Empower Advisory Group, LLC

Item 1 – Cover Page EMPOWER ADVISORY GROUP, LLC (EAG) Disclosure Brochure for Online Advice & Managed Account Services for Empower Premier IRA 8515 East Orchard Road Greenwood Village, CO 80111 Telephone: 866-317-6586 March 31, 2026 This Brochure provides information about the qualifications and business practices of Empower Advisory Group, LLC (EAG). Specifically, this Brochure provides information on the qualifications and business practices for the advisory services provided by EAG and sub-advised by Morningstar Investment Management, LLC (Morningstar Investment Management). If you have any questions about the contents of this Brochure, please contact us at 866-317-6586. The information in this Brochure has not been approved or verified by the Securities and Exchange Commission (SEC) or by any state securities authority. EAG is a registered investment adviser under the Investment Advisers Act of 1940 (Advisers Act). Registration of EAG does not imply any level of skill or training. Additional information about EAG is available on the SEC website at https://adviserinfo.sec.gov or at https://empower.com/eag. The SEC’s web site also provides information about any person affiliated with EAG who is registered, or is required to be registered, as an investment adviser representative with EAG. Item 2 – Material Changes This section of the Brochure highlights and discusses any changes that were made since the Adviser’s last update on September 19, 2025. A material change was made to Item 10 and Item 14 to describe changes to representative compensation. 1  Item 3 – Table of Contents Item 1 – Cover Page ...................................................................................................................................................... 1 Item 2 – Material Changes ............................................................................................................................................ 1 Item 3 – Table of Contents ............................................................................................................................................ 2 Item 4 – Advisory Business ........................................................................................................................................... 3 Item 5 – Fees and Compensation .................................................................................................................................. 6 Item 6 – Performance-Based Fees and Side-by-Side Management .............................................................................. 7 Item 7 – Types of Clients ............................................................................................................................................... 7 Item 8 – Methods of Analysis and Investment Strategies and Risk of Loss................................................................... 7 Item 9 – Disciplinary Information ................................................................................................................................. 9 Item 10 – Other Financial Industry Activities and Affiliations ..................................................................................... 10 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .............................. 13 Item 12 – Brokerage Practices Brokerage Selection; Best Execution ......................................................................... 14 Item 13 – Review of Accounts ..................................................................................................................................... 14 Item 14 – Client Referrals and Other Compensation .................................................................................................. 15 Item 15 – Custody ....................................................................................................................................................... 15 Item 16 – Investment Discretion ................................................................................................................................. 15 Item 17 – Voting Client Securities ............................................................................................................................... 16 Item 18 – Financial Information .................................................................................................................................. 16 2  Item 4 – Advisory Business Description of Advisory Firm EAG has been a registered investment adviser under the Advisers Act since 2000. EAG is also registered in all fifty states, the District of Columbia, Guam, U.S. Virgin Islands, and Puerto Rico. EAG offers investment management and advisory services to plan sponsors of employer-sponsored retirement plans such as 401(a), 401(k), 403(b) and 457 plans, including government entities and their participants, and to all account holders of the Empower Premier IRA (IRA holder or account holder). EAG does not choose the investments offered in employer-sponsored retirement plans or IRAs. EAG serviced plans receive recordkeeping services through Empower Retirement, LLC (Empower), the recordkeeping entity affiliated with EAG. EAG also offers investment management services to individuals and to retail brokerage account holders. More information about EAG’s services, including an applicable brochure, can be obtained by contacting EAG at the number provided on the cover page of this Brochure or by visiting EAG’s website at: https://empower.com/eag. EAG is a wholly owned subsidiary of Empower Services Holdings US, LLC (ESH US), a holding company domiciled in the State of Delaware. Empower Annuity Insurance Company of America (EAICA) owns ESH US. EAICA is a direct wholly owned subsidiary of Empower Holdings, LLC (EHL), a Delaware holding company. EHL is a direct wholly owned subsidiary of Great-West Lifeco U.S. LLC (Lifeco U.S.) and an indirect wholly owned subsidiary of Great-West Lifeco Inc. (Lifeco), a Canadian holding company. Lifeco is a subsidiary of Power Financial Corporation (Power Financial), a Canadian holding company with substantial interests in the financial services industry. Power Corporation of Canada (Power Corporation), a Canadian holding and management company, has voting control of Power Financial. The Desmarais Family Residuary Trust has voting control of Power Corporation, through a group of private holding companies that it controls. Types of Services Discussed in this Brochure: EAG provides a range of investment services directly to account holders and plan participants, as well as services provided indirectly through private-label arrangements with institutional partners (collectively, the Services). The Services include Online Advice (OA) and the Managed Account service (MA Service), also known as My Total Retirement (MTR). Other services that may be available to account holders include Spend-Down Advice, Financial Planning Service and Retirement Income Projection Tools and Services. EAG provides its Services through a proprietary, computer-based software program that Morningstar Investment Management developed and maintains. In addition, EAG provides sub-advisory and technology services to outside adviser firms through a service called Advisor Managed Accounts (AMA). This service enables the AMA firms to offer their own investment advisory and management services within retirement plans serviced by Empower. There is no guarantee provided by any party that participation in any of the advisory services will result in a profit. Morningstar Investment Management LLC: Morningstar Investment Management is a registered investment adviser wholly owned by Morningstar, Inc.; it is not affiliated with EAG or any company that is affiliated with EAG. Morningstar Investment Management is in Chicago, Illinois. A copy of its Form ADV Part 2A brochure may be obtained at https://adviserinfo.sec.gov. Morningstar Investment Management serves as an independent financial expert (IFE) in accordance with the Department of Labor SunAmerica Advisory Opinion 2001-09A, dated December 14, 2001. Morningstar Investment Management uses its proprietary methodology to evaluate the available investment options in a retirement plan, retail brokerage account or IRA and to develop an individualized investment strategy for plan participants and account holders. The plan, plan sponsor, plan fiduciary or IRA provider must select and continuously maintain investment options that cover broad asset categories. The investment options selected for the plan or IRA generally consist of a broad range of asset classes. More information is provided under Item 10 – Other Financial Industry Affiliations. Item 8, Methods of Analysis and Investment Strategies and Risk of Loss discusses the general risks of investing. The risks associated with the investment options can vary significantly with each particular investment category and the relative risks of categories may change. Accordingly, EAG may make changes from time to time regarding the availability of investment options. This Brochure discusses in greater detail below the fees, risks, responsibilities of plan provider/account holder and limitations for each of these services. Each mutual fund option has its own fees and expenses, as detailed in each fund’s prospectus. Certain EAG’s Services rely on Morningstar Investment Management’s proprietary methodology, which is based on a review of available quantitative data to analyze and screen the investment options within a plan or IRA. Morningstar Investment Management also applies qualitative analysis by investment professionals, such as evaluations of investment managers, portfolios, and individual investments. The primary sources of information used by Morningstar Investment Management are the extensive databases and methodologies of Morningstar Investment Management and/or its affiliates, and interviews with 3  investment managers. Other sources include financial publications, annual reports, prospectuses, press releases, and SEC filings. Morningstar Investment Management combines this information with other factors — including actuarial data, stock market exposure, probability analysis, and mean-variance optimization — into its proprietary software program to analyze a complex set of market data and variables. The result is an advanced model capable of providing investment recommendations and projections of different outcomes. Using this model, Morningstar Investment Management develops an investment strategy tailored to each account holder’s investment goals. Online Advice (OA) 1. OA is based on the software program developed by Morningstar Investment Management. It provides each account holder with retirement goal forecasting advice and fund-specific asset allocation recommendations tailored to the account holder’s financial situation and retirement goals. OA is tailored for individuals who wish to manage their own retirement account with the assistance of the service’s tools and investment advice. OA provides the account holder with a retirement goal forecast through various assumptions and hypothetical financial and economic scenarios. These scenarios are based on factors such as historic returns, market volatility, cross-correlations, calculated risk premiums, interest rate fluctuations, inflation, and market conditions, all of which have limitations. The account holders can interact with OA to see how changes in their decisions about their savings, expected retirement age, level of investment risk and retirement income goal may affect the system’s forecast. Account holders who enroll in OA are responsible for implementing the asset allocation that is best suited for their needs and investment strategy. The investment recommendations provided by OA are limited to proprietary mutual funds of Empower Funds, Inc. (EFI or Empower Funds) and proprietary insurance products of EAICA and Empower Life & Annuity Insurance Company of New York (ELAINY). OA does not make any recommendations about investing in any individual stocks or other asset classes. IRA holder Responsibilities: Account holders are responsible for making their investment decisions and may implement OA recommendations either online or by phone. Account holders are also solely responsible for reviewing and updating the information they input in the OA service with respect to the completeness, accuracy, and timeliness of the information. Account holders should review their retirement accounts periodically to monitor changes in the market and the value of their investments. A failure by an individual to review and update their account information through OA may materially affect the content and value of the service. Limitations on the Online Advice Services: The recommendations provided through OA are estimates based on the responses and information provided by the account holders. Neither EAG nor Morningstar Investment Management make any guarantees or warranties, express or implied, as to the accuracy, timeliness, or completeness of such information. The OA service is also subject to the general market and financial conditions existing at the time of use. The retirement goal forecast and investment recommendations provided by OA are not a guarantee of future results, nor are they a guarantee that an account holder will achieve their retirement goals. Account holders should only use OA as a tool in their retirement planning and not as a substitute for their own informed judgment. Neither EAG nor Morningstar Investment Management has an obligation to update any information for a specific individual or to proactively contact the individual to obtain updated information. A failure by an individual to review and update account information through OA may materially affect the content and value of the Services. 2. Managed Account Service (also known as My Total Retirement) EAG offers a discretionary managed account service (Managed Account, MA Service, or MTR). This is a professional and flexible asset management program based on data resulting from the methodologies and proprietary software program developed and employed by Morningstar Investment Management. In the MA Service, EAG has discretionary authority over the allocation of available investment options, without prior account holder approval of each transaction. EAG implements ongoing investment transfers and investment allocation changes for individuals enrolled in the MA Service. The MA Service designs a specific asset allocation portfolio for the account holder that reflects the individual’s retirement goals, life stages, specified risk constraint and overall financial situation. The MA Service considers IRA assets and will also consider other assets and investments not included within the IRA, if the account holder provides data. On a periodic basis, individual accounts in the MA Service are re-forecasted, which may include rebalancing and reallocating the individual’s asset allocation portfolio. EAG does this to maintain alignment with the allocation percentages determined by Morningstar Investment Management through various assumptions and hypothetical financial and economic scenarios. 4  Such scenarios are based on different factors such as historical returns, market volatility, cross-correlations, calculated risk premiums, interest rate fluctuations, inflation, market conditions, and the personal financial circumstances of the account holder. Account holders receive an account update and forecast statement annually and can update their personal information at any time by calling EAG at their toll-free customer service number or by visiting the appropriate website. The investment recommendations and allocations provided by the MA Service are limited to proprietary mutual funds of Empower Funds and proprietary insurance products of EAICA and ELAINY. MA Service does not make any recommendations about investing in any individual stocks or other asset classes. Limitations on the Managed Accounts Service: When account holders enroll in the MA Service, they must transfer and allocate their entire IRA account balance to the Managed Account. Once enrolled in the MA Service, account holders delegate certain account management functions to EAG including functionality for fund-to-fund transfers, change fund allocations, the dollar cost averaging tool and/or the rebalancer tool. However, individuals in the MA Service retain full inquiry access to their accounts and may still take a distribution withdrawal, if permissible. Account holders may un-enroll at any time from the MA Service. Once they do so, the account holders resume full responsibility for the investment management of their accounts. An individual may un-enroll online or by contacting an EAG investment adviser representative. See Termination of Services below for information about transactions following unenrollment. Spend-Down Advice 3. EAG also provides account holders enrolled in any of the above EAG’s Services with an additional feature of Spend-Down Advice, which includes retirement planning tools. The Spend-Down Advice illustrates how long the desired income may last in retirement and determines how much spendable income the account holder may be able to sustain throughout their retirement. The Spend-Down Advice provides both the amount and sources of income available throughout their retirement. The services provided under Spend-Down Advice provide projections of spendable income and do not constitute investment advice under the Advisers Act. Retirement Income Projection Tools and Services 4. EAG may offer online tools and services for account holders to convert projected or actual retirement savings into estimated monthly retirement income. This interactive retirement planning service consists of various retirement income projection tools. These tools are informational in nature, do not reflect actual investment results, and are not guarantees of future results. These tools do not constitute investment advice under the Advisers Act. Enrollment in EAG’s Services: The Services are available to all account holders of the Empower Premier IRA, including Roth and Traditional IRAs. Account holders must agree to the Terms of Service prior to using any of the online services, which EAG may amend from time to time. The advice and recommendations provided through the Services are based on the responses or other information provided by or about the account holder. Neither EAG nor Morningstar Investment Management make any guarantees or warranties, express or implied, as to the accuracy, timeliness, or completeness of such information. The Services are also subject to the general market and financial conditions existing at the time of usage. The retirement goal forecast and investment advice recommendations are not a guarantee of future results and are not a guarantee that a person will achieve their retirement goals. Termination of Services: Online Advice: Account holders may discontinue their use of OA at any time. Because EAG does not affect changes to the account holder’s asset allocation and account balances, the individual’s balances will not be affected unless and until the individual affirmatively changes their asset allocation and balance after discontinuing use of OA. MA Service: Account holders utilizing the MA Service may cancel online or by calling an EAG investment adviser representative at the toll-free customer service number. After cancellation of the MA Service, the account holder will have the ability to make allocation and investment option changes to their account, usually one to two business days following cancellation. Accordingly, the account holder’s asset allocation will remain the same as established in the MA Service unless and until the account holder affirmatively changes his/her asset allocation after cancellation of the MA Service. Account Holder Information: 5  EAG uses and provides storage of any information at the individual’s sole risk and responsibility. Such information includes, without limitation, an individual’s personal and non-public information, account number, password, identification, portfolio information, account balances and any other information available on an individual’s personal computer. The individual is responsible for providing and maintaining the communications equipment (including personal computers and modems) and telephone or other services required for accessing and using electronic or automated services, and for all communications service fees and charges incurred by the individual in accessing these services. EAG shall not bear any responsibility for either errors or failures caused by the malfunction of any computer, communication systems, any computer viruses, and related problems that may be associated with the use of the Services. Assets Under Management: With respect to the services provided by EAG, as of December 31, 2025: Discretionary investment management among all services: $ 164,237,996,079 Non-discretionary investment advisory services among all services in the amount of: $ 31,188,325,400 $ 195,426,321,479 Total discretionary and non-discretionary investment management and advisory services in the amount of: Item 5 – Fees and Compensation Quarterly Fee Annualized Fee Principal Account Balance < $100,000 0.125% 0.50% Next $150,000 0.10% 0.40% Next $150,000 0.075% 0.30% > $400,000 0.05% 0.20% EAG reserves the right to offer current, new, or prospective IRA holders discounted fees or other promotional pricing or to waive periodic fees, subject to proper notification and disclosure. If an account holder cancels their participation in the MA Service or Empower Premier IRA at any time within a fee cycle, the fee is based on average assets managed during the billing period; E AG will debit the fee from the account according to EAG procedures. Online Advice: EAG does not charge a separate fee for OA. Retirement Income Projection Tools and Services: EAG does not charge a separate fee to IRA account holders for the retirement income projection tools and services. 6  Other Fees and Expenses: Accounts invested in mutual funds and other investments may be subject to other investment fees. The mutual fund may directly impose fees such as fund operating expenses or redemption fees. Information about the fees imposed by specific investment choices is available in each fund’s prospectus. EAG allocates assets of MTR users to funds or to the general account product as described below. EFSI executes securities transactions that occur as a result of the services provided by EAG described in this Brochure. An account holder will directly pay advisory fees to EAG for the MA Service and indirectly pay fees to ECM for the Empower Funds included in the IRA investment options. Each fund’s share price includes the fees paid to ECM for management of the Empower Funds. The Empower Guaranteed Income Fund (the Guaranteed Fund), a general account group funding agreement issued by EAICA and ELAINY, assesses fees and expenses associated with the operation and management of the Guaranteed Fund through adjustments to the Guaranteed Fund’s applicable crediting rate. Accordingly, there are no explicit charges associated with the Guaranteed Fund. The Guaranteed Fund offers a guaranteed minimum interest rate of 0.15%. Item 6 – Performance-Based Fees and Side-by-Side Management EAG does not charge any performance-based or side-by-side management fees. Item 7 – Types of Clients EAG offers investment advisory and management services to account holders of the Empower Premier IRA, an Empower retail brokerage account or another plan elected managed account services. Additionally, EAG provides investment advice to participants in retirement plans for which Empower provides recordkeeping services. IRA holders and plan participants typically must be considered residents of the United States, the U.S. Virgin Islands, Guam, or Puerto Rico. A plan sponsor may apply additional restrictions for participation due to plan or regulatory requirements. EAG may also be engaged by individuals to provide investment advisory services within or alongside EAG’s other advisory services and products, such as an Empower Premier IRA, an Empower Premier Investment Account, Personal Strategy, Personal Strategy+ Advisory Services, Core Managed Account Advisory Services, or certain brokerage accounts. Item 8 – Methods of Analysis and Investment Strategies and Risk of Loss The Services described in this Brochure are based on the proprietary asset allocation and retirement income projection methodologies developed by Morningstar Investment Management. The development of investment advice by Morningstar Investment Management involves investment methodologies across products and services as described herein. Morningstar Investment Management and/or its affiliates focus on specific investment areas such as capital market assumptions and a valuation-driven approach to asset allocation. Analysis Methods: In providing advisory services, Morningstar Investment Management reviews available quantitative data to analyze and screen the investment options available for the Services which are limited to proprietary mutual funds of Empower Funds and proprietary insurance products of EAICA and ELAINY. The analysis will include quantitative analytics and fundamental research on the investment options available. Morningstar Investment Management draws on Morningstar’s comprehensive database of fund and security analytics. Morningstar Investment Management uses a combination of portfolios and customizations as part of a larger portfolio construction process. For the MA Service and OA, they generate hundreds of unique portfolios (ranging from conservative to aggressive) for each retirement plan or product using a customized approach to blending traditional asset allocation models with liability-driven investing and decumulation strategies. The asset classes and sub-asset classes used to build these model portfolios depend on the specific investment options available within the plan. Using this model, they develop an investment strategy tailored to your investment goals and assign you to one of those portfolios. They start with all of the available information received from the service provider and/or you and then make assumptions about certain pieces of information. You can review and refine some of these assumed data points through the website or over the phone. These assumptions can have a significant impact on the strategies created for you and are related to social security income, salary growth, inflation rates, retirement income goal, and risk capacity. They combine this information with other factors into a proprietary software program that can provide investment recommendations and a projection of different outcomes. They use a concept called total wealth to determine your risk capacity. This helps determine an appropriate target risk level for your retirement 7  account by considering your risk exposure in all your other accounts that you have told us about that you earmarked for retirement. The total wealth methodology accounts for your financial capital (total saved assets and tradeable assets such as stocks and bonds) as well as your human capital (future earnings and savings potential). Using this methodology, they assign a target risk level based on your total economic worth. Morningstar Investment Management uses the FinaMetrica risk profiling methodology, which is built using ‘psychometrics,’ a combination of psychology and statistics. While the science of creating psychometric questionnaires is complex, it can provide a picture of who you are and where you fit on the scale of a conservative to high risk-taker. After completing the risk tolerance questionnaire, your results will be a score ranging from 0 (very low risk group) to 100 (very high-risk group). Although the scoring is objective, subjectivity cannot be completely eliminated using planning tools like this. There is no guarantee that the risk tolerance questionnaire will accurately assess your tolerance to risk, and the accuracy of the analysis is contingent upon the appropriateness and accuracy of the assumptions. The risk tolerance questionnaire does not collect or consider all potentially relevant details about your personal or financial situation, which is why they pair it with our total wealth methodology. After completing the risk tolerance questionnaire, your score will account for a 20% weighting in the target equity determination for your investment strategy, with the other 80% weighting coming from your total wealth determination. The target risk level changes over time to help ensure you are still investing in a portfolio for your specific situation and risk capacity. In general, we try to provide a smooth transition from an aggressive equity portfolio to a more conservative fixed portfolio as you near retirement. Investment Strategy: When accumulating for retirement, the investment strategy is generally based on information such as retirement account balances, expected retirement age, savings rate and other preferences provided by the individual. If you have already retired, the investment strategy is based upon account balances, additional cash flows, and life expectancy. This retirement strategy may include some or all of the following: • Retirement Income Goal (accumulation phase): The retirement income goal is the projected amount of money, after tax, that the individual will need throughout retirement. The projection typically uses the individual’s current take home pay, but the individual has an option to change this projected retirement income amount. • Income Outlook (accumulation phase): The income outlook is a projection of the annual income that the individual may receive during retirement. This is based on an annualized view of the accumulated investment wealth, combined with social security benefits and any pension or other income data provided to EAG. • Total Retirement Income (in-retirement phase): Total retirement income is the projected amount of money that one can expect to receive on an annual basis in order to maintain income throughout retirement. • IMPORTANT: When Morningstar Investment Management determines the income projections described above, these projections are based on hypothetical performance data and do not represent actual or guaranteed results. Projections may vary over time with each additional use of the Service. Estimated Tax: Morningstar Investment Management estimates federal, state income, and capital gains taxes based on marginal tax rate calculations. Morningstar Investment Management uses these calculations when it conducts income simulations. Tax data is updated annually based on the United States Internal Revenue Code (IRC) and similar state tax data. Morningstar Investment Management uses income data for the individual and their spouse/partner to estimate federal and state tax exposure. Morningstar Investment Management appropriately reduces the tax exposure for pre-tax deferrals, tax-deferred capital gains, and yield and distribution of Roth proceeds. Based on the information that the individual provides, Morningstar Investment Management provides an estimate of the tax exposure but may not include all tax considerations. Please consult a tax adviser for a complete understanding of your tax situation. General Risks of Investing: Investing in securities involves the risk of loss that clients should be prepared to bear. Neither EAG nor Morningstar Investment Management or their affiliates guarantee that the recommendations will result in achieving the retirement income goal. Neither EAG nor Morningstar Investment Management or their affiliates can guarantee that you can or will avoid negative returns in any of the recommendations. An investment’s future performance may differ substantially from 8  its historical performance and as a result, may incur a loss. Past performance is no guarantee of future results. Additionally, the IRA provider may make changes from time to time with respect to the investment options available in the IRA. While a diversified investment portfolio, including a portfolio of investment products representing different asset categories, can mitigate some risks, it does not and cannot prevent all losses. Ultimately, the investor bears such risks. Below are some of the common factors that can produce a loss in a client’s account and/or in a specific investment product or asset category: • Market Risk: Stock and bond markets are volatile and can decline significantly in response to adverse issuer, political, regulatory, market, or economic developments in the U.S. and in other countries. Market risk may affect a single company, a sector of the economy, a country or geopolitical region, or the market as a whole. Market risk may impact stock and or bond markets in unanticipated and different ways. Business Risk: These risks are associated with a particular industry or a company within an industry. • • Capitalization Risk: Limited resources or less diverse products or services may hinder small-cap and mid-cap companies. Their stocks have historically been more volatile than the stocks of larger, more established companies. • Category or Style Risk: During various periods of time, one category or style may underperform or outperform other categories and styles. • Credit Risk: The risk that the issuer of a security may be unable to make interest payments and/or repay principal when due. A downgrade to an issuer’s credit rating or a perceived change in an issuer’s financial strength may affect a security’s value and impact the performance of the issue – along with any mutual fund or exchange- traded fund that holds it. • Interest Rate Risk: Interest rate changes significantly affect a debt security’s market value. Generally, when interest rates rise the debt security’s market value declines, and when interest rates decline, market values rise. A longer bond maturity normally involves a greater risk and higher yield, while a shorter bond maturity results in lower risk and lower yield. Inflation Risk: When inflation is present, purchasing power may erode at the rate of inflation. • • Reinvestment Risk: The risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e., interest rate). This relates primarily to fixed income securities. • An investment in a money market fund is not insured or guaranteed by the Federal Deposit Insurance Corporation (FDIC) or any other government agency. Although some money market funds such as the Empower Government Money Market Fund strive to preserve the value of the investment at $1.00 per share, it is possible to lose money by investing in a money market fund. • The benefits and guarantees of the Guaranteed Fund, including the applicable crediting rate, are subject to the financial strength, solvency and claims-paying ability of EAICA and ELAINY, respectively. The respective general accounts of EAICA and ELAINY are not segregated or insulated from the claims of creditors. The Guaranteed Fund is subject to many of the risks associated with a portfolio of fixed-income securities including, but not limited to credit risk, interest rate risk, liquidity risk, and inflation risk. The Guaranteed Fund is not FDIC- insured and no bank or savings association guarantees the Guaranteed Fund. For more complete information about any of the mutual funds or investment products available within the IRA, please contact us at the number listed on the cover page. Item 9 – Disciplinary Information EAG, as a registered investment adviser, is required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of EAG or the integrity of EAG’s management. EAG has the following disciplinary event to report relative to this item: On August 29, 2025, EAG and its broker/dealer affiliate, Empower Financial Services, Inc. (EFSI), settled a matter with the SEC. 9  The SEC found that, from July 1, 2019 through December 31, 2022, certain retirement plan advisors of EFSI and EAG, all of whom were both registered representatives associated with EFSI and investment adviser representatives associated with EAG, did not sufficiently disclose whether retirement plan advisors were acting as a registered representative or an investment adviser representative when recommending that a plan participant enroll in EAG’s managed account service. Additionally, EFSI and EAG did not adequately disclose the conflicts of interest presented by certain incentive compensation arrangements, leading to misleading statements made to plan participants. Finally, the SEC found that EFSI did not establish, maintain and enforce written policies and procedures reasonably designed to identify and address conflicts of interest in connection with recommendations to enroll in EAG’s managed account service. As a result, the SEC determined that EAG violated section 206(2) of the Investment Advisers Act of 1940 (“Advisers Act”) and EFSI failed to comply with the disclosure and conflict of interest obligations of Regulation Best Interest (“Reg BI”), thereby violating Reg BI’s General Obligation (Exchange Act Rule 15l-1(a)(1)). Without admitting or denying the findings, EFSI and EAG entered into a settlement with the SEC, pursuant to which EAG was censured; ordered to cease and desist from committing or causing any future violations of Section 206(2) of the Advisers Act thereunder; and EAG agreed to pay a civil monetary penalty in the amount of $750,000; and disgorgement of $4,063,569.80. EFSI was censured; ordered to cease and desist and agreed to pay a civil monetary penalty of $750,000. Item 10 – Other Financial Industry Activities and Affiliations EAG is not a registered broker-dealer. However, due to the organizational structure of EAG’s indirect parent company, EAICA, certain EFSI registered representatives are also EAG supervised persons and are required to comply with EAG policies and procedures when acting as an investment advisory representative. EAG and its supervised persons are not registered as a futures commission merchant, commodity pool operator, commodity trading advisor, or an associated person of the foregoing entities. Other Financial Industry Affiliations: EAG has arrangements that are material to its advisory business or its clients/account holders with the related entities shown below. These related entities may receive certain fees that are unrelated to EAG’s fees for its Services. Recordkeeping and Administrative Services Company: Empower Retirement, LLC (Empower) is a comprehensive administrative and recordkeeping services provider for financial institutions and employers, which include educational, advisory, enrollment, and communication services for employer- sponsored defined contribution plans and associated defined benefit plans under IRC Section 401(a), 401(k), 403(b), 408, and 457. Empower receives a 35-bps shareholder service fee from the Investor Class shares of Empower Funds for recordkeeping and administrative services provided for IRA holders, pursuant to a Shareholder Services Agreement between the parties. Insurance Companies: Empower Annuity Insurance Company of America (EAICA) is an insurance company domiciled in the State of Colorado. EAG is a wholly owned direct subsidiary of ESH US, which is owned by EAICA. EAICA, pursuant to various agreements, may provide investment products, recordkeeping, and other administrative services through its affiliates. Empower Life & Annuity Insurance Company of New York (ELAINY) is an insurance company domiciled in the State of New York. EAG is under common control with ELAINY and is an affiliate of ELAINY where EAICA indirectly owns EAG and is the sole owner of ELAINY. ELAINY, pursuant to various agreements, may provide investment products and administrative services through its affiliate, Empower, to retirement plans for which EAG may also provide its services. Empower Annuity Insurance Company (EAIC) is an insurance company domiciled in the State of Connecticut. EAG is under common control with EAIC and is an affiliate of EAIC where EAICA indirectly owns EAG and is the sole owner of EAIC. EAIC, pursuant to various agreements, may provide investment products and administrative services individually and through its affiliate, Empower, to retirement plans for which EAG may also provide its services. Broker-Dealer: Empower Financial Services, Inc. (EFSI), an affiliate of EAG, is a registered broker-dealer and wholly owned subsidiary of EAICA. 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. EFSI executes all transactions that occur as a result of participation in the Services. 10  Trust Company: Empower Trust Company, LLC (ETC) is a trust company and affiliate of EAG. ETC is a wholly owned subsidiary of ESH US, which is a wholly owned subsidiary of EAICA and is chartered under the laws of the State of Colorado. ETC is the custodian of all Empower Premier IRA accounts. ETC may provide discretionary or directed trustee and/or custodial services for EAG’s clients and also serves as the trustee for certain collective investment trusts. Investment Company: Empower Funds, Inc. (EFI or Empower Funds), an investment company registered under the Investment Company Act of 1940, is affiliated with EAG. Empower Funds provides investment products to retirement plans and IRAs for which EAG may also provide its services. Empower Capital Management, LLC manages Empower Funds as discussed below. Shares of Empower Funds are available to account holders of the Empower Premier IRA and may also be investment options in retirement plans advised by EAG. Investment Adviser Affiliates: Empower Capital Management, LLC (ECM), an affiliate of EAG, is a registered investment adviser under the Advisers Act and is the investment adviser for Empower Funds, which are investment options in the Empower Premier IRA. ECM is a wholly owned subsidiary of ESH US, which is a wholly owned subsidiary of EAICA. EAG provides managed accounts, guidance, and advice services to IRA holders and to participants in certain defined contribution plans. Irish Life Investment Managers Limited (ILIM) – a Dublin, Ireland based, SEC registered investment adviser. ILIM is part of the Lifeco group of companies; Lifeco has operations in Canada, the United States, Europe, and Asia through ownership of companies including EAICA. EAG is an indirect wholly owned subsidiary of EAICA. EAICA is an indirect wholly owned subsidiary of Lifeco, which controls ILIM. ILIM manages the index series of Empower Funds. Holding Company: Great-West Lifeco Inc. (Lifeco), EAG’s indirect parent company, owns approximately 6% of Franklin Templeton Investments’ parent company, Franklin Resources, Inc. (Franklin) as of January 1, 2024. Franklin or certain of its investment management subsidiaries (collectively, the Franklin Group entities) may provide management, advisory or sub-advisory services to investment funds that may be investment options in a Managed Account. Franklin and Lifeco have entered into arrangements under which Lifeco has committed to allocate Lifeco and affiliate assets over a period of time to be managed by Franklin’s investment managers and to support the availability of Franklin Group entity products and services on enterprise platforms. As a result, Empower and Lifeco will derive an economic benefit to the extent that Franklin Group entities provide management, advisory or sub-advisory services to funds or products. If Franklin achieves certain revenue thresholds under those arrangements, Lifeco will receive contingent transaction consideration and Lifeco and other Empower affiliates will derive an economic benefit if assets are allocated to a Franklin investment option. Branding: The affiliated companies of EAG; Empower Personal Wealth, LLC; ECM; EFSI; EAICA; EAIC; ELAINY; Empower Funds; Empower; and ETC operate under the multiple brands of Empower and Empower Institutional depending upon the products, services and retirement markets involved. These brands do not materially affect the internal structure of EAG or EAG’s corporate ownership. Conflicts of Interest: The investment recommendations and allocations provided by the Services are limited to Empower Funds’ proprietary mutual funds and EAICA’s and ELAINY’s proprietary insurance products. EAG does not receive compensation from its parent company or any of its affiliates as a result of these allocations. EAG has an agreement with Morningstar Investment Management wherein EAG pays Morningstar Investment Management for sub- advisory services. EAG mitigates these conflicts of interest related to affiliated investment options by utilizing Morningstar Investment Management as sub-adviser who remains independent from EAG and its related persons with respect to their methods of analysis and investment strategies. Morningstar Investment Management’s methodology also controls the investment allocations and recommendations. 11  An account holder will pay advisory fees directly to EAG for MTR, and indirectly to ECM and Empower. Each Empower Fund’s share price includes the fees paid to ECM and Empower. Conflicts related to fund recommendations: The Services operate by recommending or allocating an Account Holder’s assets to funds available to the IRA. The custodian of the IRA platform (rather than EAG) generally establishes the funds available for EAG’s recommendations within an IRA. The investment options are comprised solely of investment options sponsored by EAG’s affiliates. • Proprietary investment funds. EAG’s affiliates offer proprietary investment funds within the Empower Premier IRA. EAG will recommend or allocate the IRA to Empower Funds, which are proprietary investment funds, or to proprietary insurance products described below. These investment funds generate additional income to EAG’s affiliates to compensate the affiliates for administering, managing, and supervising these funds. EAG’s affiliate Empower Funds will be the exclusive provider of the investment funds available through the Services. • Proprietary insurance products. EAG’s indirect parent company, EAICA, and its affiliate, ELAINY, offer proprietary insurance products for investment, such as the Guaranteed Fund. As a default, EAG will allocate account holder assets to the Guaranteed Fund. A general account product is an insurance product backed by the general account of an insurance company, such as EAICA or ELAINY. These EAG affiliates generate revenue by retaining spread (which is the difference between actual earnings on contracts offered by the insurer), and the crediting rate declared and guaranteed by the insurer through the contract. Conflicts related to increased use and promotion of the Services: • Increased advisory fee income. EAG’s representatives may recommend that you use the Services. If you enroll in certain Services, EAG will earn additional compensation. • Increased affiliate fee income. When you use the Services, EAG may recommend you increase contributions or utilize other savings or investment strategies. EAG’s affiliates provide a bundle of recordkeeping, trust, custody, brokerage, investment, and other related services to retirement plans and to IRA products. If you pay for these related services through an arrangement where the EAG affiliates charge a direct fee, these affiliates may receive additional fees for these services. These additional fees result from EAG’s recommendations because you may contribute, invest, or transact in more assets with EAG’s family of companies. • Representative Compensation. EAG has authorized its individual adviser representatives and EFSI, an affiliate of EAG, and its licensed agents and registered representatives who are Empower employees (collectively referred to as, “Agents”) to solicit, refer and market EAG’s services. Agents receive a salary and are eligible to receive incentive compensation (including bonus payments) paid by Empower. Certain Agents serve in “Wealth Solutions Advisor,” and similar roles that educate prospective clients about available products and services, and, provide investment advice. Agents receive incentive compensation paid by Empower when they refer a retirement plan participant to an EAG representative in its rollover/distribution call center to consider whether to roll over plan assets into advisory accounts with EAG. Depending on the position type of the referring Agent, an Agent also receives incentive compensation paid by Empower when the referred participant ultimately rolls over assets into and funds an advisory account with EAG. Under an incentive compensation plan applicable to Wealth Solutions Advisors and certain other roles, incentive compensation is based, in part, on funded net asset accumulation and retention and compensation varies by product “grade” (or tier). Specifically, Grade 1 products include Empower Personal Cash and self-directed brokerage accounts (taxable and IRA/SEP); Grade 2 products include Empower Investment Account, Empower Managed Portfolio, SmartSolution IRA/Roth IRA, and Premier Non-Managed accounts; and Grade 3 products include Personal Strategy, Personal Strategy+, and Premier Managed accounts. Grade 1 products are self-directed and, when recommending or opening a self-directed brokerage account, Agents do not act in a fiduciary capacity. Payout rates are generally higher for higher-grade products based on individual product complexity and the requisite expertise required of Agents to discuss and open such products. These arrangements create conflicts of interest because Agents have financial incentives to recommend or encourage enrollment in, or selection of, certain products or services or to encourage rollovers or transfers of additional assets. Compensation paid to Agents does not increase the fees paid by account holders. Other Agents’ individual performance goals, within Workplace Planning & Advice and including, but not limited to, Workplace Planning Consultants, are based on a combination of factors including the number and quality of customer engagements during the measurement period and the amount of customer assets retained or accumulated as a result of those engagements. Depending on position type, performance goals also include: total 12  asset growth and retention (including retention and external rollover ratios); introductions or referrals to Wealth Solutions Advisors (described above); client satisfaction measures; and planning-activity measures (such as advice acceptance rates). Additional qualitative factors include leadership, teamwork, client experience, quality and efficiency of client interactions, and adherence to corporate policies and regulatory standards. Incentive compensation is not guaranteed and is determined and paid periodically (for example, monthly or quarterly). Other Business Activities: Certain senior managers and officers of EAG may also serve as executive officers of EAG’s indirect parent company, EAICA, and other affiliates of EAG. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading EAG’s Code of Ethics: EAG has adopted a written Code of Ethics (the Code) in compliance with Rule 204A-1 of the Advisers Act. The Code sets forth standards of business conduct expected of advisory personnel. EAG requires certain EAG advisory personnel to report their personal securities holdings and transactions in accordance with the Advisers Act. EAG requires its advisory personnel to comply with the Code. EAG will provide a copy of the Code to current or prospective clients upon request. The Code includes provisions related to: • Fiduciary responsibility to clients; • Compliance with federal securities laws; • Protection and safeguarding of confidential information; • Giving and receiving gifts, gratuities, and entertainment; • Political contributions; • Reporting and monitoring personal securities transactions; • Avoiding and disclosing conflicts of interest; and • Reporting violations of the Code. Personal Trading: The Code requires pre-clearance of certain securities transactions. Officers, managers, and certain employees of EAG (collectively, Access Persons) may trade for their own personal accounts in securities that EAG may recommend to and/or purchase for its advisory clients. EAG continually monitors personal trading in accordance with the Code and federal securities laws. EAG intends for the Code to ensure that the personal securities transactions and the outside business activities of EAG’s Access Persons do not interfere with making decisions in the best interest of advisory clients. Principal Trading: EAG has adopted a policy and practice not to engage in any principal transactions. EAG holds no investments for its own accounts that EAG could buy from, or sell to, an advisory client. EAG’s Board of Managers must approve a change in this policy. EAG would only permit a principal transaction after meeting the review and approval requirements described under the anti-fraud section of the Advisers Act. Participation or Interest in Client Transactions: Affiliate EFSI Effects Securities Transactions for Advisory Clients Registered representatives of EFSI may make recommendations to retirement plan participants, IRA Account Holders and other investment account holders and provide wholesaling, direct sales, enrollment, and/or communication services to account holders for which EAG may also provide its services. Pershing LLC, a non-affiliated clearing house, or EFSI execute all securities transactions that occur as a result of EAG’s services described in this Brochure. EFSI receives 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 discloses its affiliation with these entities. Allocations in the investment options are solely determined and based on Morningstar Investment Management’s software and not determinations made by EAG. The compensation paid by EAG to Morningstar 13  Investment Management for Morningstar Investment Management’s proprietary software advice program does not vary based on the allocations made or recommended by Morningstar Investment Management. Because Morningstar Investment Management is unaffiliated with EAG and EFSI, EAG does not believe there is a conflict of interest. Affiliate EAICA or ELAINY Proprietary Investments for Advisory Clients Investment options into which account holder assets may be allocated, pursuant to the OA or the MA Services, may be through a fixed funding agreement issued by EAICA or ELAINY. Because Morningstar Investment Management is unaffiliated with EAG, EAICA, ELAINY and their affiliates, EAG does not believe there is a conflict of interest. However, in all instances, EAG will disclose its affiliation with EAICA and/or EAICA’s affiliates, as applicable. Affiliate Empower Retirement, LLC Empower receives a 35-bps shareholder service fee from the Investor Class shares of Empower Funds for recordkeeping and administrative services provided for IRA holders, pursuant to a Shareholder Services Agreement between the parties. Item 12 – Brokerage Practices Brokerage Selection; Best Execution For the Empower Premier IRA, the IRA platform provider selects the broker-dealer used by the IRA and determines the reasonableness of the compensation. EAG’s affiliated recordkeeper, Empower, processes and EFSI generally execute transactions recommended by Morningstar Investment Management for the Services. Soft Dollar Practices: As a matter of policy, EAG does not utilize research or other products or services from third parties in connection with client securities transactions on a soft-dollar commission basis. Trade Aggregation: 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, most trades are mutual funds where trade aggregation does provide any additional client benefits. Item 13 – Review of Accounts At least annually, EAG personnel review the methodologies used by Morningstar Investment Management to power the OA and MA Services to ensure that they are consistent with investment advisory best practices, current technology, applicable laws, and the terms of the agreement between EAG and Morningstar Investment Management. Neither EAG nor Morningstar Investment Management review the personal financial information of account holders as provided by the account holders and do not assume responsibility for any incomplete or erroneous information. Such information, which includes date of birth, salary, gender, and/or state of residence, must be reviewed periodically by the account holder who in turn is responsible for notifying EAG of any changes, errors, or omissions to such information. Online Advice: EAG does not conduct a review of account holder accounts and does not provide investment oversight, monitoring, or rebalancing. Account holders in the OA service receive investment recommendations from EAG based on the investment options provided in the Empower Premier IRA. It is the responsibility of OA clients to review and update their accounts to adjust for changes in the investments they own and to determine whether the recommendations are suitable for their particular investment needs. OA clients should also review and update their accounts if significant changes occur in their personal circumstances. EAG conducts the following review of account holder accounts: Managed Account Service (also known as My Total Retirement): Under the MA Service, EAG periodically monitors, rebalances, and reallocates account holder assets in the investment options, based on Morningstar Investment Management’s software program. On an annual basis, account holders enrolled in the MA Service will receive an Annual Kit containing an account update and forecast statement. Morningstar Investment Management updates the capital market assumptions underlying their methodology used to construct the asset classes, at 14  least annually, and then makes changes to the portfolio allocations, as necessary. EAG also regularly monitors the portfolios based on current portfolio allocations and makes adjustments, as necessary. Reporting to Clients: Account holders enrolled in the MA Service receive an MA Welcome Kit shortly after enrollment and an account update at least annually. Account holders enrolled in OA can review their accounts and generate their own reports at any time. EAG encourages individuals to update significant changes to their personal information via the appropriate toll-free customer service number. Item 14 – Client Referrals and Other EAG has authorized its Agents to solicit, refer and market EAG’s services. Agents receive a salary and are eligible to receive incentive compensation (including bonus payments) paid by Empower. Certain Agents serve in “Wealth Solutions Advisor,” and similar roles that educate prospective clients about available products and services, and, provide investment advice. Agents receive incentive compensation paid by Empower when they refer a retirement plan participant to an EAG representative in its rollover/distribution call center to consider whether to roll over plan assets into advisory accounts with EAG. Depending on the position type of the referring Agent, an Agent also receives incentive compensation paid by Empower when the referred participant ultimately rolls over assets into and funds an advisory account with EAG. Under an incentive compensation plan applicable to Wealth Solutions Advisors and certain other roles, incentive compensation is based, in part, on funded net asset accumulation and retention and compensation varies by product “grade” (or tier). Specifically, Grade 1 products include Empower Personal Cash and self-directed brokerage accounts (taxable and IRA/SEP); Grade 2 products include Empower Investment Account, Empower Managed Portfolio, SmartSolution IRA/Roth IRA, and Premier Non-Managed accounts; and Grade 3 products include Personal Strategy, Personal Strategy+, and Premier Managed accounts. Grade 1 products are self-directed and, when recommending or opening a self-directed brokerage account, Agents do not act in a fiduciary capacity. Payout rates are generally higher for higher-grade products based on individual product complexity and the requisite expertise required of Agents to discuss and open such products. These arrangements create conflicts of interest because Agents have financial incentives to recommend or encourage enrollment in, or selection of, certain products or services or to encourage rollovers or transfers of additional assets. Compensation paid to Agents does not increase the fees paid by account holders. Other Agents’ individual performance goals, within Workplace Planning & Advice and including, but not limited to, Workplace Planning Consultants, are based on a combination of factors including the number and quality of customer engagements during the measurement period and the amount of customer assets retained or accumulated as a result of those engagements. Depending on position type, performance goals also include: total asset growth and retention (including retention and external rollover ratios); introductions or referrals to Wealth Solutions Advisors (described above); client satisfaction measures; and planning-activity measures (such as advice acceptance rates). Additional qualitative factors include leadership, teamwork, client experience, quality and efficiency of client interactions, and adherence to corporate policies and regulatory standards. Incentive compensation is not guaranteed and is determined and paid periodically (for example, monthly or quarterly). Compensation paid to Agents or EAG representatives does not increase the fees paid by the account holder. Item 15 – Custody EAG does not maintain actual custody of its clients’ cash, bank accounts, or securities. However, Advisers Act Rule 206(4)-2 deems EAG to have constructive custody with respect to certain client funds and securities. This is because an affiliated party (ETC) is the custodian and directed or discretionary trustee of certain retirement plan accounts. In addition to annual audits, these accounts are subject to surprise custody verifications by an independent public accountant each year, as required by Rule 206(4)-2. Account holders receive periodic account statements (at least quarterly) from their custodian and should carefully review these statements. Item 16 – Investment Discretion EAG provides discretionary investment management services for those account holders who enroll and participate in the MA Service; EAG does not offer or engage in discretionary investment services for OA. The MA Service is a professional, flexible asset management program that utilizes data from the methodologies and proprietary software program developed and employed by Morningstar Investment Management. To provide the MA Service to account holders, EAG retains discretionary authority over the allocation of available investment options without requiring 15  prior approval of each transaction. EAG implements ongoing investment transfers and investment direction changes for plan participants enrolled in the MA Service. Item 17 – Voting Client Securities EAG does not assume the responsibility to provide assistance, exercise voting powers or other decision-making authority regarding proxies or other issuer communications for the Empower Premier IRA accounts. Generally, if a mutual fund offered in the IRA files a proxy statement, account holders in the fund receive and may vote the proxy. Item 18 – Financial Information As previously discussed, under certain circumstances EAG has discretionary authority over certain client funds and securities. Accordingly, EAG must disclose information about its financial condition that is reasonably likely to impair its ability to meet contractual commitments to its clients. EAG has no financial commitment that impairs its ability to meet contractual commitments to its clients, nor has EAG been the subject of bankruptcy proceedings. Further, EAG does not require or solicit prepayment of fees of more than $1,200 per client more than six months in advance. This is not an Offer to Purchase or Sell Securities. The information contained in this Brochure, including information regarding Empower Funds, is for disclosure and other informational purposes only. It is not an offer to sell or a solicitation of an offer to buy any securities and may not be relied upon in connection with the purchase or sale of any security. 16 

Item 1 – Cover Page EMPOWER ADVISORY GROUP, LLC (EAG) Disclosure Brochure for: Online Advice & Managed Account Service (My Total Retirement) 8515 East Orchard Road Greenwood Village, CO 80111 Telephone: 855-756-4738 March 31, 2026 This Brochure provides information about the qualifications and business practices of Empower Advisory Group, LLC (EAG). Specifically, this Brochure provides information on the qualifications and business practices for the advisory services provided by E AG and sub- advised by Morningstar Investment Management, LLC (Morningstar Investment Management). If you have any questions about the contents of this Brochure, please contact us at 855-756-4738. The information in this Brochure has not been approved or verified by the Securities and Exchange Commission (SEC) or by any state securities authority. EAG is a registered investment adviser under the Investment Advisers Act of 1940 (Advisers Act). Registration of EAG does not imply any level of skill or training. Additional information about EAG is available on the SEC website at https://adviserinfo.sec.gov or on EAG’s website at https://empower.com/eag. The SEC’s web site also provides information about any person affiliated with EAG who is registered, or is required to be registered, as an investment adviser representative with EAG. Item 2 – Material Changes This section of the Brochure highlights and discusses any material changes that were made since the Adviser’s last update on September 19, 2025. A material change was made to Item 10 and Item 14 to describe changes to representative compensation 1  Item 3 – Table of Contents Item 1 – Cover Page .............................................................................................................................................................................................1 Item 2 – Material Changes ...................................................................................................................................................................................1 Item 3 – Table of Contents...................................................................................................................................................................................2 Item 4 – Advisory Business: .................................................................................................................................................................................3 Item 5 – Fees and Compensation: .......................................................................................................................................................................6 Item 6 – Performance-Based Fees and Side –by Side Management ...................................................................................................................7 Item 7 –Types of Clients .......................................................................................................................................................................................7 Item 8 – Methods of Analysis and Investment Strategies and Risk of Loss.........................................................................................................7 Item 9 – Disciplinary Information ......................................................................................................................................................................10 Item 10 – Other Financial Industry Activities and Affiliations ...........................................................................................................................10 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .....................................................................13 Item 12 – Brokerage Practices ...........................................................................................................................................................................14 Item 13 – Review of Accounts ...........................................................................................................................................................................14 Item 14 – Client Referrals and Other Compensation.........................................................................................................................................15 Item 15 – Custody ..............................................................................................................................................................................................15 Item 16 – Investment Discretion .......................................................................................................................................................................15 Item 17 – Voting Client Securities ......................................................................................................................................................................15 Item 18 – Financial Information .........................................................................................................................................................................15 2  Item 4 – Advisory Business: Description of Advisory Firm EAG has been a registered investment adviser under the Advisers Act since 2000. EAG is also registered in all 50 states, the District of Columbia, Guam, US Virgin Islands, and Puerto Rico. EAG offers investment management and advisory services to plan sponsors of employer-sponsored retirement plans such as 401(a), 401(k), 403(b) and 457 plans, including government entities and their participants, and to all account holders of the Empower Premier IRA, Empower Premier Investment account and Empower Managed Portfolio accounts. EAG does not choose the investments offered in employer-sponsored retirement plans or IRAs. EAG serviced plans receive recordkeeping services through Empower Retirement, LLC (Empower), the recordkeeping entity affiliated with EAG. EAG also offers investment management services to individuals and to retail brokerage account holders. More information about EAG’s services, including an applicable brochure, can be obtained by contacting EAG at the number provided on the cover page of this Brochure or by visiting EAG’s website at https://empower.com/eag. EAG is a wholly owned subsidiary of Empower Services Holdings US, LLC, (ESH US), a holding company domiciled in the State of Delaware. ESH US is owned by Empower Annuity Insurance Company of America (EAICA). EAICA is a direct, wholly owned subsidiary of Empower Holdings, LLC (EHL), a Delaware holding company. EHL is a direct wholly owned subsidiary of Great-West Lifeco U.S. LLC. (Lifeco U.S.) and an indirect wholly owned subsidiary of Great-West Lifeco Inc. (Lifeco), a Canadian holding company. Lifeco is a subsidiary of Power Financial Corporation (Power Financial), a Canadian holding company with substantial interests in the financial services industry. Power Corporation of Canada (Power Corporation), a Canadian holding and management company, has voting control of Power Financial. The Desmarais Family Residuary Trust has voting control of Power Corporation, through a group of private holding companies that it controls. Types of Services Discussed in this Brochure: EAG provides a range of direct account holder-level and participant-level investment services as well as services provided indirectly through private-label arrangements with institutional partners (the Services). The Services include Online Advice (OA) and the Managed Account service (MA Service) or My Total Retirement (MTR). Other services that may be available to clients include Spend-Down Advice, Financial Planning Service and Retirement Income Projection Tools and Services. EAG provides its Services through a proprietary, computer-based software program that is developed and maintained by Morningstar Investment Management. In addition, EAG provides sub-advisory and technology services to outside adviser firms through a service called Advisor Managed Accounts (AMA). This service enables the AMA firms to offer their own investment advisory and management services within retirement plans serviced by Empower. The total sub-advised assets as of December 31, 2025, for this service totaled $8,897,935,196.31. There is no guarantee provided by any party that participation in any of the advisory services will result in a profit. Morningstar Investment Management LLC: Morningstar Investment Management is a registered investment adviser wholly owned by Morningstar, Inc. and is not affiliated with EAG or any company that is affiliated with EAG. Morningstar Investment Management is located in Chicago, Illinois. A copy of its Form ADV Part 2A Brochure may be obtained at https://adviserinfo.sec.gov. Morningstar Investment Management serves as an independent financial expert (IFE) in accordance with the Department of Labor SunAmerica Advisory Opinion 2001-09A, dated December 14, 2001 (the SunAmerica Opinion). Morningstar Investment Management uses its proprietary methodology to evaluate the available investment options in a retirement plan and to develop an individualized investment strategy for plan participants and account holders. The plan, plan sponsor or plan fiduciary must select and continuously maintain investment options that cover broad asset categories. The investment options selected for the plan generally consist of a broad range of asset classes. More information is provided under Item 10 – Other Financial Industry Affiliations. Item 8, Methods of Analysis and Investment Strategies and Risk of Loss discusses the general risks of investing. The risks associated with the investment options can vary significantly with each particular investment category and the relative risks of categories may change. Accordingly, EAG may make changes from time to time regarding the availability of certain investment options. The fees, risks, responsibilities of plan sponsor, plan provider, and participant, and limitations for each of these services are discussed in greater detail below. Fees and expenses are also explained in the respective prospectus, which accompanies each investment option, as applicable. Certain EAG’s Services rely on Morningstar Investment Management’s proprietary methodology, which is based on a review of available quantitative data to analyze and screen the investment options within a plan. Morningstar Investment Management also applies qualitative analysis by investment professionals, such as evaluations of investment managers, portfolios, and individual investments. The primary sources of information used by Morningstar Investment Management are the extensive databases and methodologies of Morningstar Investment Management and/or its affiliates, and interviews with investment managers. Other sources include financial publications, annual reports, prospectuses, press releases, and SEC filings. Morningstar Investment Management combines this information with other factors — including actuarial data, stock market exposure, probability analysis, and mean-variance optimization — into its proprietary software program to analyze a complex set of market data and variables. The result is an advanced model capable of providing investment recommendations and projections of different outcomes. Using this model, Morningstar Investment Management develops an investment strategy tailored to your investment goals. 3  1. Online Advice OA is based on the software program developed by Morningstar Investment Management. It provides the participant with retirement goal forecasting advice and fund-specific asset allocation recommendations tailored to the specific participant’s financial situation and retirement goals. OA is tailored for individuals who wish to manage their own retirement account with the assistance of the service tools and investment advice. OA provides participants with a retirement goal forecast through various assumptions and hypothetical financial and economic scenarios. These scenarios are based on factors such as historic returns, market volatility, cross-correlations, calculated risk premiums, interest rate fluctuations, inflation, and market conditions; all of which have limitations. The participants can interact with OA to see how changes in their decisions about their savings, expected retirement age, level of investment risk and retirement income goals may affect the system’s forecast. Participants who enroll in OA are responsible for determining the portfolio allocation that is best suited for their needs and investment strategy. The investment recommendations provided by OA are limited to the available investment options within the participant’s specific retirement plan. EAG does not provide advice for, or recommend allocations of, individual stocks (including employer stock, unless you or your employer instructs EAG otherwise), self-directed brokerage accounts, guaranteed certificate funds, or employer-directed monies, or any other investment options that do not satisfy the methodology requirements of the subadviser who provides investment methodology to EAG. If applicable, your balances in any of these investment options or vehicles may be liquidated, subject to the following exceptions: (i) your Plan’s instructions restricting the sale of employer stock, (ii) investment provider restrictions, and/or (iii) your instructions to retain employer stock in an amount up to 20% of your Account balance. Participant Responsibilities: Participants are responsible for making their investment decisions and may implement OA recommendations either online or by phone. Participants are also solely responsible for reviewing and updating the information they input in the OA service with respect to the completeness, accuracy, and timeliness of the information. Participants should review their retirement accounts periodically to monitor changes in the market and the value of their investments. A failure by an individual to review and update their account information through OA may materially affect the content and value of the service. Limitations of the Online Advice Service: The recommendations provided through OA are estimates based on the responses and information provided by the participants. Neither EAG nor Morningstar Investment Management make any guarantees or warranties, express or implied, as to the accuracy, timeliness, or completeness of such information. The OA service is also subject to the general market and financial conditions existing at the time of use. The retirement goal forecast and investment recommendations provided by OA is not a guarantee of future results, nor is it a guarantee that a participant will achieve their retirement goals. Participants should only use OA as a tool in their retirement planning and not as a substitute for their own informed judgment. Neither EAG nor Morningstar Investment Management has an obligation to update any information for a specific individual or to proactively contact the individual to obtain updated information. A failure by an individual to review and update account information through OA may materially affect the content and value of services received from EAG. 2. Managed Account Service (also known as My Total Retirement) EAG offers a discretionary managed account service (Managed Account, MA Service or MTR). This is a professional and flexible asset management program based on data resulting from the methodologies and proprietary software program developed and employed by Morningstar Investment Management. In the MA Service, EAG has discretionary authority over the allocation of available investment options, without prior participant approval of each transaction. All ongoing investment transfers and investment direction changes are implemented for individuals enrolled in the MA Service. The MA Service designs a specific asset allocation portfolio for the participant that reflects the individual’s retirement goals, life stages, specified risk constraint and overall financial situation. The MA Service considers plan assets and other assets and investments not included within the plan if provided by the participant. On a periodic basis, individual accounts in the MA Service are re-forecasted, which may include rebalancing and reallocating the individual’s asset allocation portfolio. This is done to maintain alignment with the allocation percentages determined by Morningstar Investment Management through various assumptions and hypothetical financial and economic scenarios. Participants receive an account update and forecast statement annually and can update their personal information at any time by calling EAG at their plan’s toll-free customer service number, or by visiting the appropriate website. Some plan providers may offer a guaranteed lifetime benefit withdrawal option to plan participants who are approaching retirement or are in retirement. If the plan provider offers this service and if the participant meets the retirement criteria established by the plan provider or plan sponsor, the investment strategy may include a suggested amount that can be withdrawn while maintaining income throughout retirement. It may also include information about allocating a portion of the managed account balance for the purchase of an annuity or other guaranteed income product. 4  Limitations on the Managed Accounts Service: When participants enroll in the MA Service, they must transfer and allocate their entire retirement account balance to the Managed Account. For participants, there is an exception of employer stock and employer directed monies. EAG does not provide advice for, or recommend allocations of, individual stocks (including employer stock, unless you or your employer instructs EAG otherwise), self-directed brokerage accounts, guaranteed certificate funds, or employer-directed monies, or any other investment options that do not satisfy the methodology requirements of the subadviser who provides investment methodology to EAG. If applicable, your balances in any of these investment options or vehicles may be liquidated, subject to the following exceptions: (i) your Plan’s instructions restricting the sale of employer stock, (ii) investment provider restrictions, and/or (iii) your instructions to retain employer stock in an amount up to 20% of your Account balance. To the extent you provide EAG with instructions related to employer stock in your Account, such instructions will be implemented as soon as reasonably practicable, which may take up to six (6) months to complete. As your Account is periodically rebalanced or re-allocated, EAG will liquidate to decrease the amount of such employer stock held in your Account, if any, to the extent the actual amount of employer stock in your Account exceeds your instructed maximum allocation to employer stock. However, EAG will not increase the amount of employer stock held in your Account, if any, if at any point the amount of employer stock in your Account is below your instructed maximum allocation to employer stock. For participants, certain outside non-advisable assets may be permitted while also participating in the MA Service. However, the participant’s entire advisable account balance must be allocated to the MA Service. Once enrolled in the MA Service, participants delegate certain account management functions to EAG including functionality for fund-to- fund transfers, change fund allocations, the dollar cost averaging tool and/or the rebalancer tool. However, individuals in the MA Service retain full inquiry access to their accounts and may still request approval for loans or take a distribution withdrawal, if permissible. Participants may un-enroll at any time from the MA Service. Once they do so, the participants resume full responsibility for the investment management of their accounts. An individual may un-enroll online or by contacting an EAG investment adviser representative. 3. Spend-Down Advice Participants who are enrolled in any of EAG’s Services discussed above are also provided with an additional feature of Spend-Down Advice, which includes retirement planning tools. The Spend-Down Advice illustrates how long the desired income may last in retirement and determines how much spendable income the participant may be able to sustain throughout their retirement. The Spend-Down Advice provides both the amount and sources of income available throughout their retirement. The services provided under Spend-Down Advice provide projections of spendable income and do not constitute investment advice under the Advisers Act. 4. Retirement Income Projection Tools and Services EAG may offer online tools and services for participants to convert projected or actual retirement savings into estimated monthly retirement income. This interactive retirement planning service consists of various retirement income projection tools. These tools are informational in nature, do not reflect actual investment results, and are not guarantees of future results. These tools do not constitute investment advice under the Advisers Act. Enrollment in EAG’s Services: Plan providers and plan sponsors select the Service(s) (i.e., OA and/or the MA Service) that are available to plan participants and how participants can authorize the Service(s). Participants must agree to the terms of a user agreement (Terms of Service). EAG may amend Terms of Service from time to time, to allow continued use of any of the Services. As part of a participant’s enrollment in the MA Service, the participant receives a MA Welcome Kit shortly after enrollment. The participant additionally receives an Annual Kit. Each kit provides the participant an update on their account and information on reaching their retirement goals. In certain instances, Plan Sponsors may authorize EAG to enroll participants automatically in the MA Service based on information provided to EAG by the Plan Sponsors. In such instances, current participants in the Plan receive the Terms of Service and are given a defined period of time in which to cancel or opt-out of the MA Service without incurring an advisory fee (the Free Look or Promotional Period). Participants’ automatic enrollment in the Service by the Plan Sponsors is based upon personal financial information provided by the Plan Sponsor, including date of birth, salary, gender, and state of residence. Participants may review this information online or by contacting an EAG investment adviser representative. With this type of enrollment, the MA Service may be designated as a qualified default investment alternative (“QDIA”), as permitted under the Employee Retirement Income Security Act (ERISA.) Participants are solely responsible for reviewing the personal financial information they or their Plan Sponsor provide, and for notifying EAG of any changes or updates. Participants who are eligible for their employer-sponsored retirement plan or that otherwise elect to opt-in after the Free Look or Promotional Period concludes, may not be eligible for an advisory fee waiver that is otherwise available in the Free Look or Promotional Period. The advice and recommendations provided through the Services are based on the responses or other information provided by or about the participant by the Plan Sponsor and/or the participant. Neither EAG nor Morningstar Investment Management make any guarantees or warranties, express or implied, as to the accuracy, timeliness, or completeness of such information. The Services are also subject to the general market and financial conditions existing at the time of usage. The retirement goal forecast and investment advice 5  recommendations are not a guarantee of future results and are not a guarantee that a particular person will achieve their retirement goals. Termination of Services: Online Advice: Participants may discontinue their use of OA at any time. Because EAG does not affect changes to the participant’s/account holder’s asset allocation and account balances, the individual’s balances will not be affected unless and until the individual affirmatively changes their asset allocation and balance after the cancellation of OA. MA Service: Participants utilizing the MA Service may cancel online or by calling an EAG investment adviser representative at the toll-free customer service number. After cancellation of the MA Service, the participant will have the ability to make allocation and investment option changes to their account, usually one to two business days following cancellation. Accordingly, the participant’s asset allocation will remain the same as established in the MA Service unless and until the participant affirmatively changes his/her asset allocation after cancellation of the MA Service. If your Plan selected investment options that are exclusive to the MA Service, the assets in those investments may be liquidated upon cancellation of the service, based on your Plan Sponsor’s direction. Those assets will be transferred to an investment option chosen by your Plan Sponsor. Once the transaction settles, you can initiate an allocation change and/or transfer of those assets if you wish. Participant Information: EAG’s use and storage of any information provided is at the individual’s sole risk and responsibility. Such information includes, without limitation, an individual’s personal and non-public information, account number, password, identification, portfolio information, account balances and any other information available on an individual’s personal computer. The individual is responsible for providing and maintaining the communications equipment (including personal computers and modems) and telephone or other services required for accessing and using electronic or automated services, and for all communications service fees and charges incurred by the individual in accessing these services. EAG shall not bear any responsibility for either errors or failures caused by the malfunction of any computer, communication systems, any computer viruses, and related problems that may be associated with the use of the Services. Assets Under Management: With respect to the services provided by EAG, as of December 31, 2025: Discretionary investment management among all services: $ 164,237,996,079 $ 31,188,325,400 Non-discretionary investment advisory services among all services in the amount of: $ 195,426,321,479 Total discretionary and non-discretionary investment management and advisory services in the amount of: Item 5 – Fees and Compensation: For employer-sponsored retirement plans, fees are subject to negotiation by the plan sponsor, which may include plan-level pricing credits depending on the various option(s) selected by the plan for its participants. In some instances, if agreed to by the plan, the plan sponsors or recordkeeper may pay EAG’s fees on behalf of plan participants. EAG reserves the right to offer discounted fees or other promotional pricing or to waive fees for any particular period of time subject to proper notification and disclosure. 1. Online Advice Service Fees Managed Account Service Fees EAG does not charge a separate fee for OA. 2. EAG may charge participants a fee for the MA Service based on the Terms of Service with the participant and/or the plan sponsor’s agreement with EAG. EAG may offer plans tiered pricing schedules based on the enrollment method the plan uses for offering or enrolling its participants in the MA Service. Such options include, but are not limited to, pricing schedules based on the plan sponsor’s selection of an opt-out versus opt-in enrollment methodology. Applicable pricing schedules for each of the options are made available to the plan sponsors, which they may use to select the option for their employer-sponsored retirement plan. Pursuant to the Terms of Service and/or the plan sponsor’s agreement with EAG, the fee for the MA Service is based upon a percentage of assets managed. The applicable fee for the MA Service varies. EAG fully discloses the applicable fee to participants 6  prior to or at the time of enrollment within the enrollment disclosure materials. In addition, EAG discloses the fee to participants in the Terms of Service when the participant enrolls in the MA Service. The maximum annualized fee that EAG may charge to a participant is 0.65% of the participant’s account balance. EAG debits the advisory fee from the participant’s account following each applicable billing period. If a participant cancels enrollment in the MA Service at any time within a given billing period, pursuant to the participant’s Terms of Service and/or the plan sponsor’s agreement with EAG, the participant’s fee is based upon a percentage of assets managed during the billing period. The fee will be debited from the participant’s account or paid by the plan sponsor according to EAG’s agreement and procedures. If the plan sponsor terminates its service agreement with the plan’s recordkeeping service provider, the participant’s advisory fee is debited as of such date of termination or paid by the plan sponsor according to EAG’s agreement and procedures. 3. Retirement Income Projection Tools and Services EAG does not charge a separate fee to plan sponsors or participants for the retirement income projection tools and services. 4. Other Fees and Expenses In addition to any previously negotiated and disclosed recordkeeper fees, commission payments and other administrative servicing fees and expenses for each plan, EAG may pay cash compensation or referral fees to unaffiliated firms for soliciting and referring plan sponsors and their participants to enroll in EAG’s MA Service. Accounts invested in mutual funds, separate accounts, collective investment alternatives and other investments may be subject to other investment fees. Fees such as fund operating expenses or redemption fees may be imposed at the investment company level. Information about the fees imposed by specific investment choices is available in the fund prospectuses or offering memoranda for the securities. EAG may allocate member assets to funds or investment alternatives with these fees or costs. All securities transactions that occur as a result of the services provided by EAG as described in this Brochure are executed by Empower Financial Services, Inc., (EFSI) for which it 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 program investment options. A participant will pay advisory fees to EAG for the MA Service. Participants pay indirectly, through inclusion in the fund share price, additional investment management fees to ECM if Empower Funds are included among the available investment options within a Member’s plan. The fees paid to ECM are for management of the Empower Funds. EAG and EFSI representatives may recommend that you use the Services. If you elect to use the MA Service, EAG will earn additional compensation in the form of advisory fees. Also, EAG and EFSI representatives are eligible to receive incentive compensation (including bonus payments) in addition to their salary, for communicating with, educating and/or enrolling plan participants in the MA Service. The incentive or bonus compensation an EAG or EFSI representative receives depends on position type but generally is calculated based on Empower’s profitability and the achievement of individual performance goals that includes factors unrelated to the adoption of investment products or services offered through Empower, such as the Services. See Item 10 and Item 14 for additional detail regarding these compensation arrangements and conflicts of interest. Item 6 – Performance-Based Fees and Side–by-Side Management EAG does not charge any performance-based or side-by-side management fees. Item 7 –Types of Clients EAG provides investment advice to participants in their retirement plans for which Empower provides recordkeeping services. Members typically must be considered residents of the United States, the U.S. Virgin Islands, Guam, or Puerto Rico. The plan sponsor may apply additional restrictions for participation due to plan or regulatory requirements. EAG may also be engaged by individuals to provide investment advisory services within or alongside EAG’s other advisory services and products, an Empower Premier IRA, an Empower Premier Investment Account, Personal Strategy, Personal Strategy+ Advisory Services, Core Managed Account Advisory Services, or certain brokerage accounts. Item 8 – Methods of Analysis and Investment Strategies and Risk of Loss The Services described in this Brochure are based on the proprietary asset allocation and retirement income projection methodologies developed by Morningstar Investment Management. The development of investment advice by Morningstar Investment Management involves the investment methodologies across the products and services described herein. Morningstar Investment Management or its affiliates focus on specific investment areas such as capital market assumptions and a valuation-driven approach to asset allocation. Analysis Methods: 7  In providing advisory services, Morningstar Investment Management reviews available quantitative data to analyze and screen the investment options within a plan. The portfolios are typically constrained to a set of investment options defined by the plan sponsor, which may include EAG affiliated investment products. The analysis will include quantitative analytics and fundamental research on the investment options available. Morningstar Investment Management draws on Morningstar’s comprehensive database of fund and security analytics. Morningstar Investment Management uses a combination of portfolios and customizations as part of a larger portfolio construction process. For the MA Service and OA, they generate unique portfolios (ranging from conservative to aggressive) for each retirement plan or product using a customized approach to blending traditional asset allocation models with liability-driven investing and decumulation strategies. The asset classes and sub-asset classes used to build these model portfolios depend on the specific investment options available within the plan. Using this model, they develop an investment strategy tailored to your investment goals and assign you to one of those portfolios. They start with all of the available information received from the service provider and/or you and then make assumptions about certain pieces of information. You have the ability to review and refine some of these assumed data points through the website or over the phone. These assumptions can have a significant impact on the strategies created for you and are related to social security income, salary growth, inflation rates, retirement income goal, and risk capacity. They combine this information with other factors into a proprietary software program that can provide investment recommendations and a projection of different outcomes. They use a concept called total wealth to determine your risk capacity. This helps determine an appropriate target risk level for your retirement account by considering your risk exposure in all your other accounts that you have told us about that are earmarked for retirement. The total wealth methodology accounts for your financial capital (total saved assets and tradeable assets such as stocks and bonds) as well as your human capital (future earnings and savings potential). Using this methodology, they assign a target risk level based on your total economic worth. The target risk level changes over time to help ensure you are still investing in a portfolio for your specific situation and risk capacity. In general, we try to provide a smooth transition from an aggressive equity portfolio to a more conservative fixed portfolio as you near retirement. Investment Strategy: If accumulating for retirement, the investment strategy is generally based on information such as retirement account balances, expected retirement age, savings rate and other preferences provided by the individual. If you have already retired, and if the plan provider offers a guaranteed lifetime withdrawal benefit program, the investment strategy is based upon account balances, additional cash flows, and life expectancy. This retirement strategy may include some or all of the following: • Retirement Income Goal (accumulation phase): The retirement income goal is the projected amount of money after tax that the individual will need throughout retirement. This calculation can be based on current income, adjusted to reflect the estimated dollar value at retirement age. Typically, the calculation solves for 75% pre-tax income replacement (although plan providers may request a default percentage that differs from the standard), and then the Services project the after-tax value of that amount at retirement age to determine a retirement income goal. The individual has an option to change this projected retirement income amount. • Income Outlook (accumulation phase): The income outlook is a projection of the annual income that the individual may receive during retirement. This is based on an annualized view of the accumulated investment wealth, combined with social security benefits and any pension or other income provided to EAG. • Total Retirement Income (in-retirement phase): If your plan provider or plan sponsor offers the in-retirement services, total retirement income is the projected amount of money that one can expect to receive on an annual basis in order to maintain income throughout retirement. • IMPORTANT: When Morningstar Investment Management determines the income projections described above, these projections are based on hypothetical performance data and do not represent actual or guaranteed results. Your projections may vary over time with each additional use of the service. Estimated Tax: Morningstar Investment Management estimates federal, state income, and capital gains taxes based on marginal tax rate calculations. Morningstar Investment Management uses these calculations when it conducts income simulations. Tax data is updated annually based on the United States Internal Revenue Code (IRC) and similar state tax data. Morningstar Investment Management uses income data for the individual and their spouse/partner to estimate federal and state tax exposure. The tax exposure is appropriately reduced for pre-tax deferrals, tax-deferred capital gains, and yield and distribution of Roth proceeds. Based on the information that the individual provides, Morningstar Investment Management provides an estimate of the tax exposure but may not include all tax considerations. Please consult a tax adviser for a complete understanding of your tax situation. General Risks of Investing: Investing in securities involves the risk of loss that clients should be prepared to bear. Neither EAG nor Morningstar Investment Management or their affiliates guarantees that the recommendations will result in achieving the retirement income goal. Neither EAG 8  nor Morningstar Investment Management or their affiliates can guarantee that negative returns can or will be avoided in any of the recommendations. An investment’s future performance may differ substantially from its historical performance and as a result, may incur a loss. Past performance is no guarantee of future results. Additionally, the plan provider may make changes from time to time with respect to the investment options available in the plan. While a diversified investment portfolio, including a portfolio of investment products representing different asset categories, can mitigate some risks, it does not and cannot prevent all losses. Ultimately, such risks are borne by the investor. Below are some of the common factors that can produce a loss in a client’s account and/or in a specific investment product or asset category: • Market Risk: Stock and bond markets are volatile and can decline significantly in response to adverse issuer, political, regulatory, market, or economic developments in the U.S. and in other countries. Market risk may affect a single company, a sector of the economy, a country or geopolitical region, or the market as a whole. Market risk may impact stock and or bond markets in unanticipated and different ways. Business Risk: These risks are associated with a particular industry or a particular company within an industry. • • Capitalization Risk: Small-cap and mid-cap companies may be hindered due to limited resources or less diverse products or services. Their stocks have historically been more volatile than the stocks of larger, more established companies. • Category or Style Risk: During various periods of time, one category or style may underperform or outperform other categories and styles. • Credit Risk: The risk that the issuer of a security may be unable to make interest payments and/or repay principal when due. A downgrade to an issuer’s credit rating or a perceived change in an issuer’s financial strength may affect a security’s value and impact the performance of the issue – along with any mutual fund or exchange-traded fund that holds it. • Interest Rate Risk: The market value of a debt security is affected significantly by changes in interest rates. When interest rates rise the debt security’s market value declines. When interest rates decline, market values rise. The longer bond maturity results in the greater the risk and the higher yield. Conversely, the shorter bond maturity results in the lower risk and the lower yield. Inflation Risk: When any type of inflation is present, purchasing power may be eroding at the rate of inflation. • • Reinvestment Risk: The risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e., interest rate). This relates primarily to fixed income securities. • Exchange-traded funds: Exchange-traded funds present market and liquidity risks because they are listed on a public securities exchange and are purchased and sold via the exchange at the listed price. The price will vary based on current market conditions and may deviate from the net asset value of the exchange-traded fund’s underlying portfolio. There may also be an inactive market for certain funds, and/or losses from trading in secondary markets. • Target Date Funds: Generally, the asset allocation of each target date fund will change on an annual basis with the asset allocation becoming more conservative as the fund nears the target retirement date. The target date is the approximate date when investors plan to start withdrawing their money. The principal value of the fund(s) in a plan’s lineup is not guaranteed at any time, including at the time of target date and/or withdrawal. • An investment in a money market fund is not insured or guaranteed by the Federal Deposit Insurance Corporation (FDIC) or any other government agency. Although some money market funds such as U.S. Government money market funds strive to preserve the value of the investment at $1.00 per share, it is possible to lose money by investing in a money market fund. Additionally, other money market funds may operate under new rules and regulations permitting them to have a floating value per share. A floating value may be more or less than $1.00 per share depending on market conditions and impose liquidity/redemption fees for large or frequent withdrawals. For more complete information about any of the mutual funds or investment products available within the retirement plan, please contact your retirement plan service provider. 9  Risks Associated with Particular Types of Securities: Neither EAG nor its sub-advisers recommend a particular type of security. The plan sponsor or its agent is responsible for determining the retirement plan’s menu of investment options. It is the participant’s responsibility to read all disclosures and related materials, including prospectuses, statements of additional information and other similar materials. Item 9 – Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of EAG or the integrity of EAG’s management. EAG has the following disciplinary event to report relative to this item: On August 29, 2025, EAG and its broker/dealer affiliate, Empower Financial Services, Inc. (EFSI), settled a matter with the SEC. The SEC found that, from July 1, 2019 through December 31, 2022, certain retirement plan advisors of EFSI and EAG, all of whom were both registered representatives associated with EFSI and investment adviser representatives associated with EAG, did not sufficiently disclose whether retirement plan advisors were acting as a registered representative or an investment adviser representative when recommending that a plan participant enroll in EAG’s managed account service. Additionally, EFSI and EAG did not adequately disclose the conflicts of interest presented by certain incentive compensation arrangements, leading to misleading statements made to plan participants. Finally, the SEC found that EFSI did not establish, maintain and enforce written policies and procedures reasonably designed to identify and address conflicts of interest in connection with recommendations to enroll in EAG’s managed account service. As a result, the SEC determined that EAG violated section 206(2) of the Investment Advisers Act of 1940 (“Advisers Act”) and EFSI failed to comply with the disclosure and conflict of interest obligations of Regulation Best Interest (“Reg BI”), thereby violating Reg BI’s General Obligation (Exchange Act Rule 15l- 1(a)(1)). Without admitting or denying the findings, EFSI and EAG entered into a settlement with the SEC, pursuant to which EAG was censured; ordered to cease and desist from committing or causing any future violations of Section 206(2) of the Advisers Act thereunder; and EAG agreed to pay a civil monetary penalty in the amount of $750,000; and disgorgement of $4,063,569.80. EFSI was censured; ordered to cease and desist and agreed to pay a civil monetary penalty of $750,000. Item 10 – Other Financial Industry Activities and Affiliations EAG is not a registered broker-dealer. However, due to the organizational structure of EAG’s indirect parent company, EAICA, certain registered representatives of EFSI are also supervised persons of EAG and are required to comply with EAG policies and procedures when acting in that capacity. EAG and its supervised persons are not registered as a futures commission merchant, commodity pool operator, commodity trading advisor, or an associated person of the foregoing entities. Other Financial Industry Affiliations: EAG has arrangements that are material to its advisory business or its clients/participants with the related entities shown below. These related entities may receive certain fees that are unrelated to EAG’s fees for its Services. Recordkeeping and Administrative Services Company: Empower Retirement, LLC (Empower) is a comprehensive administrative and recordkeeping services provider for financial institutions and employers, which include educational, advisory, enrollment, and communication services for employer-sponsored defined contribution plans and associated defined benefit plans under IRC Section 401(a), 401(k), 403(b), 408, and 457. Insurance Companies: Empower Annuity Insurance Company of America (EAICA) is an insurance company domiciled in the State of Colorado. EAG is a wholly owned direct subsidiary of ESH US, which is owned by EAICA. EAICA, pursuant to various agreements, may provide investment products, recordkeeping, and other administrative services through its affiliates. Empower Life & Annuity Insurance Company of New York (ELAINY) is an insurance company domiciled in the State of New York. EAG is under common control with ELAINY and is an affiliate of ELAINY where EAICA indirectly owns EAG and is the sole owner of ELAINY. ELAINY, pursuant to various agreements, may provide investment products and administrative services through its affiliate, Empower, to retirement plans for which EAG may also provide its services. Empower Annuity Insurance Company (EAIC) is an insurance company domiciled in the State of Connecticut. EAG is under common control with EAIC and is an affiliate of EAIC where EAICA indirectly owns EAG and is the sole owner of EAIC. EAIC, pursuant to various agreements, may provide investment products and administrative services individually and through its affiliate, Empower, to retirement plans for which EAG may also provide its services. 10  Broker-Dealer: Empower Financial Services, Inc. (EFSI), an affiliate of EAG, is a registered limited broker-dealer and wholly owned subsidiary of EAICA. 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. All transactions that occur as a result of participation in the Service are executed by EFSI. EFSI may receive compensation in the form of 12b-1 fees or other compensation from the mutual fund companies or from the other investments that may be available as investment options. Trust Company: Empower Trust Company, LLC (ETC) is a trust company and affiliate of EAG. ETC is a wholly owned subsidiary of ESH US, which is a wholly owned subsidiary of EAICA. ETC is chartered under the laws of the State of Colorado. ETC may provide discretionary or directed trustee and/or custodial services for EAG’s clients. ETC also serves as the trustee for certain collective investment trusts, which may be available as investment options, and is the custodian of all Empower Premier IRA accounts. Investment Company: Empower Funds, Inc. (EFI or Empower Funds) is an investment company affiliated with EAG. It is registered under the Investment Company Act of 1940. Empower Funds may provide investment products to retirement plans and IRAs for which EAG may also provide its services. Empower Capital Management, LLC manages Empower Funds as discussed below. Shares of Empower Funds may be available for purchase by retirement plans advised by EAG or to account holders of the Empower Premier IRA, Empower Managed Portfolios or Empower Premier Investment Account. Investment Advisers: Empower Capital Management, LLC (ECM), an affiliate of EAG, is an investment adviser for EFI and is registered under the Advisers Act. It is a wholly owned subsidiary of ESH US, which is a wholly owned subsidiary of EAICA. EAG provides managed account and advice services to participants in certain defined contribution plans. It also provides services to account holders of the Empower Premier IRA, which may have as investment options certain portfolios of Empower Funds managed by ECM. Irish Life Investment Managers Limited (ILIM) – a Dublin, Ireland based, SEC registered investment adviser. ILIM is part of the Lifeco group of companies; Lifeco has operations in Canada, the United States, Europe, and Asia through ownership of companies including EAICA. EAG is an indirect wholly owned subsidiary of EAICA. EAICA is an indirect wholly owned subsidiary of Lifeco, which controls ILIM. ILIM manages the index series of Empower Funds. Holding Company: Great-West Lifeco Inc. (Lifeco), EAG’s indirect parent company, owns approximately 6% of Franklin Templeton Investments’ parent company, Franklin Resources, Inc. (Franklin) as of January 1, 2024. Franklin or certain of its investment management subsidiaries (collectively, the Franklin Group entities) may provide management, advisory or sub-advisory services to investment funds that may be investment options in a Managed Account. Franklin and Lifeco have entered into arrangements under which Lifeco has committed to allocate Lifeco and affiliate assets over a period of time to be managed by Franklin’s investment managers and to support the availability of Franklin Group entity products and services on enterprise platforms. As a result, Empower and Lifeco will derive an economic benefit to the extent that Franklin Group entities provide management, advisory or sub-advisory services to funds or products. If certain Franklin revenue thresholds are achieved under those arrangements, Lifeco will receive contingent transaction consideration and Lifeco and other Empower affiliates will derive an economic benefit if assets are allocated to a Franklin investment option. Branding: The affiliated companies of EAG, ECM, EFSI, EAICA, EAIC, ELAINY, Empower Funds, Empower, and ETC operate under the multiple brands of Empower and Empower Institutional depending upon the products, services and retirement markets involved. These brands do not materially affect the internal structure of EAG or EAG’s corporate ownership. Conflicts of Interest: The investment options available in a plan are generally established by the plan sponsor/client through which our services are delivered. In some cases, the plan investment options may include, or be comprised solely of, affiliated investment options of the institutional client or of EAG. EAG does not receive compensation from its parent company or any of its affiliates as a result of these allocations. EAG has a relationship with Morningstar Investment Management wherein Morningstar Investment Management acts as sub-adviser for the advisory services. EAG has entered into an agreement with Morningstar Investment Management under which EAG receives advisory service fees for providing services to retirement plan clients. EAG mitigates these conflicts of interest related to affiliated investment options by utilizing Morningstar Investment Management as sub- adviser who remains independent from EAG and its related persons with respect to their methods of analysis and investment strategies. Morningstar Investment Management’s methodology also controls the investment allocations and recommendations. A client/account 11  holder will pay advisory fees to EAG for the MA Service, and indirectly to ECM, if the retirement plan investment options include Empower Funds. The fund share price includes the fees paid to ECM for management of the Empower Funds. Conflicts relating to fund recommendations: The Services operate by recommending or allocating a user’s assets to funds available within a plan. The funds available for EAG’s recommendations within a plan are generally established by the plan sponsor/client through which the Services are delivered, rather than by EAG. In some cases, the investment options may include or be comprised solely of investment options sponsored by EAG’s affiliates. In other cases, the investment options may make third-party payments as described below. When this occurs, EAG’s affiliates may receive additional compensation as a result of EAG’s recommendations or allocations. These forms of additional affiliate compensation are: • • • Proprietary investment funds. EAG’s affiliates offer proprietary investment funds, and EAG may recommend or allocate your assets to our affiliates’ proprietary investment funds, including proprietary mutual funds and collective investment trusts. These proprietary investment funds generate additional investment management fees to EAG’s family of companies. This is because EAG’s affiliates provide investment management services to the proprietary fund for services like administering, managing, and supervising these funds. For example, a plan participant using the Services will pay advisory fees to EAG and indirectly to ECM if the retirement plan investment options include Empower Funds, and EAG recommends an allocation to an Empower Funds product. The fund share price includes the fees paid to ECM for management of the Empower Funds. Proprietary insurance products. EAG’s indirect parent company, EAICA, offers proprietary insurance products for investment. EAG may recommend or allocate your assets to different types of EAICA insurance products and funding agreements. The majority of EAICA insurance products are annuity contracts that are structured either as a general account product or as a separate account product. If you invest in a general account product, which is an insurance product backed by the general account of an insurance company, EAG’s affiliates generate revenue by retaining spread (which is the difference between actual earnings on contracts offered by the insurer), and the crediting rate declared and guaranteed by the insurer through the contract. EAG’s affiliates may also receive different types of fee income if you invest in the separate accounts and other third-party payments associated with investments held therein. Third-Party Payments. EAG’s affiliates may receive payments from other firms, non-proprietary investment funds or products, or providers, such as revenue sharing payments, in connection with the investments made pursuant to our recommendation or investment management. Conflicts related to increased use and promotion of the Services: • Increased advisory fee income. EAG’s representatives may recommend that you use the Services. If you enroll in certain Services, EAG will earn additional compensation. • Increased affiliate fee income. When you use the Services, EAG may recommend you increase contributions or utilize other savings or investment strategies. EAG’s affiliates provide a bundle of recordkeeping, trust, custody, brokerage, investment, and other related services to retirement plans. If you pay for these related services through an arrangement where our affiliates charge a direct fee, EAG’s affiliates may receive additional fees for these services. These additional fees result from EAG’s recommendations because you may contribute, invest, or transact in more assets with EAG’s family of companies. EAG’s affiliates may receive payments from other firms, non-proprietary investment funds or products, or providers, such as revenue sharing payments, in connection with the investments made pursuant to our recommendation or investment management. • Representative Compensation. EAG has authorized its individual adviser representatives and EFSI, an affiliate of EAG, and its licensed agents and registered representatives who are Empower employees (collectively referred to as, “Agents”) to solicit, refer and market EAG’s services. Agents receive a salary and are eligible to receive incentive compensation (including bonus payments) paid by Empower. Certain Agents serve in “Wealth Solutions Advisor,” and similar roles that educate prospective clients about available products and services, and, provide investment advice. Agents receive incentive compensation paid by Empower when they refer a retirement plan participant to an EAG representative in its rollover/distribution call center to consider whether to roll over plan assets into advisory accounts with EAG. Depending on the position type of the referring Agent, an Agent also receives incentive compensation paid by Empower when the referred participant ultimately rolls over assets into and funds an advisory account with EAG. Under an incentive compensation plan applicable to Wealth Solutions Advisors and certain other roles, incentive compensation is based, in part, on funded net asset accumulation and retention and compensation varies by product “grade” (or tier). Specifically, Grade 1 products include Empower Personal Cash and self-directed brokerage accounts (taxable and IRA/SEP); Grade 2 products include Empower Investment Account, Empower Managed Portfolio, SmartSolution IRA/Roth IRA, and Premier Non-Managed accounts; and Grade 3 products include Personal Strategy, Personal Strategy+, and Premier Managed accounts. Grade 1 products are self-directed and, when recommending or opening a self- directed brokerage account, Agents do not act in a fiduciary capacity. Payout rates are generally higher for higher-grade products based on individual product complexity and the requisite expertise required of Agents to discuss and open such products. These arrangements create conflicts of interest because Agents have financial incentives to recommend or encourage enrollment in, or selection of, certain products or services or to encourage rollovers or transfers of additional assets. Compensation paid to Agents does not increase the fees paid by account holders. 12  Other Agents’ individual performance goals, within Workplace Planning & Advice and including, but not limited to, Workplace Planning Consultants, are based on a combination of factors including the number and quality of customer engagements during the measurement period and the amount of customer assets retained or accumulated as a result of those engagements. Depending on position type, performance goals also include: total asset growth and retention (including retention and external rollover ratios); introductions or referrals to Wealth Solutions Advisors (described above); client satisfaction measures; and planning-activity measures (such as advice acceptance rates). Additional qualitative factors include leadership, teamwork, client experience, quality and efficiency of client interactions, and adherence to corporate policies and regulatory standards. Incentive compensation is not guaranteed and is determined and paid periodically (for example, monthly or quarterly. Other Business Activities: Certain senior managers and officers of EAG may also serve as executive officers of EAG’s indirect parent company, EAICA, and other affiliates of EAG. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading EAG’s Code of Ethics EAG has adopted a written Code of Ethics (the Code) in compliance with Rule 204A-1 of the Advisers Act. The Code sets forth standards of business conduct expected of advisory personnel. It requires certain advisory personnel of EAG to report their personal securities holdings and transactions in accordance with the Advisers Act. EAG’s advisory personnel are required to comply with the Code. EAG will provide a copy of the Code to current or prospective clients upon request. The Code includes provisions related to: • • • • • • • • Fiduciary responsibility to clients; Compliance with federal securities laws; Protection and safeguarding of confidential information; Giving and receiving gifts, gratuities, and entertainment; Political contributions; Reporting and monitoring personal securities transactions; Avoiding and disclosing conflicts of interest; and Reporting violations of the Code. Personal Trading: The Code requires pre-clearance of certain securities transactions. Officers, managers, and certain employees of EAG (collectively, Access Persons) may trade for their own personal accounts in securities that are recommended to and/or purchased for EAG’s advisory clients. However, because the Code would permit Access Persons to invest in the same securities as clients in some circumstances, there is a possibility that employees could benefit from market activity by a client in a security held by an Access Person. As a result, trading is continually monitored in accordance with the Code and federal securities laws. The Code is intended to ensure that the personal securities transactions and the outside business activities of EAG’s Access Persons do not interfere with making decisions in the best interest of advisory clients. Principal Trading: EAG has adopted a policy and practice not to engage in any principal transactions. EAG holds no investments for its own accounts that could be bought from, or sold to, an advisory client. In the event of any change in EAG’s policy, management must approve any such change. Any principal transactions would be permitted only after meeting the review and approval requirements described under the anti- fraud section of the Advisers Act. Participation or Interest in Client Transactions: Affiliate EFSI effects Securities Transactions for Advisory 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 receive fees from either the plan or the investment provider (fund families). All securities transactions that occur as a result 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 affiliation with these entities is disclosed. Allocations in the investment options are solely determined and based on Morningstar Investment Management’s software and not determinations made by EAG. The compensation paid by EAG to Morningstar Investment Management for Morningstar Investment Management’s proprietary software advice program does not vary based on the allocations made or recommended by Morningstar Investment Management. Because Morningstar Investment Management is unaffiliated with EAG and EFSI, EAG does not believe there is a conflict of interest. 13  Affiliate EAICA or ELAINY Proprietary Investments Investment options into which participant or accountholder assets may be allocated pursuant to the OA or the MA Services may be through a fixed and variable deferred annuity issued by EAICA or ELAINY. Because Morningstar Investment Management is unaffiliated with EAG, EAICA, ELAINY and their affiliates, EAG does not believe there is a conflict of interest. However, in all instances, EAG’s affiliation with EAICA and/or EAICA’s affiliates, as applicable, will be disclosed. Affiliate Empower Empower receives a 35 bps shareholder service fee from the applicable shares of Empower Funds for recordkeeping and administrative services provided for account holders, pursuant to a Shareholder Services Agreement between the parties. Item 12 – Brokerage Practices Brokerage Selection; Best 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 compensation. Transactions recommended by Morningstar Investment Management for the Service are processed by EAG’s affiliated recordkeeper, Empower, and generally executed through EFSI. Soft Dollar Practices: As a matter of policy, EAG does not utilize research or other products or services from third parties in connection with client securities transactions on a soft-dollar commission basis. Directed Brokerage: The plan sponsor may elect to 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 in a brokerage account under the retirement plan. Trade Aggregation: 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, most trades are mutual funds where trade aggregation does provide any additional client benefits. Item 13 – Review of Accounts At least annually, EAG personnel review the methodologies used by Morningstar Investment Management to power the OA and MA Services to ensure that they are consistent with investment advisory best practices, current technology, applicable laws, and the terms of the agreement between EAG and Morningstar Investment Management. Neither EAG nor Morningstar Investment Management review the personal financial information of participants as provided by the participants or the Plan Sponsor and do not assume responsibility for any incomplete or erroneous information. Such information, which includes date of birth, salary, gender, and/or state of residence, must be reviewed periodically by the participant and/or the Plan Sponsor who in turn are responsible for notifying EAG of any changes, errors, or omissions to such information. EAG conducts the following review of its clients’ accounts: Online Advice: EAG does not conduct review of its participants’ accounts in respect to investment oversight, monitoring, or rebalancing. Participants receive EAG’s investment recommendations based on the investment options provided in their specific retirement plan. It is the responsibility of OA clients to review and update their accounts to adjust for changes in the investments they own and to determine whether the recommendations are suitable for their particular investment needs. OA clients should also review and update their accounts if significant changes occur in their personal circumstances. Managed Account Service: Under the MA Service, participant assets in the investment options are monitored, rebalanced, and reallocated on a periodic basis by EAG, based on Morningstar Investment Management’s software program. On an annual basis, based on the individual’s birth date, those enrolled in the MA Service will receive an Annual Kit containing an account update and forecast statement. Morningstar Investment Management updates the capital market assumptions underlying their methodology used to construct the asset classes, at least annually, then makes changes to the portfolio allocations, as necessary. EAG also regularly monitors the portfolios based on current portfolio allocations and makes adjustments as necessary. Reporting to Clients: Participants enrolled in the MA Service receive a MA Welcome Kit shortly after enrollment and an account update at least annually. Participants enrolled in OA can review their accounts and generate their own reports at any time. Individuals are encouraged to update 14  significant changes to their personal information via the appropriate toll-free customer service number. In addition, all individuals receiving Services are provided quarterly account statements generated by the plan’s recordkeeper. Item 14 – Client Referrals and Other Compensation EAG has authorized Agents to solicit, refer and market EAG’s services. Agents receive a salary and are eligible to receive incentive compensation (including bonus payments) paid by Empower. Certain Agents serve in “Wealth Solutions Advisor,” and similar roles that educate prospective clients about available products and services, and, provide investment advice. Agents receive incentive compensation paid by Empower when they refer a retirement plan participant to an EAG representative in its rollover/distribution call center to consider whether to roll over plan assets into advisory accounts with EAG. Depending on the position type of the referring Agent, an Agent also receives incentive compensation paid by Empower when the referred participant ultimately rolls over assets into and funds an advisory account with EAG. Under an incentive compensation plan applicable to Wealth Solutions Advisors and certain other roles, incentive compensation is based, in part, on funded net asset accumulation and retention and compensation varies by product “grade” (or tier). Specifically, Grade 1 products include Empower Personal Cash and self-directed brokerage accounts (taxable and IRA/SEP); Grade 2 products include Empower Investment Account, Empower Managed Portfolio, SmartSolution IRA/Roth IRA, and Premier Non-Managed accounts; and Grade 3 products include Personal Strategy, Personal Strategy+, and Premier Managed accounts. Grade 1 products are self- directed and, when recommending or opening a self-directed brokerage account, Agents do not act in a fiduciary capacity. Payout rates are generally higher for higher-grade products based on individual product complexity and the requisite expertise required of Agents to discuss and open such products. These arrangements create conflicts of interest because Agents have financial incentives to recommend or encourage enrollment in, or selection of, certain products or services or to encourage rollovers or transfers of additional assets. Compensation paid to Agents does not increase the fees paid by account holders. Other Agents’ individual performance goals, within Workplace Planning & Advice and including, but not limited to, Workplace Planning Consultants, are based on a combination of factors including the number and quality of customer engagements during the measurement period and the amount of customer assets retained or accumulated as a result of those engagements. Depending on position type, performance goals also include: total asset growth and retention (including retention and external rollover ratios); introductions or referrals to Wealth Solutions Advisors (described above); client satisfaction measures; and planning-activity measures (such as advice acceptance rates). Additional qualitative factors include leadership, teamwork, client experience, quality and efficiency of client interactions, and adherence to corporate policies and regulatory standards. Incentive compensation is not guaranteed and is determined and paid periodically (for example, monthly or quarterly). Compensation paid to Agents or EAG representatives does not increase the fees paid by the plan, plan sponsor or Members. Item 15 – Custody EAG does not maintain actual custody of its clients’ or participant’s cash, bank accounts, or securities. Pursuant to Rule 206(4)-2 of the Advisers Act as amended, EAG is deemed to have constructive custody with respect to certain client funds and securities. This is because an affiliated party is the custodian and directed or discretionary trustee of certain retirement plan accounts. In addition to annual audits, these accounts are subject to surprise custody verifications by an independent public accountant each year, as required by Rule 206(4)-2. If applicable, EAG’s clients receive periodic account statements (at least quarterly) from their custodian and should carefully review these statements. Certain clients may have assets held by unaffiliated custodians. Item 16 – Investment Discretion EAG provides discretionary investment management services for those plan participants who enroll and participate in the MA Service; EAG does not offer or engage in discretionary investment services for OA. The MA Service is a professional, flexible asset management program that utilizes data from the methodologies and proprietary software program developed and employed by its IFE, Morningstar Investment Management. To provide the MA Service to plan participants, EAG retains discretionary authority over the allocation of available investment options without requiring prior approval of each transaction. All ongoing investment transfers and investment direction changes are implemented for plan participants enrolled in the MA Service. Item 17 – Voting Client Securities EAG does not assume the responsibility to aid or vote proxies or other issuer communications regarding your Account, or to exercise voting or other decision-making authority regarding proxies or other issuer communications. Correspondence regarding the matters described in this section will be handled in connection with the Plan’s policies and service provider arrangements. EAG, as a registered investment adviser, and as a matter of practice, does not accept authority to vote client securities in connection with any of the services described in this Brochure. Correspondence regarding the matters described in this section will be handled in connection with the Plan’s policies and service provider arrangements. Item 18 – Financial Information As previously discussed, under certain circumstances EAG has discretionary authority over certain client funds and securities. Accordingly, EAG is required to disclose information about its financial condition that is reasonably likely to impair its ability to meet contractual commitments to its clients. EAG has no financial commitment that impairs its ability to meet contractual commitments to its clients, nor 15  has EAG been the subject of a bankruptcy proceeding. Further, EAG does not require or solicit prepayment of fees in excess of $1,200 per client more than six months in advance. This is not an Offer to Purchase or Sell Securities. The information contained in this Brochure, including information regarding Empower Funds, is for disclosure and other informational purposes only. It is not an offer to sell or a solicitation of an offer to buy any securities and may not be relied upon in connection with the purchase or sale of any security. 16 

Item 1 – Cover Page EMPOWER ADVISORY GROUP, LLC (EAG) Disclosure Brochure Online Advice & Professional Management Program 8515 East Orchard Road Greenwood Village, CO 80111 Telephone: 866-575-4977 www.empower.com/eag March 31, 2026 This Brochure provides information about the qualifications and business practices of Empower Advisory Group, LLC (EAG). Specifically, this Brochure provides information on the qualifications and business practices for the advisory services provided by EAG and sub-advised by Financial Engines Advisors L.L.C. (FEA). If you have any questions about the contents of this Brochure, please contact us at 866-575-4977. The information in this Brochure has not been approved or verified by the Securities and Exchange Commission (SEC) or by any state securities authority. EAG is a federally registered investment adviser under the Investment Advisers Act of 1940 (Advisers Act). Registration of EAG does not imply any level of skill or training. Additional information about EAG is available on the SEC website at www.adviserinfo.sec.gov or at EAG’s website at www.empower.com/EAG. The SEC’s web site also provides information about any person affiliated with EAG who is registered, or is required to be registered, as an investment adviser representative with EAG. Item 2 - Material ChangesThis section of the Brochure highlights and discusses any material changes that were made since the Adviser’s last update on September 19, 2025. A material change was made to Item 10 and Item 14 to describe changes to representative compensation. 1  Item 3 - Table of Contents Item 1 – Cover Page ........................................................................................................................................... 1 Item 2 -- Material Changes ................................................................................................................................ 1 Item 3 -- Table of Contents ................................................................................................................................ 2 Item 4 – Advisory Business ................................................................................................................................ 3 Item 5 — Fees and Compensation ..................................................................................................................... 8 Item 6 — Performance-Based Fees and Side-by-Side Management ................................................................. 9 Item 7 — Types of Clients .................................................................................................................................. 9 Item 8 — Method of Analysis, Investment Strategies and Risk of Loss ............................................................ 9 Item 9 — Disciplinary Information ................................................................................................................... 12 Item 10 – Other Financial Industry Activities and Affiliations .......................................................................... 13 Item 11 — Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................. 17 Item 12 — Brokerage Practices Brokerage Selection; Best Execution ............................................................ 18 Item 13 — Review of Accounts ........................................................................................................................ 19 Item 14 — Client/Member Referrals and Other Compensation ...................................................................... 19 Item 15 — Custody .......................................................................................................................................... 20 Item 16 — Investment Discretion .................................................................................................................... 20 Item 17 — Voting Client Securities .................................................................................................................. 20 Item 18 — Financial Information ..................................................................................................................... 20 2  Item 4 – Advisory Business Description of Advisory Firm EAG has been a registered investment adviser under the Advisers Act since 2000. EAG is also registered in all 50 states, the District of Columbia, Virgin Islands, Guam, and Puerto Rico. EAG offers investment management and advisory services to plan sponsors of employer-sponsored retirement plans such as 401(a), 401(k), 403(b) and 457 plans, including government entities and their participants, and to all account holders of the Empower Premier IRA (IRA holder or account holder). EAG does not choose the investments offered in employer-sponsored retirement plans or IRAs. EAG-serviced plans receive recordkeeping services through Empower Retirement, LLC (Empower), the recordkeeping entity affiliated with EAG. EAG also offers investment management services to individuals and to retail brokerage account holders. EAG’s sub-advisory relationship with FEA does not currently provide for investment management and advisory services to IRA holders, individuals or retail brokerage account holders. More information about EAG’s services, including an applicable brochure, can be obtained by contacting EAG at the number provided on the cover page of this Brochure or by visiting EAG’s website at: www.empower.com/eag. EAG is a wholly owned subsidiary of Empower Services Holdings US, LLC, (ESH US) a holding company domiciled in the State of Delaware. ESH US is owned by Empower Annuity Insurance Company of America (EAICA). EAICA is a direct, wholly owned subsidiary of Empower Holdings, LLC (EHL), a Delaware holding company. EHL is a direct wholly owned subsidiary of Great-West Lifeco U.S. LLC (Lifeco U.S.) and an indirect wholly owned subsidiary of Great-West Lifeco Inc. (Lifeco), a Canadian holding company. Lifeco is a subsidiary of Power Financial Corporation (Power Financial), a Canadian holding company with substantial interests in the financial services industry. Power Corporation of Canada (Power Corporation), a Canadian holding and management company, has voting control of Power Financial. The Desmarais Family Residuary Trust has voting control of Power Corporation, through a group of private holding companies it controls. Types of Services Discussed in this Brochure: As part of its sub-advisory relationship with FEA, EAG provides non-discretionary investment advisory services through an online service called Online Advice (OA) and discretionary investment advisory services through the Professional Management Program, and Professional Management Program with Income Beyond Retirement, all of which are referred to as Professional Management Program (PMP or Professional Management) (collectively, the Services). Participants that enroll in one of the advisory service programs are referred to as “Members.” Plan Sponsors or other entities who engage EAG to provide services are referred to as “Clients.” FEA can also advise with respect to collective trusts and insurance products if a plan sponsor includes those products with the investment lineup. There is no guarantee provided by any party that participation in any of the advisory services will result in a profit. Financial Engines Advisors, L.L.C. software to develop FEA is a registered investment adviser, wholly owned by Edelman Financial Engines, LLC, and is not affiliated with EAG or any company that is affiliated with EAG. FEA is headquartered in Santa Clara, California. A copy of FEA’s Form ADV Brochure may be obtained at either www.edelmanfinancialengines.com or http://www.adviserinfo.sec.gov. FEA utilizes proprietary individualized recommendations for allocation of assets within Member accounts. The methodology is designed to provide personalized and diversified investment recommendations for Members. Procedurally, FEA considers a variety of inputs, including desired retention of company stock (up to 20%), risk preference, asset class exposure limitations, assets held outside the plan and desired retirement age. FEA may also take into 3  consideration certain client holdings outside the retirement plan as part of its analysis where Members provide such information. Online Advice 1. OA is a non-discretionary service for Members to get objective advice. Members who choose to receive this service are responsible for implementing OA’s personalized recommendations within their retirement plan accounts and checking back regularly to get updated personalized recommendations. Neither FEA nor EAG places transactions on behalf of the Members or monitors the personalized recommendations OA Members receive. OA includes the following features: • A forecast of the potential future account value or the potential annual retirement income based on the information provided by a Member; • A forecast of the likelihood that a Member will achieve their self-reported retirement income or account value goals, taking into consideration the total household investment portfolio as known by the service; • Recommendations among the investment alternatives available in the employer-sponsored retirement plan (generally mutual funds, other investment company securities, and sometimes, one or more equity securities issued by the plan sponsor); and Guidance on savings rate and retirement age. • Members can use OA as frequently as they choose to monitor progress toward their retirement goals, receive forecasts and investment recommendations, and access available educational content. OA updates the investment information of most mutual funds and stocks in plan accounts daily. Members are responsible for periodically revisiting OA to: • Update account information to reflect changes in holdings, including purchases and sales of investments; • Update personal information (including retirement goals) to reflect changes in personal or financial circumstances; and/or Review any updates regarding changes to Member’s account value or forecast. • The failure of an OA Member to review and periodically update their personal and financial information can materially affect the value of the investment advisory services provided. For certain Members, some account information may be updated automatically when the Member revisits OA if EAG has an established electronic communications link with the Member’s plan sponsor and/or plan provider or other financial institution. For manually added and linked accounts, EAG relies on Members to provide ongoing and updated data either by logging in to refresh a linked account or by manually updating accounts that were added manually. OA offers Members investment analysis of mutual funds and stocks in the form of Scorecards. The Scorecards for individual equity securities depict the relative risk and historical performance of the individual stock. 4  Professional Management Program (PMP) 2. PMP is a discretionary service, which personalizes each portfolio to fit the Member’s needs and the specific characteristics of the plan by using the program’s methodology and information provided by the Member. PMP simulates thousands of scenarios to find an investment mix designed to optimize the Member’s opportunity for potential future value, including the goal of providing steady income through retirement. PMP may include any of the following features: • A Retirement Plan or similar document showing how EAG will manage and allocate the account, e.g., the portfolio allocation target, suggestions regarding the Member’s savings and a forecast regarding their likelihood of achieving their self-articulated retirement goals; • Periodic portfolio monitoring; • Quarterly Retirement Updates outlining, among other things, how the account is performing against goals; • Phone access to investment adviser representatives via a toll-free number as well as online account access; and • Non-discretionary investment advice on retirement accounts outside the plan account. PMP Members authorize EAG to direct the plan provider to execute transactions on a discretionary basis to move toward the account’s allocation target (and to otherwise manage the account) without prior approval of each transaction. PMP is generally made available to plan participants in a defined contribution plan through an agreement between EAG and the plan and/or the sponsoring employer. That agreement will specify the methods of enrollment into PMP for eligible plan participants, which may include: • An “opt-in” method of enrollment where a retirement plan participant actively elects to enroll in PMP; • An “opt-out” method of enrollment where eligible plan participants are automatically enrolled in PMP in accordance with plan or plan sponsor specifications, with the ability to withdraw at any time without penalty. With this type of enrollment, Professional Management may be designated as a qualified default investment alternative (“QDIA”), as permitted under the Employee Retirement Income Security Act (ERISA); or • Some combination of both methods, as determined by the plan or plan sponsor and as agreed to by EAG. Members who enroll in PMP grant EAG the discretionary authority to determine an allocation target for the plan account based upon a variety of inputs provided to EAG. This discretionary authority allows EAG to allocate the Member’s plan account among the menu of investment alternatives that have been selected by the plan or plan sponsor, typically excluding any brokerage window option (if applicable) or other plan-restricted investments. To allow EAG to provide PMP, the plan provider supplies information about each Member and the plan account. PMP Members may provide additional information to the program concerning a variety of inputs, including desired retention of company stock (up to 20%), risk preference, asset class exposure limitations, assets held outside the plan and desired retirement age. EAG may also take into consideration certain Member holdings outside the retirement plan as part of its analysis where the Member provides such information. 5  The program determines an investment strategy and an allocation target based on a Member’s current age, an assumption about the retirement age, the available investments for the account, any pension plan information provided, an assumption about risk tolerance that is based on the Member’s current age and assumed retirement age, the Member’s current portfolio allocation, and any additional information provided by the Member. Additional information provided by the Member may modify these parameters. During the period following enrollment, the program determines how to transition the account toward the allocation target and directs EAG regarding allocation of the account (which may include transfer or exchange directions). The program provides directions regarding new contributions to the account. Accounts of then-current PMP Members newly eligible for the Income Beyond Retirement feature of PMP may also be subject to a similar transition. Certain plan participants, such as plan sponsor “insiders,” as defined under applicable regulations, and non-U.S. participants in plans, may not be eligible for PMP. Income Beyond Retirement: Members may also, if their plan sponsor has elected to offer this service, access PMP’s Income Beyond Retirement feature. This service provides certain portfolio management and income payout options to retirees and near retirees from their 401(k) or similar plan account. For those who elect this feature, PMP manages the Member’s portfolio to balance between income and growth, seeking to protect the ability of the account to generate future income. Income Beyond Retirement also seeks to provide additional flexibility for a Member by allowing Members to determine the portion of their account to be managed on a standard “growth” objective and, separately, the portion to be managed on an “income” objective. Income Beyond Retirement seeks to manage investments and to create payouts that could continue into the Member’s early 90s. Upon request, in addition to managing the investment allocations in such accounts, EAG will work with the plan provider to calculate and facilitate withdrawals from the Member’s plan account post-retirement. Members pay no additional fees for the Income Beyond Retirement feature, and, if available, they can transition to an Income Beyond Retirement portfolio either automatically (upon eligibility) or at their request (as defined, in part, by the agreement between EAG and the relevant plan sponsor). An account balance is maintained for an optional out-of-plan annuity purchase. An in-plan annuity need not be included in a plan’s investment lineup for a plan sponsor to offer Income Beyond Retirement to its participants. While EAG may provide general educational information regarding an out-of-plan annuity, it does not sell or distribute annuities and does not receive any compensation related to out-of-plan annuity purchases. Affiliates of EAG may offer or sell annuities. Income Beyond Retirement availability is subject to establishment of certain data connectivity arrangements between EAG and the applicable plan provider and is subject to applicable retirement plan provisions related to plan withdrawals. As part of the suite of advisory services available to participants in employer-sponsored retirement plans described above, EAG may provide plan participants with a “Retirement Evaluation.” The Retirement Evaluation is delivered in printed or electronic format to specified plan participants who have not enrolled in the service, and is designed to communicate some (or all) of the following information: • A summary of the current value of the plan participant’s plan account; • A forecast of how much the plan account investments, and other investments that plan participants submit for analysis, might be worth at retirement; 6  • Whether a change is suggested to the plan participant’s contribution rate, their portfolio’s risk and diversification, unrestricted company stock holdings, target date usage, and/or investment style and allocation; Investment proposals; and • • A projection of the plan participant’s annual income at retirement, based on how much the plan account, Social Security, and certain other benefit accounts could provide. Once enrolled in PMP, Members delegate certain account management functions to EAG. As a result of the delegation, the following functions are no longer available to the Member: functionality for fund-to-fund transfers, fund change allocations, and/or the rebalancing tool. Members in PMP retain full-inquiry access to their account and may still request certain services from Empower, including approval for loans and distribution withdrawals. EAG does not manage restricted investments or Member assets held in a brokerage account under the retirement plan. However, the disclosure of any of these types of investments held by the Member may influence the recommendations provided on the managed assets. Termination of Services: Members may cancel their participation in PMP at any time by calling EAG at the toll-free customer service number. After cancellation of PMP, the Member will have the ability to make allocation and investment option changes to their account, usually within one to two business days following cancellation, subject to applicable investment restrictions. Accordingly, the plan participant’s asset allocation will remain the same as established in PMP at the time of the cancellation, unless and until the plan participant affirmatively and unilaterally changes their asset allocation after cancellation. Information: The use and storage of any information, including, without limitation, an individual’s personal and non- public information, account number, password, identification, portfolio information, and account balances is provided at the individual’s sole risk and responsibility. The individual is responsible for providing and maintaining the communications equipment (including personal computers and modems) and telephone or other services required for accessing and using electronic or automated services. The individual is also responsible for all communications service fees and charges incurred when accessing these services. EAG shall not bear any responsibility for either errors or failures caused by the malfunction of any computer, communication systems, computer viruses, or related problems that may be associated with the use of the services. 7  Assets Under Management: With respect to the services provided by EAG, as of December 31, 2025: Discretionary investment management among all services (including the PMP described herein) in the amount of: $ 164,237,996,079 Non-discretionary investment advisory services among all services in the amount of: $ 31,188,325,400 Total discretionary and non-discretionary investment management and advisory services in the amount of: $ 195,426,321,479 Item 5 — Fees and Compensation Online Advice - Advisory Fees and Compensation: There is no separate fee for OA. Professional Management Program – Advisory Fees and Compensation: Fees for PMP are negotiable on a plan sponsor-by-sponsor basis. Generally, Members in PMP pay EAG, on a periodic basis, usually quarterly, in arrears, based on a percentage of assets managed in their retirement plan account (up to 0.60%, typically declining for account balances greater than $100,000). The initial fee schedule may be reduced depending upon the various option(s) selected by the plan sponsor for its participants. Fees are subject to change and EAG may offer certain plan sponsors or Members discounted fees or other promotional pricing. Payment of Fees: Fees for service setup may be assessed to the plan sponsor, the plan, or participants prior to the Services being available for Member enrollment. Service setup fees may also be assessed if changes are made to the plan. When adopting the Services, plan sponsors determine if these fees will be paid by the plan sponsor, the plan, or Members. Annual platform fees may be invoiced to the client upon the Services being available for enrollment and thereafter on the anniversary date of establishing the Services for the plan. Additional Fees and Expenses: Members invested in mutual funds, separate accounts, collective investment alternatives and other investments may be subject to other fees, typically imposed by such investments. Fees, such as fund operating expenses or redemption fees, may be imposed at the investment company level. Information about the fees imposed by specific investment choices is available in the fund prospectuses or offering memoranda for the securities. EAG may allocate Member assets to funds or investment alternatives with these additional fees or costs. All securities transactions that occur as a result of the Services provided by EAG, as described in this Brochure, are executed by Empower Financial Services, Inc. (EFSI), for which EFSI 8  may receive compensation in the form of 12b-1 fees and other compensation from mutual fund companies and from the other investments that may be available as investment options. A Member will pay advisory fees to EAG for PMP. Additional investment management fees are paid to ECM if Empower Funds are included among the available investment options within a Member’s plan. The fees paid to ECM are for management of the Empower Funds; these management fees are included in the fund share price. EAG and EFSI representatives may recommend that you use the Services. If you elect to use PMP, EAG will earn additional compensation in the form of advisory fees. Also, EAG and EFSI representatives are eligible for incentive compensation (including bonus payments), in addition to their salary, for communicating with, educating and/or enrolling plan participants in the Services. The incentive or bonus compensation an EAG or EFSI representative receives depends on position type, but generally is calculated based on Empower’s profitability and the achievement of individual performance goals that may include factors unrelated to the adoption of investment products or services offered through Empower or EAG, such as the Services. See Item 10 and Item 14 for additional detail regarding these compensation arrangements and conflicts of interest Item 6 — Performance-Based Fees and Side-by-Side Management EAG does not charge any performance–based or side-by-side management fees. Item 7 — Types of Clients EAG is engaged by plan sponsor clients to provide investment advice to Members in their retirement plans for which Empower provides recordkeeping services. Members typically must be considered residents of the United States, the U.S. Virgin Islands, Guam, or Puerto Rico. The plan sponsor may apply additional restrictions for participation due to plan or regulatory requirements. A Member account must have at least $5 to receive the initial investment advice transaction. EAG may also be engaged by individuals to provide investment advisory services within or alongside EAG’s other advisory services and products, such as an Empower Premier IRA, an Empower Premier Investment Account, Personal Strategy and Personal Strategy+ Advisory Services, Core Managed Account Advisory Services, or certain brokerage accounts. Item 8 — Method of Analysis, Investment Strategies and Risk of Loss Methods of Analysis and Investment Strategies: FEA provides the analysis and investment strategies used in the OA and PMP Services. FEA utilizes proprietary software to develop individualized recommendations for the allocation of assets within individual retirement plan accounts. The methodology is designed to provide personalized and diversified investment recommendations for Members, considering variables such as time horizon to retirement, risk tolerance, outside assets and other personal circumstances. The methodology may also provide calculations for retirement plan installment distribution amounts. Methodology Overview: FEA’s investment philosophy is guided by certain basic principles, including: • Developing diversified portfolios that feature a range of asset classes and market sectors; • Utilizing holdings that strike a balance between those that are the most cost-effective and those that we forecast may offer added return; • Maintaining investment strategies, and often individual investments, longer term; 9  • Strategically reallocating investments as conditions warrant and as goals, time frames or other material realities of Members change; and • Periodically rebalancing as needed to ensure long-term commitment to overall strategies and allocation targets. On a Member level, FEA’s recommended or managed portfolio allocations are driven by many factors. Some of the key factors include: • Member investment objectives (i.e., growth, income, or a combination); • Member risk tolerance; • Member circumstances (time horizon, pensions, other household investments, state of residence, etc.); • Available investment securities within Member accounts; and Forward-looking models of securities’ risk expected returns, and correlations. • FEA’s approach may also be informed by certain established academic research, such as Modern Portfolio Theory and returns-based style analysis, as well as by established discoveries in behavioral finance. Although FEA may recommend more frequent trading or holding assets short-term in certain circumstances, frequent and/or short-term trading strategies are generally avoided. Based on that, it is anticipated that the primary advice will reflect strategies geared towards consistent and long-term strategies and holding periods. At times, however, there may be reasons to effect changes within an account. Reasons for reallocations to new or different allocations, or for tweaking existing portfolios, may include: • Client-driven: Changes in Member objectives, preferences or data may necessitate a revised target allocation. • Rebalancing: When an asset category or particular investment product has experienced a material appreciation or decline in value beyond the assigned relative percentage for that asset category or investment product, the extra amount may be sold, and the proceeds invested in asset categories or investment products that have not appreciated as much or have declined in percentage. • Updated assessment of forward-looking returns, risks, and correlations: FEA regularly updates its risk and return models, which may affect its assessment of prospects at the level of macroeconomic factors, asset classes, and/or individual investments. These updates may lead to revised target allocations in Member accounts. Consistent with its fiduciary duties, FEA’s policy is to exercise high levels of care and prudence in making and implementing investment decisions for Member accounts. FEA typically employs validation tests and operational, oversight and quality control procedures. However, FEA relies on a significant amount of data from multiple sources and cannot guarantee that all relevant data are free from error. Certain data are regularly presented to Members who are responsible for informing EAG of any inaccuracies in a timely manner. The methods of analysis and investment strategies applied to services offered to Members through the workplace depend in part on their stated goals. For Members on the growth objective, the program recommends portfolio allocation that is designed to maximize expected returns in a manner consistent with the Member’s stated risk level. For Members on the income objective, the program recommends a portfolio allocation designed to provide steady payouts in retirement in line with the Member’s needs, stated risk tolerance and time horizon, among other factors. 10  Due to algorithms and the statistical nature of FEA’s process, a number of potential portfolios will satisfy FEA’s criteria for an appropriate investment strategy and allocation. The optimal set of portfolios that offer the highest expected return for various levels of risk is often referred to as the “efficient frontier.” The efficient frontier is not a line, but instead is a thin band of portfolios with varying allocations. The portfolio that is selected for implementation is the product of optimization enhancements developed by FEA, which consider portfolio turnover, concentration, risk and expected return, and number of positions and transactions, among other factors. The universe of available investment alternatives may be designated by the plan sponsor or other plan fiduciary (in the case of a defined contribution plan account), or by a plan-appointed financial institution. Undesignated investments or securities may have characteristics similar or superior to those available investment alternatives being analyzed. Neither FEA nor EAG has authority or responsibility to select investment alternatives available for Member accounts, nor does FEA or EAG have the authority or responsibility to monitor investment choices for the continued appropriateness for inclusion, or to monitor the adequacy of the investment alternatives. General Risks of Investing: Investing in securities involves risk of loss that Members should be prepared to bear. Neither EAG nor FEA or their affiliates guarantee that the recommendations will result in achieving the retirement income goal. Neither EAG nor FEA or their affiliates can guarantee that negative returns can or will be avoided in any of the recommendations. An investment’s future performance may differ substantially from its historical performance and may incur a loss. Past performance is no guarantee of future results. Additionally, the plan provider may make changes from time to time with respect to the investment options available in the plan. While a diversified investment portfolio, including a portfolio of investment products representing different asset categories, can mitigate some risks, it does not and cannot prevent all losses. Ultimately, such risks are borne by the investor. Below are some of the common factors that can produce a loss in a Member’s account and/or in a specific investment product or asset category: • Market Risk: Stock and bond markets are volatile and can decline significantly in response to adverse issuer, political, regulatory, market or economic developments in the U.S. and in other countries. Market risk may affect a single company, a sector of the economy, a country or geopolitical region, or the market as a whole. Market risk may impact stock and/or bond markets in unanticipated and different ways. • Business Risk: These risks are associated with a particular industry or a particular company within an industry. • Capitalization Risk: Small-cap and mid-cap companies may be hindered due to limited resources or less diverse products or services, and their stocks have historically been more volatile than the stocks of larger, more established companies. • Category or Style Risk: During various periods of time, one category or style may underperform or outperform other categories and styles. • Credit Risk: The risk that the issuer of a security may be unable to make interest payments and/or repay principal when due. A downgrade to an issuer’s credit rating or a perceived change in an issuer’s financial strength may affect a security’s value and impact the performance of the issue along with any mutual fund or exchange-traded fund which holds it. 11  • Interest Rate Risk: The market value of a debt security is affected significantly by changes in interest rates. When interest rates rise, the debt security’s market value declines. When interest rates decline, market values rise. The longer bond maturity results in the greater risk and the higher yield. Conversely, the shorter bond maturity results in the lower risk and the lower yield. Inflation Risk: When any type of inflation is present, purchasing power may erode at the rate of inflation. • • Reinvestment Risk: The risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e., interest rate). This relates primarily to fixed income securities. • Exchange-traded funds: Exchange-traded funds present market and liquidity risks because they are listed on a public securities exchange and are purchased and sold via the exchange at the listed price. The price will vary based on current market conditions and may deviate from the net asset value of the exchange- traded fund’s underlying portfolio. There may also be an inactive market for certain funds, and/or losses from trading in secondary markets. • Target Date Funds: Generally, the asset allocation of each target date fund will change on an annual basis with the asset allocation becoming more conservative as the fund nears the target retirement date. The target date is the approximate date when investors plan to start withdrawing their money. The principal value of the fund(s) in a plan’s lineup is not guaranteed at any time, including at the time of target date and/or withdrawal. • An investment in a money market fund is not insured or guaranteed by the FDIC or any other government agency. Although some money market funds such as U.S. Government money market funds strive to preserve the value of the investment at $1.00 per share, it is possible to lose money by investing in a money market fund. Additionally, other money market funds may operate under new rules and regulations permitting them to have a “floating” value per share. A floating value may be more or less than $1.00 per share (depending on market conditions) and impose liquidity/redemption fees for large or frequent withdrawals. For more complete information about any of the mutual funds or investment products available within the retirement plan, please contact your retirement plan service provider. Risks Associated with Particular Types of Securities: Neither EAG nor its sub-advisers recommend a particular type of security. The plan sponsor or its agent is responsible for determining the retirement plan’s investment options. It is the Member’s responsibility to read all disclosure and related materials, including prospectuses, statements of additional information and other similar material. Item 9 — Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of EAG or the integrity of EAG’s management. EAG has the following disciplinary event to report relative to this item: On August 29, 2025, EAG and its broker/dealer affiliate, Empower Financial Services, Inc.(EFSI), settled a matter with the SEC. The SEC found that, from July 1, 2019 through December 31, 2022, certain retirement plan advisors of EFSI and EAG, all of whom were both registered representatives associated with EFSI and investment adviser representatives associated with EAG, did not sufficiently disclose whether retirement plan advisors were acting as a registered representative or an investment adviser representative when recommending that a plan participant enroll in EAG’s managed account service. Additionally, EFSI and EAG did not adequately 12  disclose the conflicts of interest presented by certain incentive compensation arrangements, leading to misleading statements made to plan participants. Finally, the SEC found that EFSI did not establish, maintain and enforce written policies and procedures reasonably designed to identify and address conflicts of interest in connection with recommendations to enroll in EAG’s managed account service. As a result, the SEC determined that EAG violated section 206(2) of the Investment Advisers Act of 1940 (“Advisers Act”) and EFSI failed to comply with the disclosure and conflict of interest obligations of Regulation Best Interest (“Reg BI”), thereby violating Reg BI’s General Obligation (Exchange Act Rule 15l-1(a)(1)). Without admitting or denying the findings, EFSI and EAG entered into a settlement with the SEC, pursuant to which EAG was censured; ordered to cease and desist from committing or causing any future violations of Section 206(2) of the Advisers Act thereunder; and EAG agreed to pay a civil monetary penalty in the amount of $750,000; and disgorgement of $4,063,569.80. EFSI was censured; ordered to cease and desist and agreed to pay a civil monetary penalty of $750,000. Item 10 – Other Financial Industry Activities and Affiliations EAG is not a registered broker-dealer. However, due to the organizational structure of EAG’s indirect parent company, EAICA, certain registered representatives of EFSI are also supervised persons of EAG and are required to comply with EAG policies and procedures when acting in that capacity. EAG and its management persons are not registered as a futures commission merchant, commodity pool operator, a commodity trading advisor, or an associated person of the foregoing entities. Other Financial Industry Affiliations EAG has arrangements that are material to its advisory business or its clients or Members with the related entities shown below. These related entities may receive certain fees that are unrelated to EAG’s fees for its services. Recordkeeping and Administrative Services Company institutions and employers, which Empower Retirement, LLC (Empower) is a comprehensive administrative and recordkeeping services provider for financial include educational, advisory, enrollment, and communication services for employer-sponsored defined contribution plans and associated defined benefit plans under Internal Revenue Code Section 401(a), 401(k), 403(b), 408, and 457. Insurance Companies Empower Annuity Insurance Company of America (EAICA) is an insurance company domiciled in the State of Colorado. EAG is a wholly owned direct subsidiary of Empower Services Holdings US, LLC, (ESH US), which is owned by EAICA. EAICA, pursuant to various agreements, may provide investment products, recordkeeping, and other administrative services through its affiliates. Empower Life & Annuity Insurance Company of New York (ELAINY) is an insurance company domiciled in the State of New York. EAG is under common control with ELAINY and is an affiliate of ELAINY where EAICA indirectly owns EAG and is the sole owner of ELAINY. ELAINY, pursuant to various agreements, may provide investment products and administrative services through its affiliate, Empower, to retirement plans for which EAG may also provide its services. Empower Annuity Insurance Company (EAIC) is an insurance company domiciled in the State of Connecticut. EAG is under common control with EAIC and is an affiliate of EAIC where EAICA indirectly owns EAG and is the sole owner of EAIC. EAIC, pursuant to various agreements, may provide investment products and 13  administrative services individually and through its affiliate, Empower, to retirement plans for which EAG may also provide its services. Broker-Dealer Empower Financial Services, Inc. (EFSI), an affiliate of EAG, is a registered broker/dealer and wholly owned subsidiary of EAICA. It is responsible for the trades which are executed within PMP and OA. 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. All transactions which occur as a result of participation in PMP and OA are executed by EFSI. EFSI may receive compensation in the form of 12b-1 fees or other compensation from the mutual fund companies or from the other investments that may be available as plan investment options. Trust Company Empower Trust Company, LLC (ETC) is a trust company and affiliate of EAG. ETC is a wholly owned subsidiary of ESH US, which is a wholly owned subsidiary of EAICA. ETC is chartered under the laws of the State of Colorado. ETC may provide discretionary or directed trustee and/or custodial services for EAG’s clients/Members. ETC also serves as the trustee for certain collective investment trusts, which may be available as plan investment options, and is the custodian of all Empower Premier IRAs. Investment Company Empower Funds, Inc. (EFI) is an investment company affiliated with EAG. It is registered under the Investment Company Act of 1940. EFI may provide investment products to retirement plans for which EAG may also provide its services. Empower Funds is managed by Empower Capital Management, LLC as discussed below. Shares of Empower Funds may be available for purchase by retirement plans advised by EAG or to account holders of the Empower Premier IRA; Empower Managed Portfolios or Empower Premier Investment Account. Investment Advisers Empower Capital Management (ECM), an affiliate of EAG, is an investment adviser for EFI and is registered under the Investment Advisers Act of 1940. It is a wholly owned subsidiary of ESH US, which is a wholly owned subsidiary of EAICA. EAG provides its discretionary and non-discretionary services to participants in certain defined contribution plans; a plan may select certain portfolios of Empower Funds managed by ECM as investment options within the plan. Irish Life Investment Managers Limited (ILIM) is a Dublin, Ireland based, SEC registered investment adviser. ILIM is part of the Great-West Lifeco, Inc. (Lifeco) group of companies; Lifeco has operations in Canada, the United States, Europe, and Asia through ownership of companies including EAICA. EAG is an indirect wholly owned subsidiary of EAICA. EAICA is an indirect wholly owned subsidiary of Lifeco, which controls ILIM. ILIM manages the index series of Empower Funds. Holding Company Great-West Lifeco Inc. (Lifeco), EAG’s indirect parent company, owns approximately 6% of Franklin Templeton Investments’ parent company, Franklin Resources, Inc. (Franklin) as of January 1, 2024. Franklin or certain of its investment management subsidiaries (collectively, the Franklin Group entities) may provide management, advisory or sub-advisory services to investment funds that may be investment options in a Managed Account. Franklin and Lifeco have entered into arrangements under which Lifeco has committed to allocate Lifeco and affiliate assets over a period of time to be managed by Franklin’s investment managers and to support the availability of Franklin Group entity products and services on enterprise platforms. As a result, Empower and Lifeco will derive an economic benefit to the extent that Franklin Group entities provide 14  management, advisory or sub-advisory services to funds or products. If certain Franklin revenue thresholds are achieved under those arrangements, Lifeco will receive contingent transaction consideration and Lifeco and other Empower affiliates will derive an economic benefit if assets are allocated to a Franklin investment option. Branding: The affiliated companies of EAG; ECM; EFSI; EAICA; ELAINY; EAIC; EFI; Empower Retirement, LLC; and ETC operate under the multiple brands of Empower and Empower Institutional depending upon the products, services and retirement markets involved. These brands do not materially affect the internal structure of EAG or EAG’s corporate ownership. Conflicts of Interest: The plan investment options available in PMP are chosen by the plan sponsor/client. In some cases, the plan investment options may include or be comprised solely of affiliated investment options of the institutional client or of EAG. Participation in PMP may result in an allocation to one or more investment options managed by an affiliate of EAG. EAG does not receive compensation from its parent company or any of its affiliates as a result of these allocations. EAG has a relationship with FEA wherein FEA acts as sub-adviser for the advisory services. EAG has entered into an agreement with FEA under which EAG receives advisory services fees for providing advisory services to retirement plan clients. EAG mitigates these conflicts of interest related to affiliated investment options by utilizing FEA as sub- adviser that remains independent from EAG and its related persons in their methods of analysis and investment strategies. FEA’s methodology also controls the investment allocations and recommendations. A Member will pay advisory fees to EAG for PMP, and indirectly to ECM, if Empower Funds are included among the available investment options within a Member’s plan and are invested in by the Member. If applicable, the fees paid to ECM for management of the Empower Funds are included in the fund share price. Conflicts relating to fund recommendations: The Services operate by recommending or allocating a Member’s assets to funds available within a plan. The funds available for EAG’s recommendations within a plan are generally determined by the plan sponsor/client through which the Services are delivered, rather than by EAG. In some cases, the investment options may include or be comprised solely of investment options offered by EAG’s affiliates, as selected and determined by the plan sponsor/client. In other cases, the investment options may make third-party payments described below. When this occurs, EAG’s affiliates may receive additional compensation as a result of EAG’s recommendations or allocations. These forms of additional affiliate compensation are: • Proprietary investment funds. EAG’s affiliates offer proprietary investment funds and EAG may recommend or allocate assets to our affiliates’ proprietary investment funds, including proprietary mutual funds and collective investment trusts through EFI and ETC, respectively. These proprietary investment funds generate additional investment management fees to EAG’s family of companies. This is because EAG’s affiliates provide investment management services to the proprietary fund, for services like administering, managing, and supervising these funds. For example, a Member using the Services will pay advisory fees to EAG and indirectly to ECM if Empower Funds are included in the retirement plan investment options, and an allocation is made to an EFI product. The fees paid to ECM for management of the Empower Funds are included in the fund share price. • Proprietary insurance products. EAG’s indirect parent company, EAICA, offers proprietary insurance products for investment. EAG may recommend or allocate your assets to different types of EAICA insurance products and funding agreements. The majority of EAICA insurance products are annuity 15  contracts that are structured either as a “general account” product or as a “separate account” product. If you invest in a general account product, which is an insurance product backed by the general account of an insurance company, EAG’s affiliates generate revenue by retaining spread (which is the difference between actual earnings on contracts offered by the insurer) and the crediting rate declared and guaranteed by the insurer through the contract. EAG’s affiliates may also receive different types of fee income if you invest in the separate accounts and other third-party payments associated with investments held therein. • Third-Party Payments. EAG’s affiliates may receive payments from other firms, non-proprietary investment funds or products, or providers, such as revenue sharing payments, in connection with the investments made pursuant to recommendations or investment management. Conflicts related to increased use and promotion of the Services: • Increased advisory fee income. EAG’s representatives may recommend that you use the Services. If you enroll in certain Services, such as PMP, EAG will earn additional compensation in the form of advisory fees. • Increased affiliate fee income. When you use the Services, EAG may recommend you increase contributions or utilize other savings or investment strategies. EAG’s affiliates provide a bundle of recordkeeping, trust, custody, brokerage, investment, and other related services to retirement plans and other investment accounts. If you pay for these related services through an arrangement where our affiliates charge a direct fee, EAG’s affiliates may receive additional fees for these services. These additional fees result from EAG’s recommendations because you may contribute, invest, or transact in more assets with EAG’s family of companies. • Representative Compensation. EAG has authorized its individual adviser representatives and EFSI, an affiliate of EAG, and its licensed agents and registered representatives who are Empower employees (collectively referred to as, “Agents”) to solicit, refer and market EAG’s services. Agents receive a salary and are eligible to receive incentive compensation (including bonus payments) paid by Empower. Certain Agents serve in “Wealth Solutions Advisor,” and similar roles that educate prospective clients about available products and services, and, provide investment advice. Agents receive incentive compensation paid by Empower when they refer a retirement plan participant to an EAG representative in its rollover/distribution call center to consider whether to roll over plan assets into advisory accounts with EAG. Depending on the position type of the referring Agent, an Agent also receives incentive compensation paid by Empower when the referred participant ultimately rolls over assets into and funds an advisory account with EAG. Under an incentive compensation plan applicable to Wealth Solutions Advisors and certain other roles, incentive compensation is based, in part, on funded net asset accumulation and retention and compensation varies by product “grade” (or tier). Specifically, Grade 1 products include Empower Personal Cash and self-directed brokerage accounts (taxable and IRA/SEP); Grade 2 products include Empower Investment Account, Empower Managed Portfolio, SmartSolution IRA/Roth IRA, and Premier Non-Managed accounts; and Grade 3 products include Personal Strategy, Personal Strategy+, and Premier Managed accounts. Grade 1 products are self-directed and, when recommending or opening a self-directed brokerage account, Agents do not act in a fiduciary capacity. Payout rates are generally higher for higher-grade products based on individual product complexity and the requisite expertise required of Agents to discuss and open such products. These arrangements create conflicts of interest because Agents have financial incentives to recommend or encourage enrollment in, or selection of, certain products or services or to encourage rollovers or transfers of additional assets. Compensation paid to Agents does not increase the fees paid by account holders. 16  Other Agents’ individual performance goals, within Workplace Planning & Advice and including, but not limited to, Workplace Planning Consultants, are based on a combination of factors including the number and quality of customer engagements during the measurement period and the amount of customer assets retained or accumulated as a result of those engagements. Depending on position type, performance goals also include: total asset growth and retention (including retention and external rollover ratios); introductions or referrals to Wealth Solutions Advisors (described above); client satisfaction measures; and planning-activity measures (such as advice acceptance rates). Additional qualitative factors include leadership, teamwork, client experience, quality and efficiency of client interactions, and adherence to corporate policies and regulatory standards. Incentive compensation is not guaranteed and is determined and paid periodically (for example, monthly or quarterly). Other Business Activity Certain senior managers and officers of EAG may also serve as executive officers of EAG’s indirect parent company, EAICA and other affiliates of EAG. Item 11 — Code of Ethics, Participation or Interest in Client Transactions and Personal Trading EAG Code of Ethics EAG and FEA have each adopted their respective Code of Ethics pursuant to Rule 204A-1 of the Investment Advisers Act of 1940 (Advisers Act). EAG’s Code of Ethics (EAG’s Code) sets forth a standard of business conduct expected of advisory personnel. It requires EAG’s advisory personnel, among other things, to report their personal securities holdings and transactions in accordance with the Advisers Act. EAG’s Access Persons must comply with EAG’s Code. A copy of EAG’s Code will be provided to the current or prospective clients, upon request. EAG’s Code includes provisions related to: • Fiduciary responsibility to clients/Members; • Compliance with federal securities laws; • Protection and safeguarding of confidential information; • Giving and receiving gifts, gratuities, and entertainment; • Political contributions; • Reporting and monitoring personal securities transactions; • Avoiding and disclosing conflicts of interest; and • Reporting violations of the EAG’s Code. Personal Trading EAG’s Code requires pre-clearance of certain securities transactions. Officers, managers, and certain employees of EAG (collectively, Access Persons) may trade for their own personal accounts in securities which are recommended to and/or purchased for EAG’s advisory clients. However, because EAG’s Code would permit Access Persons to invest in the same securities as clients/Members in some circumstances, there is a possibility that employees could benefit from market activity by a client/Member in a security held by an Access Person. As a result, trading is continually monitored in accordance with EAG’s Code and federal 17  securities laws. EAG’s Code is intended to ensure that the personal securities transactions and the outside business activities of EAG’s Access Persons do not interfere with making decisions in the best interest of advisory clients or Members. Principal Trading EAG has adopted a policy and practice not to engage in any principal transactions. EAG holds no investments for its own accounts which could be bought from, or sold to, an advisory client/Member. In the event of any change in EAG’s policy, any such change must be approved by management. Any principal transactions would be permitted only after meeting the review and approval requirements described under the anti-fraud section of the Advisers Act. Participation or Interest in Client Transactions: Affiliate EFSI Effects Securities Transactions for Advisory Clients Registered representatives of EFSI may make recommendations to retirement plan participants and 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 receive fees from either the plan or the investment provider (fund families). All securities transactions which occur as a result 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 affiliation with these entities is disclosed. Allocations in the investment options are solely determined and based on FEA’s software and not determinations made by EAG. The compensation paid by EAG to FEA for FEA’s proprietary software advice program does not vary based on the allocations made or recommended by FEA. Because FEA is unaffiliated with EAG and EFSI, EAG does not believe there is a conflict of interest. Affiliate Empower Retirement, LLC Empower Retirement, LLC receives a 35 bps shareholder service fee from the applicable shares of Empower Funds for recordkeeping and administrative services provided for account holders, pursuant to a Shareholder Services Agreement between the parties. Item 12 — Brokerage Practices Brokerage Selection; Best 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 nor recommend broker-dealers for stock transactions or self-directed brokerage accounts and does not determine the reasonableness of broker-dealer’s compensation. Transactions recommended by FEA for the PMP and OA are processed by our recordkeeper, Empower, and executed through EFSI. Soft Dollar Practices As a matter of policy, EAG does not utilize research, or other products or services from third parties in connection with client/Member securities transactions on a soft-dollar commission basis. 18  Directed Brokerage The plan sponsor may elect to 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 in a brokerage account under the retirement plan. Trade Aggregation EAG does not bunch orders or engage in block trades to execute equity orders for Members. Member accounts are generally held in trust per regulatory requirements. Further, most trades are mutual funds where trade aggregation does provide any additional Member benefits. Item 13 — Review of Accounts OA users may generate their own reports as frequently as they choose. OA Members are responsible for reviewing and updating their accounts to adjust for changes in the investments they own and to determine whether the recommendations are suitable for their particular investment needs. OA Members should review and update their accounts when significant changes occur in their personal circumstances. FEA may from time to time provide e-mail notifications to plan participants who elect to receive such messages, concerning changes in the value of the plan participants’ investments, chances of reaching the plan participants’ goals, or other OA account-related information. For PMP Members, account reviews are the responsibility of FEA for the services provided as sub-adviser. Working with support from FEA as well as the compliance department, EAG will conduct random Member account reviews to assure that the management of the account is consistent with the methodology of the FEA services and that the discretionary and non-discretionary investment advisory services are prudent from a fiduciary perspective. Designated personnel will conduct reviews. EAG reviews accounts on a periodic basis but will review accounts as needed based on circumstances (i.e., if a question or complaint is received by EAG). FEA, as sub-adviser, will provide quarterly reports to all Members enrolled in PMP. These reports include information regarding holdings, balances, transaction activity, and applicable estimated payout amounts. If requested by a retirement plan sponsor, FEA also will provide reports to plan sponsors reflecting plan level activity for a certain time period. Item 14 — Client/Member Referrals and Other Compensation EAG has authorized Agents to solicit, refer and market EAG’s services. Agents receive a salary and are eligible to receive incentive compensation (including bonus payments) paid by Empower. Certain Agents serve in “Wealth Solutions Advisor,” and similar roles that educate prospective clients about available products and services, and, provide investment advice. Agents receive incentive compensation paid by Empower when they refer a retirement plan participant to an EAG representative in its rollover/distribution call center to consider whether to roll over plan assets into advisory accounts with EAG. Depending on the position type of the referring Agent, an Agent also receives incentive compensation paid by Empower when the referred participant ultimately rolls over assets into and funds an advisory account with EAG. Under an incentive compensation plan applicable to Wealth Solutions Advisors and certain other roles, incentive compensation is based, in part, on funded net asset accumulation and retention and compensation varies by product “grade” (or tier). Specifically, Grade 1 products include Empower Personal Cash and self-directed brokerage accounts (taxable and IRA/SEP); Grade 2 products include Empower Investment Account, Empower Managed Portfolio, SmartSolution IRA/Roth IRA, and Premier Non-Managed accounts; and Grade 3 products include Personal Strategy, Personal Strategy+, and Premier Managed accounts. Grade 1 products are self-directed and, when recommending or opening a self-directed brokerage account, Agents do not act in a fiduciary capacity. Payout rates are generally higher 19  for higher-grade products based on individual product complexity and the requisite expertise required of Agents to discuss and open such products. These arrangements create conflicts of interest because Agents have financial incentives to recommend or encourage enrollment in, or selection of, certain products or services or to encourage rollovers or transfers of additional assets. Compensation paid to Agents does not increase the fees paid by account holders. Other Agents’ individual performance goals, within Workplace Planning & Advice and including, but not limited to, Workplace Planning Consultants, are based on a combination of factors including the number and quality of customer engagements during the measurement period and the amount of customer assets retained or accumulated as a result of those engagements. Depending on position type, performance goals also include: total asset growth and retention (including retention and external rollover ratios); introductions or referrals to Wealth Solutions Advisors (described above); client satisfaction measures; and planning- activity measures (such as advice acceptance rates). Additional qualitative factors include leadership, teamwork, client experience, quality and efficiency of client interactions, and adherence to corporate policies and regulatory standards. Incentive compensation is not guaranteed and is determined and paid periodically (for example, monthly or quarterly). Compensation paid to Agents or EAG representatives does not increase the fees paid by the plan, plan sponsor or Members. Item 15 — Custody EAG does not maintain actual custody of its clients’ or Members’ cash, bank accounts, or securities. Pursuant to Rule 206(4)-2 of the Advisers Act, EAG is deemed to have constructive custody with respect to certain client funds and securities. This is because an affiliated party is the custodian and directed or discretionary trustee of certain retirement plan accounts. In addition to annual audits, these accounts are subject to surprise custody verifications by an independent public accountant each year, as required by Rule 206(4)-2. If applicable, plan sponsors receive periodic account statements (at least quarterly) from their custodian and should carefully review these statements. Certain clients may have assets held by unaffiliated custodians. Item 16 — Investment Discretion EAG provides discretionary investment management services for those Members who enroll and participate in PMP; EAG does not offer or engage in discretionary investment services for OA. PMP is a professional, flexible asset management program that utilizes data from the methodologies and proprietary software program developed and employed by FEA. To provide PMP to plan participants, EAG retains discretionary authority over the allocation of available plan investment options without requiring prior approval of each transaction. All ongoing investment transfers and investment direction changes are implemented for Members enrolled in PMP. Each Member who actively enrolls in the program must agree to the Terms & Conditions for the program. Each Member who is auto-enrolled in the program, by direction of the plan sponsor, receives a copy of the Terms & Conditions. Item 17 — Voting Client Securities EAG, as a registered investment adviser, and as a matter of practice, does not accept authority to vote client/Member securities in connection with any of the Services described in this Brochure. Correspondence regarding the matters described in this section will be handled in connection with the Plan’s policies and service provider arrangements. Item 18 — Financial Information As previously discussed, under certain circumstances EAG has discretionary authority over certain client funds and securities. Accordingly, EAG is required to disclose only information about its financial condition that is reasonably likely to impair EAG’s ability to meet contractual commitments to its clients. EAG has no 20  financial commitment that impairs its ability to meet contractual commitments to its clients, nor has EAG been the subject of a bankruptcy proceeding. Finally, EAG does not require or solicit prepayment of fees in excess of $1,200 per client/Member more than six months in advance. This is not an Offer to Purchase or Sell Securities. The information contained in this Brochure, including information regarding Empower Funds, is for disclosure and other informational purposes only. It is not an offer to sell or a solicitation of an offer to buy any securities and may not be relied upon in connection with the purchase or sale of any security. 21 

Item 1 — Cover Page EMPOWER ADVISORY GROUP, LLC (EAG) Disclosure Brochure Financial Planning Service 8515 East Orchard Road Greenwood Village, CO 80111 Telephone: 833-301-9355 March 31, 2026 This Brochure provides information on the qualifications and business practices of Empower Advisory Group, LLC (EAG) for the financial planning services provided by EAG. If you have any questions about the contents of this Brochure, please contact us at 833-301-9355. The information in this Brochure has not been approved or verified by the Securities and Exchange Commission (SEC) or by any state securities authority. EAG is a registered investment adviser under the Investment Advisers Act of 1940 (Advisers Act). Registration of EAG does not imply any level of skill or training. Additional information about EAG is available on the SEC website at www.adviserinfo.sec.gov or at EAG’s website at https://www.empower.com/EAG. The SEC’s web site also provides information about any person affiliated with EAG who is registered, or are required to be registered, as an investment adviser representative with EAG. Item 2 — Material Changes This section of the Brochure highlights and discusses any changes that were made since the Adviser’s last update on September 19, 2025. A material change was made to Item 10 and Item 14 to describe changes to representative compensation. 1  Item 3 - Table of Contents Item 1 — Cover Page .......................................................................................................................................................... 1 Item 2 — Material Changes ................................................................................................................................................ 1 Item 3 – Table of Contents ................................................................................................................................................. 2 Item 4 – Advisory Business ................................................................................................................................................. 3 Item 5 — Fees and Compensation ....................................................................................................................................... 4 Item 6 — Performance-Based Fees and Side-by-Side Management ....................................................................................... 4 Item 7 — Types of Clients ................................................................................................................................................... 4 Item 8 — Method of Analysis, Investment Strategies and Risk of Loss .................................................................................. 4 Item 9 — Disciplinary Information ...................................................................................................................................... 6 Item 10 – Other Financial Industry Activities and Affiliations ................................................................................................ 6 Item 11 — Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............................................. 8 Item 12 — Brokerage Practices ........................................................................................................................................... 9 Item 13 — Review of Accounts ........................................................................................................................................... 9 Item 14 — Client Referrals and Other Compensation ........................................................................................................... 9 Item 15 — Custody .......................................................................................................................................................... 10 Item 16 — Investment Discretion ..................................................................................................................................... 10 Item 17 — Voting Client Securities .................................................................................................................................... 10 Item 18 — Financial Information ...................................................................................................................................... 10 2  Item 4 – Advisory Business Description of Advisory Firm EAG has been a registered investment adviser under the Advisers Act since 2000. EAG is also registered in all fifty states, the District of Columbia, US Virgin Islands, Guam, and Puerto Rico. EAG offers investment management and advisory services to plan sponsors of employer-sponsored retirement plans such as 401(a), 401(k), 403(b) and 457 plans, including government entities and their participants and to all account holders of the Empower Premier IRA (IRA holder, account holder). EAG does not choose the investments offered in employer-sponsored retirement plans or IRAs. EAG also offers investment management services to retail brokerage account holders. EAG serviced plans receive recordkeeping services through Empower Retirement, LLC (Empower), the recordkeeping entity affiliated with EAG. More information about EAG’s services, including an applicable brochure can be obtained by contacting EAG at the number provided on the cover page of this Brochure or by visiting EAG’s website at: www.empower.com/EAG. EAG is a wholly owned subsidiary of Empower Services Holdings US, LLC (ESH US), a holding company domiciled in the State of Delaware. Empower Annuity Insurance Company of America (EAICA) owns ESH US. EAICA is a direct wholly owned subsidiary of Empower Holdings, LLC (EHL), a Delaware holding company. EHL is a direct wholly owned subsidiary of Great-West Lifeco U.S. LLC. (Lifeco U.S.) and an indirect wholly owned subsidiary of Great-West Lifeco Inc. (Lifeco), a Canadian holding company. Lifeco is a subsidiary of Power Financial Corporation (Power Financial), a Canadian holding company with substantial interests in the financial services industry. Power Corporation of Canada (Power Corporation), a Canadian holding and management company, has voting control of Power Financial. The Desmarais Family Residuary Trust has voting control of Power Corporation, through a group of private holding companies that it controls. Types of Services EAG offers a comprehensive financial planning service (the Service). In the Service, you will consult with an EAG representative to discuss your life and household situation and your financial position, goals, and obligations. Prior to the consultation, EAG will gather information from your account(s) that are record kept, administered, and/or offered through Empower or its affiliates (Empower Account(s)) and from you to inform the Service. EAG will then produce a “point-in-time” financial plan for you and will review it with you. EAG generates the plan utilizing proprietary and/or third-party investment methodology and assumptions. The content of the financial plan will vary based on your financial position and other factors but typically includes suggestions on how you might potentially achieve financial goals, an investment risk analysis, and an evaluation of your insurance needs. EAG does not implement transactions from the financial plan unless you affirmatively request it. EAG does not review or monitor the financial plan on an ongoing basis. Also, EAG does not update the plan unless you re-engage with EAG to produce a subsequent, updated financial plan, even if you participate in the Service pursuant to an ongoing subscription pricing model. Additionally, EAG does not have discretion to act on your behalf as part of the Service. As such, you are responsible for instructing EAG to implement suggestions that EAG may make as part of the Service. You should carefully consider other relevant factors (such as tax implications) when deciding whether and how to implement suggestions generated by the Service. You are not obliged to use EAG or Empower to implement financial planning suggestions produced by the Service. There is no guarantee provided by any party that participation in any of the advisory services will result in a profit. Client Information The use and storage of any information provided is at the client’s sole risk and responsibility. Such information includes, without limitation, a client’s personal and non-public information, account number, password, identification, portfolio information, account balances and any other information available on a client’s personal computer. The client is responsible for providing and maintaining the communications equipment (including personal computers and modems) and telephone or other services required for accessing and using electronic or automated services, and for all communications service fees and charges incurred by the client in accessing these services. EAG shall not bear any responsibility for errors or failures caused by the malfunction of any computer, communication systems, any computer viruses, or related problems that may be associated with the use of the services. Assets under Management With respect to the services provided by EAG, as of December 31, 2025: Discretionary investment management among all services in the amount of: $ 164,237,996,079 $ 31,188,325,400 Non-discretionary investment advisory services among all services in the amount of: 3  $ 195,426,321,479 Total discretionary and non-discretionary investment management and advisory services in the amount of: Item 5 — Fees and Compensation The fees you pay for the Service depend on the type of your Empower account(s), as described below. In the case that your retirement plan sponsor pays for the Service, there is no additional cost to you. Service delivered through your retirement plan’s relationship with Empower: If you receive the Service in connection with your retirement plan’s relationship with Empower, EAG can receive a fee for the Service in several ways. Fees for the Service are negotiable on a plan sponsor-by-plan sponsor basis. • • • First, your retirement plan sponsor may pay EAG a fee from the plan sponsor’s own corporate assets, in which case you will pay no separate fee to use the Service; Second, a retirement plan’s fiduciaries may choose to offer the Service as part of the bundle of recordkeeping services that Empower provides to the plan, in which case you will pay no separate fee to use the Service; or Third, your employer and/or the retirement plan’s fiduciaries may offer you access to the Service if you pay the fee for EAG’s Service yourself. This fee may be a one-time fee, or an ongoing fee based on a subscription model. If EAG requires you to pay a separate fee for the Service, you will go through a vendor payment process where you will authorize the amount of the Service fee prior to receiving the Service. Service delivered through your employer’s relationship with Empower: If you receive the Service in connection with your employer’s relationship with Empower, EAG can receive a fee for the Service in several ways. Fees for the Service are negotiable on an employer-by- employer basis. • • First, your employer may pay EAG a fee from the employer’s own corporate assets, in which case you will pay no separate fee to use the Service; Second, your employer may offer you access to the Service for a fee as negotiated between the employer and EAG. In certain cases, EAG may agree to provide the Service for no fee. This fee may be a one-time fee, or an ongoing fee based on a subscription model. If EAG requires you to pay a separate fee for the Service, you will go through a vendor payment process where you will authorize the amount of the Service fee prior to receiving the Service. Service through an IRA or brokerage account: If you receive the Service through an IRA or brokerage account offered by Empower, you may pay a separate fee to EAG for the Service. This fee may be a one-time fee, or an ongoing fee based on a subscription model. You will go through a vendor payment process during which you will authorize the amount of the Service fee prior to receiving the Service. Fees are subject to change and EAG may offer certain plan sponsors or clients discounted fees or other promotional pricing. EAG will notify you of fee changes, and your continued use of the Service means that you accept any fee change. Subscription Service One-Time Use $299 one-time plus $29 monthly or if enrolled in Empower Managed Accounts, $199 one-time plus $15 monthly. $499, or $399 if enrolled in Empower Managed Accounts. You may upgrade from the one-time fee to the subscription service with no charge for the first 3 months and then $29 per month thereafter. EAG’s representatives may recommend that you use the Service. If you elect to use the Service, EAG will earn additional compensation since you will pay a fee for the service. Item 6 — Performance-Based Fees and Side-by-Side Management EAG does not charge any performance–based or side-by-side management fees. Item 7 — Types of Clients EAG provides investment advice and financial planning to clients in their retirement plans for which Empower provides recordkeeping services. EAG may also be engaged by individuals to provide investment advisory services within or alongside an IRA or, in some instances, a retail brokerage account. Clients typically must be considered residents of the United States, the U.S. Virgin Islands, Guam, or Puerto Rico. A plan sponsor may apply additional restrictions for participation due to plan or regulatory requirements. The Service requires the client to complete a separate agreement with EAG, which may include separate fees. EAG may also be engaged by individuals to provide investment advisory services within or alongside an Empower Premier IRA, an Empower 4  retail brokerage account or another plan elected managed account services. Item 8 — Method of Analysis, Investment Strategies and Risk of Loss Methods of Analysis and Investment Strategies The Service is designed to help individuals plan for future goals and needs. The Service addresses topics such as budgeting, debt management, savings strategies, life insurance, estate planning, retirement income planning, college planning, emergency savings planning, and social security planning. Since we cannot guarantee the accuracy of any assumption, we limit the assumptions to those most reasonable to predict. We believe using the long-term return on a portfolio, rebalanced annually, is more meaningful than predicting the performance of individual holdings. Additionally, we believe that focusing on clients’ savings and its relation to their current lifestyle is more reasonable than predicting their actual income and expenses for the next 30 years. For example, in consideration of individual budgeting difficulties and inconsistencies, we believe it is better to focus on what clients save by considering their income this year relative to the amount they saved and/or contributed to a 401(k) or IRA. If a client is not saving enough relative to their goals and objectives, or does not understand their spending habits, we believe that establishing a budget is an appropriate next step. Financial planning is an ongoing process. We want to show clients a financial plan that has a range of possibilities. Depending on a client’s goals and personal situation, the financial plan may need to be updated over time. An established financial plan helps clients make more appropriate decisions because they have better information. When clients focus only on short-term returns and financial objectives, they might miss the long-term returns and financial objectives. Therefore, when discussing progress towards goals with clients, it is important to provide the context of a long-term plan, rather than quarterly returns. General Risks of Investing Investing in securities involves risk of loss that clients should be prepared to bear. Neither EAG nor its affiliates guarantee that the recommendations will result in achieving the retirement income goal. Neither EAG nor its affiliates can guarantee that you can or will avoid negative returns in any of the recommendations. An investment’s future performance may differ substantially from its historical performance and may incur a loss. Past performance is no guarantee of future results. Additionally, for company retirement plans, the plan provider may make changes from time to time with respect to the investment options available in the plan. While a diversified investment portfolio, including a portfolio of investment products representing different asset categories, can mitigate some risks, it does not and cannot prevent all losses. Ultimately, the investor bears such risks. Below are some of the common factors that can produce a loss in a client’s account and/or in a specific investment product, or asset category: • • • • • • • • • • Market Risk: Stock and bond markets are volatile and can decline significantly in response to adverse issuer, political, regulatory, market or economic developments in the U.S. and in other countries. Market risk may affect a single company, a sector of the economy, a country or geopolitical region, or the market as a whole. Market risk may impact stock and or bond markets in unanticipated and different ways. Business Risk: These risks are associated with a particular industry or a particular company within an industry. Capitalization Risk: Limited resources or less diverse products or services may hinder Small-cap and mid-cap companies, and such companies’ stocks have historically been more volatile than the stocks of larger, more established companies. Category or Style Risk: During various periods of time, one category or style may underperform or outperform other categories and styles. Credit Risk: The risk that the issuer of a security may be unable to make interest payments and/or repay principal when due. A downgrade to an issuer’s credit rating or a perceived change in an issuer’s financial strength may affect a security’s value and impact the performance of the issue along with any mutual fund or exchange-traded fund that holds it. Interest Rate Risk: Interest rate changes significantly affect a debit security’s market. When interest rates rise, the debt security’s market value declines. When interest rates decline, market values rise. The longer bond maturity results in the greater risk and the higher yield. Conversely, the shorter bond maturity results in the lower risk and the lower yield. Inflation Risk: When any type of inflation is present, purchasing power may be eroding at the rate of inflation. Reinvestment Risk: The risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e., interest rate). This relates primarily to fixed income securities. Exchange-traded funds: Exchange-traded funds present market and liquidity risks because they are listed on a public securities exchange and are purchased and sold via the exchange at the listed price. The price will vary based on current market conditions and may deviate from the net asset value of the exchange-traded fund’s underlying portfolio. There may also be an inactive market for certain funds, and/or losses from trading in secondary markets. Target Date Funds: Generally, the asset allocation of each target date fund will change on an annual basis with the asset allocation becoming more conservative as the fund nears the target retirement date. The target date is the approximate date when investors plan to start withdrawing their money. The principal value of the fund(s) in a plan’s lineup is not guaranteed at any time, including at the time of target date and/or withdrawal. 5  • An investment in a money market fund is not insured or guaranteed by the Federal Deposit Insurance Corporation (FDIC) or any other government agency. Although some money market funds such as U.S. Government money market funds strive to preserve the value of the investment at $1.00 per share, it is possible to lose money by investing in a money market fund. Additionally, other money market funds may operate under rules and regulations permitting them to have a “floating” value per share. A floating value may be more or less than $1.00 per share depending on market conditions and impose liquidity/redemption fees for large or frequent withdrawals. For more complete information about any of the mutual funds or investment products available within a retirement plan or other investment account, please contact your service provider or account manager at the phone number on page 1. Risks Associated with Particular Types of Securities The plan sponsor or its agent is responsible for determining a retirement plan’s investment options. It is the client’s responsibility to read all disclosure and related materials, including prospectuses, statements of additional information, and other similar materials. Item 9 — Disciplinary Information EAG, as a registered investment adviser, is required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of EAG or the integrity of EAG’s management. EAG has the following disciplinary event to report relative to this item: On August 29, 2025, EAG and its broker/dealer affiliate, Empower Financial Services, Inc. (EFSI), settled a matter with the SEC. The SEC found that, from July 1, 2019 through December 31, 2022, certain retirement plan advisors of EFSI and EAG, all of whom were both registered representatives associated with EFSI and investment adviser representatives associated with EAG, did not sufficiently disclose whether retirement plan advisors were acting as a registered representative or an investment adviser representative when recommending that a plan participant enroll in EAG’s managed account service. Additionally, EFSI and EAG did not adequately disclose the conflicts of interest presented by certain incentive compensation arrangements, leading to misleading statements made to plan participants. Finally, the SEC found that EFSI did not establish, maintain and enforce written policies and procedures reasonably designed to identify and address conflicts of interest in connection with recommendations to enroll in EAG’s managed account service. As a result, the SEC determined that EAG violated section 206(2) of the Investment Advisers Act of 1940 (“Advisers Act”) and EFSI failed to comply with the disclosure and conflict of interest obligations of Regulation Best Interest (“Reg BI”), thereby violating Reg BI’s General Obligation (Exchange Act Rule 15l- 1(a)(1)). Without admitting or denying the findings, EFSI and EAG entered into a settlement with the SEC, pursuant to which EAG was censured; ordered to cease and desist from committing or causing any future violations of Section 206(2) of the Advisers Act thereunder; and EAG agreed to pay a civil monetary penalty in the amount of $750,000; and disgorgement of $4,063,569.80. EFSI was censured; ordered to cease and desist and agreed to pay a civil monetary penalty of $750,000. Item 10 – Other Financial Industry Activities and Affiliations EAG is not a registered broker-dealer. However, due to the organizational structure of EAG’s indirect parent company, EAICA, certain registered representatives of EFSI are also supervised persons of EAG and are required to comply with EAG policies and procedures when acting in that capacity. EAG and its management persons are not registered as a futures commission merchant, a commodity pool operator, a commodity trading advisor, or an associated person of the foregoing entities. Other Financial Industry Affiliations EAG has arrangements that are material to its advisory business or its clients with the related entities shown below. These related entities may receive certain fees that are unrelated to EAG’s fees for its services. Recordkeeping and Administrative Services Company Empower Retirement, LLC (Empower) is a comprehensive administrative and recordkeeping services provider for financial institutions and employers, which include educational, advisory, enrollment, and communication services for employer-sponsored defined contribution plans and associated defined benefit plans under Internal Revenue Code Section 401(a), 401(k), 403(b), 408, and 457. Insurance Companies Empower Annuity Insurance Company of America (EAICA) is an insurance company domiciled in the State of Colorado. EAG is a wholly owned direct subsidiary of ESH US, which is owned by EAICA. EAICA, pursuant to various agreements, may provide investment products, recordkeeping, and other administrative services through its affiliates. Empower Life & Annuity Insurance Company of New York (ELAINY) is an insurance company domiciled in the State of New York. EAG is under common control with ELAINY and is an affiliate of ELAINY where EAICA indirectly owns EAG and is the sole owner of ELAINY. ELAINY, pursuant to various agreements, may provide investment products and administrative services through its affiliate, Empower, to retirement plans for which EAG may also provide its services. 6  Empower Annuity Insurance Company (EAIC) is an insurance company domiciled in the State of Connecticut. EAG is under common control with EAIC and is an affiliate of EAIC where EAICA indirectly owns EAG and is the sole owner of EAIC. EAIC, pursuant to various agreements, may provide investment products and administrative services individually and through its affiliate, Empower, to retirement plans for which EAG may also provide its services. Broker-Dealer Empower Financial Services, Inc. (EFSI), an affiliate of EAG, is a registered broker-dealer and wholly owned subsidiary of EAICA. 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. EFSI executes the transactions that occur as a result of participation in the Service. EFSI may receive compensation in the form of 12b-1 fees, or other compensation from the mutual fund companies or from the other investments that may be available as investment options. Trust Company Empower Trust Company, LLC (ETC) is a trust company and affiliate of EAG. ETC is a wholly owned subsidiary of ESH US, which is a wholly owned subsidiary of EAICA. ETC is chartered under the laws of the State of Colorado. ETC may provide discretionary or directed trustee and/or custodial services for EAG’s clients. ETC also serves as the trustee for certain collective investment trusts which may be available as plan investment options and is the custodian of all Empower Premier IRAs. Investment Company Empower Funds, Inc. (EFI or Empower Funds), an investment company registered under the Investment Company Act of 1940, is affiliated with EAG. EFI may provide investment products to retirement plans for which EAG may also provide its services. Empower Capital Management, LLC manages EFI as discussed below. Shares of Empower Funds may be available for purchase by retirement plans and other investment accounts advised by EAG. Investment Advisers Empower Capital Management, LLC (ECM), an affiliate of EAG, is a registered investment adviser under the Advisers Act and is the investment adviser for EFI, portfolios of which a plan may select as plan investment options. It is a wholly owned subsidiary of ESH US, which is a wholly owned subsidiary of EAICA. EAG provides its discretionary and non-discretionary services to participants in certain defined contribution plans. Irish Life Investment Managers Limited (ILIM) isa Dublin, Ireland based, SEC registered investment adviser. ILIM is part of the Lifeco group of companies; Lifeco has operations in Canada, the United States, Europe, and Asia through ownership of companies including EAICA. EAG is an indirect wholly owned subsidiary of EAICA. EAICA is an indirect wholly owned subsidiary of Lifeco which controls ILIM. ILIM manages the index series of Empower Funds. Holding Company Great-West Lifeco Inc. (Lifeco), EAG’s indirect parent company, owns approximately 6% of Franklin Templeton Investments’ parent company, Franklin Resources, Inc. (Franklin) as of January 1, 2024. Franklin or certain of its investment management subsidiaries (collectively, the Franklin Group entities) may provide management, advisory or sub-advisory services to investment funds that may be investment options in a Managed Account. Franklin and Lifeco have entered into arrangements under which Lifeco has committed to allocate Lifeco and affiliate assets over a period of time to be managed by Franklin’s investment managers and to support the availability of Franklin Group entity products and services on enterprise platforms. As a result, Empower and Lifeco will derive an economic benefit to the extent that Franklin Group entities provide management, advisory or sub-advisory services to funds or products. If Franklin achieves revenue thresholds under those arrangements, Lifeco will receive contingent transaction consideration and Lifeco and other Empower affiliates will derive an economic benefit if assets are allocated to a Franklin investment option. Branding The affiliated companies of EAG; Empower Personal Wealth, LLC; ECM; EFSI; EAICA; EAIC; ELAINY; Empower Funds; Empower; and ETC operate under the multiple brands of Empower and Empower Institutional depending upon the products, services and retirement markets involved. These brands do not materially affect the internal structure of EAG or EAG’s corporate ownership. Conflicts of Interest Conflicts relating to fund recommendations: The Service operates by recommending or allocating a user’s assets to funds available within a plan or IRA. The plan sponsor/client through which the Service is delivered, or the IRA platform custodian (rather than EAG) generally establishes the funds available for EAG’s recommendations within a plan or IRA. In some cases, the investment options may include or be comprised solely of investment options sponsored by EAG’s affiliates. In other cases, the investment options may make third party payments described below. When this occurs, EAG’s affiliates may receive additional compensation as a result of EAG’s recommendations or allocations. These forms of additional affiliate compensation are: • Proprietary investment funds. EAG’s affiliates offer proprietary investment funds, and EAG may recommend or allocate your assets to our affiliates’ proprietary investment funds, such as proprietary mutual funds and collective investment trusts. These proprietary investment funds generate additional investment management fees to EAG’s family of companies. This is because 7  EAG’s affiliates provide investment management services to the proprietary fund itself, for service like administering, managing, and supervising these funds. For example, a plan participant using the Service will directly pay advisory fees to EAG and indirectly to ECM if the retirement plan investment options include Empower Funds, and EAG recommends an allocation to an Empower product. The fund share price includes the fees paid to ECM for management of the Empower Funds. • Proprietary insurance products. EAG’s indirect parent company, EAICA, offers proprietary insurance products for investment. EAG may recommend or allocate your assets to different types of Lifeco insurance products and funding agreements. The majority of Empower’s insurance products are annuity contracts that are structured either as a “general account” product or as a “separate account” product. If you invest in a general account product, which is an insurance product backed by the general account of an insurance company, EAG’s affiliates generate revenue by retaining spread, which is the difference between actual earnings on contracts offered by the insurer, and the crediting rate declared and guaranteed by the insurer through the contract. EAG’s affiliates may also receive different types of fee income if you invest in the separate accounts and other third-party payments associated with investments held therein. • Third-Party Payments. EAG’s affiliates may receive payments from other firms, non-proprietary investment funds or products, or providers, such as revenue sharing payments, in connection with the investments made pursuant to our recommendation or investment management. Conflicts related to increased use and promotion of the Service. • Increased advisory fee income. EAG’s representatives may recommend that you use the Service. If you enroll in certain Service, EAG will earn additional compensation, since you will pay fees to use the Service. • Increased affiliate fee income. When you use the Service, EAG may recommend you increase contributions or utilize other savings or investment strategies. EAG’s affiliates provide a bundle of recordkeeping, trust, custody, brokerage, investment, and other related services to retirement plans and to other investment products. If you pay for these various related services through an arrangement where our affiliates charge a direct fee, EAG’s affiliates may receive additional fees for these services as a result of EAG’s recommendations, because you may contribute, invest, or transact in more assets with EAG’s family of companies. • Representative Compensation. EAG has authorized its individual adviser representatives and EFSI, an affiliate of EAG, and its licensed agents and registered representatives who are Empower employees (collectively referred to as, “Agents”) to solicit, refer and market EAG’s services. Agents receive a salary and are eligible to receive incentive compensation (including bonus payments) paid by Empower. Certain Agents serve in “Wealth Solutions Advisor,” and similar roles that educate prospective clients about available products and services, and, provide investment advice. Agents receive incentive compensation paid by Empower when they refer a retirement plan participant to an EAG representative in its rollover/distribution call center to consider whether to roll over plan assets into advisory accounts with EAG. Depending on the position type of the referring Agent, an Agent also receives incentive compensation paid by Empower when the referred participant ultimately rolls over assets into and funds an advisory account with EAG. Under an incentive compensation plan applicable to Wealth Solutions Advisors and certain other roles, incentive compensation is based, in part, on funded net asset accumulation and retention and compensation varies by product “grade” (or tier). Specifically, Grade 1 products include Empower Personal Cash and self-directed brokerage accounts (taxable and IRA/SEP); Grade 2 products include Empower Investment Account, Empower Managed Portfolio, SmartSolution IRA/Roth IRA, and Premier Non-Managed accounts; and Grade 3 products include Personal Strategy, Personal Strategy+, and Premier Managed accounts. Grade 1 products are self-directed and, when recommending or opening a self-directed brokerage account, Agents do not act in a fiduciary capacity. Payout rates are generally higher for higher-grade products based on individual product complexity and the requisite expertise required of Agents to discuss and open such products. These arrangements create conflicts of interest because Agents have financial incentives to recommend or encourage enrollment in, or selection of, certain products or services or to encourage rollovers or transfers of additional assets. Compensation paid to Agents does not increase the fees paid by account holders. • Other Agents’ individual performance goals, within Workplace Planning & Advice and including, but not limited to, Workplace Planning Consultants, are based on a combination of factors including the number and quality of customer engagements during the measurement period and the amount of customer assets retained or accumulated as a result of those engagements. Depending on position type, performance goals also include: total asset growth and retention (including retention and external rollover ratios); introductions or referrals to Wealth Solutions Advisors (described above); client satisfaction measures; and planning-activity measures (such as advice acceptance rates). Additional qualitative factors include leadership, teamwork, client experience, quality and efficiency of client interactions, and adherence to corporate policies and regulatory standards. Incentive compensation is not guaranteed and is determined and paid periodically (for example, monthly or quarterly). EAG also has conflicts of interest when it makes suggestions to users through the Service. EAG may suggest utilizing financial products or services which will pay additional compensation to EAG or its affiliates. For example, if a financial plan suggests that a user considers a managed account service, the managed account service available through the user’s account may be EAG’s own investment management service, and the use of the service would earn EAG investment management fees. EAG does not have discretion to implement suggestions made through the Service without prior client approval. 8  Other Business Activity Certain senior managers and officers of EAG may also serve as executive officers of EAG’s indirect parent company, EAICA, and other affiliates of EAG. Item 11 — Code of Ethics, Participation or Interest in Client Transactions and Personal Trading EAG Code of Ethics EAG adopted a Code of Ethics (the Code) pursuant to Advisers Act Rule 204A-1. The Code sets forth the standard of business conduct expected of advisory personnel and applies to EAG’s advisory personnel (referred to as Supervised Persons). EAG requires certain Supervised Persons to report their personal securities holdings and transactions in accordance with the Advisers Act. EAG requires its Supervised Persons to comply with the Code. EAG will provide a copy of the Code to the current or prospective clients, upon request. The Code includes provisions related to: • • • • • • • • Fiduciary responsibility to clients; Compliance with federal securities laws; Protection and safeguarding of confidential information; Giving and receiving gifts, gratuities, and entertainment; Political contributions; Reporting and monitoring personal securities transactions; Avoiding and disclosing conflicts of interest; and Reporting violations of the Code. Personal Trading The Code requires pre-clearance of certain securities transactions. Officers, managers, and certain employees of EAG (collectively, Access Persons) may trade for their own personal accounts in securities that EAG recommends and/or purchased for its advisory clients. However, because the Code would permit Access Persons to invest in the same securities as clients in some circumstances, there is a possibility that employees could benefit from market activity by a client in a security held by an Access Person. As a result, EAG continually monitors trading in accordance with the Code and federal securities laws. EAG intends for the Code to ensure that the personal securities transactions and the outside business activities of EAG’s Access Persons do not interfere with making decisions in the best interest of advisory clients. Principal Trading EAG has adopted a policy and practice not to engage in any principal transactions. EAG holds no investments for its own accounts that EAG could buy from, or sell to, an advisory client. In the event of any change in EAG’s policy, management must approve any such change. EAG would only permit a principal transaction after meeting the review and approval requirements described under the anti-fraud section of the Advisers Act. Participation or Interest in Client Transactions Registered representatives of EFSI may make recommendations to you and provide wholesaling, direct sales, enrollment, and/or communication services to retirement plans and their participants and other investment accounts for which EAG may also provide its services. In return, EFSI or Empower may receive fees from either the plan or the investment provider (fund families). EFSI executes all securities transactions that occur as a result of EAG’s services described in this Brochure. 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 discloses its affiliation with these entities. Item 12 — Brokerage Practices Brokerage Selection; Best Execution For retirement plans, the plan sponsor or its agent selects the broker-dealer used by a 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 compensation. Soft Dollar Practices As a matter of policy, EAG does not utilize research, or other products or services from third parties in connection with client securities transactions on a soft-dollar commission basis. Directed Brokerage A plan sponsor may elect to offer brokerage services to participants in its retirement plan. EAG does not participate in such decisions and does not provide recommended portfolios or investment recommendations on assets held in a brokerage account under a retirement plan. 9  Trade Aggregation EAG does not bunch orders or engage in block trades to execute equity orders for clients, as accounts, generally, are held in trust per regulatory requirements. Further, most trades are mutual funds where trade aggregation does provide any additional client benefits. Item 13 — Review of Accounts Designated personnel will conduct reviews. EAG reviews accounts on a periodic basis but will review accounts as needed based on circumstances such as if EAG receives a question or complaint. Item 14 — Client Referrals and Other Compensation EAG has authorized Agents to solicit, refer and market EAG’s services. Agents receive a salary and are eligible to receive incentive compensation (including bonus payments) paid by Empower. Certain Agents serve in “Wealth Solutions Advisor,” and similar roles that educate prospective clients about available products and services, and, provide investment advice. Agents receive incentive compensation paid by Empower when they refer a retirement plan participant to an EAG representative in its rollover/distribution call center to consider whether to roll over plan assets into advisory accounts with EAG. Depending on the position type of the referring Agent, an Agent also receives incentive compensation paid by Empower when the referred participant ultimately rolls over assets into and funds an advisory account with EAG. Under an incentive compensation plan applicable to Wealth Solutions Advisors and certain other roles, incentive compensation is based, in part, on funded net asset accumulation and retention and compensation varies by product “grade” (or tier). Specifically, Grade 1 products include Empower Personal Cash and self-directed brokerage accounts (taxable and IRA/SEP); Grade 2 products include Empower Investment Account, Empower Managed Portfolio, SmartSolution IRA/Roth IRA, and Premier Non-Managed accounts; and Grade 3 products include Personal Strategy, Personal Strategy+, and Premier Managed accounts. Grade 1 products are self-directed and, when recommending or opening a self- directed brokerage account, Agents do not act in a fiduciary capacity. Payout rates are generally higher for higher-grade products based on individual product complexity and the requisite expertise required of Agents to discuss and open such products. These arrangements create conflicts of interest because Agents have financial incentives to recommend or encourage enrollment in, or selection of, certain products or services or to encourage rollovers or transfers of additional assets. Compensation paid to Agents does not increase the fees paid by account holders. Other Agents’ individual performance goals, within Workplace Planning & Advice and including, but not limited to, Workplace Planning Consultants, are based on a combination of factors including the number and quality of customer engagements during the measurement period and the amount of customer assets retained or accumulated as a result of those engagements. Depending on position type, performance goals also include: total asset growth and retention (including retention and external rollover ratios); introductions or referrals to Wealth Solutions Advisors (described above); client satisfaction measures; and planning-activity measures (such as advice acceptance rates). Additional qualitative factors include leadership, teamwork, client experience, quality and efficiency of client interactions, and adherence to corporate policies and regulatory standards. Incentive compensation is not guaranteed and is determined and paid periodically (for example, monthly or quarterly)) Compensation paid to Agents or EAG representatives does not increase the fees paid by the account holder. Item 15 — Custody EAG does not maintain actual custody of its clients’ cash, bank accounts, or securities. Pursuant to Advisers Act Rule 206(4)-2, as amended, EAG is deemed to have constructive custody with respect to certain client funds and securities because an affiliated party is the custodian and directed or discretionary trustee of certain retirement plan accounts. In addition to annual audits, these accounts are subject to surprise custody verifications by an independent public accountant each year, as required by Rule 206(4)-2. If applicable, plan sponsors receive periodic account statements (at least quarterly) from their custodian and should carefully review these statements. Certain clients may have assets held by unaffiliated custodians. Item 16 — Investment Discretion EAG provides discretionary investment management services for those Plan participants who enroll and participate in a managed account service. The Service does not provide EAG with any investment discretion. Item 17 — Voting Client Securities EAG, as a registered investment adviser, and as a matter of practice, does not accept authority to vote client securities in connection with any of the services described in this Brochure. Correspondence regarding the matters described in this section will be handled in connection with the Plan’s policies and service provider arrangements. Item 18 — Financial Information As previously discussed, under certain circumstances EAG has discretionary authority over certain client funds and securities, although the Service does not provide EAG with discretionary authority over client accounts. Accordingly, EAG must disclose only the information about EAG’s financial condition that is reasonably likely to impair its ability to meet contractual commitments to its clients. EAG has no financial 10  commitment that impairs its ability to meet contractual commitments to its clients, nor has EAG been the subject of a bankruptcy proceeding. Finally, EAG does not require or solicit prepayment of fees of more than $1,200 per client more than six months in advance. This is not an Offer to Purchase or Sell Securities. The information contained in this Brochure, including information regarding Empower Funds, is for disclosure and other informational purposes only. It is not an offer to sell or a solicitation of an offer to buy any securities and may not be relied upon in connection with the purchase or sale of any security. 11 

Item 1 – Cover Page EMPOWER ADVISORY GROUP, LLC Disclosure Brochure Personal Strategy Wrap Fee Program 8515 East Orchard Road, 4T2 Greenwood Village, CO 80111 Telephone: 866-317-6586 www.empower.com March 31, 2026 This Wrap Fee Program Brochure (Brochure) provides information about the qualifications and business practices of Empower Advisory Group, LLC (EAG). Specifically, this Brochure provides information on the qualifications and business practices for the advisory services provided by EAG for the Personal Strategy and Personal Strategy+ advisory services. If you have any questions about the contents of this Brochure, please contact us at 855-855-8005. The information in this Brochure has not been approved or verified by the Securities and Exchange Commission (SEC) or by any state securities authority. EAG is a federally registered investment adviser under the Investment Advisers Act of 1940 (Advisers Act). Registration of EAG does not imply any level of skill or training. Additional information about EAG is available on the SEC website at https://adviserinfo.sec.gov or at EAG’s website at https://empower.com/EAG. The SEC’s web site also provides information about any person affiliated with EAG who is registered, or is required to be registered, as an investment adviser representative with EAG. Item 2 — Material Changes This section of the Brochure highlights and discusses any changes that were made since the Adviser’s last update on September 19, 2025. A material change was made to Item 10 and Item 14 to describe changes to representative compensation. 1  Item 3 — Table of Contents Item 1 – Cover Page ....................................................................................................................................................... 1 Item 2 — Material Changes ........................................................................................................................................... 1 Item 3 — Table of Contents ........................................................................................................................................... 2 Item 4 — Advisory Business........................................................................................................................................... 3 Item 5 — Fees and Compensation ................................................................................................................................. 6 Item 6 – Performance Based Fees and Side by Side Management ............................................................................... 7 Item 7 – Types of Clients ............................................................................................................................................... 7 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ......................................................................... 8 Item 9 — Disciplinary Information ............................................................................................................................... 12 Item 10 – Other Financial Industry Activities and Affiliations ..................................................................................... 12 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............................... 15 Item 12 – Brokerage Practices ..................................................................................................................................... 15 Item 13 – Review of Accounts ..................................................................................................................................... 16 Item 14 – Client Referrals and Other Compensation................................................................................................... 16 Item 15 — Custody ...................................................................................................................................................... 18 Item 16 – Investment Discretion ................................................................................................................................. 18 Item 17 — Voting Client Securities .............................................................................................................................. 18 Item 18 — Financial Information ................................................................................................................................. 18 2  Item 4 — Advisory Business Description of Advisory Firm EAG has been a registered investment adviser under the Advisers Act since 2000. EAG is also registered in all 50 states, the District of Columbia, Virgin Islands, Guam, and Puerto Rico. EAG offers investment management and advisory services to plan sponsors of employer-sponsored retirement plans such as 401(a), 401(k), 403(b) and 457 plans, including government entities and their participants, and to all account holders of the Empower Premier IRA (IRA holder or account holder). EAG does not choose the investments offered in employer-sponsored retirement plans or IRAs. EAG also offers investment management services to individuals and to retail brokerage account holders. More information about EAG’s services, including an applicable brochure, can be obtained by contacting EAG at the number provided on the cover page of this Brochure or by visiting EAG’s website at: www.empower.com/eag. EAG is a wholly owned subsidiary of Empower Services Holdings US, LLC (ESH US), a holding company domiciled in the State of Delaware. Empower Annuity Insurance Company of America (EAICA) owns ESH US. EAICA is a direct, wholly owned subsidiary of Empower Holdings, LLC (EHL), a Delaware holding company. EHL is a direct wholly owned subsidiary of Great-West Lifeco U.S. LLC (Lifeco U.S.) and an indirect wholly owned subsidiary of Great-West Lifeco Inc. (Lifeco), a Canadian holding company. Lifeco is a subsidiary of Power Financial Corporation (Power Financial), a Canadian holding company with substantial interests in the financial services industry. Power Corporation of Canada (Power Corporation), a Canadian holding and management company, has voting control of Power Financial. The Desmarais Family Residuary Trust has voting control of Power Corporation; through a group of private holding companies it controls. Types of Services Discussed in this Brochure: TM EAG provides a range of advisory services directly to Personal Strategy® and Personal Strategy+ clients (the Services). The Services include the Personal Strategy core managed account advisory services (Advisory Services or Managed Accounts) and Personal Strategy+ advisory and investment management services for enrolled active or former employer-sponsored retirement accounts (Personal Strategy+ Services). Our Services combine technology with objective financial advice from Investment Advisor Representatives (Advisor(s)) who act as fiduciaries to our clients. EAG charges an all-inclusive fee for its Advisory Services and Personal Strategy+ Services described in this Brochure. Our Services are comprised of the services described below. Availability of some of the Advisory Services depends on the level of investment by a client. The web, mobile, tablet, and personal financial management aggregation service (Dashboard) provided to clients is delivered through Empower Personal Wealth, LLC (Empower Personal Wealth). Personal Strategy Core Managed Account Advisory Services (Advisory Services or Managed Accounts): Clients are required to establish brokerage accounts at a qualified custodian (Broker or Brokers) identified by EAG. All identified Brokers are member firms of the Financial Industry Regulatory Authority, Inc. and the Securities Investor Protection Corporation. The currently identified Broker is: Pershing Advisor Solutions LLC One Pershing Plaza, 4th Floor, Jersey City, NJ 07399, www.pershing.com/who-we-serve/registered-investment-advisors. All Managed Account client assets described herein are held in custody at the above-listed Broker except as noted otherwise herein. Pershing is not affiliated with EAG. Advisory Services: Periodic rebalancing Tax optimization and tax loss harvesting, as applicable In some instances, collaboration with CPA and estate planning professionals Portfolio personalization, as applicable • Ongoing discretionary investment management • • • • 3  Financial planning education • • U.S. equity portfolio Smart Weighting ™, as applicable • Custody services included at no additional charge • Securities transaction costs included at no additional charge • Assignment of a personal financial Advisor or team • Unaffiliated, qualified custodian • Minimum relationship (Household) size is generally $100,000 • Access to a Socially Responsible Personal Strategy that systematically screens U.S.-based companies based on their actions in three key areas: environmental, social, and governance • Access to a Market Cap Weighted Personal Strategy that more closely aligns with U.S. market benchmarks by utilizing a market capitalization weighted approach to U.S. equities • Access to an unaffiliated Private Equity Offering for qualifying clients, which provides the opportunity to invest in funds of private equity funds. Private Equity Offerings are subject to additional fees, which include significantly higher fees and additional layers of expenses relative to other investment options within Personal Strategy. Private Equity Offerings are custodied by UMB Bank, N.A. • Access to Personal Strategy+ Services as described below. Personal Strategy+ Services In addition to the Advisory Services listed above, EAG also provides Personal Strategy+ Services to clients also enrolled in Personal Strategy+. Our Personal Strategy+ Services are for active or former retirement accounts like 401k, 403b and 457s. Personal Strategy+ is not available to Empower plan accounts. Pershing holds in custody the taxable Managed Account from which the fees for Personal Strategy+ Services are deducted (unless the client elects the credit card payment method); However, the employer-sponsored retirement accounts to which EAG provides Personal Strategy+ Services are held away at the respective plan’s financial institution and are not held at Pershing. Retirement Plan Assessment Service includes an employer plan analysis, an EAG may offer certain eligible clients a limited-scope, no additional fee, non-discretionary service designed to help clients monitor and maintain a target investment allocation within eligible employer-sponsored retirement accounts initial target allocation held away from Empower. The service recommendation based on the plan’s available investment options, and periodic review with proactive outreach, generally every six months, to identify allocation drift and provide non-discretionary recommendations to rebalance or otherwise adjust the account. EAG does not have discretionary authority, does not execute transactions, and does not have custody of these accounts; clients are solely responsible for implementing any recommendations. Eligibility, required onboarding (including maintaining an active account aggregation connection and providing plan information), service scope, and any future transition to a paid service are governed by a separate agreement. Socially Responsible Investing In addition to the Core Personal Strategy offering, EAG offers investment portfolios with a socially responsible lens. EAG defines Socially Responsible Investing (SRI) as the application of value-based investment filters coupled with the integration of ESG factors. EAG partners with Sustainalytics, a provider of ESG and Corporate Governance research, for ESG scoring data. “ESG” stands for Environmental, Social, and Governance, which represent three categories of corporate risks and opportunities. Building Socially Responsible portfolios begins with the same underlying methodology and investment philosophies as the Core Personal Strategy, but for the U.S. equity component of the portfolio the investment team considers Sustainalytics’ ESG rating before adding each individual security. Sustainalytics provides an ESG Rating for each individual equity security that evaluates ESG factors that it deems financially material. Sustainalytics evaluates 20 “material ESG issues” (MEIs) across all sub-industries and assesses each MEI for how material it is to each sub-industry and subsequent company. If an ESG issue is considered material at the sub-industry level but is not relevant for the specific company, it can be removed from that company’s rating. Due to limited scoring data, in the SRI accounts small-cap stocks are represented by a mix of non-ESG exchange-traded funds (ETFs,) and foreign equities use a set of diversified ESG-optimized ETFs on the foreign developed and emerging market 4  sectors. SRI accounts also hold non-ESG ETFs in international small-cap equities due to a lack of desirable investment options. Any utilization of EAG’s optional SRI strategy feature, which integrates ESG factors into the Personal Strategy methodology, is pursuant to the client’s affirmative election only. Unless the client affirmatively elects the optional SRI strategy, EAG’s default investment portfolio strategy does not consider ESG factors. The performance of EAG’s Core Managed Accounts will differ from the performance of SRI accounts due to differences in holdings and investments. Advisors are available during normal business hours and are accessible via telephone, email, or by video conference. Advice is based on each client’s financial situation typically evidenced by accounts that clients have linked through the Dashboard, as well as detailed information about personal circumstances such as age, investment time horizon, risk tolerance, expectations, goals, and investment restrictions. There is no guarantee provided by any party that participation in any of the Services will result in a profit. Termination of Services: Clients may cancel their participation in Services at any time by providing written notice to EAG. To facilitate a termination of services, clients may emailor otherwise speak with their Advisor or call EAG at the toll-free customer service number. The minimum total Household assets for continuation of Core Advisory Services (i.e., excluding Personal Strategy+ assets) is $25,000. EAG will terminate the Personal Strategy relationship (Advisory Services and Personal Strategy+ Services) for all accounts within a Household if the Household does not maintain a minimum balance of at least $25,000 in their Core Advisory Services. Information: The use and storage of any information, including, without limitation, an individual’s personal and non- public information, account number, password, identification, portfolio information, and account balances is provided at the individual’s sole risk and responsibility. The individual is responsible for providing and maintaining the communications equipment (including personal computers and modems) and telephone or other services required for accessing and using electronic or automated services. The individual is also responsible for all communications service fees and charges incurred when accessing these services. EAG shall not bear any responsibility for either errors or failures caused by the malfunction of any computer, communication systems, computer viruses, or related problems that may be associated with the use of the Services. For clients who elect to participate in our Personal Strategy+ offering, EAG’s Portfolio Management staff will have access to employer-sponsored retirement account information, including personally identifying information and financial information (Personal Information), as well as general information about a client’s retirement plan, such as the investment options, plan management fees and other data (Plan Data). Assets Under Management: With respect to the services provided by EAG, as of December 31, 2025: Discretionary investment management among all services (including the PMP described herein) in the amount of: $164,237,996,079 Non-discretionary investment advisory services among all services in the amount of: $31,188,325,400 Total discretionary and non-discretionary investment management and advisory services in the amount of: $195,426,321,479 5  Item 5 — Fees and Compensation EAG charges a single fee for Advisory Services and a single fee for Personal Strategy+ Services, both of which are based on the value of the client’s respective assets under management (AUM). The single fee includes portfolio management, trading commissions, and except with respect to Personal Strategy+ Services, custody services. Advisory Services Fees and Compensation: The fee for Advisory Services commences upon the first date that the Broker receives a client’s assets, including cash and securities, in a Managed Account. EAG charges a fee for all client assets it manages as part of the Advisory Services, which includes uninvested cash. Fees and rates are calculated daily and deducted on a monthly basis in arrears. EAG reserves the right to negotiate separate fee and billing arrangements at its sole discretion. The client authorizes EAG to debit Advisory Services fees directly from the client’s Managed Accounts held with the Broker. If insufficient cash is available to pay such fees, securities will be liquidated to pay the unpaid balance. On an annualized basis, EAG bases its Advisory Services fee on the following schedule calculated as a percentage of the total AUM: Investment Services Clients ($100,000 - $249,999 total AUM) 0.89% Wealth Management Clients ($250,000 - $999,999 total AUM) 0.89% Private Clients ($1 million or more total AUM) tiered structure $3MM or less AUM On only the next $2MM AUM On only the next $5MM AUM On only the AUM over $10MM 0.79% 0.69% 0.59% 0.49% For example, here is how your annual Advisory Services fee would be calculated if you are a Private Client with $7.5 million AUM: • • • The fee for the first $3 million of your total AUM would be calculated at 0.79% annually, The fee for the next $2 million portion of your AUM ($3,000,001 to $5 million) would be calculated at 0.69% annually, and The fee for the last $2.5 million portion of your AUM ($5,000,001 to $7.5 million) would be calculated at 0.59% annually. Personal Strategy+ Advisory Fees and Compensation: Fees for Personal Strategy+ Services are charged monthly in arrears and calculated based on month-end assets (or last asset value available during the month). The annualized fee rate for Personal Strategy+ Services is 0.49%. Personal Strategy+ Services fees commence upon successful aggregation of the employer-sponsored retirement account assets and either the confirmation or establishment of an eligible Managed Account or the enrollment in a credit card payment method. If the client does not already have a fee account designated and does not elect credit card payment as described below, the client authorizes EAG to deduct advisory fees for Personal Strategy+ Services from the client’s largest taxable Managed Account held with the Broker. Payment of Fees: Personal Strategy+ clients have the option to select credit card payment of advisory fees for Personal Strategy+ Services. For clients who authorize EAG to charge their credit card for Personal Strategy+ Services fees, EAG engages a third- party vendor to provide the credit card billing option to Personal Strategy+ Services clients. Credit card information is processed by the vendor through Dashboard integration and complete account credentials are not stored or accessible by EAG or EAG’s employees. By electing to pay fees for Personal Strategy+ Services with a credit card, the client agrees to be held to the specific terms and conditions of their credit card agreement directly with the applicable card-issuing financial institution. While EAG accepts credit card payment for Personal Strategy+ Services, such acceptance is not a recommendation to pay advisory fees by credit card. Selecting this payment method may or may not be the best option, depending on the client’s financial circumstances. While paying advisory fees via credit card could provide more opportunity for assets to grow (as 6  a result of fees not being paid directly from assets), these payments will be subject to the interest rate of the applicable credit card sponsor in the event that the balance of the credit card is not paid off each month. This interest rate is typically much higher than any advisory fees paid for investment services, and the interest rate applicable to credit card borrowing may exceed the performance return of the account. Clients should carefully consider whether paying for Services with a credit card is appropriate for their specific circumstances, given the benefits and drawbacks. EAG does not assess any surcharge to clients who elect to pay for Personal Strategy+ Services with a credit card. EAG’s Personal Strategy+ Services are limited to providing investment advice and management of the assets in a client’s employer-sponsored retirement account(s), and the plan administrator continues to act as the qualified custodian for these accounts. Any transaction or performance information provided by EAG is for informational purposes only, as the plan administrator for the employer-sponsored retirement account(s) is the official custodian and recordkeeper for all performance and transaction information. EAG reserves the right to reduce its advisory fee rate at its discretion, including for promotional events that may result in complimentary or reduced advisory fee rates for new clients, for current clients for referrals, or for early adoption of new services. The fee rate also has been reduced for personnel (including employees and consultants) of EAG and its affiliates. These reductions apply to clients of the same households. Fee errors are corrected promptly upon discovery. In determining whether to establish an account, a client should be aware that the overall cost to the client of Advisory Services will be higher or lower than the client would incur by purchasing separately the types of securities available through the Advisory Services. In comparing the cost of the Advisory Services with unbundled services, the client should consider the turnover rate in EAG’s investment strategies, trading activity in the account, standard advisory fees, and brokerage commissions that would be charged at other broker-dealers and investment advisers. Additional Fees and Expenses: All fees paid to EAG for Advisory Services are separate and distinct from the fees and expenses charged by underlying pooled investment vehicles (e.g., ETFs, mutual funds, closed-end investment companies or other managed investments). The specific fees and expenses are described in each vehicle’s prospectus or other offering document. Additional investment management fees are paid to Empower Capital Management, LLC (ECM) if Empower Funds are included among the available investment options within a client’s plan. The fees paid to ECM are for management of the Empower Funds; these management fees are included in the fund share price. In addition, there are other third-party costs assessed that are not included in the Advisory Services fees, such as costs associated with exchanging currencies, wire transfer fees, Personal Strategy+ plan administration fees charged by the plan administrator, Personal Strategy+ plan transaction fees, or other fees required by law, as applicable. If a client elects to pay for Personal Strategy+ Services by credit card, there may be other fees associated with the specific terms and conditions of that credit card. Clients who participate in a Private Equity fund through an arrangement with Institutional Capital Network (iCapital) will pay additional fees charged by iCapital or the underlying funds, which include significantly higher fees and additional layers of expenses relative to other investment options within Personal Strategy. Item 6 – Performance Based Fees and Side by Side Management EAG does not charge any performance–based or side-by-side management fees. Clients considering an investment in an iCapital Private Equity fund should be aware that, although EAG does not charge performance fees, iCapital’s underlying fund managers may do so, and these additional fees include significantly higher fees and additional layers of expenses relative to other investment options within Personal Strategy. Item 7 – Types of Clients EAG generally provides Services to: Individuals, • • High-net worth individuals, 7  Corporations and other business entities, and Charitable Organizations. • • Our Advisory Services are offered to clients who sign up with a minimum of $100,000 of AUM with us. Clients who elect to enroll in our Personal Strategy+ program are also required to have a Managed Account with a minimum of $25,000 in assets. The minimum AUM requirements may be reduced or waived at EAG’s discretion. Clients who invest below $250,000 using the Services (Investment Services Client(s)) fall under our Investment Services tier. In addition to access to the free Dashboard, Investment Services Clients have access to a team of Advisors who assist in planning their investment goals. Investment Service Clients normally have portfolios consisting of ETFs with goals of diversification and tax efficiency. Clients who invest between $250,000 and less than $1 million using the Services (Wealth Management Client(s)) fall under our Wealth Management tier. Wealth Management Clients are provided with a comprehensive financial plan to help address retirement, college planning and tax optimization needs. They are offered a dedicated financial Advisor and a customized portfolio of individual securities and ETFs designed to meet their financial goals. Clients who invest at least $1 million using the Services (Private Client(s)) fall under EAG’s Private Client tier, which is designed for high-net worth investors who want a robust financial plan along with personalized service and portfolio management. Private Clients have access to financial Advisors and financial planning specialists, private banking services, legacy and estate planning specialists, and family-tiered billing with reduced fees for assets over a certain level. Private Client portfolios offer a blend of individual securities and bonds, as well as ETFs. Private Clients are also eligible to participate in the Private Equity fund. The Private Equity fund is made available to Private Clients through an arrangement with iCapital. Private Clients who invest in this program have the opportunity to invest in the iDirect Private Markets Fund (Fund), a registered closed end fund product advised by iCapital, which is responsible for Fund investment selection and portfolio management in private equity investments. Clients who participate in the Private Equity Fund will incur additional fees charged by the Fund, which include significantly higher fees and additional layers of expenses relative to other investment options within Personal Strategy. Though no longer offered to new clients, existing clients utilizing the Vintage iCapital Private Equity (Vintage) Offering will remain invested in the Vintage product. These eligible Vintage investors were Private Clients who had been with EAG for at least six months and who had at least $5 million invested with Personal Strategy. The Vintage Offering was made through an arrangement with iCapital. Private Clients who invested in this program had the opportunity to invest in an access fund sponsored by iCapital, which in turn invested in one or more underlying private equity funds. Clients who participated in the Vintage Offering through this arrangement with iCapital will continue to pay additional fees charged by iCapital or the underlying funds. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss EAG’s investment analysis emphasizes asset allocation research and portfolio diversification techniques over individual security analysis. EAG’s methods and techniques include: • • • Sampling and screening relevant baskets of securities, or indices, in order to select the desired security attributes. Correlation analysis – evaluating the historical relationship of two securities or market segments movement in relation to each other. Fundamental analysis – evaluating securities based upon historical and projected financial performance. Within US equities, Managed Accounts employs an approach termed Smart WeightingTM. The starting universe is generally ETFs and US stocks traded on an exchange with a market capitalization over $250 million and sufficient liquidity. The objective of the approach is to maintain relatively even weighting in company size, style and economic sector. Securities are selected largely to complete this factor exposure in conjunction with other existing holdings. In other asset classes we employ a mix of low-cost ETFs in an attempt to generate an efficient exposure to the asset class. The most important areas for consideration in ETF selection are underlying exposure, liquidity, and cost. 8  All investments involve risk. EAG does not guarantee the results of the advice given. Significant losses can occur by investing in any security, or by following any strategy, including those recommended or applied by EAG. EAG offers its clients an array of investment strategies (Personal Strategy). A client’s assets are managed within a given Personal Strategy based upon the client’s overall investment objectives and suitability parameters. A Personal Strategy is a comprehensive investment portfolio. It is focused on achieving the client’s financial goals and is designed to grow with the client over time. Portfolios in a Personal Strategy can be customized for a client’s needs or wants; however, EAG maintains ultimate investment discretion. Clients should be aware that to the extent a personalized trading restriction limits full strategy implementation, it may impact their account performance relative to other non-restricted peers in the same strategy. Personal Strategy asset allocations go beyond basic stock and bond portfolios. The Personal Strategy service invests globally, primarily utilizing individual equities and ETFs. EAG’s unique Smart Weighting approach adds further diversification and potential return by providing exposure to all areas of the U.S. stock market while avoiding being overweight to high-risk segments. EAG believes that asset allocation is an important investment decision. The goal-based nature of a Personal Strategy means the client’s asset allocation is linked to their evolving situation, thereby maximizing the likelihood of long-term success. EAG has a Market Cap Weighted strategy as an additional investment strategy option for Advisory Services clients who prefer a traditional approach that is more closely aligned with U.S. market benchmarks. EAG will utilize its Smart Weighting methodology for the allocation of U.S. equities in a client’s Managed Account(s) unless the client directs EAG to utilize the Market Cap Weighted strategy’s market-weighting methodology. EAG’s Smart Weighting methodology weights economic sector, style, and size more equally than a market-weighted methodology. A market-weighted methodology utilizes a market capitalization weighted approach to U.S. equities, approximately weighting each position based on its free-float market capitalization value within the broader U.S. total stock market. Target allocations for Personal Strategy+ accounts will be built in an attempt to align with the fundamental asset allocation of the client’s Personal Strategy. In alignment with this general approach to investing, preference will generally go to selecting low-cost passive index funds over actively managed mutual funds for otherwise similar plan options. Funds are selected within the context of their overall fit in the portfolio allocation and how well they represent a particular asset class that the Personal Strategy is aiming to replicate. The investment selection process involves a cost/benefit analysis that takes into consideration cost, diversification benefits, risk, return, our preference for unaffiliated products, and plan constraints. There will be allocation and performance differences between a client’s Personal Strategy+ employer-sponsored retirement account(s) and the client’s Core Personal Strategy Managed Account(s). General Risks of Investing: Investing in securities involves risk of loss that clients should be prepared to bear. Neither EAG nor its affiliates guarantee that the recommendations will result in achieving the retirement income goal. Neither EAG nor its affiliates can guarantee that you can or will avoid negative returns in any of the recommendations. An investment’s future performance may differ substantially from its historical performance and may incur a loss. Past performance is no guarantee of future results. Additionally, the plan provider may make changes from time to time with respect to the investment options available in the plan. While a diversified investment portfolio, including a portfolio of investment products representing different asset categories, can mitigate some risks, it does not and cannot prevent all losses. Ultimately, the investor bears such risks. Below are some of the common factors that can produce a loss in a client’s account and/or in a specific investment product or asset category: Market Risk: Stock and bond markets are volatile and can decline significantly in response to adverse issuer, political, regulatory, market or economic developments in the U.S. and in other countries. Market risk may affect a single company, a sector of the economy, a country or geopolitical region, or the market as a whole. Market risk may impact 9  stock and/or bond markets in unanticipated and different ways. • Business Risk: These risks are associated with a particular industry or a particular company within an industry. • Capitalization Risk: Limited resources or less diverse products or services may hinder small-cap and mid-cap companies, and such companies’ stocks have historically been more volatile than the stocks of larger, more established companies. • Category or Style Risk: During various periods of time, one category or style may underperform or outperform other categories and styles. • Credit Risk: The risk that the issuer of a security may be unable to make interest payments and/or repay principal when due. A downgrade to an issuer’s credit rating or a perceived change in an issuer’s financial strength may affect a security’s value and impact on the performance of the issue along with any mutual fund or ETF that holds it. • Interest Rate Risk: Interest rate changes significantly affect a debt security’s market value. When interest rates rise, the debt security’s market value declines. When interest rates decline, market values rise. The longer bond maturity results in the greater risk and the higher yield. Conversely, the shorter bond maturity results in the lower risk and the lower yield. Inflation Risk: When any type of inflation is present, purchasing power may erode at the rate of inflation. • • Reinvestment Risk: The risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e., interest rate). This relates primarily to fixed income securities. • Exchange-traded funds: ETFs present market and liquidity risks because they are listed on a public securities exchange and are purchased and sold via the exchange at the listed price. The price will vary based on current market conditions and may deviate from the net asset value of the ETF’s underlying portfolio. There may also be an inactive market for certain funds, and/or losses from trading in secondary markets. • Target Date Funds: Generally, the asset allocation of each target date fund will change on an annual basis with the asset allocation becoming more conservative as the fund nears the target retirement date. The target date is the approximate date when investors plan to start withdrawing their money. The principal value of the fund(s) in a plan’s lineup is not guaranteed at any time, including at the time of target date and/or withdrawal. • An investment in a money market fund is not insured or guaranteed by the Federal Deposit Insurance Corporation (FDIC) or any other government agency. Although some money market funds such as U.S. Government money market funds strive to preserve the value of the investment at $1.00 per share, it is possible to lose money by investing in a money market fund. Additionally, other money market funds may operate under new rules and regulations permitting them to have a “floating” value per share. A floating value may be more or less than $1.00 per share (depending on market conditions) and impose liquidity/redemption fees for large or frequent withdrawals. Additionally, participating in the Private Equity fund and investing in the Fund involves significant risks including, but not limited to, liquidity risk, market risk, concentration risk, and potentially highly volatile performance. The Fund is considered a speculative investment and involves a high degree of risk relative to other investment options within Personal Strategy. The Fund is uniquely illiquid in that a client may be unable to liquidate or redeem any or a substantial portion of their investment in the Fund because the Fund in its sole discretion may, but is not required to, provide the client with an offer to redeem a limited portion of their shares. The inability to sell Fund shares could result in the need to sell some or all of a client’s more liquid assets (including to pay EAG’s fees) at a time when it is not optimal to do so, which could result in the client’s account holding a greater concentration of less liquid assets. In-House Portfolio Management: EAG does not utilize outside portfolio managers for Advisory Services except as noted below. All Personal Strategy accounts are managed by EAG’s in-house professionals. EAG’s Personal Strategy Investment Committee acts as the Portfolio Management Team for this wrap fee program. 10  Note that certain portfolio decisions for both Managed Accounts and Personal Strategy+ involve investing in or recommending an investment in securities issued by pooled investment vehicles, e.g., mutual funds, ETFs, and private funds. Outside portfolio managers make investment management decisions for such pooled investment vehicles. Empower Personal Strategy Investment Committee: Our Empower Personal Strategy Investment Committee is dedicated to constructing and maintaining strategic investment portfolios. This includes security selection, portfolio monitoring, and trade oversight. The Committee combines expertise and decades of experience to build a wide range of portfolios designed to help clients meet their financial goals. Craig Birk CFP®, Chief Investment Officer As CIO for Empower Personal Wealth, Craig leads the Empower Personal Strategy Investment Committee, focused on translating improvements in technology into better financial lives. Previously, Craig was CIO of Personal Capital. Jonathan Kreider CFA, EVP and Head of Empower Investments Jonathan leads Empower’s proprietary funds business and is responsible for fund development and management, investment sales and service, and the investment research functions. He has been the Head of Empower Investments since January 2020; prior to that, he was the VP of Investment Products from August 2016. Lacey Cobb CFA, CFP®, Senior Director of Advice Solutions Lacey is Director of Advice Solutions. She has extensive investment industry experience, with a career beginning in 2008 and encompassing roles in advice solutions at Personal Capital and trading at Polaris Greystone. Lacey focuses on personalized strategy selection and contributes to security selection and client education. Brendan Erne CFA, CSRIC, Senior Director of Portfolio Management Brendan leads our research and trading team with a focus on portfolio construction and socially responsible investing. Prior to joining EAG, he was the director of portfolio management at Personal Capital for over 11 years. Marta Norton CFA, Chief Investment Strategist Marta is Empower’s Chief Investment Strategist and is responsible for developing Empower’s economic and market outlook. She shares her commentary across the enterprise, with both Workplace and Wealth clients. A regular speaker at industry conferences, Marta also appears frequently in financial media. She joined Empower in 2024. Previously she was the Chief Investment Officer for the Americas at Morningstar Wealth. Roger Hobby, EVP Personal Wealth Distribution and Advisory Roger joined Empower in 2024. In his role, he is responsible for distribution and advisory services nationally. He has over 35 years of experience in the financial services industry and was previously 11  at Fidelity Investments, where he was the Head of Distribution for Private Wealth Management, Executive Services, Workplace Planning and Advice, and Stock Plan Services. Certified Financial Planner Board of Standards Inc. (CFP Board) owns the certification marks CFP®, CERTIFIED FINANCIAL PLANNER™, CFP® (with plaque design), and CFP® (with flame design) in the U.S., which it authorizes use of by individuals who successfully complete CFP Board’s initial and ongoing certification requirements. Item 9 — Disciplinary Information EAG, as a registered investment adviser, is required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of EAG or the integrity of EAG’s management. EAG has the following disciplinary event to report relative to this item: On August 29, 2025, EAG and its broker/dealer affiliate, Empower Financial Services, Inc. (EFSI), settled a matter with the SEC. The SEC found that, from July 1, 2019 through December 31, 2022, certain retirement plan advisors of EFSI and EAG, all of whom were both registered representatives associated with EFSI and investment adviser representatives associated with EAG, did not sufficiently disclose whether retirement plan advisors were acting as a registered representative or an investment adviser representative when recommending that a plan participant enroll in EAG’s managed account service. Additionally, EFSI and EAG did not adequately disclose the conflicts of interest presented by certain incentive compensation arrangements, leading to misleading statements made to plan participants. Finally, the SEC found that EFSI did not establish, maintain and enforce written policies and procedures reasonably designed to identify and address conflicts of interest in connection with recommendations to enroll in EAG’s managed account service. As a result, the SEC determined that EAG violated section 206(2) of the Investment Advisers Act of 1940 (“Advisers Act”) and EFSI failed to comply with the disclosure and conflict of interest obligations of Regulation Best Interest (“Reg BI”), thereby violating Reg BI’s General Obligation (Exchange Act Rule 15l-1(a)(1)). Without admitting or denying the findings, EFSI and EAG entered into a settlement with the SEC, pursuant to which EAG was censured; ordered to cease and desist from committing or causing any future violations of Section 206(2) of the Advisers Act thereunder; and EAG agreed to pay a civil monetary penalty in the amount of $750,000; and disgorgement of $4,063,569.80. EFSI was censured; ordered to cease and desist and agreed to pay a civil monetary penalty of $750,000. Item 10 – Other Financial Industry Activities and Affiliations EAG is a wholly owned direct subsidiary of ESH US, which is owned by EAICA. Due to the ownership and organizational structure, EAG has other financial industry affiliations with related entities described below. EAG may provide services to, receive services from, or direct or receive business to or from other members of the Empower organization. In some instances, EAG has arrangements that are material to its advisory business with related entities outlined below. Licensed representatives of EAG and other EAG’s advisory staff are employed by Empower Retirement, LLC (Empower) and are Empower Associates. EAG is not a registered broker-dealer, however, there are a very limited number of licensed EAG representatives that an affiliated broker/dealer, Empower Financial Services, Inc. (EFSI), also supervises. Other Financial Industry Affiliations Recordkeeping and Administrative Services Company Empower Retirement, LLC (Empower) is a comprehensive administrative and recordkeeping services provider for financial institutions and employers, which include educational, advisory, enrollment, and communication services for employer-sponsored defined contribution plans and associated defined benefit plans under Internal Revenue Code Section 401(a), 401(k), 403(b), 408, and 457. Insurance Companies 12  Empower Annuity Insurance Company of America (EAICA) is an insurance company domiciled in the State of Colorado. EAG is a wholly owned subsidiary of ESH US, which is owned by EAICA. EAICA, pursuant to various agreements, may provide investment products, recordkeeping, and other administrative services through its affiliates. Empower Life & Annuity Insurance Company of New York (ELAINY) is an insurance company domiciled in the State of New York. EAG is under common control with ELAINY and is an affiliate of ELAINY where EAICA indirectly owns EAG and is the sole owner of ELAINY. ELAINY, pursuant to various agreements, may provide investment products and administrative services through its affiliate, Empower, to retirement plans for which affiliated investment advisers may also provide services. Empower Annuity Insurance Company (EAIC) is an insurance company domiciled in the State of Connecticut. EAG is under common control with EAIC and is an affiliate of EAIC where EAICA indirectly owns EAG and is the sole owner of EAIC. EAIC, pursuant to various agreements, may provide investment products and administrative services individually and through its affiliate, Empower, to retirement plans for which EAG may also provide its services. Broker-Dealer Empower Financial Services, Inc. (EFSI), an affiliate of EAG, is a registered limited broker-dealer and wholly owned subsidiary of EAICA. EFSI may provide wholesaling, direct sales, or enrollment and/or communication services to retirement plans and their participants. Specifically, EFSI may act as an endorser of EAG’s investment advisory services for qualified or eligible plan participants. Trust Company Empower Trust Company, LLC (ETC) is a trust company and affiliate of EAG. ETC is a wholly owned subsidiary of ESH US, which is a wholly owned subsidiary of EAICA. ETC is chartered under the laws of the State of Colorado. Investment Company Empower Funds, Inc. (EFI or Empower Funds), an investment company registered under the Investment Company Act of 1940, is affiliated with EAG. ECM is the investment adviser to EFI, as discussed below. Investment Advisers Empower Capital Management, LLC (ECM), an affiliate of EAG, is a registered investment adviser under the Advisers Act and is the investment adviser for Empower Funds. It is a wholly owned subsidiary of ESH US, which is a wholly owned subsidiary of EAICA. Irish Life Investment Management, Limited (ILIM) is a Dublin, Ireland based SEC registered investment adviser. ILIM is part of the Lifeco group of companies; Lifeco has operations in Canada, the United States, Europe, and Asia through ownership of companies including EAICA. EAG is an indirect wholly owned subsidiary of EAICA. EAICA is an indirect wholly owned subsidiary of Lifeco EAICA is an indirect wholly owned subsidiary of Lifeco, which controls ILIM. ILIM manages the index series of Empower Funds. Holding Company Great-West Lifeco Inc. (Lifeco), EAG’s indirect parent company, owns approximately 6% of Franklin Templeton Investments’ parent company, Franklin Resources, Inc. (Franklin) as of January 1, 2024. Franklin or certain of its investment management subsidiaries (collectively, the Franklin Group entities) may provide management, advisory or sub-advisory services to investment funds that may be investment options in a Managed Account. Franklin and Lifeco have entered into arrangements under which Lifeco has committed to allocate Lifeco and affiliate assets over a period of time to be managed by Franklin’s investment managers and to support the availability of Franklin Group entity products and services on enterprise platforms. As a result, Empower and Lifeco will derive an economic benefit to the extent that Franklin Group entities provide management, advisory or sub-advisory services to funds or products. If Franklin achieves certain revenue thresholds under those arrangements, Lifeco will receive contingent transaction consideration and Lifeco and other Empower affiliates will derive an economic benefit if assets are allocated to a Franklin investment option. 13  Branding The affiliated companies of EAG, Empower Personal Wealth, ECM, EFSI, EAICA, EAIC, ELAINY, Empower Funds, Empower, and ETC operate under the multiple brands of Empower and Empower Institutional depending upon the products, services and retirement markets involved. These brands do not materially affect the internal structure of EAG or EAG’s corporate ownership. Conflicts of Interest EAG has authorized EFSI, an affiliate broker/dealer of EAG, and its licensed agents and registered representatives who are Empower employees (collectively referred to as Agents) to refer prospective clients to EAG. In this arrangement, in addition to their salary, such Agents may earn bonus compensation based upon successful referrals or endorsements. Empower also indirectly compensates other Agents and EAG representatives through bonus compensation, in addition to their salary, in the event that a referred prospect becomes a new client of EAG’s Services. The compensation paid to Agents or EAG representatives does not increase the fees paid by the client. EAG also has conflicts of interest to the extent that it makes investment recommendations to clients or suggests use of affiliated financial products or services which will pay additional compensation to its affiliates. Conflicts related to increased use and promotion of the Services: • Increased advisory fee income. EAG’s representatives may recommend that you use the Services. If you enroll in certain Services, EAG will earn additional compensation in the form of advisory fees. • Increased affiliate fee income. When you use the Services, EAG may recommend you increase contributions or utilize other savings or investment strategies. EAG’s affiliates provide a bundle of recordkeeping, trust, custody, brokerage, investment, and other related services to retirement plans and other investment accounts. If you pay for these related services through an arrangement where our affiliates charge a direct fee, EAG’s affiliates may receive additional fees for these services. These additional fees result from EAG’s recommendations because you may contribute, invest, or transact in more assets with EAG’s family of companies. • Representative Compensation. EAG has authorized its individual adviser representatives and EFSI, an affiliate of EAG, and its licensed agents and registered representatives who are Empower employees (collectively referred to as, “Agents”) to solicit, refer and market EAG’s services. Agents receive a salary and are eligible to receive incentive compensation (including bonus payments) paid by Empower. Certain Agents serve in “Wealth Solutions Advisor,” and similar roles that educate prospective clients about available products and services, and, provide investment advice. Agents receive incentive compensation paid by Empower when they refer a retirement plan participant to an EAG representative in its rollover/distribution call center to consider whether to roll over plan assets into advisory accounts with EAG. Depending on the position type of the referring Agent, an Agent also receives incentive compensation paid by Empower when the referred participant ultimately rolls over assets into and funds an advisory account with EAG. Under an incentive compensation plan applicable to Wealth Solutions Advisors and certain other roles, incentive compensation is based, in part, on funded net asset accumulation and retention and compensation varies by product “grade” (or tier). Specifically, Grade 1 products include Empower Personal Cash and self-directed brokerage accounts (taxable and IRA/SEP); Grade 2 products include Empower Investment Account, Empower Managed Portfolio, SmartSolution IRA/Roth IRA, and Premier Non- Managed accounts; and Grade 3 products include Personal Strategy, Personal Strategy+, and Premier Managed accounts. Grade 1 products are self-directed and, when recommending or opening a self-directed brokerage account, Agents do not act in a fiduciary capacity. Payout rates are generally higher for higher-grade products based on individual product complexity and the requisite expertise required of Agents to discuss and open such products. These arrangements create conflicts of interest because Agents have financial incentives to recommend or encourage enrollment in, or selection of, certain products or services or to encourage rollovers or transfers of additional assets. Compensation paid to Agents does not increase the fees paid by account holders. • Other Agents’ individual performance goals, within Workplace Planning & Advice and including, but not limited to, Workplace Planning Consultants, are based on a combination of factors including the number and quality of 14  customer engagements during the measurement period and the amount of customer assets retained or accumulated as a result of those engagements. Depending on position type, performance goals also Other Business Activity Certain senior managers and officers of EAG may also serve as executive officers of EAG’s parent company EAICA, and other EAG affiliates. Investment Lines of Credit/Loan Advances EAG will make introductions for investment lines of credit or loan advances in certain situations. Both are offered by Pershing/Bank of New York who serves as the custodian and broker-dealer but is otherwise an unaffiliated financial institution. These offerings are opened only at the client’s sole discretion, and EAG does not receive payment or remuneration for making these introductions or in the event that any credit or loan advance is made. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading EAG Code of Ethics EAG has adopted a Code of Ethics (EAG’s Code) pursuant to Advisers Act Rule 204A-1. EAG’s Code sets forth a standard of business conduct expected of advisory personnel. It requires EAG’s advisory personnel, among other things, to report their personal securities holdings and transactions in accordance with the Advisers Act. EAG requires its officers, managers, and certain employees (Access Persons) to comply with EAG’s Code. EAG will provide a copy of EAG’s Code to current or prospective clients, upon request. EAG’s Code includes provisions related to: • Fiduciary responsibility to clients/Members; • Compliance with federal securities laws; • Protection and safeguarding of confidential information; • Giving and receiving gifts, gratuities, and entertainment; • Political contributions; • Reporting and monitoring personal securities transactions; • Avoiding and disclosing conflicts of interest; and • Reporting violations of the EAG’s Code. Personal Trading EAG’s Code requires pre-clearance of certain securities transactions. Access Persons may trade for their own personal accounts in securities that EAG recommends to and/or purchases for its advisory clients. However, because EAG’s Code would permit Access Persons to invest in the same securities as clients in some circumstances, there is a possibility that employees could benefit from market activity by a client in a security held by an Access Person. As a result, EAG continuously monitors trading in accordance with EAG’s Code and federal securities laws. EAG intends for EAG’s Code to ensure that the personal securities transactions and the outside business activities of EAG’s Access Persons do not interfere with making decisions in the best interest of advisory clients or Members. Principal Trading EAG has adopted a policy and practice not to engage in any principal transactions. EAG holds no investments for its own accounts that EAG could buy from, or sell to, an advisory client. In the event of any change in EAG’s policy, management must approve any such change. EAG would only permit a principal transaction after meeting the review and approval requirements described under the anti-fraud section of the Advisers Act. Item 12 – Brokerage Practices Brokerage Selection; Best Execution 15  Transactions recommended for the Advisory Services discussed in this Brochure are executed through Pershing. Personal Strategy+ Services transactions are executed through the respective plan’s financial institution where the employer- sponsored retirement account is held. Soft Dollar Practices As a matter of policy, EAG does not utilize research, or other products or services from third parties in connection with client securities transactions on a soft-dollar commission basis. Trade Aggregation EAG’s Managed Accounts client trades are batched throughout the day to leverage operational and market efficiencies. Client-directed transactions and liquidations may not be executed on a same-day basis. Portfolio transaction requests, including liquidations, can be monitored via the Dashboard, or via the custodian’s website; however, neither site is real-time with respect to liquidations and transactions. EAG trades Managed Accounts exclusively with Pershing and this creates a conflict of interest because of the operational support services Pershing provides to EAG. In recognition of this conflict, we have implemented a periodic analysis to evaluate execution quality and a cross-functional Best Execution Committee which oversees the review process. EAG communicates Personal Strategy+ trade orders through a third-party (Third-Party Service Provider). The Third- Party Service Provider communicates orders to the financial institution where a client’s Personal Strategy+ account is held, and the financial institution is responsible for executing the trades. Personal Strategy+ trade orders will not be executed on the day they are communicated by EAG and may be delayed due to circumstances outside of our control. Generally, the Third-Party Service Provider will communicate trades to the financial institution within 36 hours, but some orders may take longer for multi-part trades. Once an order has been successfully communicated, execution of the trade typically takes one business day, but will depend on the financial institution. If a client elects to invest in the Private Equity offering, the client will invest in a registered closed end fund product advised by iCapital, which is responsible for fund investment selection and portfolio management in private equity securities. Supplemental information on this program is provided to Private Clients upon request. EAG seeks to effect orders correctly, promptly, and in the best interests of our clients. In the event an error occurs in the handling of any client transaction, due to our actions, or inaction, we will offer to correct the error upon discovery (within the confines of the account requirements and restrictions) and without disadvantaging the client. Compensation or consideration for the error loss may be paid to clients through the offer of fee waivers or fee credits for management Services in lieu of cash or securities. Negative investment performance returns resulting from the implementation of an investment strategy are not considered a trade error for purposes of our policy. Item 13 – Review of Accounts EAG utilizes portfolio management software in concert with the client’s Advisor to monitor and manage clients’ accounts on a continual basis. Exception reporting is monitored by Portfolio Manager Deviations from an account’s determined asset allocation parameters and the addition or removal of a specific security from the designated model portfolio may trigger periodic rebalancing. For clients who enroll in our Personal Strategy+ program, our Portfolio Management Team monitors underlying investment allocations using the Third-Party Service Provider’s application, which identifies when a client’s account is out of alignment with their Personal Strategy+ allocation. The Portfolio Management Team will also periodically revisit the client’s allocation relative to underlying investment lineup changes and make changes, as necessary. EAG provides clients with online access to their financial information through the Dashboard. In addition, EAG provides a detailed monthly report to each client. Clients also continue to receive account statements and confirmations from the designated Broker (Pershing) or Personal Strategy+ plan administrator (if applicable). Clients are urged to periodically compare statements prepared by EAG and their Broker (Pershing) or Personal Strategy+ plan administrator (if applicable) with specific emphasis on activity, holdings, and valuations. Item 14 – Client Referrals and Other Compensation 16  Promotions EAG has periodic promotions offering various items, such as technology products, fee waivers on management fees, or reduced management fees. Client referrals, or other referral arrangements as outlined below, may, from time to time, be combined with promotional offers. Any combination of referral benefits and promotional items will not result in a client paying a higher advisory fee. EAG will disclose the terms of promotional offers to clients at the time of the offers. Client Referrals From time to time, EAG offers free Advisory Services for a certain period for existing clients who refer new clients to EAG. When the referred client signs up and begins trading, both the existing client and referred client receive fee- waived Advisory Services for the same period of time. From time to time, Advisors may also offer other incentives for client referrals. EAG will disclose the details of those incentives to existing and referred clients at the time of the offer. Prospective clients that are referred by existing clients should be aware that the referring client will receive an economic benefit for making the referral. The free Advisory Services awarded, or any other incentive provided by EAG, do not increase the fees or costs for the referring or referred client. Referrals by Affiliates EAG has an Endorsement Agreement in place with EFSI, an affiliated broker-dealer, whereby EFSI or EFSI registered representatives will refer certain high-net worth clients to EAG. EFSI or EFSI registered representatives may receive direct or indirect compensation for these referrals. Agents and EAG representatives receive incentive compensation paid by Empower when they refer a retirement plan participant to an EAG representative in its rollover/distribution call center to consider whether to rollover plan assets into advisory accounts with EAG. Depending on the position type of the referring Agent or EAG representative involved, an Agent or EAG representative also receives incentive compensation paid by Empower when the referred participant ultimately rolls over their assets into and funds an advisory account with EAG. Any affiliated referral compensation arrangement will not increase costs for clients. Third-Party Client Introductions EAG also has referral arrangements with unaffiliated third parties for client referrals. These third parties introduce prospective clients to EAG and will receive compensation in the form of cash payments for these introductions. These third parties are eligible for compensation even if the referred prospect does not become a client. Such compensation will be paid pursuant to a written agreement. These referral arrangements will not result in increased fees or costs for clients. Testimonials and Endorsements EAG enters into agreements with clients and non-client Third Parties (Promoters) to provide testimonials or endorsements of our Advisory Services. Any advertisement that displays a testimonial or endorsement provided by a Promoter will disclose clearly and prominently whether the Promoter i) is a client of EAG; ii) is paid or unpaid; and iii) creates any other material conflict of interest. If the Promoter is paid, EAG confirms that the Promoter is not disqualified under Federal Securities Laws and discloses the compensation range. Individuals who become clients as a result of our various referral programs acknowledge in our client agreement that they have reviewed, read, and understood our disclosures and Part 2A of EAG’s Form ADV. Affiliate Marketing Program Empower Personal Wealth offers an Affiliate Marketing Program (AMP) to web-based authors and participates in co-registration agreements, where the participants (affiliate or affiliates) are compensated for each person who uses the affiliates’ webpages to register with the Dashboard and link at least $100,000 in new investable assets to the Dashboard. These affiliates are eligible for compensation even if the referred person does not become a client. Affiliates will financially benefit from referring users to EAG or affiliates. This creates a conflict of interest and incentivizes affiliates to present content favorable to EAG or affiliates of EAG because of the compensation structure of the AMP. No additional fees or costs are charged to persons who register with the Dashboard and become a client as a result of the AMP. Other Referral Arrangements 17  Empower Personal Wealth enters into referral agreements with third parties who refer prospective clients to the Dashboard (Referrer or Referrers) under which Referrers receive compensation for each individual who acknowledges that they have at least $100,000 in investable assets. Individuals referred by Referrers to the Dashboard and subsequently become clients do not pay any increased fees to EAG as a result of the referral arrangement. Item 15 — Custody EAG does not maintain actual custody of its clients’ cash, bank accounts, or securities. If applicable, clients receive periodic account statements (at least quarterly) from their custodian and should carefully review these statements. Item 16 – Investment Discretion Personal Strategy+ Services EAG offers clients Personal Strategy+ Services, which are ongoing, discretionary wealth management Services on employer- sponsored retirement accounts. This is a distinct offering from our point-in-time retirement plan allocation services that are available to all Core Managed Account clients upon request. EAG’s Personal Strategy+ Services are limited to providing investment advice and management of the assets in a client’s employer-sponsored retirement account(s) and the plan administrator continues to act as the qualified custodian for these accounts. Any transaction or performance information provided by EAG is for informational purposes only, as the plan administrator for the employer-sponsored retirement account(s) is the official custodian and recordkeeper for all performance and transaction information. If the client would like to use the advice provided, the client will need to ensure a trade is placed in accordance with the plan’s rules since EAG does not have custody of the plan account. Item 17 — Voting Client Securities EAG uses a third-party proxy voting service to help fulfill our voting obligations in voting proxy ballots for our clients. Votes are cast through the Broadridge ProxyEdge® platform, which provides access to proxy voting recommendations as well as historical voting information. Services provided to us through ProxyEdge® include reporting, auditing, and recordkeeping. With the assistance of Broadridge, Glass Lewis & Co. (“Glass Lewis”) provides EAG recommendations based on Glass Lewis’ own internal guidelines, research, and analysis. Votes are generally cast consistent with Glass Lewis guidelines and recommendations; however, EAG will vote otherwise, or abstain, if it is deemed in the best interest of its clients to do so. EAG votes proxies for SRI accounts in the same manner as the Core Personal Strategy portfolios, which use the Glass Lewis standard policy. This policy does not take an activist or ESG-specific approach. Clients with at least $5 million in AUM in Personal Strategy are permitted to vote their own proxies by “opting out” of proxy voting services during the account opening process, or at any time, by submitting a request in writing to EAG. If a client chooses to “opt out,” they do so on an “all or none” basis and agree to respond to their own proxies independently of EAG. Additionally, to the extent a client holds a foreign direct security that is not a Personal Strategy position, Glass Lewis is unable to vote proxy ballots for those client-mandated holdings. EAG does not vote proxies for holdings in Personal Strategy+ advised accounts. EAG maintains relevant and appropriate proxy records. A client may obtain a complete copy of the Policies & Procedures related to proxy voting by requesting this information in writing to their Advisor. The client may also request in writing, from their Advisor, information concerning the manner in which proxy votes have been cast on behalf of the client during the prior annual period. Such information is provided in writing as soon as practicable. Item 18 — Financial Information As previously discussed, under certain circumstances EAG has discretionary authority over certain client funds and securities. Accordingly, EAG must disclose only information about its financial condition that is reasonably likely to impair EAG’s ability to meet contractual commitments to its clients. EAG has no financial commitment that impairs its ability to meet contractual commitments to its clients, nor has EAG been the subject of a bankruptcy proceeding. Finally, EAG does not require or solicit prepayment of fees of more than $1,200 per client/Member more than six months in advance. 18  This is not an Offer to Purchase or Sell Securities. The information contained in this Brochure, including information regarding Empower Funds, is for disclosure and other informational purposes only. It is not an offer to sell or a solicitation of an offer to buy any securities and may not be relied upon in connection with the purchase or sale of any security. 19 

Item 1 – Cover Page EMPOWER ADVISORY GROUP, LLC Wrap Fee Program Brochure for: EMPOWER MANAGED PORTFOLIOS 8515 East Orchard Road Greenwood Village, CO 80111 Telephone: 844-878-5454 March 31, 2026 This wrap fee brochure provides information about the qualifications and business practices of Empower Advisory Group, LLC (EAG). If you have any questions about the contents of this brochure, please contact us at the phone number above. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (SEC) or by any state securities authority. EAG is a registered investment adviser under the Investment Advisers Act of 1940 (Advisers Act). Registration of EAG does not imply any level of skill or training. Additional information about EAG is available on the SEC’s website at https://adviserinfo.sec.gov or on EAG’s website at https://empower.com/EAG. The SEC’s web site also provides information about any person affiliated with EAG who is registered, or is required to be registered, as an investment adviser representative with EAG. Item 2 – Material Changes This section of the Brochure highlights and discusses any material changes that the Adviser made since the Adviser’s last update on September 19, 2025. A material change was made to Item 10 and Item 14 to describe changes to representative compensation. 1  Item 3 -Table of Contents Item 1 – Cover Page ............................................................................................................................................................................ 1 Item 2 – Material Changes .................................................................................................................................................................. 1 Item 3 -Table of Contents ................................................................................................................................................................... 2 Item 4 – Advisory Business ................................................................................................................................................................. 3 Item 5 – Fees and Compensation ....................................................................................................................................................... 4 Item 6 – Performance-Based Fees and Side –by Side Management .................................................................................................. 5 Item 7 –Types of Clients ...................................................................................................................................................................... 5 Item 8 – Methods of Analysis and Investment Strategies .................................................................................................................. 5 Item 9 – Disciplinary Information ....................................................................................................................................................... 6 Item 10 - Other Financial Industry Activities and Affiliations ............................................................................................................. 7 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...................................................... 9 Item 12 – Brokerage Practices ............................................................................................................................................................ 9 Item 13 – Review of Accounts ............................................................................................................................................................ 9 Item 14 – Client Referrals and Other Compensation........................................................................................................................ 10 Item 15 - Custody .............................................................................................................................................................................. 10 Item 16 – Investment Discretion ...................................................................................................................................................... 10 Item 17 – Voting Client Securities ..................................................................................................................................................... 10 Item 18 – Financial Information ........................................................................................................................................................ 10 2  Item 4 – Advisory Business Description of Advisory Firm EAG has been a registered investment adviser under the Advisers Act since 2000. EAG is also registered with state securities divisions in all 50 states, the District of Columbia, Guam, US Virgin Islands, and Puerto Rico. EAG offers investment management and advisory services primarily to plan sponsors of employer-sponsored retirement plans such as 401(a), 401(k), 403(b) and 457 plans, including government entities and their participants, and to all account holders of the Empower IRA (IRA holder or account holder). EAG does not choose the investments offered in employer-sponsored retirement plans or IRAs. EAG serviced plans receive recordkeeping services through Empower Retirement, LLC (Empower), the recordkeeping entity affiliated with EAG. EAG also offers investment management services to individuals and to retail brokerage account holders. In addition, EAG offers Empower Managed Portfolios (the MP Service) to account holders of Empower Brokerage accounts. More information about EAG’s services, including an applicable brochure, can be obtained by contacting EAG at the number provided on the cover page of this Brochure or by visiting EAG’s website at https://empower.com/eag. EAG is a wholly owned subsidiary of Empower Services Holdings US, LLC (ESH US), a holding company domiciled in the State of Delaware. Empower Annuity Insurance Company of America (EAICA) owns ESH US. EAICA is a direct wholly owned subsidiary of Empower Holdings, LLC (EHL), a Delaware holding company. EHL is a direct wholly owned subsidiary of Great-West Lifeco U.S., LLC (Lifeco US) and an indirect wholly owned subsidiary of Great-West Lifeco Inc. (Lifeco), a Canadian holding company. Lifeco is a subsidiary of Power Financial Corporation (Power Financial), a Canadian holding company with substantial interests in the financial services industry. Power Corporation of Canada (Power Corporation), a Canadian holding and management company, has voting control of Power Financial. The Desmarais Family Residuary Trust has voting control of Power Corporation, through a group of private holding companies that it controls. Types of Services Discussed in this Brochure: The MP Service is an investment management service utilizing asset allocation models comprised mainly of Empower Funds for customers with Empower Brokerage accounts. EAG creates the MP Service portfolios from the following Empower Funds plus a cash alternative investment (the Funds and the Cash Fund): Fund Name Symbol CUSIP Empower Core Strategies: U.S. Equity Fund MXEBX 39137G264 Empower Core Strategies: International Equity Fund MXECX 39137G256 Empower Core Strategies: Flexible Bond Fund MXEDX 39137G249 Empower Core Strategies: Inflation- Protected Securities Fund MXEGX 39137G223 This Brochure discusses in greater detail the fees, risks, account holder responsibilities and limitations for the MP Service. The prospectus and Statement of Additional Information materials that accompany each investment option, as applicable, also fully explain the fees and expenses of the Empower Funds listed above. There is no guarantee provided by any party that participation in any of the advisory services will result in a profit. Enrollment in the MP Service: To enroll in the MP Service, you must have a minimum amount of $5,000 in assets in your account subject to the MP Service (Account). The MP Service asks you to provide EAG with information about yourself, your financial situation, your investment objectives, and your investment risk preferences. The MP Service uses this information to manage your Account and calls it your investment profile (Investment Profile). Using your Investment Profile, EAG will make an initial investment allocation of your Account using EAG’s investment methodology. EAG does not provide tax advice through the MP Service. After enrolling in the MP Service, you can no longer make trades in the funds in your Account managed by the MP Service, although you can terminate participation in the MP Service as described below. Each quarter, EAG will review your Account allocation in light of your Investment Profile and its investment methodology and reallocate your Account if EAG deems it appropriate under the MP Service’s parameters. These rebalancing transactions will take place without consideration of the tax consequences of the transaction. You will be responsible for capital gains and losses associated with the reallocation activity. It is important that you provide EAG with the information needed to populate your Investment Profile, and that you update your Investment Profile as information changes. You can make updates by contacting EAG’s phone center, or by returning an updated profile questionnaire to EAG. If there is a change in the information you previously provided to EAG for your Investment Profile, it is your responsibility to contact EAG to update your Investment Profile. If you wish to terminate the MP Service relative to your Account, you should contact the EAG service 3  center by telephone. If you terminate the MP Service, you may choose to transfer your assets in-kind to an Empower Investment Account, a taxable brokerage account offered by Empower. If you do not choose this option, EAG will move all the assets in the Account into the cash alternative investment option, and there may be tax consequences associated with the movement out of the funds in the MP Service into the cash alternative investment. You may then receive your account balance or transfer the account balance to an Empower Investment Account or other outside account to invest in other investment options. Assets Under Management: The SEC adopted a uniform method for advisers to calculate assets under management for regulatory purposes, which it refers to as an adviser’s “regulatory assets under management.” Regulatory assets under management are generally an adviser’s gross assets, i.e., assets under management without deduction for outstanding indebtedness or other accrued but unpaid liabilities. EAG reports its regulatory assets under management in Item 5 of Part 1 of Form ADV, which is located at www.adviserinfo.sec.gov. As of December 31,2025: $ 164,237,996,079 Discretionary investment management among all services $ 31,188,325,400 Non-discretionary investment advisory services among all services in the amount of: $ 195,426,321,479 Total discretionary and non-discretionary investment management and advisory services in the amount of: Item 5 – Fees and Compensation EAG charges an investment service fee for providing the MP Service (the Investment Service Fee). EAG charges the Investment Service Fee, shown below as an annual percentage of assets subject to the MP Service and held in your Account. EAG debits the Investment Service Fee quarterly based on the number of days in the quarter you used the MP Service. EAG calculates the fees on an average daily Account balance and assessed in arrears. You authorize EAG or its designee to debit your Account for the Investment Service Fee. A deduction showing the Investment Service Fee will appear on your Account statements. If you stop using the MP Service, EAG will charge your Account for the portion of the calendar quarter when you used the MP Service. During your relationship with EAG, EAG’s fees may change. EAG will notify you of fee changes, and your continued use of the MP Service means that you accept any fee change. The MP Service is a wrap fee program, and the Investment Service Fee is a wrap fee, sometimes referred to as a unitary fee. This means that the Investment Service Fee includes your cost of several investment services and functions provided by EAG, its affiliates, and their subcontractors. These services and functions include the following: • • • • • • investment methodology to manage your Account; portfolio management services, including ongoing evaluation and reinvestment; trade execution, clearing and settlement services; custody services; reporting services, including tax reporting; and brokerage account services. Investment Service Fee: Assets subject to the MP Service Total Annual fee Quarterly portion of Annual fee The first $100,000 0.50% 0.125% $100,001 to $250,000 0.40% 0.10% $250,001 to $400,000 0.30% 0.075% Over $400,000 0.20% 0.05% The Investment Service Fee does not include the cost of the Empower Funds or the cash alternative investment described above. For more information about the fees assessed by these investments, including information about the expense ratios and share class, please review the Fund prospectus. On behalf of EAG, Pershing will provide you with a Fund prospectus separately, upon EAG’s investment of your Account in the Funds and the Cash Fund. You can also contact EAG for additional information. 4  EFSI will charge your brokerage account ancillary fees that are applicable under the MP Service but not part of the Investment Service Fee, such as for outgoing account transfers, returned and voided checks, fed funds wires, and overnight/express mail. These fees are subject to change. Other: EAG has authorized Empower Financial Services, Inc. (EFSI), an affiliate of EAG, and its licensed agents and registered representatives who are Empower employees to solicit, refer, and market EAG’s services. Certain EAG and EFSI representatives are eligible to receive incentive compensation (including bonus payments) in addition to salary for communicating with, educating, and/or assisting plan participants or account holders to enroll in services, such as the MP Service. For Wealth Solutions Advisors and certain other roles, incentive compensation credits and payout rates vary by product “grade” (tier) and are generally higher for higher-grade products, which creates an incentive to recommend those products. Incentive compensation depends on position type and is generally based on Empower’s profitability and achievement of individual performance goals. See Item 10 and Item 14 for additional detail regarding these compensation arrangements and conflicts of interest.. Item 6 – Performance-Based Fees and Side-by-Side Management EAG does not charge any performance-based or side-by-side management fees (fees based on investment performance or a share of capital gains on, or capital appreciation of, the assets of a client). Item 7 –Types of Clients EAG offers investment advisory and management services to employer-sponsored retirement plans. These include 401(a), 401(k), 403(b) and 457 plans, including government entities and their participants through arrangements with the plan’s recordkeeper and to account holders of the Empower Premier IRA or another plan elected managed account services. The MP Service is currently available only to those who have a retail Empower brokerage account. Item 8 – Methods of Analysis and Investment Strategies In providing investment management services, EAG relies on several approaches to select and manage asset allocation and underlying strategies. EAG develops the asset allocation models using a constrained mean-variance optimization approach. EAG uses capital market assumptions for the expected returns, standard deviations, and correlation between each asset class to optimize the maximum expected return per unit of risk at each pre-defined risk level, subject to reasonable investment management constraints. The models represent a range of equity/fixed income mixes such that each client can be individually assigned to a model. Capital market assumptions are generated using an expected return approach and various asset-class-specific risk inputs. We currently target seven individual inputs into our capital market assumptions - four equity inputs, two fixed income inputs, and a risk-free rate: 1. 2. 3. 4. 5. 6. 7. Risk-Free Rate: The process typically starts with an assumption regarding the risk-free rate. The current risk-free rate is generally assumed to be the current yield on the three-month U.S. Treasury T-Bill. The historical risk-free rate is the average 30-day T-Bill yield since 1926. Equity Risk Premium (equity): We define the equity risk premium as the average return on large-cap U.S. equities using the longest time series available, less the historical risk-free rate. Country Risk Premium (equity): The country risk premium for non-U.S. developed markets is a function of the volatility- adjusted equity risk premium for domestic large-cap equities. The country risk premium for non-U.S. emerging markets is a function of the volatility-adjusted equity risk premium for domestic large-cap equities. Value Premium (equity): We calculate the value premium using the historical returns of the appropriate Russell® Value and Growth indices since their inception in 1979. Size Premium (equity): Small-cap and mid-cap size premia are a function of the average annual returns associated with these types of investments, less the return of comparable large cap investments. Default Premium (fixed income): We estimate the default premium using the historical excess returns generated by corporate bonds, relative to comparable government bonds over long-term periods. Horizon Premium (fixed income): We estimate the horizon premium using the historical excess returns generated by longer-term government bonds, relative to comparable shorter-term government bonds over long-term periods. Expected standard deviations and correlations between asset classes are based on long-term results from relevant securities indices associated with each asset class. Finally, EAG establishes minimum and maximum allocations to each asset class based on both absolute and relative positioning to ensure that mathematical-created allocations are appropriately weighted based on historical anomalies that EAG does not project into the future. When assigning clients to particular portfolios, EAG asks clients to complete a risk tolerance questionnaire that assesses their tolerance and capacity for investment risk. Next, we assign clients to the model that aligns most closely with their risk characteristics. The risk tolerance questionnaire analyzes three factors: 1. Overall investment knowledge and capacity for investment risk, 2. Tolerance for investment risk, and 3. Time horizon for investment. 5  EAG scores and plots each investor’s results against a preset matrix that determines which of the portfolios is most appropriate. For example, EAG will assign a conservative portfolio to investors scoring low on risk tolerance and short on time horizon. Whereas EAG will assign an aggressive portfolio to investors scoring high on risk tolerance and with a longer time horizon. EAG does not constrain itself to limited types of investments or methodologies. EAG may use a variety of proprietary analytics and third- party data sources in constructing the analyses supporting the investment decisions and subsequent monitoring and adjustments. General Risks of Investing Investing in securities involves risk of loss that clients should be prepared to bear. Neither EAG nor its affiliates guarantee that the recommendations will result in achieving the retirement income goal. Neither EAG nor its affiliates can guarantee that you can or will avoid negative returns in any of the recommendations. An investment’s future performance may differ substantially from its historical performance and may incur a loss. Past performance is no guarantee of future results. You should carefully consider the benefits of a well-balanced and diversified investment portfolio. Market or other economic conditions that cause one category of assets to perform very well often cause another asset category to underperform. Diversification does not guarantee investment returns and does not eliminate the risk of loss. Below are some of the common risk factors that could produce a loss in a client’s account, a specific investment product, or asset category: • Market Risk: Stock and bond markets are volatile and can decline significantly in response to adverse issuer, political, regulatory, market or economic developments in the U.S. and in other countries. Market risk may affect a single company, a sector of the economy, a country or geopolitical region, or the market as a whole. Market risk may impact stock and/or bond markets in unanticipated and different ways. • Business Risk: These risks are associated with a particular industry or a particular company within an industry. • Capitalization Risk: Limited resources or less diverse products or services may hinder small-cap and mid-cap companies, and such companies’ stocks have historically been more volatile than the stocks of larger, more established companies. • Category or Style Risk: During various periods of time, one category or style may underperform or outperform other categories and styles. • • Credit Risk: The risk that the issuer of a security may be unable to make interest payments and/or repay principal when due. A downgrade to an issuer’s credit rating or a perceived change in an issuer’s financial strength may affect a security’s value and impact the performance of the issue along with any mutual fund or exchange-traded fund that holds it. Interest Rate Risk: Interest rate changes significantly affect a debt security’s market value. When interest rates rise the debt security’s market value declines. When interest rates decline, market values rise. The longer bond maturity results in the greater risk and the higher yield. Conversely, the shorter bond maturity results in the lower risk and the lower yield. Inflation Risk: When any type of inflation is present, purchasing power may erode at the inflation rate. • • Reinvestment Risk: The risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e., interest rate). This relates primarily to fixed income securities. • • Exchange-traded funds: Exchange-traded funds present market and liquidity risks because they are listed on a public securities exchange and are purchased and sold via the exchange at the listed price. The price will vary based on current market conditions and may deviate from the net asset value of the exchange-traded fund’s underlying portfolio. There may also be an inactive market for certain funds, and/or losses from trading in secondary markets. Target Date Funds: Generally, the asset allocation of each target date fund will change on an annual basis with the asset allocation becoming more conservative as the fund nears the target retirement date. The target date is the approximate date when investors plan to start withdrawing their money. The principal value of the fund(s) in a plan’s lineup is not guaranteed at any time, including at the time of target date and/or withdrawal. • An investment in a money market fund is not insured or guaranteed by the Federal Deposit Insurance Corporation (FDIC) or any other government agency. Although some money market funds such as U.S. Government money market funds strive to preserve the value of the investment at $1.00 per share, it is possible to lose money by investing in a money market fund. Additionally, other money market funds may operate under new rules and regulations permitting such funds to have a “floating” value per share. A floating value may be more or less than $1.00 per share depending on market conditions and impose liquidity/redemption fees for large or frequent withdrawals. For more complete information about any of the mutual funds or investment products available within the Account, please contact the phone number on page 1. Item 9 – Disciplinary Information EAG, as a registered investment adviser, is required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of EAG or the integrity of EAG’s management. EAG has the following disciplinary event to report relative to this item: On August 29, 2025, EAG and its broker/dealer affiliate, Empower Financial Services, Inc. (EFSI), settled a matter with the SEC. 6  The SEC found that, from July 1, 2019 through December 31, 2022, certain retirement plan advisors of EFSI and EAG, all of whom were both registered representatives associated with EFSI and investment adviser representatives associated with EAG, did not sufficiently disclose whether retirement plan advisors were acting as a registered representative or an investment adviser representative when recommending that a plan participant enroll in EAG’s managed account service. Additionally, EFSI and EAG did not adequately disclose the conflicts of interest presented by certain incentive compensation arrangements, leading to misleading statements made to plan participants. Finally, the SEC found that EFSI did not establish, maintain and enforce written policies and procedures reasonably designed to identify and address conflicts of interest in connection with recommendations to enroll in EAG’s managed account service. As a result, the SEC determined that EAG violated section 206(2) of the Investment Advisers Act of 1940 (“Advisers Act”) and EFSI failed to comply with the disclosure and conflict of interest obligations of Regulation Best Interest (“Reg BI”), thereby violating Reg BI’s General Obligation (Exchange Act Rule 15l- 1(a)(1)). Without admitting or denying the findings, EFSI and EAG entered into a settlement with the SEC, pursuant to which EAG was censured; ordered to cease and desist from committing or causing any future violations of Section 206(2) of the Advisers Act thereunder; and EAG agreed to pay a civil monetary penalty in the amount of $750,000; and disgorgement of $4,063,569.80. EFSI was censured; ordered to cease and desist and agreed to pay a civil monetary penalty of $750,000. Item 10 - Other Financial Industry Activities and Affiliations EAG is not a registered broker-dealer. However, due to the organizational structure of EAG’s indirect parent company, Lifeco, certain EFSI registered representatives are also EAG supervised persons and are required to comply with EAG policies and procedures when acting in that advisory capacity. EAG and its management persons are not, and do not have an application pending to register as, a futures commission merchant, commodity pool operator, commodity trading advisor, or an associated person of the foregoing entities. Other Financial Industry Affiliations EAG has arrangements that are material to its advisory business or its clients/participants/account holders with the related entities shown below. These related entities may receive certain fees that are unrelated to EAG’s fees for its advisory services. Recordkeeping and Administrative Services Company Empower Retirement, LLC (Empower) is a comprehensive administrative and recordkeeping service provider for financial institutions and employers, which include educational, advisory, enrollment, and communication services for employer-sponsored defined contribution plans and associated defined benefit plans under Internal Revenue Code Section 401(a), 401(k), 403(b), 408, and 457. Insurance Companies Empower Annuity Insurance Company of America (EAICA) is an insurance company domiciled in the State of Colorado. EAG is a wholly owned direct subsidiary of ESH US, which is owned by EAICA. EAICA, pursuant to various agreements, may provide investment products, recordkeeping, and other administrative services through its affiliates. Empower Life & Annuity Insurance Company of New York (ELAINY) is an insurance company domiciled in the State of New York. EAG is under common control with ELAINY and is an affiliate of ELAINY where EAICA indirectly owns EAG and is the sole owner of ELAINY. ELAINY, pursuant to various agreements, may provide investment products and administrative services through its affiliate, Empower, to retirement plans for which EAG may also provide its services. Empower Annuity Insurance Company (EAIC) is an insurance company domiciled in the State of Connecticut. EAG is under common control with EAIC and is an affiliate of EAIC where EAICA indirectly owns EAG and is the sole owner of EAIC. EAIC, pursuant to various agreements, may provide investment products and administrative services individually and through its affiliate, Empower, to retirement plans for which EAG may also provide its services. Broker-Dealer Empower Financial Services, Inc. (EFSI), an affiliate of EAG, is a registered broker/dealer, principal underwriter and distributor of Empower Funds and wholly owned subsidiary of EAICA. EFSI may provide wholesaling, direct sales, enrollment and/or communication services to retirement plans, their participants and to Empower Brokerage account holders for which EAG may also provide its services. EFSI executes certain trades; however, EFSI does not execute trades for the MP Service, but through a non-affiliated broker-dealer. Trust Company Empower Trust Company, LLC (ETC) is a trust company and affiliate of EAG. ETC is a wholly owned subsidiary of ESH US, which is a wholly owned subsidiary of EAICA. ETC is chartered under the laws of the State of Colorado. ETC may provide discretionary or directed trustee and/or custodial services for EAG’s clients. ETC also serves as the trustee for certain collective investment trusts that may be available as investment options and is the custodian of all Empower Premier IRA accounts. Investment Company Empower Funds, Inc. (EFI or Empower Funds), an investment company registered under the Investment Company Act of 1940, is affiliated with EAG. EFI may provide investment products to retirement plans for which EAG may also provide its services. Empower Capital Management, LLC manages Empower Funds as discussed below. Shares of Empower Funds may be available for purchase by retirement 7  plans advised by EAG or to account holders of the Empower Premier IRA, MP Service, or Empower Premier Investment Account. Investment Advisers Empower Capital Management, LLC (ECM), an affiliate of EAG, is a registered investment adviser under the Advisers Act and is the investment adviser for EFI. It is a wholly owned subsidiary of ESH US, which is a wholly owned subsidiary of EAICA. EAG provides managed account, guidance, and advice services to participants in certain defined contribution plans and to account holders of the Empower IRA and an Empower retail brokerage account that may have as investment options certain portfolios of ECM-managed Empower Funds. EAG also provides the MP Service, which has as its investment options of four Empower Funds managed by ECM. Irish Life Investment Managers Limited (ILIM) – a Dublin, Ireland based, SEC registered investment adviser. ILIM is part of the Lifeco group of companies; Lifeco has operations in Canada, the United States, Europe, and Asia through ownership of companies including EAICA. EAG is an indirect wholly owned subsidiary of EAICA. EAICA is an indirect wholly owned subsidiary of Lifeco, which controls ILIM. ILIM manages the index series of Empower Funds. Holding Company: Great-West Lifeco Inc. (Lifeco), EAG’s indirect parent company, owns approximately 6% of Franklin Templeton Investments’ parent company, Franklin Resources, Inc. (Franklin) as of January 1, 2024. Franklin or certain of its investment management subsidiaries (collectively, the Franklin Group entities) may provide management, advisory or sub-advisory services to investment funds that may be investment options in a Managed Account. Franklin and Lifeco have entered into arrangements under which Lifeco has committed to allocate Lifeco and affiliate assets over a period of time to be managed by Franklin’s investment managers and to support the availability of Franklin Group entity products and services on enterprise platforms. As a result, Empower and Lifeco will derive an economic benefit to the extent that Franklin Group entities provide management, advisory or sub-advisory services to funds or products. If Franklin achieves certain revenue thresholds under those arrangements, Lifeco will receive contingent transaction consideration and Lifeco and other Empower affiliates will derive an economic benefit if assets are allocated to a Franklin investment option. Branding The affiliated companies of EAG; Empower Personal Wealth, LLC; ECM; EFSI; EAICA; EAIC; ELAINY; Empower Funds; Empower; and ETC, operate under the multiple brands of Empower and Empower Institutional depending upon the products, services and retirement markets involved. These brands do not materially affect the internal structure of EAG or EAG’s corporate ownership. Conflicts of Interest Investment models for the MP Service are comprised mainly of Empower Funds. ECM provides services to Empower Funds for administering, managing, and supervising the funds. Because participation in the MP Service will result in an allocation to one or more investment options managed by ECM, use of the MP Service will result in an increase of the assets for which ECM charges service fees. The fund share price includes the fees paid to ECM for management of the Empower Funds. EAG does not receive compensation from its parent company or any of its affiliates as a result of allocations to Empower Funds. Representative Compensation EAG has authorized its individual adviser representatives and EFSI, an affiliate of EAG, and its licensed agents and registered representatives who are Empower employees (collectively referred to as, “Agents”) to solicit, refer and market EAG’s services. Agents receive a salary and are eligible to receive incentive compensation (including bonus payments) paid by Empower. Certain Agents serve in “Wealth Solutions Advisor,” and similar roles that educate prospective clients about available products and services, and, provide investment advice. Agents receive incentive compensation paid by Empower when they refer a retirement plan participant to an EAG representative in its rollover/distribution call center to consider whether to roll over plan assets into advisory accounts with EAG. Depending on the position type of the referring Agent, an Agent also receives incentive compensation paid by Empower when the referred participant ultimately rolls over assets into and funds an advisory account with EAG. Under an incentive compensation plan applicable to Wealth Solutions Advisors and certain other roles, incentive compensation is based, in part, on funded net asset accumulation and retention and compensation varies by product “grade” (or tier). Specifically, Grade 1 products include Empower Personal Cash and self-directed brokerage accounts (taxable and IRA/SEP); Grade 2 products include Empower Investment Account, the MP Service, SmartSolution IRA/Roth IRA, and Premier Non- Managed accounts; and Grade 3 products include Personal Strategy, Personal Strategy+, and Premier Managed accounts. Grade 1 products are self-directed and, when recommending or opening a self-directed brokerage account, Agents do not act in a fiduciary capacity. Payout rates are generally higher for higher-grade products based on individual product complexity and the requisite expertise required of Agents to discuss and open such products. These arrangements create conflicts of interest because Agents have financial incentives to recommend or encourage enrollment in, or selection of, certain products or services or to encourage rollovers or transfers of additional assets. Compensation paid to Agents does not increase the fees paid by account holders. Other Agents’ individual performance goals, within Workplace Planning & Advice and including, but not limited to, Workplace Planning Consultants, are based on a combination of factors including the number and quality of customer engagements during the measurement period and the amount of customer assets retained or accumulated as a result of those engagements. Depending on position type, performance goals also include: total asset growth and retention (including retention and external rollover ratios); introductions or referrals to Wealth Solutions Advisors (described above); client satisfaction measures; and planning-activity measures (such as advice acceptance rates). Additional qualitative factors include leadership, teamwork, client experience, quality and efficiency of client interactions, and 8  adherence to corporate policies and regulatory standards. Incentive compensation is not guaranteed and is determined and paid periodically (for example, monthly or quarterly). Other Business Activities Certain senior managers and officers of EAG may also serve as executive officers of EAG’s indirect parent company, EAICA, and other affiliates of EAG. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading EAG’s Code of Ethics EAG has adopted a written Code of Ethics (the Code) in compliance with Rule 204A-1 of the Advisers Act. The Code sets forth standards of business conduct expected of advisory personnel and applies to EAG’s advisory personnel (referred to as Supervised Persons). EAG requires its Supervised Persons to report their personal securities holdings and transactions in accordance with the Advisers Act. EAG requires its Supervised Persons to comply with the Code. EAG will provide a copy of the Code to current or prospective clients upon request. EAG’s Code includes provisions related to: • • • • • • • • Fiduciary responsibility to clients; Compliance with federal securities laws; Protection and safeguarding of confidential information; Giving and receiving gifts, gratuities, and entertainment; Political contributions; Reporting and monitoring personal securities transactions; Avoiding and disclosing conflicts of interest; and Reporting violations of the Code. Personal Trading The Code requires pre-clearance of certain securities transactions. Officers, managers, and certain employees of EAG (collectively, Access Persons) may trade for their own personal accounts in securities that EAG recommends and/or purchases for its advisory clients. As a result, EAG continually monitors trading in accordance with the Code and federal securities laws. EAG intends for the Code to ensure that the personal securities transactions and outside business activities of EAG’s Access Persons do not interfere with making decisions in the best interest of advisory clients. Principal Trading EAG has adopted a policy and practice not to engage in any principal transactions. EAG holds no investments for its own accounts that EAG could buy from, or sell to, an advisory client. In the event of any change in EAG’s policy, management must approve any such change. EAG would only permit a principal transaction after meeting the review and approval requirements described under the anti-fraud section of the Advisers Act. Participation or Interest in Client Transactions Registered representatives of EFSI may make recommendations to retirement plan participants and provide wholesaling, direct sales, enrollment, and/or communication services to retirement plans, their participants and to account holders for which EAG may also provide its services. Item 12 – Brokerage Practices Brokerage Selection; Best Execution EAG’s non-affiliated service provider, Lockwood Advisors, Inc., or its affiliates, including Pershing LLC, processes transactions for the MP Service. Soft Dollar Practices As a matter of policy, EAG does not utilize research, or other products or services from third parties in connection with client securities transactions on a soft-dollar commission basis. Item 13 – Review of Accounts At least annually, EAG personnel review the methodologies used to establish the managed portfolios. EAG does not assume responsibility for any incomplete or erroneous information provided by an account holder. Account holders should periodically review and update their information. Each quarter, EAG will review your Account allocation in light of your Investment Profile and its investment methodology and rebalance your Account if EAG deems it appropriate under the MP Service’s parameters. 9  EAG’s product oversight analysts will review a sample of client Accounts quarterly to ensure that clients receive all appropriate documentation for their Accounts. The review will also ensure initial Account allocations are consistent with the Investment Profile and its investment methodology, and that EAG timely performs rebalancing. If EAG becomes aware of a matter that requires the client’s attention to resolve, EAG will promptly notify the client. Item 14 – Client Referrals and Other Compensation EAG does not pay cash or other compensation to external solicitors for referrals to Empower Brokerage or the MP Service. EAG has authorized Agents to solicit, refer and market EAG’s services. Agents receive a salary and are eligible to receive incentive compensation (including bonus payments) paid by Empower. Certain Agents serve in “Wealth Solutions Advisor,” and similar roles that educate prospective clients about available products and services, and, provide investment advice. Agents receive incentive compensation paid by Empower when they refer a retirement plan participant to an EAG representative in its rollover/distribution call center to consider whether to roll over plan assets into advisory accounts with EAG. Depending on the position type of the referring Agent, an Agent also receives incentive compensation paid by Empower when the referred participant ultimately rolls over assets into and funds an advisory account with EAG. Under an incentive compensation plan applicable to Wealth Solutions Advisors and certain other roles, incentive compensation is based, in part, on funded net asset accumulation and retention and compensation varies by product “grade” (or tier). Specifically, Grade 1 products include Empower Personal Cash and self-directed brokerage accounts (taxable and IRA/SEP); Grade 2 products include Empower Investment Account, the MP Service, SmartSolution IRA/Roth IRA, and Premier Non-Managed accounts; and Grade 3 products include Personal Strategy, Personal Strategy+, and Premier Managed accounts. Grade 1 products are self-directed and, when recommending or opening a self-directed brokerage account, Agents do not act in a fiduciary capacity. Payout rates are generally higher for higher-grade products based on individual product complexity and the requisite expertise required of Agents to discuss and open such products. These arrangements create conflicts of interest because Agents have financial incentives to recommend or encourage enrollment in, or selection of, certain products or services or to encourage rollovers or transfers of additional assets. Compensation paid to Agents does not increase the fees paid by account holders. Other Agents’ individual performance goals, within Workplace Planning & Advice and including, but not limited to, Workplace Planning Consultants, are based on a combination of factors including the number and quality of customer engagements during the measurement period and the amount of customer assets retained or accumulated as a result of those engagements. Depending on position type, performance goals also include: total asset growth and retention (including retention and external rollover ratios); introductions or referrals to Wealth Solutions Advisors (described above); client satisfaction measures; and planning-activity measures (such as advice acceptance rates). Additional qualitative factors include leadership, teamwork, client experience, quality and efficiency of client interactions, and adherence to corporate policies and regulatory standards. Incentive compensation is not guaranteed and is determined and paid periodically (for example, monthly or quarterly)Compensation paid to Agents or EAG representatives does not increase the fees paid by the account holder. Item 15 - Custody EAG does not maintain actual custody of its clients’ cash, bank accounts, or securities. Pershing LLC is the custodian for the MP Service and is responsible for any reporting requirements. Item 16 – Investment Discretion EAG provides discretionary investment management services for those account holders who enroll in MP Service. EAG retains discretionary authority over the allocation of available investment options without requiring prior approval of each transaction. EAG implements all ongoing investment transfers and investment direction changes for account holders enrolled in the MP Service. Item 17 – Voting Client Securities EAG does not assume the responsibility to aid or vote proxies or other issuer communications regarding your Account. EAG will also refrain from voting or other decision-making authority regarding proxies or other issuer communications. Correspondence regarding the matters described in this section will be handled in connection with the Account’s policies and service provider arrangements. EAG, as a registered investment adviser, and as a matter of practice, does not accept authority to vote client securities in connection with any of the services described in this Brochure. Correspondence regarding the matters described in this section will be handled in connection with the policies and service provider arrangements. Item 18 – Financial Information As previously discussed, under certain circumstances, EAG has discretionary authority over certain client funds and securities. Accordingly, EAG must disclose information about EAG’s financial condition that is reasonably likely to impair EAG’s ability to meet contractual commitments to its clients. EAG has no financial commitment that impairs its ability to meet contractual commitments to its clients, nor has EAG been the subject of a bankruptcy proceeding. Further, EAG does not require or solicit prepayment of fees of more than $1,200 per client more than six months in advance. 10  This is not an Offer to Purchase or Sell Securities. The information contained in this Brochure, including information regarding Empower Funds, is for disclosure and other informational purposes only. It is not an offer to sell or a solicitation of an offer to buy any securities and may not be relied upon in connection with the purchase or sale of any security. 11 

Item 1 – Cover Page EMPOWER ADVISORY GROUP, LLC Disclosure Brochure for Online Advice & Managed Account Services for Empower Premier Investment Account 8515 East Orchard Road Greenwood Village, CO 80111 Telephone: 866-317-6586 March 31, 2026 This Brochure provides information about the qualifications and business practices of Empower Advisory Group, LLC (EAG). Specifically, this Brochure provides information on the qualifications and business practices for the advisory services provided by EAG and sub-advised by Morningstar Investment Management, LLC (Morningstar Investment Management) for the Empower Premier Investment Account, a taxable investment account. If you have any questions about the contents of this Brochure, please contact us at 866-317-6586. The information in this Brochure has not been approved or verified by the Securities and Exchange Commission (SEC) or by any state securities authority. EAG is a registered investment adviser under the Investment Advisers Act of 1940 (Advisers Act). Registration of EAG does not imply any level of skill or training. Additional information about EAG is available on the SEC website at https://adviserinfo.sec.gov or at https://empower.com/eag. The SEC’s web site also provides information about any person affiliated with EAG who is registered, or is required to be registered, as an investment adviser representative with EAG. Item 2 – Material Changes This section of the Brochure highlights and discusses any changes that were made since the Adviser’s last update on September 19, 2025. A material change was made to Item 10 and Item 14 to describe changes to representative compensation.  Item 3 – Table of Contents Item 1 – Cover Page .................................................................................................................................................................................... 1 Item 2 – Material Changes .......................................................................................................................................................................... 1 Item 3 – Table of Contents ......................................................................................................................................................................... 2 Item 4 – Advisory Business ......................................................................................................................................................................... 3 Item 5 – Fees and Compensation ............................................................................................................................................................... 6 Item 6 – Performance-Based Fees and Side-by-Side Management ............................................................................................................ 6 Item 7 – Types of Clients ............................................................................................................................................................................. 6 Item 8 – Methods of Analysis and Investment Strategies and Risk of Loss ................................................................................................ 6 Item 9 – Disciplinary Information ............................................................................................................................................................... 8 Item 10 – Other Financial Industry Activities and Affiliations ..................................................................................................................... 9 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............................................................. 11 Item 12 – Brokerage Practices Brokerage Selection; Best Execution ........................................................................................................ 12 Item 13 – Review of Accounts .................................................................................................................................................................. 12 Item 14 – Client Referrals and Other Compensation ................................................................................................................................ 13 Item 15 – Custody ..................................................................................................................................................................................... 13 Item 16 – Investment Discretion .............................................................................................................................................................. 14 Item 17 – Voting Client Securities ............................................................................................................................................................. 14 Item 18 – Financial Information ................................................................................................................................................................ 14 2  Item 4 – Advisory Business Description of Advisory Firm: EAG has been a registered investment adviser under the Advisers Act since 2000. EAG is also registered in all fifty states, the District of Columbia, Guam, U.S. Virgin Islands, and Puerto Rico. EAG offers investment management and advisory services to plan sponsors of employer-sponsored retirement plans such as 401(a), 401(k), 403(b) and 457 plans, including government entities and their participants, investors in the Empower Premier Investment Account (account holder) and to investors in the Empower Premier IRA (IRA holder). EAG does not choose the investments offered in employer-sponsored retirement plans or IRAs. EAG-serviced plans receive recordkeeping services through Empower Retirement, LLC (Empower), the recordkeeping entity affiliated with EAG. EAG also offers investment management services to individuals and to retail brokerage account holders. More information about EAG’s services, including an applicable brochure, can be obtained by contacting EAG at the number provided on the cover page of this Brochure or by visiting EAG’s website at: https://empower.com/eag. EAG is a wholly owned subsidiary of Empower Services Holdings US, LLC (ESH US), a holding company domiciled in the State of Delaware. Empower Annuity Insurance Company of America (EAICA) owns ESH US. EAICA is a direct, wholly owned subsidiary of Empower Holdings, LLC (EHL), a Delaware holding company. EHL is a direct wholly owned subsidiary of Great-West Lifeco U.S. LLC. (Lifeco U.S.) and an indirect wholly owned subsidiary of Great-West Lifeco Inc. (Lifeco), a Canadian holding company. Lifeco is a subsidiary of Power Financial Corporation (Power Financial), a Canadian holding company with substantial interests in the financial services industry. Power Corporation of Canada (Power Corporation), a Canadian holding and management company, has voting control of Power Financial. The Desmarais Family Residuary Trust has voting control of Power Corporation, through a group of private holding companies that it controls. Types of Services Discussed in this Brochure: EAG provides a range of investment services directly to account holders, IRA holders, and plan participants, as well as services provided indirectly through private-label arrangements with institutional partners (collectively, the Services). The Services include Online Advice (OA) and the Managed Account service, also known as My Total Retirement (MA Service or MTR). Other services that may be available to account holders include Spend-Down Advice, Financial Planning Service and Retirement Income Projection Tools and Services. EAG provides its Services through a proprietadiscry, computer-based software program that Morningstar Investment Management developed and maintains. The investment advisory product described in this brochure is the Empower Premier Investment Account, a taxable brokerage account. Holders of this account are referred to as “account holders.” In addition, EAG provides sub-advisory and technology services to outside adviser firms through a service called Advisor Managed Accounts (AMA). This service enables the AMA firms to offer their own investment advisory and management services within retirement plans serviced by Empower. There is no guarantee provided by any party that participation in any of the advisory services will result in a profit. Morningstar Investment Management LLC Morningstar Investment Management is a registered investment adviser wholly owned by Morningstar, Inc., and it is not affiliated with EAG or any company that is affiliated with EAG. Morningstar Investment Management is located in Chicago, Illinois. A copy of its Form ADV Part 2A Brochure may be obtained at https://adviserinfo.sec.gov. For the managed account services to retirement plans, Morningstar Investment Management serves as an independent financial expert (IFE) in accordance with the Department of Labor SunAmerica Advisory Opinion 2001-09A, dated December 14, 2001. Morningstar Investment Management uses its proprietary methodology to evaluate the available investment options in a retirement plan, IRA, or brokerage account and to develop an individualized investment strategy for plan participants, IRA holders, and account holders. The plan, plan sponsor, plan fiduciary, IRA provider, or brokerage account provider must select and continuously maintain investment options that cover broad asset categories. The investment options selected for the plan, IRA, or brokerage account generally consist of a broad range of asset classes. More information is provided under Item 10 – Other Financial Industry Affiliations. Certain EAG Services rely on Morningstar Investment Management’s proprietary methodology, which is based on a review of available quantitative data to analyze and screen the investment options within a plan, IRA, or brokerage account. Morningstar Investment Management also applies qualitative analysis by investment professionals, such as evaluations of investment managers, portfolios, and individual investments. The primary sources of information used by Morningstar Investment Management are the extensive databases and methodologies of Morningstar Investment Management and/or its affiliates, and interviews with investment managers. Other sources include financial publications, annual reports, prospectuses, press releases, and SEC filings. Morningstar Investment Management combines this information with other factors including actuarial data, stock market exposure, probability analysis, and mean-variance optimization into its proprietary software program to analyze a complex set of market data and variables. The result is an advanced model capable of providing investment recommendations and projections of different outcomes. Using this model, Morningstar Investment Management develops an investment strategy tailored to each account holder’s investment goals. 3  Online Advice (OA) 1. OA is based on the software program developed by Morningstar Investment Management. It provides each account holder with retirement goal forecasting advice and fund-specific asset allocation recommendations tailored to the account holder’s financial situation and retirement goals. OA is tailored for individuals who wish to manage their own retirement account with the assistance of the service tools and investment advice. OA provides the account holder with retirement/investment goal forecasting through various assumptions and hypothetical financial and economic scenarios. These scenarios are based on factors such as historic returns, market volatility, cross-correlations, calculated risk premiums, interest rate fluctuations, inflation, and market conditions, all of which have limitations. The account holders can interact with OA to see how changes in their decisions about their savings, expected retirement age, level of investment risk and retirement income goals may affect the system’s forecast. Account holders who enroll in OA are responsible for determining the asset allocation that is best suited for their needs and investment strategy. OA does not make any recommendations about investing in any individual stocks. Account Holder Responsibilities: With respect to OA, account holders are responsible for making their investment decisions and may implement OA recommendations either online or by phone. Account holders are also solely responsible for reviewing and updating the information they input in the OA service with respect to the completeness, accuracy, and timeliness of the information. Account holders should review their accounts periodically to monitor changes in the market and the value of their investments. A failure by an individual to review and update their account information through OA may materially affect the content and value of the service. Limitations of the Online Advice Service: The recommendations provided through OA are estimates based on the responses and information provided by the account holders. Neither EAG nor Morningstar Investment Management make any guarantees or warranties, express or implied, as to the accuracy, timeliness, or completeness of such information. The OA service is also subject to the general market and financial conditions existing at the time of use. The investment recommendations and, if applicable, retirement goal forecasting provided by OA are not a guarantee of future results, nor are they a guarantee that an account holder will achieve their investment goals. Account holders should only use OA as a tool in their investment planning and not as a substitute for their own informed judgment. Neither EAG nor Morningstar Investment Management has an obligation to update any information for a specific individual or to proactively contact the individual to obtain updated information. A failure by an individual to review and update account information through OA may materially affect the content and value of the Services. Managed Account Service (also known as My Total Retirement) 2. EAG offers a discretionary managed account service (Managed Account, MA Service or MTR). This is a professional and flexible asset management program based on data resulting from the methodologies and proprietary software program developed and employed by Morningstar Investment Management. In the MA Service, EAG has discretionary authority over the allocation of available investment options, without prior account holder approval of each transaction. EAG implements ongoing investment transfers and investment allocation changes for individuals enrolled in the MA Service. The MA Service designs a specific asset allocation portfolio for the account holder that reflects the individual’s retirement goals, life stages, specified risk constraint and overall financial situation. The MA Service considers account assets and other assets and investments not included within the investment account, if the account holder provides data. On a periodic basis, individual accounts in the MA Service are re-forecasted, which may include rebalancing and reallocating the individual’s asset allocation portfolio. EAG does this to maintain alignment with the allocation percentages determined by Morningstar Investment Management through various assumptions and hypothetical financial and economic scenarios. Account holders receive an account update and forecast statement annually and can update their personal information at any time by calling EAG at its toll-free customer service number or by visiting the appropriate website. MA Service does not make any recommendations about investing in any individual stocks. Limitations on the Managed Accounts Service: When account holders enroll in the MA Service, they must transfer and allocate their entire brokerage account balance to the Managed Account. Once enrolled in the MA Service, account holders delegate certain account management functions to EAG including functionality for fund- to-fund transfers, change fund allocations, the dollar cost averaging tool and/or the rebalancer tool. However, individuals in the MA Service retain full inquiry access to their accounts and may still take a withdrawal. Account holders may un-enroll at any time from the MA Service. 4  Once they do so, the account holders resume full responsibility for the investment management of their accounts. An individual may un- enroll online or by contacting an EAG investment adviser representative. See Termination of Services below for information about transactions following unenrollment. Spend-Down Advice 3. EAG also provides account holders enrolled in any of the above EAG Services with an additional feature of Spend-Down Advice, which includes retirement planning tools. The Spend-Down Advice illustrates how long the desired income may last in retirement and determines how much spendable income the account holder may be able to sustain throughout their retirement. The Spend-Down Advice provides both the amount and sources of income available throughout their retirement. The services provided under Spend-Down Advice provide projections of spendable income and do not constitute investment advice under the Advisers Act. Retirement Income Projection Tools and Services 4. EAG may offer online tools and services for account holders to convert projected or actual retirement savings into estimated monthly retirement income. This interactive retirement planning service consists of various retirement income projection tools. These tools are informational in nature, do not reflect actual investment results, and are not guarantees of future results. These tools do not constitute investment advice under the Advisers Act. Enrollment in EAG’s Services: The Services are available to all account holders of the Empower Premier Investment Account. Account holders must agree to the Terms of Service prior to using any of the online services, which EAG may amend from time to time. The advice and recommendations provided through the Services are based on the responses or other information provided by or about the account holder. Neither EAG nor Morningstar Investment Management make any guarantees or warranties, express or implied, as to the accuracy, timeliness, or completeness of such information. The Services are also subject to the general market and financial conditions existing at the time of usage. The retirement goal forecast and investment advice recommendations are not a guarantee of future results and are not a guarantee that a particular person will achieve their retirement goals. Termination of Services: Online Advice: Account holders may discontinue their use of OA at any time. Because EAG does not affect changes to the account holder’s asset allocation and account balances, the individual’s balances will not be affected unless and until the individual affirmatively changes their asset allocation and balance after discontinuing use of OA. MA Service: Account holders utilizing the MA Service may cancel by calling an EAG investment adviser representative at the toll-free customer service number. After cancellation of the MA Service, the account holder will have the ability to make allocation and investment option changes to their account, usually one to two business days following cancellation. Accordingly, the account holder’s asset allocation will remain the same as established in the MA Service unless and until the account holder affirmatively changes his/her asset allocation after cancellation of the MA Service. Account Holder Information: EAG uses and provides storage of any information at the individual’s sole risk and responsibility. Such information includes, without limitation, an individual’s personal and non-public information, account number, password, identification, portfolio information, account balances, and any other information available on an individual’s personal computer. The individual is responsible for providing and maintaining the communications equipment (including personal computers and modems) and telephone or other services required for accessing and using electronic or automated services, and for all communications service fees and charges incurred by the individual in accessing these services. EAG shall not bear any responsibility for either errors or failures caused by the malfunction of any computer, communication systems, any computer viruses, and related problems that may be associated with the use of the Services. Assets Under Management With respect to the services provided by EAG, as of December 31, 2025: $ 164,237,996,079 Discretionary investment management among all services: $ 31,188,325,400 Non-discretionary investment advisory services among all services in the amount of: $ 195,426,321,479 Total discretionary and non-discretionary investment management and advisory services in the amount of: 5  Item 5 – Fees and Compensation Managed Account Service for Empower Premier Investment Account: EAG charges account holders a quarterly fee for the MA Service based upon the average assets managed during the billing period. EAG normally deducts the advisory fee from the account following the end of each quarter; it totals the Annualized Fee shown below. Annualized Fee Principal Account Balance < $100,000 Next $150,000 Next $150,000 > $400,000 Quarterly Fee 0.125% 0.10% 0.075% 0.05% 0.50% 0.40% 0.30% 0.20% EAG reserves the right to offer current, new, or prospective account holders discounted fees or other promotional pricing or to waive fees, for any particular period of time, subject to proper notification and disclosure. If an account holder cancels their participation in the MA Service or Empower Premier Investment Account at any time within a fee cycle, the fee is based on average assets managed during the billing period; EAG will debit the fee from the account according to EAG procedures. Online Advice: EAG does not charge a separate fee for OA. Retirement Income Projection Tools and Services: EAG does not charge a separate fee to account holders for the retirement income projection tools and services. Other Fees and Expenses: Accounts invested in mutual funds and other investments may be subject to other investment fees. The mutual fund may directly impose fees such as fund operating expenses or redemption fees. Information about the fees imposed by specific investment choices is available in each fund’s prospectus. EAG will allocate assets of MTR users to funds. Empower Financial Services, Inc. (EFSI) executes securities transactions that occur as a result of the services provided by EAG described in this Brochure, for which it 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 account investment options. An Account Holder will directly pay advisory fees to EAG for the MA Service and indirectly pay additional investment management fees to Empower Capital Management, LLC (ECM), if the available investment options available to the Account Holder include Empower Funds. If applicable, the fund share price includes the fees paid to ECM for management of the Empower Funds. Item 6 – Performance-Based Fees and Side-by-Side Management EAG does not charge any performance-based or side-by-side management fees. Item 7 – Types of Clients EAG offers investment advisory and management services to certain account holders of Empower Premier IRA, an Empower retail brokerage account or another plan elected managed account services. Additionally, EAG provides financial planning to participants in retirement plans for which Empower provides recordkeeping services and where the Plan Sponsor has agreed to offer the service. Account holders, IRA holders and plan participants typically must be considered residents of the United States, the U.S. Virgin Islands, Guam, or Puerto Rico. A plan sponsor may apply additional restrictions for participation due to plan or regulatory requirements. Item 8 – Methods of Analysis and Investment Strategies and Risk of Loss The Services described in this Brochure are based on the proprietary asset allocation and retirement/investment income projection methodologies developed by Morningstar Investment Management. The development of investment advice by Morningstar Investment Management involves investment methodologies across products and services as described herein. Morningstar Investment Management and/or its affiliates focus on specific investment areas such as capital market assumptions and a valuation-driven approach to asset allocation. Analysis Methods: In providing advisory services, Morningstar Investment Management reviews available quantitative data to analyze and screen the investment options available for the Services. The analysis will include quantitative analytics and fundamental research on the investment options available. Morningstar Investment Management draws on Morningstar’s comprehensive database of fund and security analytics. You can find the list of available investment options and corresponding documents for the Empower Premier Taxable Account by clicking 6  this link: Empower IRA and Investing Services or by inputting the following into your browser: https://ira.empower-retirement.com/participant/#/investmentInformation/140039-01 EAG reserves the right to modify the available investment options, from time to time, subject to analysis and screening by Morningstar Investment Management. Once the available investment options are identified, Morningstar Investment Management processes the data using a series of optimization routines. These optimization routines serve as a blueprint for how the asset classes are combined to help achieve an optimal portfolio for a given level of risk. The model portfolios include both equity and non-equity asset classes that are chosen to represent a broad range of investment categories available for the Services. The asset allocation process requires that there be significant benefit (generally through increased diversification) to adding the asset class to the model portfolios. In addition, investment options within the investment menu must provide significant exposure to the desired asset class in order to be selected. The asset classes that are ultimately used will depend on the available investment options that are considered for the construction of the fund-level model portfolios. Investment Strategy: When accumulating for retirement, the investment strategy is generally based on information such as retirement account balances, expected retirement age, savings rate and other preferences provided by the individual. If you have already retired, the investment strategy is based upon account balances, additional cash flows, and life expectancy. This retirement strategy may include some or all of the following: • Retirement Income Goal (accumulation phase): The retirement income goal is the projected amount of money after tax that the individual will need throughout retirement. The projection typically uses the individual’s current take home pay, but the individual has an option to change this projected retirement income amount. • Income Outlook (accumulation phase): The income outlook is a projection of the annual income that the individual may receive during retirement. This is based on an annualized view of the accumulated investment wealth, combined with social security benefits and any pension or other income data provided to EAG. • Total Retirement Income (in-retirement phase): Total retirement income is the projected amount of money that one can expect to receive on an annual basis in order to maintain income throughout retirement. • IMPORTANT: When Morningstar Investment Management determines the income projections described above, these projections are based on hypothetical performance data and do not represent actual or guaranteed results. Projections may vary over time with each additional use of the Service. Risk Strategy: Morningstar Investment Management determines a risk strategy based on several factors, such as current age and time until retirement, gender, salary, total current wealth, deferral rate, and retirement goals. If the individual can purchase an annuity and has retired or is approaching retirement, the risk strategy also considers longevity and liquidity needs. The risk level corresponds to an asset mix that will serve as the basis for the recommendations of specific funds appropriate for the individual. The target risk level changes over time to help ensure you are still investing in a portfolio for your specific situation and risk capacity. In general, we try to provide a smooth transition from an aggressive equity portfolio to a more conservative fixed portfolio as you near retirement. Estimated Tax: Morningstar Investment Management estimates federal, state income, and capital gains taxes based on marginal tax rate calculations. Morningstar Investment Management uses these calculations when it conducts income simulations. Tax data is updated annually based on the United States Internal Revenue Code (IRC) and similar state tax data. Morningstar Investment Management uses income data for the individual and their spouse/partner to estimate federal and state tax exposure. Morningstar Investment Management appropriates reduces the tax exposure for pre-tax deferrals, tax-deferred capital gains, and yield and distribution of Roth proceeds. Based on the information that the individual provides, Morningstar Investment Management provides an estimate of the tax exposure but may not include all tax considerations. Please consult a tax adviser for a complete understanding of your tax situation. General Risks of Investing: Investing in securities involves the risk of loss that clients should be prepared to bear. Neither EAG nor Morningstar Investment Management or their affiliates guarantees that the recommendations will result in achieving the retirement income goal. Neither EAG nor Morningstar Investment Management or their affiliates can guarantee that you can or will avoid negative returns in any of the recommendations. An investment’s future performance may differ substantially from its historical performance and as a result, may incur a loss. Past performance is no guarantee of future results. Additionally, the account provider may make changes from time to time with respect to the investment options available in the account. 7  While a diversified investment portfolio, including a portfolio of investment products representing different asset categories, can mitigate some risks, it does not and cannot prevent all losses. Ultimately, the investor bears such risks. Below are some of the common factors that can produce a loss in a client’s account and/or in a specific investment product or asset category: • Market Risk: Stock and bond markets are volatile and can decline significantly in response to adverse issuer, political, regulatory, market, or economic developments in the U.S. and in other countries. Market risk may affect a single company, a sector of the economy, a country or geopolitical region, or the market as a whole. Market risk may impact stock and or bond markets in unanticipated and different ways. Business Risk: These risks are associated with a particular industry or a particular company within an industry. • • Capitalization Risk: Limited resources or less diverse products or services may hinder small-cap and mid-cap companies. Their stocks have historically been more volatile than the stocks of larger, more established companies. • Category or Style Risk: During various periods of time, one category or style may underperform or outperform other categories and styles. • Credit Risk: The risk that the issuer of a security may be unable to make interest payments and/or repay principal when due. A downgrade to an issuer’s credit rating or a perceived change in an issuer’s financial strength may affect a security’s value and impact the performance of the issue along with any mutual fund or exchange-traded fund that holds it. • Interest Rate Risk: Interest rate changes significantly affect a debt security’s market value. Generally, when interest rates rise the debt security’s market value declines, and when interest rates decline, market values rise. A longer bond maturity normally involves a greater risk and higher yield, while a shorter bond maturity results in lower risk and lower yield. Inflation Risk: When any type of inflation is present, purchasing power may be eroding at the rate of inflation. • • Reinvestment Risk: The risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e., interest rate). This relates primarily to fixed income securities. • Target Date Funds: Generally, the asset allocation of each target date fund will change on an annual basis with the asset allocation becoming more conservative as the fund nears the target retirement date. The target date is the approximate date when investors plan to start withdrawing their money. The principal value of the fund(s) in a plan’s lineup is not guaranteed at any time, including at the time of target date and/or withdrawal. • An investment in a money market fund is not insured or guaranteed by the Federal Deposit Insurance Corporation (FDIC) or any other government agency. Although some money market funds strive to preserve the value of the investment at $1.00 per share, it is possible to lose money by investing in a money market fund. Additionally, other money market funds may operate under new rules and regulations permitting them to have a floating value per share. A floating value may be more or less than $1.00 per share depending on market conditions and impose liquidity/redemption fees for large or frequent withdrawals. For more complete information about any of the mutual funds or investment products available within the account, please contact us at the number listed on the cover page. Item 9 – Disciplinary Information EAG, as a registered investment adviser, is required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of EAG or the integrity of EAG’s management. EAG has the following disciplinary event to report relative to this item: On August 29, 2025, EAG and its broker/dealer affiliate, Empower Financial Services, Inc. (EFSI), settled a matter with the SEC. The SEC found that, from July 1, 2019 through December 31, 2022, certain retirement plan advisors of EFSI and EAG, all of whom were both registered representatives associated with EFSI and investment adviser representatives associated with EAG, did not sufficiently disclose whether retirement plan advisors were acting as a registered representative or an investment adviser representative when recommending that a plan participant enroll in EAG’s managed account service. Additionally, EFSI and EAG did not adequately disclose the conflicts of interest presented by certain incentive compensation arrangements, leading to misleading statements made to plan participants. Finally, the SEC found that EFSI did not establish, maintain and enforce written policies and procedures reasonably designed to identify and address conflicts of interest in connection with recommendations to enroll in EAG’s managed account service. As a result, the SEC determined that EAG violated section 206(2) of the Investment Advisers Act of 1940 (“Advisers Act”) and EFSI failed to comply with the disclosure and conflict of interest obligations of Regulation Best Interest (“Reg BI”), thereby violating Reg BI’s General Obligation (Exchange Act Rule 15l- 1(a)(1)). 8  Without admitting or denying the findings, EFSI and EAG entered into a settlement with the SEC, pursuant to which EAG was censured; ordered to cease and desist from committing or causing any future violations of Section 206(2) of the Advisers Act thereunder; and EAG agreed to pay a civil monetary penalty in the amount of $750,000; and disgorgement of $4,063,569.80. EFSI was censured; ordered to cease and desist and agreed to pay a civil monetary penalty of $750,000. Item 10 – Other Financial Industry Activities and Affiliations EAG is not a registered broker-dealer. However, due to the organizational structure of EAG’s indirect parent company, EAICA, certain EFSI registered representatives are also EAG supervised persons and are required to comply with EAG policies and procedures when acting as an investment advisor representative. EAG and its management persons are not registered as a futures commission merchant, commodity pool operator, commodity trading advisor, or an associated person of the foregoing entities. Other Financial Industry Affiliations: EAG has arrangements that are material to its advisory business or its clients/account holders with the related entities shown below. These related entities may receive certain fees that are unrelated to EAG’s fees for its Services. Recordkeeping and Administrative Services Company: Empower Retirement, LLC (Empower) is a comprehensive administrative and recordkeeping services provider for financial institutions and employers, which include educational, advisory, enrollment, and communication services for employer-sponsored defined contribution plans and associated defined benefit plans under IRC Section 401(a), 401(k), 403(b), 408, and 457. Insurance Companies: Empower Annuity Insurance Company of America (EAICA) is an insurance company domiciled in the State of Colorado. EAG is a wholly owned direct subsidiary of ESH US, which is owned by EAICA. EAICA, pursuant to various agreements, may provide investment products, recordkeeping, and other administrative services through its affiliates. Empower Life & Annuity Insurance Company of New York (ELAINY) is an insurance company domiciled in the State of New York. EAG is under common control with ELAINY and is an affiliate of ELAINY where EAICA indirectly owns EAG and is the sole owner of ELAINY. ELAINY, pursuant to various agreements, may provide investment products and administrative services through its affiliate, Empower, to retirement plans for which EAG may also provide its services. Empower Annuity Insurance Company (EAIC) is an insurance company domiciled in the State of Connecticut. EAG is under common control with EAIC and is an affiliate of EAIC where EAICA indirectly owns EAG and is the sole owner of EAIC. EAIC, pursuant to various agreements, may provide investment products and administrative services individually and through its affiliate, Empower, to retirement plans for which EAG may also provide its services. Broker-Dealer: Empower Financial Services, Inc. (EFSI), an affiliate of EAG, is a registered broker-dealer and wholly owned subsidiary of EAICA. EFSI may provide wholesaling, direct sales, enrollment and/or communication services to retirement plans and their participants and to IRA or retail accounts for which EAG may also provide its services. EFSI executes all transactions that occur as a result of participation in the Services. Trust Company: Empower Trust Company, LLC (ETC) is a trust company and affiliate of EAG. ETC is a wholly owned subsidiary of ESH US, which is a wholly owned subsidiary of EAICA. ETC is chartered under the laws of the State of Colorado. ETC may provide discretionary or directed trustee and/or custodial services for EAG’s clients. ETC also serves as the trustee for certain collective investment trusts, which may be available as investment options. Investment Company: Empower Funds, Inc. (EFI or Empower Funds), an investment company registered under the Investment Company Act of 1940, is affiliated with EAG. EFI may provide investment products to retirement plans, IRAs, and retail accounts for which EAG may also provide its services. ECM manages EFI as discussed below. Shares of EFI managed funds are available to account holders of the Empower Premier IRA, the Empower Premier Investment Account, and may also be investment options in retirement plans advised by EAG. Investment Adviser Affiliates: Empower Capital Management, LLC (ECM), an affiliate of EAG, is a registered investment adviser under the Advisers Act and is the investment adviser for EFI, which are investment options in the Empower Premier IRA and the Empower Premier Investment Account. It is a wholly owned subsidiary of ESH US, which is a wholly owned subsidiary of EAICA. EAG provides managed account, guidance, and advice services to account holders, IRA holders and to participants in certain defined contribution plans. Irish Life Investment Managers Limited (ILIM) – a Dublin, Ireland based, SEC registered investment adviser. ILIM is part of the Lifeco group of companies; Lifeco has operations in Canada, the United States, Europe, and Asia through ownership of companies including EAICA. EAG 9  is an indirect wholly owned subsidiary of EAICA. EAICA is an indirect wholly owned subsidiary of Lifeco which controls ILIM. ILIM manages the index series of Empower Funds. Holding Company: Great-West Lifeco Inc. (Lifeco), EAG’s indirect parent company, owns approximately 6% of Franklin Templeton Investments’ parent company, Franklin Resources, Inc. (Franklin) as of January 1, 2024. Franklin or certain of its investment management subsidiaries (collectively, the Franklin Group entities) may provide management, advisory or sub-advisory services to investment funds that may be investment options in a Managed Account. Franklin and Lifeco have entered into arrangements under which Lifeco has committed to allocate Lifeco and affiliate assets over a period of time to be managed by Franklin’s investment managers and to support the availability of Franklin Group entity products and services on enterprise platforms. As a result, Empower and Lifeco will derive an economic benefit to the extent that Franklin Group entities provide management, advisory or sub-advisory services to funds or products. If Franklin achieves certain revenue thresholds under those arrangements, Lifeco will receive contingent transaction consideration and Lifeco and other Empower affiliates will derive an economic benefit if assets are allocated to a Franklin investment option. Branding: The affiliated companies of EAG; Empower Personal Wealth, LLC; ECM; EFSI; EAICA; EAIC; ELAINY; Empower Funds; Empower; and ETC operate under the multiple brands of Empower and Empower Institutional depending upon the products, services and retirement markets involved. These brands do not materially affect the internal structure of EAG or EAG’s corporate ownership. Conflicts of Interest: The investment recommendations and allocations provided by the Services may contain Empower Funds’s proprietary mutual funds and EAICA’s and ELAINY’s proprietary insurance products. EAG does not receive compensation from its parent company or any of its affiliates as a result of these allocations. EAG has an agreement with Morningstar Investment Management wherein EAG pays Morningstar Investment Management for sub-advisory services. EAG mitigates these conflicts of interest related to affiliated investment options by utilizing Morningstar Investment Management as sub- adviser who remains independent from EAG and its related persons with respect to their methods of analysis and investment strategies. Morningstar Investment Management’s methodology also controls the investment allocations and recommendations. An account holder will pay advisory fees directly to EAG for MTR, and indirectly to ECM and Empower. Each Empower Fund’s share price includes the fees paid to ECM and Empower. Conflicts related to fund recommendations: The Services operate by recommending or allocating an Account Holder’s assets to funds available to the account. A designated team of Empower employees (rather than EAG), in consultation with Morningstar Investment Management selects and periodically reviews the funds available for EAG’s recommendations within an account. In some cases, the investment options may include or be comprised solely of investment options sponsored by EAG’s affiliates. In other cases, the investment options may make third-party payments as described below. When this occurs, EAG’s affiliates may receive additional compensation as a result of EAG’s recommendations or allocations. These forms of additional affiliate compensation are: • Proprietary investment funds: EAG’s affiliates offer proprietary investment funds within the Empower Premier Investment Account. EAG will recommend or allocate the account to one or more Empower Funds, which are proprietary investment funds. These investment funds generate additional income to EAG’s affiliates to compensate the affiliates for administering, advising, managing, and/or supervising these funds. For example, an Account Holder using the Services will pay advisory fees to EAG and indirectly to ECM if the account investment options include Empower Funds, and EAG recommends an allocation to an Empower Funds product. The fund share price includes the fees paid to ECM for management of the Empower Funds. • Proprietary insurance products. EAG’s indirect parent company, EAICA, offers proprietary insurance products for investment. EAG may recommend or allocate your assets to different types of EAICA insurance products and funding agreements. The majority of EAICA insurance products are annuity contracts that are structured either as a general account product or as a separate account product. If you invest in a general account product, which is an insurance product backed by the general account of an insurance company, EAG’s affiliates generate revenue by retaining spread (which is the difference between actual earnings on contracts offered by the insurer), and the crediting rate declared and guaranteed by the insurer through the contract. EAG’s affiliates may also receive different types of fee income if you invest in the separate accounts and other third-party payments associated with investments held therein. • Third-Party Payments. EAG’s affiliates may receive payments from other firms, non-proprietary investment funds or products, or providers, such as revenue sharing payments, in connection with the investments made pursuant to our recommendation or investment management. 10  Conflicts related to increased use and promotion of the Services: • Increased advisory fee income. EAG’s representatives may recommend that you use the Services. If you enroll in certain Services, EAG will earn additional compensation in the form of advisory fees. • Increased affiliate fee income. When you use the Services, EAG may recommend you increase contributions or utilize other savings or investment strategies. EAG’s affiliates provide a bundle of recordkeeping, trust, custody, brokerage, investment, and other related services to retirement plans and to IRA or retail brokerage products. If you pay for these related services through an arrangement where the EAG affiliates charge a direct fee, these affiliates may receive additional fees for these services. These additional fees result from EAG’s recommendations because you may contribute, invest, or transact in more assets with EAG’s family of companies. EAG’s affiliates may receive payments from other firms, non-proprietary investment funds or products, or providers, such as revenue sharing payments, in connection with the investments made pursuant to our recommendation or investment management. • Representative Compensation. EAG has authorized its individual adviser representatives and EFSI, an affiliate of EAG, and its licensed agents and registered representatives who are Empower employees (collectively referred to as, “Agents”) to solicit, refer and market EAG’s services. Agents receive a salary and are eligible to receive incentive compensation (including bonus payments) paid by Empower. Certain Agents serve in “Wealth Solutions Advisor,” and similar roles that educate prospective clients about available products and services, and, provide investment advice. Agents receive incentive compensation paid by Empower when they refer a retirement plan participant to an EAG representative in its rollover/distribution call center to consider whether to roll over plan assets into advisory accounts with EAG. Depending on the position type of the referring Agent, an Agent also receives incentive compensation paid by Empower when the referred participant ultimately rolls over assets into and funds an advisory account with EAG. Under an incentive compensation plan applicable to Wealth Solutions Advisors and certain other roles, incentive compensation is based, in part, on funded net asset accumulation and retention and compensation varies by product “grade” (or tier). Specifically, Grade 1 products include Empower Personal Cash and self- directed brokerage accounts (taxable and IRA/SEP); Grade 2 products include Empower Investment Account, Empower Managed Portfolio, SmartSolution IRA/Roth IRA, and Premier Non-Managed accounts; and Grade 3 products include Personal Strategy, Personal Strategy+, and Premier Managed accounts. Grade 1 products are self-directed and, when recommending or opening a self-directed brokerage account, Agents do not act in a fiduciary capacity. Payout rates are generally higher for higher-grade products based on individual product complexity and the requisite expertise required of Agents to discuss and open such products. These arrangements create conflicts of interest because Agents have financial incentives to recommend or encourage enrollment in, or selection of, certain products or services or to encourage rollovers or transfers of additional assets. Compensation paid to Agents does not increase the fees paid by account holders. Other Agents’ individual performance goals, within Workplace Planning & Advice and including, but not limited to, Workplace Planning Consultants, are based on a combination of factors including the number and quality of customer engagements during the measurement period and the amount of customer assets retained or accumulated as a result of those engagements. Depending on position type, performance goals also include: total asset growth and retention (including retention and external rollover ratios); introductions or referrals to Wealth Solutions Advisors (described above); client satisfaction measures; and planning-activity measures (such as advice acceptance rates). Additional qualitative factors include leadership, teamwork, client experience, quality and efficiency of client interactions, and adherence to corporate policies and regulatory standards. Incentive compensation is not guaranteed and is determined and paid periodically (for example, monthly or quarterly). Other Business Activities: Certain senior managers and officers of EAG may also serve as executive officers of EAG’s indirect parent company, EAICA, and other affiliates of EAG. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading EAG’s Code of Ethics: EAG has adopted a written Code of Ethics (the Code) in compliance with Advisers Act Rule 204A-1. The Code sets forth standards of business conduct expected of advisory personnel. EAG requires certain EAG advisory personnel to report their personal securities holdings and transactions in accordance with the Advisers Act. EAG requires its advisory personnel to comply with the Code. EAG will provide a copy of the Code to current or prospective clients upon request. The Code includes provisions related to: • Fiduciary responsibility to clients; • Compliance with federal securities laws; • Protection and safeguarding of confidential information; • Giving and receiving gifts, gratuities, and entertainment; 11  • Political contributions; • Reporting and monitoring personal securities transactions; • Avoiding and disclosing conflicts of interest; and • Reporting violations of the Code. Personal Trading: The Code requires pre-clearance of certain securities transactions. Officers, managers, and certain employees of EAG (collectively, Access Persons) may trade for their own personal accounts in securities that EAG may recommend to and/or purchase for its advisory clients. EAG continually monitors personal trading in accordance with the Code and federal securities laws. EAG intends for the Code to ensure that the personal securities transactions and the outside business activities of EAG’s Access Persons do not interfere with making decisions in the best interest of advisory clients. Principal Trading: EAG has adopted a policy and practice not to engage in any principal transactions. EAG holds no investments for its own accounts that EAG could buy from, or sell to, an advisory client. EAG’s Board of Managers must approve a change in this policy. EAG would only permit principal transactions after meeting the review and approval requirements described under the anti-fraud section of the Advisers Act. Participation or Interest in Client Transactions: Affiliate EFSI Effects Securities Transactions for Advisory Clients Registered representatives of EFSI may make recommendations to account holders and provide wholesaling, direct sales, enrollment, and/or communication services to account holders for which EAG may also provide its services. EFSI executes all securities transactions that occur as a result of EAG’s services described in this Brochure. 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 discloses its affiliation with these entities. Allocations in the investment options are solely determined and based on Morningstar Investment Management’s software and not determinations made by EAG. The compensation paid by EAG to Morningstar Investment Management for Morningstar Investment Management’s proprietary software advice program does not vary based on the allocations made or recommended by Morningstar Investment Management. Because Morningstar Investment Management is unaffiliated with EAG and EFSI, EAG does not believe there is a conflict of interest. Affiliate EAICA or ELAINY Proprietary Investments Investment options into which account holder assets may be allocated, pursuant to the MA Services may be through a fixed funding agreement issued by EAICA or ELAINY. Because Morningstar Investment Management is unaffiliated with EAG, EAICA, ELAINY and their affiliates, EAG does not believe there is a conflict of interest. However, in all instances, EAG will disclose its affiliation with EAICA and/or EAICA’s affiliates, as applicable. Affiliate Empower Retirement, LLC Empower receives a 35-bps shareholder service fee from the applicable shares of Empower Funds for recordkeeping and administrative services provided for account holders, pursuant to a Shareholder Services Agreement between the parties. Item 12 – Brokerage Practices Brokerage Selection; Best Execution Pershing LLC, an unaffiliated party, processes the Empower Premier Investment Account transactions related to the Services. Soft Dollar Practices: As a matter of policy, EAG does not utilize research or other products or services from third parties in connection with client securities transactions on a soft-dollar commission basis. Trade Aggregation: EAG does not bunch orders or engage in block trades to execute equity orders for clients. Further, most trades are mutual funds where trade aggregation does provide any additional client benefits. Item 13 – Review of Accounts At least annually, EAG personnel review the methodologies used by Morningstar Investment Management to power the MA Services to ensure that they are consistent with investment advisory best practices, current technology, applicable laws, and the terms of the agreement between EAG and Morningstar Investment Management. Neither EAG nor Morningstar Investment Management review the personal financial information of account holders as provided by the account holders and do not assume responsibility for any incomplete or erroneous information. The account holder must periodically review such information, which includes date of birth, salary, gender, and/or state of residence, and is responsible for notifying EAG of any changes, errors, or omissions to such information. 12  Online Advice: EAG does not conduct a review of account holder accounts and does not provide investment oversight, monitoring, or rebalancing. Account holders in the OA service receive investment recommendations from EAG based on the investment options provided in the Empower Premier IRA. It is the responsibility of OA clients to review and update their accounts to adjust for changes in the investments they own and to determine whether the recommendations are suitable for their particular investment needs. OA clients should also review and update their accounts if significant changes occur in their personal circumstances. EAG conducts the following review of account holder accounts: Managed Account Service: Under the MA Service, EAG periodically monitors, rebalances, and reallocates account holder assets in the investment options, based on Morningstar Investment Management’s software program. On an annual basis, account holders enrolled in the MA Service will receive an Annual Kit containing an account update and forecast statement. Morningstar Investment Management updates the capital market assumptions underlying their methodology used to construct the asset classes, at least annually, and then makes changes to the portfolio allocations, as necessary. EAG also regularly monitors the portfolios based on current portfolio allocations and makes adjustments, as necessary. Reporting to Clients: Account holders enrolled in the MA Service receive an MA Welcome Kit shortly after enrollment and an account update at least annually. EAG encourages individuals to update significant changes to their personal information online or via the appropriate toll-free customer service number. Item 14 – Client Referrals and Other Compensation EAG has authorized its individual adviser representatives and EFSI, an affiliate of EAG, and its licensed agents and registered representatives who are Empower employees (collectively referred to as, “Agents”) to solicit, refer and market EAG’s services. Agents receive a salary and are eligible to receive incentive compensation (including bonus payments) paid by Empower. Certain Agents serve in “Wealth Solutions Advisor,” and similar roles that educate prospective clients about available products and services, and, provide investment advice. Agents receive incentive compensation paid by Empower when they refer a retirement plan participant to an EAG representative in its rollover/distribution call center to consider whether to roll over plan assets into advisory accounts with EAG. Depending on the position type of the referring Agent, an Agent also receives incentive compensation paid by Empower when the referred participant ultimately rolls over assets into and funds an advisory account with EAG. Under an incentive compensation plan applicable to Wealth Solutions Advisors and certain other roles, incentive compensation is based, in part, on funded net asset accumulation and retention and compensation varies by product “grade” (or tier). Specifically, Grade 1 products include Empower Personal Cash and self-directed brokerage accounts (taxable and IRA/SEP); Grade 2 products include Empower Investment Account, Empower Managed Portfolio, SmartSolution IRA/Roth IRA, and Premier Non-Managed accounts; and Grade 3 products include Personal Strategy, Personal Strategy+, and Premier Managed accounts. Grade 1 products are self-directed and, when recommending or opening a self-directed brokerage account, Agents do not act in a fiduciary capacity. Payout rates are generally higher for higher-grade products based on individual product complexity and the requisite expertise required of Agents to discuss and open such products. These arrangements create conflicts of interest because Agents have financial incentives to recommend or encourage enrollment in, or selection of, certain products or services or to encourage rollovers or transfers of additional assets. Compensation paid to Agents does not increase the fees paid by account holders. Other Agents’ individual performance goals, within Workplace Planning & Advice and including, but not limited to, Workplace Planning Consultants, are based on a combination of factors including the number and quality of customer engagements during the measurement period and the amount of customer assets retained or accumulated as a result of those engagements. Depending on position type, performance goals also include: total asset growth and retention (including retention and external rollover ratios); introductions or referrals to Wealth Solutions Advisors (described above); client satisfaction measures; and planning-activity measures (such as advice acceptance rates). Additional qualitative factors include leadership, teamwork, client experience, quality and efficiency of client interactions, and adherence to corporate policies and regulatory standards. Incentive compensation is not guaranteed and is determined and paid periodically (for example, monthly or quarterly). Compensation paid to Agents or EAG representatives does not increase the fees paid by the account holder. Item 15 – Custody EAG does not maintain actual custody of its clients’ cash, bank accounts, or securities related to the Services. Pershing LLC is the custodian for the Services and is responsible for any related reporting requirements. 13  Item 16 – Investment Discretion EAG provides discretionary investment management services for those account holders who enroll and participate in the MA Service; EAG does not offer or engage in discretionary investment services for OA. The MA Service is a professional, flexible asset management program that utilizes data from the methodologies and proprietary software program developed and employed by Morningstar Investment Management. To provide the MA Service to account holders, EAG retains discretionary authority over the allocation of available investment options without requiring prior approval of each transaction. Item 17 – Voting Client Securities EAG does not assume the responsibility to provide assistance, exercise voting powers or other decision-making authority regarding proxies or other issuer communications for the Empower Premier Investment Account. Generally, if a mutual fund offered in the account files a proxy statement, account holders in the fund receive and may vote the proxy. Item 18 – Financial Information As previously discussed, under certain circumstances EAG has discretionary authority over certain client funds and securities. Accordingly, EAG must disclose information about its financial condition that is reasonably likely to impair its ability to meet contractual commitments to its clients. EAG has no financial commitment that impairs its ability to meet contractual commitments to its clients, nor has EAG been the subject of a bankruptcy proceeding. Further, EAG does not require or solicit prepayment of fees of more than $1,200 per client more than six months in advance. This is not an Offer to Purchase or Sell Securities. The information contained in this Brochure, including information regarding Empower Funds, is for disclosure and other informational purposes only. It is not an offer to sell or a solicitation of an offer to buy any securities and may not be relied upon in connection with the purchase or sale of any security. 14