EMPOWER FINANCIAL ADVISORY, LLC

Empower Financial Advisory, LLC Form ADV Part 2A – Disclosure Brochure Effective: February 13, 2026 This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of Empower Financial Advisory, LLC (“Empower Financial” or the “Advisor”). If you have any questions about the content of this Disclosure Brochure, please contact the Advisor at 860-494-2600 or via email at ClientLiaison@EmpowerFA.com. Empower Financial is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure Brochure provides information about Empower Financial to assist you in determining whether to retain the Advisor. Additional information about Empower Financial and its Advisory Persons is available on the SEC’s website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 313968. Empower Financial Advisory, LLC 655 Winding Brook Drive, Glastonbury, CT 06033 Phone: 860-494-2600 | https://www.empowerfa.com  Item 2 – Material Changes Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory Persons of Empower Financial. For convenience, the Advisor has combined these documents into a single disclosure document. Empower Financial believes that communication and transparency are the foundation of its relationship with clients and will continually strive to provide you with complete and accurate information at all times. Empower Financial encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Advisor. Material Changes There have been no material changes to this Disclosure Brochure since the last annual amendment filing on February 7, 2025. Future Changes From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices, changes in regulations or routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if a material change occurs. At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 313968. You may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at 860-494-2600 or via email at ClientLiaison@EmpowerFA.com. Empower Financial Advisory, LLC 655 Winding Brook Drive, Glastonbury, CT 06033 Phone: 860-494-2600 | https://www.empowerfa.com Page 2  Item 3 – Table of Contents Item 1 – Cover Page ............................................................................................................................................... 1 Item 2 – Material Changes ..................................................................................................................................... 2 Item 3 – Table of Contents ..................................................................................................................................... 3 Item 4 – Advisory Services .................................................................................................................................... 4 A. Firm Information .............................................................................................................................................................. 4 B. Advisory Services Offered ............................................................................................................................................... 4 C. Client Account Management ........................................................................................................................................... 5 D. Wrap Fee Programs ........................................................................................................................................................ 5 E. Assets Under Management ............................................................................................................................................. 6 Item 5 – Fees and Compensation ......................................................................................................................... 6 A. Fees for Advisory Services.............................................................................................................................................. 6 B. Fee Billing........................................................................................................................................................................ 6 C. Other Fees and Expenses .............................................................................................................................................. 7 D. Advance Payment of Fees and Termination ................................................................................................................... 7 E. Compensation for Sales of Securities ............................................................................................................................. 8 Item 6 – Performance-Based Fees and Side-By-Side Management .................................................................. 8 Item 7 – Types of Clients ....................................................................................................................................... 8 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................................... 8 A. Methods of Analysis ........................................................................................................................................................ 8 B. Risk of Loss ..................................................................................................................................................................... 9 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 ............... 10 A. Code of Ethics ............................................................................................................................................................... 10 B. Personal Trading with Material Interest ......................................................................................................................... 10 C. Personal Trading in Same Securities as Clients ........................................................................................................... 10 D. Personal Trading at Same Time as Client .................................................................................................................... 11 Item 12 – Brokerage Practices ............................................................................................................................ 11 A. Recommendation of Custodian[s] ................................................................................................................................. 11 B. Aggregating and Allocating Trades ............................................................................................................................... 12 Item 13 – Review of Accounts ............................................................................................................................. 12 A. Frequency of Reviews ................................................................................................................................................... 12 B. Causes for Reviews ...................................................................................................................................................... 12 C. Review Reports ............................................................................................................................................................. 12 Item 14 – Client Referrals and Other Compensation ........................................................................................ 13 A. Compensation Received by Empower Financial ........................................................................................................... 13 B. Compensation for Client Referrals ................................................................................................................................ 13 Item 15 – Custody ................................................................................................................................................. 13 Item 16 – Investment Discretion ......................................................................................................................... 13 Item 17 – Voting Client Securities ....................................................................................................................... 14 Item 18 – Financial Information ........................................................................................................................... 14 Form ADV 2B – Brochure Supplements ............................................................................................................. 14 Privacy Policy ....................................................................................................................................................... 26 Empower Financial Advisory, LLC 655 Winding Brook Drive, Glastonbury, CT 06033 Phone: 860-494-2600 | https://www.empowerfa.com Page 3  Item 4 – Advisory Services A. Firm Information Empower Financial Advisory, LLC (“Empower Financial” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as a Limited Liability Company (“LLC”) under the laws of the State of Connecticut. Empower Financial was founded in June 2017 and became a registered investment advisor in May 2021. Empower Financial is owned and operated by Ronald E. Williams, Jr., CFP® (President and Chief Compliance Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Empower Financial. B. Advisory Services Offered Empower Financial offers wealth management services to individuals, high net worth individuals, trusts, estates, and small businesses (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. Empower Financial's fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Investment Management Services Empower Financial provides customized wealth management solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary investment management and related planning/advisory services. Empower Financial works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio strategy. Empower Financial will then construct an investment portfolio, consisting of diversified mutual funds and/or exchange-traded funds (“ETFs”) to achieve the Client’s investment goals. The Advisor may also utilize individual stocks, bonds, and/or other types of investments, as appropriate, to meet the needs of the Client. The Advisor may retain other types of investments from the Client’s legacy portfolio due to fit with the overall portfolio strategy, tax-related reasons, or other reasons as identified between the Advisor and the Client. Empower Financial’s investment strategies are primarily long-term focused, but the Advisor may buy, sell or re- allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. Empower Financial will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. Empower Financial evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Empower Financial may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Empower Financial may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. Empower Financial may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account Empower Financial Advisory, LLC 655 Winding Brook Drive, Glastonbury, CT 06033 Phone: 860-494-2600 | https://www.empowerfa.com Page 4  to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. At no time will Empower Financial accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices. Financial Planning Services Empower Financial will typically provide a variety of financial planning and consulting services. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including but not limited to, investment planning, retirement planning, personal savings, education savings, insurance needs, and other areas of a Client’s financial situation. A financial plan developed for, or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. Empower Financial may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six (6) months of contract date, assuming all information and documents requested are provided promptly. Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. C. Client Account Management Prior to engaging Empower Financial to provide investment advisory services, each Client is required to enter into one or more advisory agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include: • Establishing an Investment Strategy – Empower Financial, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives. • Asset Allocation – Empower Financial will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client. • Portfolio Construction – Empower Financial will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. • Investment Management and Supervision – Empower Financial will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs Empower Financial does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by Empower Financial. Empower Financial Advisory, LLC 655 Winding Brook Drive, Glastonbury, CT 06033 Phone: 860-494-2600 | https://www.empowerfa.com Page 5  E. Assets Under Management As of December 31, 2025, Empower manages $635,801,070 in Client assets, all of which are managed on a discretionary basis. Clients may request more current information at any time by contacting the Advisor. Item 5 – Fees and Compensation The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into one or more agreements with the Advisor based on the services selected. A. Fees for Advisory Services Investment Management Services Investment management fees are paid quarterly, advance of each calendar quarter, pursuant to the terms of the investment management agreement. Investment management fees are based on the market value of assets under management at the end of the prior calendar quarter. Investment management fees range from 0.25% to 1.50% annually. Fees may be based on the following schedule or a fixed rate up to 1.50%. Assets Under Management ($) First $400,000 Next $600,000 (Up to $1,000,000) Next $1,500,000 (Up to $2,500,000) Next $2,500,000 (Up to $5,000,000) Next $5,000,000 (Up to $10,000,000) Over $10,000,000 Annual Rate (%) 1.25% 1.00% 0.80% 0.60% 0.50% 0.25% The investment management fee in the first quarter of service is prorated from the inception date of the account[s] to the end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. Certain Clients may have a fixed rate schedule. The Client’s fees will take into consideration the aggregate assets under management with the Advisor. All securities held in accounts managed by Empower Financial will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s valuation to ensure accurate billing. The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction and custody fees, and other related costs and expenses described in Item 5.C below, which may be incurred by the Client. However, the Advisor shall not receive any portion of these commissions, fees, and costs. Financial Planning Services Empower Financial offers financial planning services as project-based engagements and ongoing financial planning services. Project-based financial planning engagements are offered at an hourly rate of up to $300 per hour or a fixed engagement fee ranging from $1,500 to $20,000 per engagement. Ongoing financial planning engagements are billed a fixed engagement fee of $1,500 to $20,000 annually. Fees may be negotiable based on the nature and complexity of the services to be provided and the overall relationship with the Advisor. An estimate for total hours and/or costs will be determined prior to engaging for these services. B. Fee Billing Investment Management Services Investment management fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at the Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s account[s] at the beginning of the respective quarter. The amount due is calculated by applying the quarterly rate (annual rate divided by 4) to the total assets under management with Empower Financial at the end of the prior quarter. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the investment management fee. Clients are urged to also review and compare the statement provided by the Advisor to the brokerage statement from the Custodian, as the Custodian does not perform a verification of fees. Clients provide written authorization permitting advisory fees to be deducted by Empower Financial to be paid directly Empower Financial Advisory, LLC 655 Winding Brook Drive, Glastonbury, CT 06033 Phone: 860-494-2600 | https://www.empowerfa.com Page 6  from their account[s] held by the Custodian as part of the investment management agreement and separate account forms provided by the Custodian. Financial Planning Services Project-based financial planning fees may be invoiced up to 100% of the expected total fee upon execution of the financial planning agreement. The balance shall be invoiced upon completion of the agreed upon deliverable[s]. The Advisor will only charge an advance fee for project-based engagements expected to be completed in less than six (6) months. Ongoing financial planning engagements are billed with an advance fee for the completion of the financial plan and then an ongoing financial planning fee, which may be billed quarterly, semi-annually or annually. The Advisor will not collect an advance for services that will not be completed in less than six (6) months. In such instances where services will exceed this timeframe, the Advisor will bill as the project progresses. C. Other Fees and Expenses Clients may incur certain fees or charges imposed by third parties, other than Empower Financial, in connection with investments made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities execution fees charged by the Custodian, as applicable. The Advisor's recommended Custodian does not charge securities transaction fees for ETF and equity trades in a Client's account, provided that the account meets the terms and conditions of the Custodian's brokerage requirements. However, the Custodian typically charges for mutual funds and other types of investments. The fees charged by Empower Financial are separate and distinct from these custody and execution fees. In addition, all fees paid to Empower Financial for wealth management services are separate and distinct from the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee. A Client may be able to invest in these products directly, without the services of Empower Financial, but would not receive the services provided by Empower Financial which are designed, among other things, to assist the Client in determining which products or services are most appropriate for each Client’s financial situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by Empower Financial to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information. D. Advance Payment of Fees and Termination Investment Management Services Empower Financial may be compensated for its investment management services in advance of the quarter in which services are rendered. Either party may terminate the investment management agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the investment management agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination, the Advisor will refund any unearned, prepaid investment management fees from the effective date of termination to the end of the quarter. The Client’s investment management agreement with the Advisor is non-transferable without the Client’s prior consent. Financial Planning Services Empower Financial is partially compensated for its financial planning services in advance of the services. Either party may terminate the financial planning agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the financial planning agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination, the Client shall be billed for the percentage of the engagement scope completed by the Advisor or in the case of an hourly engagement, the actual hours worked by the Advisor. Upon termination, the Advisor will refund any unearned, prepaid planning fees from the effective date of termination to the end of the quarter. The Client’s financial planning agreement with the Advisor is non-transferable without the Client’s prior consent. Empower Financial Advisory, LLC 655 Winding Brook Drive, Glastonbury, CT 06033 Phone: 860-494-2600 | https://www.empowerfa.com Page 7  E. Compensation for Sales of Securities Empower Financial does not buy or sell securities to earn commissions and does not receive any compensation for securities transactions in any Client account, other than the investment management fees noted above. Certain Advisory Persons are also licensed as independent insurance professionals. As an independent insurance professional, an Advisory Person may earn commission-based compensation for selling insurance products, including insurance products they sell to Clients. Insurance commissions earned by Advisory Persons are separate and in addition to the Advisor’s fees. This practice presents a conflict of interest as the Advisory Person has an incentive to recommend insurance products to the Client for the purpose of generating commissions rather than solely based on the Client’s needs. Clients are under no obligation, contractually or otherwise, to purchase insurance products through any Advisory Person affiliated with the Advisor. Please see Item 10 below. Item 6 – Performance-Based Fees and Side-By-Side Management Empower Financial does not charge performance-based fees for its wealth management services. The fees charged by Empower Financial are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by any Client. Empower Financial does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients. Item 7 – Types of Clients Empower Financial offers wealth management services to individuals, high net worth individuals, trusts, estates, and small businesses. Empower Financial generally does not impose a minimum relationship size. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis Empower Financial primarily employs fundamental and technical analysis methods in developing investment strategies for its Clients. Research and analysis from Empower Financial are derived from numerous sources, including financial media companies, third-party research materials, Internet sources, and review of company activities, including annual reports, prospectuses, press releases and research prepared by others. Fundamental analysis utilizes economic and business indicators as investment selection criteria. This criteria consists generally of ratios and trends that may indicate the overall strength and financial viability of the entity being analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with a value discounted by the market. While this type of analysis helps the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the fundamental analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Technical analysis involves the analysis of past market data rather than specific company data in determining the recommendations made to clients. Technical analysis may involve the use of charts to identify market patterns and trends, which may be based on investor sentiment rather than the fundamentals of the company. The primary risk in using technical analysis is that spotting historical trends may not help to predict such trends in the future. Even if the trend will eventually reoccur, there is no guarantee that Empower Financial will be able to accurately predict such a reoccurrence. As noted above, Empower Financial generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. Empower Financial will typically hold all or a portion of a security for more than a year, but Empower Financial Advisory, LLC 655 Winding Brook Drive, Glastonbury, CT 06033 Phone: 860-494-2600 | https://www.empowerfa.com Page 8  may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, Empower Financial may also buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the fundamentals of the security, sector or asset class. B. Risk of Loss Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should be prepared to bear the potential risk of loss. Empower Financial will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their investment goals. While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon, tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client participation in this process, including full and accurate disclosure of requested information, is essential for the analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or other factors that may affect this analysis. The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process. Following are some of the risks associated with the Advisor’s investment strategies: Market Risks The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall financial markets. ETF Risks The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs has a large bid- ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. Bond ETFs Bond ETFs are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices will fall if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the coupon rate of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower rate than was previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at a rate that exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e. the risk associated with purchasing a debt instrument which includes the possibility of the company defaulting on its repayment obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of the company’s rating which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity Risks, i.e. the risk that a bond may not be sold as quickly as there is no readily available market for the bond. Empower Financial Advisory, LLC 655 Winding Brook Drive, Glastonbury, CT 06033 Phone: 860-494-2600 | https://www.empowerfa.com Page 9  Mutual Fund Risks The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day. Past performance is not a guarantee of future returns. Investing in securities and other investments involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with the Advisor. Item 9 – Disciplinary Information There are no legal, regulatory or disciplinary events involving Empower Financial or its management person. Empower Financial values the trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence on any advisor or service provider that the Client engages. The backgrounds of the Advisor or Advisory Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 313968. Item 10 – Other Financial Industry Activities and Affiliations Insurance Agency Affiliations As noted in Item 5, certain Advisory Persons are also licensed insurance professionals. Implementations of insurance recommendations are separate and apart from one’s role with Empower Financial. As an insurance professional, an Advisory Person may receive customary commissions and other related revenues from the various insurance companies whose products are sold. Advisory Persons are not required to offer the products of any particular insurance company. Commissions generated by insurance sales do not offset regular advisory fees. This may cause a conflict of interest in recommending certain products of the insurance companies. Clients are under no obligation to implement any recommendations made by an Advisory Person or the Advisor. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics Empower Financial has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each Client. This Code applies to all persons associated with Empower Financial (“Supervised Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to each Client. Empower Financial and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of Empower Financial’s Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general principles that guide the Code. The Code covers a range of topics that address employee ethics and conflicts of interest. To request a copy of the Code, please contact the Advisor at 860-494-2600 or via email at ClientLiaison@EmpowerFA.com. B. Personal Trading with Material Interest Empower Financial allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Empower Financial does not act as principal in any transactions. In addition, the Advisor does not act as the general partner of a fund, or advise an investment company. Empower Financial does not have a material interest in any securities traded in Client accounts. C. Personal Trading in Same Securities as Clients Empower Financial allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and procedures. As noted above, the Advisor has adopted the Code to address insider trading (material non-public information controls); gifts and entertainment; outside business activities and personal securities reporting. When trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities. The Empower Financial Advisory, LLC 655 Winding Brook Drive, Glastonbury, CT 06033 Phone: 860-494-2600 | https://www.empowerfa.com Page 10  fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more advantageous terms than Client trades, or by trading based on material non-public information. This risk is mitigated by Empower Financial requiring reporting of personal securities trades by its Supervised Persons for review by the Chief Compliance Officer (“CCO”) or delegate. The Advisor has also adopted written policies and procedures to detect the misuse of material, non-public information. D. Personal Trading at Same Time as Client While Empower Financial allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterwards. At no time will Empower Financial, or any Supervised Person of Empower Financial, transact in any security to the detriment of any Client. Item 12 – Brokerage Practices A. Recommendation of Custodian[s] Empower Financial does not have discretionary authority to select the broker-dealer/custodian for custody and execution services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets and authorize Empower Financial to direct trades to the Custodian as agreed upon in the investment management agreement. Further, Empower Financial does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-by-trade basis. Where Empower Financial does not exercise discretion over the selection of the Custodian, it may recommend the Custodian to Clients for custody and execution services. Clients are not obligated to use the recommended Custodian and will not incur any extra fee or cost from the Advisor associated with using a custodian not recommended by Empower Financial. However, the Advisor may be limited in the services it can provide if the recommended Custodian is not engaged. Empower Financial may recommend the Custodian based on criteria such as, but not limited to, reasonableness of commissions charged to the Client, services made available to the Client, and its reputation and/or the location of the Custodian’s offices. Empower Financial will generally recommend that Clients establish their account[s] at Fidelity Clearing and Custody Solutions and related divisions and entities of Fidelity Investments, Inc., including National Financial Services LLC, and Fidelity Brokerage Services LLC (collectively “Fidelity”), a FINRA-registered broker-dealer and member SIPC. Fidelity will serve as the Client’s “qualified custodian.” Empower Financial maintains an institutional relationship with Fidelity, whereby the Advisor receives economic benefits from Fidelity. Empower Financial has established an institutional relationship with Fidelity to assist the Advisor in managing Client account[s]. Access to the Fidelity platform is provided at no charge to the Advisor. The Fidelity platform includes brokerage, custody, administrative support, record keeping, technology and related services designed to support registered investment advisors like Empower Financial in serving Clients. These services are intended to serve the best interests of the Advisor’s Clients. Fidelity may charge brokerage commissions (securities transaction fees) for effecting certain securities transactions. Fidelity enables the Advisor to obtain certain no-load mutual funds without securities transaction fees and other no- load funds at nominal transaction charges. Fidelity’s commission rates are generally considered discounted from customary retail commission rates. However, the commissions and transaction fees charged by Fidelity may be higher or lower than those charged by other custodians and broker-dealers. Please see Item 14 below for additional information. Following are additional details regarding the brokerage practices of the Advisor: 1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and other services. Empower Financial does not participate in soft dollar programs sponsored or offered by any broker- dealer/custodian. However, the Advisor receives certain economic benefits from the Custodian. Please see Item 14 below. Empower Financial Advisory, LLC 655 Winding Brook Drive, Glastonbury, CT 06033 Phone: 860-494-2600 | https://www.empowerfa.com Page 11  2. Brokerage Referrals - Empower Financial does not receive any compensation from any third party in connection with the recommendation for establishing an account. 3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where Empower Financial will place trades within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are traded within their respective account[s]. The Advisor will not engage in any principal transactions (i.e., trade of any security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a security into one Client account from another Client’s account[s]). Empower Financial will not be obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs are determined by the Custodian. A Client may pay a commission that is higher than another qualified custodian might charge to effect the same transaction. The Advisor has determined in good faith that the commissions charged by Fidelity are reasonable in relation to the value of the brokerage and research services received. In seeking best execution, the determinative factor is not necessarily the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of the Custodian’s services, including the value of research provided, execution capability, commission rates, and responsiveness. Accordingly, although the Advisor will seek competitive rates, to the benefit of all Clients, it may not necessarily obtain the lowest possible commission rates for specific Client account transactions. Although the investment research products and services that may be obtained by the Advisor will generally be used to service all of the Advisor’s Clients, they may not equally benefit all Clients. Please also see Item 14. B. Aggregating and Allocating Trades The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the Custodian. Empower Financial will execute its transactions through the Custodian as authorized by the Client. Empower Financial may aggregate orders in a block trade or trades when securities are purchased or sold through the Custodian for multiple (discretionary) accounts in the same trading day. If a block trade cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each business day must be allocated in a manner that is consistent with the initial pre-allocation or other written statement. This must be done in a way that does not consistently advantage or disadvantage any particular Clients’ accounts. Item 13 – Review of Accounts A. Frequency of Reviews Securities in Client accounts are monitored on a regular and continuous basis by its Advisory Persons and periodically by the CCO. Formal reviews are generally conducted at least annually or more frequently depending on the needs of the Client. B. Causes for Reviews In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least annually. Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify Empower Financial if changes occur in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be triggered by material market, economic or political events. C. Review Reports The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage statements will include all positions, transactions and fees relating to the Client’s account[s]. The Advisor may also provide Clients with periodic reports regarding their holdings, allocations, and performance. Empower Financial Advisory, LLC 655 Winding Brook Drive, Glastonbury, CT 06033 Phone: 860-494-2600 | https://www.empowerfa.com Page 12  Item 14 – Client Referrals and Other Compensation A. Compensation Received by Empower Financial Empower Financial may refer Clients to various unaffiliated, non-advisory professionals (e.g. attorneys, accountants, estate planners) to provide certain financial services necessary to meet the goals of its Clients. Likewise, Empower Financial may receive non-compensated referrals of new Clients from various third-parties. Participation in Institutional Advisor Platform As noted in item 12, Empower Financial has established an institutional relationship with Fidelity to assist the Advisor in managing Client account[s]. As part of the arrangement, Fidelity also makes available to the Advisor, at no additional charge to the Advisor, certain research and brokerage services, including research services obtained by Fidelity directly from independent research companies. The Advisor may also receive additional services and support from Fidelity. As a result of receiving such services for no additional cost, the Advisor may have an incentive to continue to use or expand the use of Fidelity's services. The Advisor examined this potential conflict of interest when it chose to enter into the relationship with Fidelity and has determined that the relationship is in the best interests of the Advisor’s Clients and satisfies its Client obligations, including its duty to seek best execution. Please see Item 12 above. The Advisor receives access to software and related support without cost because the Advisor renders investment management services to Clients that maintain assets at Fidelity The software and related systems support may benefit the Advisor, but not its Clients directly. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a Custodian creates a conflict of interest since these benefits may influence the Advisor's recommendation of this Custodian over one that does not furnish similar software, systems support, or services. In addition, Fidelity has provided the Advisor with financial support in the launch of the Advisor and reimbursements for various third-party service providers. B. Compensation for Client Referrals Empower Financial does not compensate, either directly or indirectly, any persons who are not supervised persons, for Client referrals. Item 15 – Custody Empower Financial does not accept or maintain custody of Client accounts, except for the limited circumstances outlined below: Deduction of Advisory Fees - To ensure compliance with regulatory requirements associated with the deduction of advisory fees, all Clients for whom Empower Financial exercises discretionary authority must hold their assets with a "qualified custodian." Clients are responsible for engaging a “qualified custodian” to safeguard their funds and securities and must instruct Empower Financial to utilize that Custodian for securities transactions on their behalf. Clients are encouraged to review statements provided by the Custodian and compare to any reports provided by Empower Financial to ensure accuracy, as the Custodian does not perform this review. Item 16 – Investment Discretion Empower Financial generally has discretion over the selection and amount of securities to be bought or sold in Client accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by Empower Financial. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will be evidenced by the Client's execution of an investment management agreement containing all applicable limitations to such authority. All discretionary trades made by Empower Financial will be in accordance with each Client's investment objectives and goals. Empower Financial Advisory, LLC 655 Winding Brook Drive, Glastonbury, CT 06033 Phone: 860-494-2600 | https://www.empowerfa.com Page 13  Item 17 – Voting Client Securities Empower Financial does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client retains the sole responsibility for proxy decisions and voting. Item 18 – Financial Information Neither Empower Financial, nor its management, have any adverse financial situations that would reasonably impair the ability of Empower Financial to meet all obligations to its Clients. Neither Empower Financial, nor any of its Advisory Persons, have been subject to a bankruptcy or financial compromise. Empower Financial is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect advance fees of $1,200 more for services to be performed six months or more in the future. Empower Financial Advisory, LLC 655 Winding Brook Drive, Glastonbury, CT 06033 Phone: 860-494-2600 | https://www.empowerfa.com Page 14  Form ADV Part 2B – Brochure Supplement for Ronald E. Williams, Jr., CFP® President and Chief Compliance Officer Effective: February 13, 2026 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Ronald E. Williams, Jr., CFP® (CRD# 1987830) in addition to the information contained in the Empower Financial Advisory, LLC (“Empower Financial” or the “Advisor”, CRD# 313968) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the Empower Financial Disclosure Brochure or this Brochure Supplement, please contact the Advisor at 860-494-2600 or via email at ClientLiaison@EmpowerFA.com. Additional information about Mr. Williams is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 1987830. Empower Financial Advisory, LLC 655 Winding Brook Drive, Glastonbury, CT 06033 Phone: 860-494-2600 | https://www.empowerfa.com Page 15  Item 2 – Educational Background and Business Experience Ronald E. Williams, Jr., CFP®, born in 1966, is dedicated to advising Clients of Empower Financial as its President and Chief Compliance Officer. Mr. Williams earned a B.A. in Business Management from Eastern Nazarene College in 1989. Mr. Williams became a Certified Financial Planner in April 1993. Additional information regarding Mr. Williams’ employment history is included below. Employment History: President and Chief Compliance Officer, Empower Financial Advisory, LLC Investment Advisor Representative, Securities America Advisors, Inc. Registered Representative, Securities America, Inc. Investment Advisor Representative, SSN Advisory, Inc. Registered Representative, Securities Service Network, LLC. Investment Advisor Representative, AdviceOne Advisory Services, LLC 06/2021 to Present 09/2020 to 06/2021 09/2020 to 06/2021 09/2017 to 09/2020 01/2000 to 09/2020 01/2001 to 09/2017 CERTIFIED FINANCIAL PLANNER™ (“CFP®”) The CERTIFIED FINANCIAL PLANNER™, CFP®, and federally registered CFP® (with flame design) marks (collectively, the “CFP® marks”) are professional certification marks granted in the United States by CERTIFIED FINANCIAL PLANNER™ Board of Standards, Inc. (“CFP® Board”). The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial planners to hold CFP® certification. It is recognized in the United States and a number of other countries for its (1) high standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical requirements that govern professional engagements with clients. Currently, more than 87,000 individuals have obtained CFP® certification in the United States. To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements: • Education – Complete an advanced college-level course of study addressing the financial planning subject areas that CFP Board’s studies have determined as necessary for the competent and professional delivery of financial planning services, and attain a Bachelor’s Degree from a regionally accredited United States college or university (or its equivalent from a foreign university). CFP Board’s financial planning subject areas include insurance planning and risk management, employee benefits planning, investment planning, income tax planning, retirement planning, and estate planning; • Examination – Pass the comprehensive CFP® Certification Examination. The examination includes case studies and client scenarios designed to test one’s ability to correctly diagnose financial planning issues and apply one’s knowledge of financial planning to real-world circumstances; • Experience – Complete at least three years of full-time financial planning-related experience (or the equivalent, measured as 2,000 hours per year); and • Ethics – Agree to be bound by CFP Board’s Standards of Professional Conduct, a set of documents outlining the ethical and practice standards for CFP® professionals. Individuals who become certified must complete the following ongoing education and ethics requirements in order to maintain the right to continue to use the CFP® marks: • Continuing Education – Complete 30 hours of continuing education hours every two years, including two hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain competence and keep up with developments in the financial planning field; and • Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The Standards prominently require that CFP® professionals provide financial planning services at a fiduciary standard of care. This means CFP® professionals must provide financial planning services in the best interests of their clients. CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP Board’s enforcement process, which could result in suspension or permanent revocation of their CFP®. Empower Financial Advisory, LLC 655 Winding Brook Drive, Glastonbury, CT 06033 Phone: 860-494-2600 | https://www.empowerfa.com Page 16  Item 3 – Disciplinary Information Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. There are no legal, civil or disciplinary events to disclose regarding Mr. Williams. However, we do encourage you to independently view the background of Mr. Williams on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 1987830. Item 4 – Other Business Activities Insurance Agency Affiliations Mr. Williams is also a licensed insurance professional. Implementations of insurance recommendations are separate and apart from Mr. Williams’ role with Empower Financial. As an insurance professional, Mr. Williams will receive customary commissions and other related revenues from the various insurance companies whose products are sold. Mr. Williams is not required to offer the products of any particular insurance company. Commissions generated by insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in recommending certain products of the insurance companies. Clients are under no obligation to implement any recommendations made by Mr. Williams or the Advisor. Mr. Williams spends approximately 10% of his time per month in this capacity. Item 5 – Additional Compensation Mr. Williams has additional business activity where compensation is received that is detailed in Item 4 above. Item 6 – Supervision Mr. Williams serves as the President of Empower Financial as well as its Chief Compliance Officer. Mr. Williams can be reached at 860-494-2600. Empower Financial has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of Empower Financial. Further, Empower Financial is subject to regulatory oversight by various agencies. These agencies require registration by Empower Financial and its Supervised Persons. As a registered entity, Empower Financial is subject to examinations by regulators, which may be announced or unannounced. Empower Financial is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor. Empower Financial Advisory, LLC 655 Winding Brook Drive, Glastonbury, CT 06033 Phone: 860-494-2600 | https://www.empowerfa.com Page 17  Form ADV Part 2B – Brochure Supplement for Lori K. Oblinger, CFP®, ChFC® Wealth Management Associate Effective: February 13, 2026 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Lori K. Oblinger, CFP®, ChFC® (CRD# 2581746) in addition to the information contained in the Empower Financial Advisory, LLC (“Empower Financial” or the “Advisor”, CRD# 313968) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the Empower Financial Disclosure Brochure or this Brochure Supplement, please contact the Advisor at 860-494-2600 or via email at ClientLiaison@EmpowerFA.com.. Additional information about Ms. Oblinger is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with her full name or her Individual CRD# 2581746. Empower Financial Advisory, LLC 655 Winding Brook Drive, Glastonbury, CT 06033 Phone: 860-494-2600 | https://www.empowerfa.com Page 18  Item 2 – Educational Background and Business Experience Lori K. Oblinger, CFP®, ChFC®, born in 1970, is dedicated to advising Clients of Empower Financial as a Wealth Management Analyst. Ms. Oblinger earned a B.S. from University of Connecticut in 1992. Additional information regarding Ms. Oblinger’s employment history is included below. Employment History: Wealth Management Associate, Empower Financial Advisory, LLC Registered Representative, Securities America, Inc. Financial Planning Associate, Heritage Capital Advisors Account Manager, Netsource, Inc. 04/2018 to Present 09/2020 to 06/2021 09/2013 to 04/2018 10/2009 to 09/2013 CERTIFIED FINANCIAL PLANNER™ (“CFP®”) The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP® (with flame design) marks (collectively, the “CFP® marks”) are professional certification marks granted in the United States by CERTIFIED FINANCIAL PLANNER™ Board of Standards, Inc. (“CFP® Board”). The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial planners to hold CFP® certification. It is recognized in the United States and a number of other countries for its (1) high standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical requirements that govern professional engagements with clients. Currently, more than 87,000 individuals have obtained CFP® certification in the United States. To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements: • Education – Complete an advanced college-level course of study addressing the financial planning subject areas that CFP Board’s studies have determined as necessary for the competent and professional delivery of financial planning services, and attain a Bachelor’s Degree from a regionally accredited United States college or university (or its equivalent from a foreign university). CFP Board’s financial planning subject areas include insurance planning and risk management, employee benefits planning, investment planning, income tax planning, retirement planning, and estate planning; • Examination – Pass the comprehensive CFP® Certification Examination. The examination includes case studies and client scenarios designed to test one’s ability to correctly diagnose financial planning issues and apply one’s knowledge of financial planning to real-world circumstances; • Experience – Complete at least three years of full-time financial planning-related experience (or the equivalent, measured as 2,000 hours per year); and • Ethics – Agree to be bound by CFP Board’s Standards of Professional Conduct, a set of documents outlining the ethical and practice standards for CFP® professionals. Individuals who become certified must complete the following ongoing education and ethics requirements in order to maintain the right to continue to use the CFP® marks: • Continuing Education – Complete 30 hours of continuing education hours every two years, including two hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain competence and keep up with developments in the financial planning field; and • Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The Standards prominently require that CFP® professionals provide financial planning services at a fiduciary standard of care. This means CFP® professionals must provide financial planning services in the best interests of their clients. CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP Board’s enforcement process, which could result in suspension or permanent revocation of their CFP®. Empower Financial Advisory, LLC 655 Winding Brook Drive, Glastonbury, CT 06033 Phone: 860-494-2600 | https://www.empowerfa.com Page 19  Chartered Financial Consultant™ (“ChFC®”) The Chartered Financial Consultant™ (ChFC®) program prepares you to meet the advanced financial planning needs of individuals, professionals, and small business owners. You'll gain a sustainable advantage in this competitive field with in-depth coverage of the key financial planning disciplines, including insurance, income taxation, retirement planning, investments, and estate planning. The ChFC® requires three years of full-time, relevant business experience, nine two-hour course-specific proctored exams, and 30 hours of continuing education every two years. Holders of the ChFC® designation must adhere to The American College’s Code of Ethics. Program Objectives: • Function as an ethical, competent and articulate practitioner in the field of financial planning • Utilize the intellectual tools and framework needed to maintain relevant and current financial planning knowledge and strategies. • Apply financial planning theory and techniques through the development of case studies and solutions. • Apply in-depth knowledge in a holistic manner from a variety of disciplines, namely, estate planning, retirement planning, or non-qualified deferred compensation. Item 3 – Disciplinary Information There are no legal, civil or disciplinary events to disclose regarding Ms. Oblinger. Ms. Oblinger has never been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims or administrative proceedings against Ms. Oblinger. Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or disciplinary events to disclose regarding Ms. Oblinger. However, we do encourage you to independently view the background of Ms. Oblinger on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with her full name or her Individual CRD# 2581746. Item 4 – Other Business Activities Insurance Agency Affiliations Ms. Oblinger is also a licensed insurance professional. Implementations of insurance recommendations are separate and apart from Ms. Oblinger’s role with Empower Financial. As an insurance professional, Ms. Oblinger will receive customary commissions and other related revenues from the various insurance companies whose products are sold. Ms. Oblinger is not required to offer the products of any particular insurance company. Commissions generated by insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in recommending certain products of the insurance companies. Clients are under no obligation to implement any recommendations made by Ms. Oblinger or the Advisor. Ms. Oblinger spends less than 5% of her time per month in this capacity. Item 5 – Additional Compensation Ms. Oblinger has additional business activity where compensation is received that is detailed in Item 4 above. Item 6 – Supervision Ms. Oblinger serves as a Wealth Management Analyst of Empower Financial and is supervised by Ronald Williams, the Chief Compliance Officer. Mr. Williams can be reached at 860-494-2600. Empower Financial Advisory, LLC 655 Winding Brook Drive, Glastonbury, CT 06033 Phone: 860-494-2600 | https://www.empowerfa.com Page 20  Empower Financial has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of Empower Financial. Further, Empower Financial is subject to regulatory oversight by various agencies. These agencies require registration by Empower Financial and its Supervised Persons. As a registered entity, Empower Financial is subject to examinations by regulators, which may be announced or unannounced. Empower Financial is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor. Empower Financial Advisory, LLC 655 Winding Brook Drive, Glastonbury, CT 06033 Phone: 860-494-2600 | https://www.empowerfa.com Page 21  Form ADV Part 2B – Brochure Supplement for Nicholas J. Gerlach Wealth Management Associate Effective: February 13, 2026 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Nicholas J. Gerlach (CRD# 7226974) in addition to the information contained in the Empower Financial Advisory, LLC (“Empower Financial” or the “Advisor”, CRD# 313968) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the Empower Financial Disclosure Brochure or this Brochure Supplement, please contact us at 860-494-2600. Additional information about Mr. Gerlach is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 7226974. Empower Financial Advisory, LLC 655 Winding Brook Drive, Glastonbury, CT 06033 Phone: 860-494-2600 | https://www.empowerfa.com Page 22  Item 2 – Educational Background and Business Experience Nicholas J. Gerlach, born in 1995, is dedicated to advising Clients of Empower Financial as a Wealth Management Associate. Mr. Gerlach earned a B.S. Actuarial Mathematics from Bryant University in 2018. Additional information regarding Mr. Gerlach’s employment history is included below. Employment History: Wealth Management Associate, Empower Financial Advisory, LLC Laborer, Jasmac Inc Grounds Keeper, Winfield Funeral Home Wealth Management Associate, Northwestern Mutual Pension Analyst, Mercer Unemployed Student, Bryant University Laborer, Boyle and Fogarty Construction 03/2021 to Present 11/2020 to 03/2021 07/2020 to 03/2021 02/2020 to 05/2020 02/2019 to 11/2019 05/2018 to 02/2019 09/2014 to 05/2018 10/2007 to 09/2017 Item 3 – Disciplinary Information There are no legal, civil or disciplinary events to disclose regarding Mr. Gerlach. Mr. Gerlach has never been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims or administrative proceedings against Mr. Gerlach. Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or disciplinary events to disclose regarding Mr. Gerlach. However, we do encourage you to independently view the background of Mr. Gerlach on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 7226974. Item 4 – Other Business Activities Mr. Gerlach is dedicated to the investment advisory activities of Empower Financial’s Clients. Mr. Gerlach does not have any other business activities. Item 5 – Additional Compensation Mr. Gerlach is dedicated to the investment advisory activities of Empower Financial’s Clients. Mr. Gerlach does not receive any additional forms of compensation. Item 6 – Supervision Mr. Gerlach serves as a Wealth Management Associate of Empower Financial and is supervised by Ronald Williams, the Chief Compliance Officer. Mr. Williams can be reached at 860-494-2600. Empower Financial has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of Empower Financial. Further, Empower Financial is subject to regulatory oversight by various agencies. These agencies require registration by Empower Financial and its Supervised Persons. As a registered entity, Empower Financial is subject to examinations by regulators, which may be announced or unannounced. Empower Financial is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor. Empower Financial Advisory, LLC 655 Winding Brook Drive, Glastonbury, CT 06033 Phone: 860-494-2600 | https://www.empowerfa.com Page 23  Form ADV Part 2B – Brochure Supplement for Ronald F. Williams Wealth Management Associate Effective: February 13, 2026 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Ronald F. Williams (CRD# 6978336) in addition to the information contained in the Empower Financial Advisory, LLC (“Empower Financial” or the “Advisor”, CRD# 313968) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the Empower Financial Disclosure Brochure or this Brochure Supplement, please contact us at 860-494-2600. Additional information about Mr. Williams is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 6978336. Empower Financial Advisory, LLC 655 Winding Brook Drive, Glastonbury, CT 06033 Phone: 860-494-2600 | https://www.empowerfa.com Page 24  Item 2 – Educational Background and Business Experience Ronald F. Williams, born in 1996, is dedicated to advising Clients of Empower Financial as a Wealth Management Associate. Mr. Williams earned a B.S. Finance and Applied Analytics from Bryant University in 2020. Additional information regarding Mr. Williams’s employment history is included below. Employment History: Wealth Management Associate, Empower Financial Advisory, LLC Driver, Ronnie Williams Racing 05/2020 to Present 04/2012 to Present Item 3 – Disciplinary Information There are no legal, civil or disciplinary events to disclose regarding Mr. Williams. Mr. Williams has never been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims or administrative proceedings against Mr. Williams. Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or disciplinary events to disclose regarding Mr. Williams. However, we do encourage you to independently view the background of Mr. Williams on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 6978336. Item 4 – Other Business Activities Ronnie Williams Racing Mr. Williams is also a Driver at Ronnie Wiliams Racing, In his role as a Driver, Mr. Williams participates in competetive racing events. Mr. Williams is compensated via race event payouts, and spends approximately 10% of his time per month in this capacity. Item 5 – Additional Compensation Mr. Williams has additional business activities where compensation is received that are detailed in Item 4 above. Item 6 – Supervision Mr. Williams serves as a Wealth Management Associate of Empower Financial and is supervised by Ronald Williams Jr., the Chief Compliance Officer. Mr. Williams Jr. can be reached at 860-494-2600. Empower Financial has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of Empower Financial. Further, Empower Financial is subject to regulatory oversight by various agencies. These agencies require registration by Empower Financial and its Supervised Persons. As a registered entity, Empower Financial is subject to examinations by regulators, which may be announced or unannounced. Empower Financial is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor. Empower Financial Advisory, LLC 655 Winding Brook Drive, Glastonbury, CT 06033 Phone: 860-494-2600 | https://www.empowerfa.com Page 25  Privacy Policy Effective: February 13, 2026 Our Commitment to You Empower Financial Advisory, LLC (“Empower Financial” or the “Advisor”) is committed to safeguarding the use of personal information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in our Privacy Policy (“Policy”). Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. Empower Financial (also referred to as "we", "our" and "us”) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you. Empower Financial does not sell your non-public personal information to anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below. Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy. Why you need to know? Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information. What information do we collect from you? Driver’s license number Date of birth Social security or taxpayer identification number Assets and liabilities Name, address and phone number[s] Income and expenses E-mail address[es] Investment activity Account information (including other institutions) Investment experience and goals What Information do we collect from other sources? Custody, brokerage and advisory agreements Other advisory agreements and legal documents Transactional information with us or others Account applications and forms Investment questionnaires and suitability documents Other information needed to service account How do we protect your information? To safeguard your personal information from unauthorized access and use we maintain physical, procedural and electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a secure office environment. Our technology vendors provide security and access control over personal information and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Client’s personal information. We require third parties that assist in providing our services to you to protect the personal information they receive from us. Empower Financial Advisory, LLC 655 Winding Brook Drive, Glastonbury, CT 06033 Phone: 860-494-2600 | https://www.empowerfa.com Page 26  How do we share your information? An RIA shares Client personal information to effectively implement its services. In the section below, we list some reasons we may share your personal information. Basis For Sharing Do we share? Can you limit? Yes No No Not Shared Yes Yes No Not Shared Servicing our Clients We may share non-public personal information with non-affiliated third parties (such as administrators, brokers, custodians, regulators, credit agencies, other financial institutions) as necessary for us to provide agreed upon services to you, consistent with applicable law, including but not limited to: processing transactions; general account maintenance; responding to regulators or legal investigations; and credit reporting. Marketing Purposes Empower Financial does not disclose, and does not intend to disclose, personal information with non-affiliated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where Empower Financial or the client has a formal agreement with the financial institution. We will only share information for purposes of servicing your accounts, not for marketing purposes. Authorized Users Your non-public personal information may be disclosed to you and persons that we believe to be your authorized agent[s] or representative[s]. Information About Former Clients Empower Financial does not disclose and does not intend to disclose, non-public personal information to non-affiliated third parties with respect to persons who are no longer our Clients. State-specific Regulations Massachusetts In response to Massachusetts law, the Client must “opt-in” to share non-public personal information with non-affiliated third parties before any personal information is disclosed. Client opt-in is obtained through the Client’s execution of authorization forms provided by the third parties, by executing an Information Sharing Authorization Form, or by other written consent by the Client, as appropriate and consistent with applicable laws and regulations. Changes to our Privacy Policy We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us. Periodically we may revise this Policy and will provide you with a revised Policy if the changes materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing. Any Questions? You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting us at 860-494-2600 or via email at ClientLiaison@EmpowerFA.com. Empower Financial Advisory, LLC 655 Winding Brook Drive, Glastonbury, CT 06033 Phone: 860-494-2600 | https://www.empowerfa.com Page 27