trades to execute equity orders for clients. Client accounts are generally held in trust per regulatory requirements. Further, rnost trades aremutual funds where trade aggregation does provide anyadditional cifedttienefIts. - - Itom13-Review, of Accounts At least annually, EAG personnel review the methodologies used by Morningstar Investment Management to powar -- the OIG, OA, and MA services to enmure that they are consistent with Investment advisory best practices, currant - technology, applicable law, and the terms of the agreement between EAG and Morningstar Investment Management, Neither EAG nor Morningstar Investment Management review the personal financial Information of participant: as - provided by the participants or the Plan Sponsor and do not assume responsibility for any Incomplete or erroneous 17 City Council _____ 19 — 95 9/19/2023