ECM is a Colorado limited liability company (“LLC”) formed in 1994 as a corporation under the name Maxim Capital Management, LLC d/b/a GW Capital Management, Inc. In 1997, it converted to an LLC under the same name. On September 24, 2012, Maxim Capital Management, LLC d/b/a GW Capital Management, LLC rebranded as Great-West Capital Management, LLC (“GWCM”). On August 1, 2022, GWCM was rebranded as Empower Capital Management, LLC. The Adviser is a wholly owned subsidiary of Empower Annuity Insurance Company of America (“EAICA”). EAICA, and its wholly owned subsidiary, Empower Life & Annuity Insurance Company of New York (“ELAINY”), offers products and services through its brand Empower (“Empower”). The Adviser provides investment advisory and related services for products offered by Empower. EAICA’s corporate headquarters are located in Greenwood Village, CO; ELAINY’s home office is located in New York, NY. EAICA is a direct wholly owned subsidiary of Empower Holdings, Inc. (“EHI”), a Delaware holding company. EHI 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. This brochure describes certain services offered and/or provided by ECM to Non-Qualified Deferred Compensation (“NQDC”) plan sponsors and participants, which include: Services Offered to Clients and Their Participants
• Advisor Managed Portfolio Services
• Investment Consulting Services Services Offered to Our Affiliates
• Administrative Services Related to the Use of Third-Party Models Services No Longer Offered but Utilized by Certain Clients and Their Participants:
• Guarantee+
• Deferred Compensation Investment Advice These services are offered and/or provided to NQDC plan sponsors, relating to company-sponsored programs that allow participants to delay receiving income on a pre-tax basis. Deferrals of the participants are deemed to be invested in the funds listed in their NQDC plan. Participants do not actually own any shares of the investment options they select. We provide services to certain of these plan sponsor clients as further described in this brochure. Services Offered to Clients and Their Participants: Advisor Managed Portfolio Services (“AMPS”) Advisor Managed Portfolios are asset allocation portfolios designed for use by plan participants in non-qualified deferred compensation plans administered by Mullin TBG Insurance Agency Services, LLC (“MTBG”) or Empower Annuity Insurance Company ("EAIC”), formerly named Prudential Retirement Insurance and Annuity Company. They are offered as a group of five portfolios based on risk tolerance – conservative, moderate, moderate growth, growth and aggressive. These portfolios 5 | P a g e are stand-alone deemed investment options that utilize mutual funds and/or variable insurance subaccounts. AMPS provide participants with asset allocation and diversification through a single deemed investment strategy; in addition, the funds may also include investments not currently offered in their plan. Participants have access to fact sheets which provide descriptions of the portfolios and the target allocation of underlying funds. Participants may select portfolios as a deemed investment option as with any other plan deemed investment option and are offered online risk tolerance questionnaires to assist them in selecting a portfolio. Generally, ECM has full investment discretion and provides oversight to these portfolios, which enables ECM to make changes to the portfolios as it deems necessary. Typically, ECM does not need the approval of the plan sponsor to make any allocation or underlying fund manager changes in the portfolios. The target asset allocation for the portfolios is set annually and the portfolios are reviewed and rebalanced periodically as needed. If an outside advisor selects the investments to be utilized in a plan or if a client instructs ECM to utilize only those investments offered to plan participants, ECM will have discretion over the allocation percentages for those selected investments only; ECM will not allocate any amounts to investments

that are not offered in the plan. Generally, we recommend investments registered under the Investment Company Act of 1940 (the “1940 Act”), which is limited to publicly traded mutual funds and closed-end funds. ECM does not provide recommendations for alternative investments such as hedge funds, private equity or other non-registered investments not covered under the 1940 Act. In some circumstances, we may allocate to a General Account of an insurance company. Investment Consulting Services We offer various investment consulting services to plan sponsors of NQDC plans, including the following:
• Advising plan sponsors in the development of a menu of deemed investment options for their participants.
• Providing plan sponsors non-discretionary investment advice, due diligence, monitoring and periodic performance reporting of their deemed investments and/or informally funded assets.
• Providing asset allocation and/or fund mapping advice to plan sponsors in the management of their informally funded assets.
• Developing investment policy statements for plan sponsors. Services Offered to Our Affiliates: Administrative Services Related to the Use of Third-Party Models ECM provides administrative services to its affiliate, MTBG regarding MTBG’s clients’ use of model portfolios managed by third-party investment advisers (those unaffiliated with MTBG or ECM). As directed by the relevant third-party adviser, ECM will administer the asset allocation and fund fulfillment model for deferred compensation plans for which MTBG acts as recordkeeper. In offering these services, we are not providing investment advice. 6 | P a g e Services No Longer Sold but Utilized by Certain Clients and Their Participants: Guarantee+ Services Guarantee+ is a service offered to plan sponsors who desire to offer lifetime income benefits as part of their NQDC plan through a variable annuity provided by an affiliated insurance company. The services described below are offered for plans administered by our affiliates MTBG and EAIC, and generally involve non-investment advisory activities. Services provided to participants include:
• Availability for current contract holders to speak with an investment adviser representative about the investments available within the contract. The Guarantee+ option is provided in connection with plans utilizing Pruco Life Insurance Company or Pruco Life Insurance Company of New Jersey annuity contracts. ECM does not review or compare annuities or guaranteed minimum withdrawal benefits of non-affiliated insurers nor do we recommend a particular annuity. Additionally, we only accommodate one annuity per person. Deferred Compensation Investment Advice Services ECM provides investment advice to participants of MTBG’s and EAIC’s NQDC plan sponsor clients regarding their participation in the NQDC plan only. Components of this service include the following:
• Risk Tolerance Assessment: A participant is asked a series of questions by an investment adviser representative to help the participant determine his/her risk profile as it relates to the participant’s plan balance.
• Investment Recommendations: ECM provides the participant an investment recommendation regarding his/her deemed investments in the plan. The investment recommendation does not include and is not designed to include other investments in the participant’s investment portfolio including, but not limited to, other retirement plans or programs, such as a company sponsored 401(k) plans, brokerage accounts, and individual retirement accounts.
• Separation of Service: Upon leaving employment, a participant may discuss his/her specific financial situation regarding the distribution and investment of his/her plan balance with an investment adviser representative. While giving investment advice to the participants, an investment adviser representative may recommend that participants invest in Advisor Managed Portfolios. The participants are made aware that if they choose to invest in Advisor Managed Portfolios, the standard fee assessed by ECM is 25 bps (0.25%). The participant can only invest in Advisor Managed Portfolios if his/her employer offers the service to its employees. Participants may also choose not to invest in Advisor Managed Portfolios, but rather model their own portfolio utilizing the investment options in their existing plan. Our Assets Under Management: As of December 31, 2022, assets under management for this service, which includes deemed values in Non-Qualified Deferred Compensation plans, were as follows: Discretionary: $ 805,815,414. Nondiscretionary: $ 468,917,771.