Description of Advisory Firm
EAG has been a registered investment adviser under the Advisers Act since 2000. EAG is also registered in
all 50 states, the District of Columbia, Virgin Islands, Guam, and Puerto Rico. EAG offers investment
management and advisory services to plan sponsors of employer-sponsored retirement plans such as 401(a),
401(k), 403(b) and 457 plans, including government entities and their participants, and to all account holders
of the Empower Premier IRA (IRA holder or account holder). EAG does not choose the investments offered
in employer-sponsored retirement plans or IRAs. EAG-serviced plans receive recordkeeping services through
Empower Retirement, LLC (Empower), the recordkeeping entity affiliated with EAG. EAG also offers
investment management services to individuals and to retail brokerage account holders. EAG’s sub-advisory
relationship with FEA does not currently provide for investment management and advisory services to IRA
holders, individuals or retail brokerage account holders. More information about EAG’s services, including
an applicable brochure, can be obtained by contacting EAG at the number provided on the cover page of this
Brochure or by visiting EAG’s website at:
www.empower.com/eag.
EAG is a wholly owned subsidiary of Empower Services Holdings US, LLC, (ESH US) a holding company
domiciled in the State of Delaware. ESH US is owned by Empower Annuity Insurance Company of America
(EAICA). EAICA is a direct, wholly owned subsidiary of Empower Holdings, LLC (EHL), a Delaware holding
company. EHL is a direct wholly owned subsidiary of Great-West Lifeco U.S. LLC (Lifeco U.S.) and an indirect
wholly owned subsidiary of Great-West Lifeco Inc. (Lifeco), a Canadian holding company. Lifeco is a
subsidiary of Power Financial Corporation (Power Financial), a Canadian holding company with substantial
interests in the financial services industry. Power Corporation of Canada (Power Corporation), a Canadian
holding and management company, has voting control of Power Financial. The Desmarais Family Residuary
Trust has voting control of Power Corporation, through a group of private holding companies it controls.
Types of Services Discussed in this Brochure:
As part of its sub-advisory relationship with FEA, EAG provides non-discretionary investment advisory
services through an online service called Online Advice (OA) and discretionary investment advisory services
through the Professional Management Program, Professional Management Program with the Income+
feature, and Professional Management Program with Income Beyond Retirement, all of which are referred
to as Professional Management Program (PMP or Professional Management) (collectively, the Services).
Participants that enroll in one of the advisory service programs are referred to as “Members.” Plan Sponsors
or other entities who engage EAG to provide services are referred to as “Clients.”
FEA can also advise with respect to collective trusts and insurance products if a plan sponsor includes those
products with the investment lineup.
There is no guarantee provided by any party that participation in any of the advisory services will result in
a profit.
Financial Engines Advisors, L.L.C.
FEA is a registered investment adviser, wholly owned by Edelman Financial Engines, LLC, and is not affiliated
with EAG or any company that is affiliated with EAG. FEA is headquartered in Santa Clara, California. A copy
of FEA’s Form ADV Brochure may be obtained at either
www.edelmanfinancialengines.com or
http://www.adviserinfo.sec.gov. FEA utilizes proprietary software to develop individualized
recommendations for allocation of assets within Member accounts. The methodology is designed to provide
personalized and diversified investment recommendations for Members. Procedurally, FEA considers a
variety of inputs, including desired retention of company stock (up to 20%), risk preference, asset class
exposure limitations, assets held outside the plan and desired retirement age. FEA may also take into
consideration certain client holdings outside the retirement plan as part of its analysis where Members
provide such information.
1. Online Advice
OA is a non-discretionary service for Members to get objective advice. Members who choose to
receive this service are responsible for implementing OA’s personalized recommendations within
their retirement plan accounts and checking back regularly to get updated personalized
recommendations. Neither FEA nor EAG places transactions on behalf of the Members or monitors
the personalized recommendations OA Members receive.
OA includes the following features:
• A forecast of the potential future account value or the potential annual retirement income
based on the information provided by a Member;
• A forecast of the likelihood that a Member will achieve their self-reported retirement income or
account value goals, taking into consideration the total household investment portfolio as
known by the service;
• Recommendations among the investment alternatives available in the employer-sponsored
retirement plan (generally mutual funds, other investment company securities, and sometimes,
one or more equity securities issued by the plan sponsor); and
• Guidance on savings rate and retirement age.
Members may use OA as frequently as they choose to monitor progress toward their retirement
goals, receive forecasts and investment recommendations, and access available educational
content. OA updates the investment information of most mutual funds and stocks in plan accounts
daily. Members are responsible for periodically revisiting OA to:
• Update account information to reflect changes in holdings, including purchases and sales of
investments;
• Update personal information (including retirement goals) to reflect changes in personal or
financial circumstances; and/or
• Review any updates regarding changes to Member’s account value or forecast.
The failure of an OA Member to review and periodically update their personal and financial
information can materially affect the value of the investment advisory services provided.
For certain Members, some account information may be updated automatically when the Member
revisits OA if EAG has an established electronic communications link with the Member’s plan sponsor
and/or plan provider or other financial institution. For manually added and linked accounts, EAG
relies on Members to provide ongoing and updated data either by logging in to refresh a linked
account or by manually updating accounts that were added manually.
OA offers Members investment analysis of mutual funds and stocks in the form of Scorecards. The
Scorecards for individual equity securities depict the relative risk and historical performance of the
individual stock.
2. Professional Management Program (PMP)
PMP is a discretionary service, which personalizes each portfolio to fit the Member’s needs and
the specific characteristics of the plan by using the program’s methodology and information
provided by the Member. PMP simulates thousands of scenarios to find an investment mix
designed to optimize the Member’s opportunity for potential future value, including the goal of
providing steady income through retirement.
PMP may include any of the following features:
• A Retirement Plan or similar document showing how EAG will manage and allocate the account,
e.g., the portfolio allocation target, suggestions regarding the Member’s savings and a forecast
regarding their likelihood of achieving their self-articulated retirement goals;
• Periodic portfolio monitoring;
• Quarterly Retirement Updates outlining, among other things, how the account is performing
against goals;
• Phone access to investment adviser representatives via a toll-free number as well as online
account access; and
• Non-discretionary investment advice on retirement accounts outside the plan account.
PMP Members authorize EAG to direct the plan provider to execute transactions on a discretionary
basis to move toward the account’s allocation target (and to otherwise manage the account) without
prior approval of each transaction. PMP is generally made available to plan participants in a defined
contribution plan through an agreement between EAG and the plan and/or the sponsoring
employer. That agreement will specify
the methods of enrollment into PMP for eligible plan
participants, which may include:
• An “opt-in” method of enrollment where a retirement plan participant actively elects to enroll in
PMP;
• An “opt-out” method of enrollment where eligible plan participants are automatically enrolled
in PMP in accordance with plan or plan sponsor specifications, with the ability to withdraw at
any time without penalty. With this type of enrollment, Professional Management may be
designated as a qualified default investment alternative (“QDIA”), as permitted under the
Employee Retirement Income Security Act (ERISA); or
• Some combination of both methods, as determined by the plan or plan sponsor and as agreed to
by EAG.
Members who enroll in PMP grant EAG the discretionary authority to determine an allocation target
for the plan account based upon a variety of inputs provided to EAG. This discretionary authority
allows EAG to allocate the Member’s plan account among the menu of investment alternatives that
have been selected by the plan or plan sponsor, typically excluding any brokerage window option (if
applicable) or other plan-restricted investments. To allow EAG to provide PMP, the plan provider
supplies information about each Member and the plan account. PMP Members may provide
additional information to the program concerning a variety of inputs, including desired retention of
company stock (up to 20%), risk preference, asset class exposure limitations, assets held outside the
plan and desired retirement age. EAG may also take into consideration certain Member holdings
outside the retirement plan as part of its analysis where the Member provides such information.
The program determines an investment strategy and an allocation target based on a Member’s
current age, an assumption about the retirement age, the available investments for the account, any
pension plan information provided, an assumption about risk tolerance that is based on the
Member’s current age and assumed retirement age, the Member’s current portfolio allocation, and
any additional information provided by the Member. Additional information provided by the Member
may modify these parameters.
During the period following enrollment, the program determines how to transition the account
toward the allocation target and directs EAG regarding allocation of the account (which may include
transfer or exchange directions). The program provides directions regarding new contributions to
the account. Accounts of then-current PMP Members newly eligible for the Income+ or Income
Beyond Retirement feature of PMP may also be subject to a similar transition. Certain plan
participants, such as plan sponsor “insiders,” as defined under applicable regulations, and non-U.S.
participants in plans, may not be eligible for PMP.
Income Beyond Retirement and Income+:
Members may also, if their plan sponsor has elected to offer this service, access PMP’s Income+ or
Income Beyond Retirement features. These services provide certain portfolio management and
income payout options to retirees and near retirees from their 401(k) or similar plan account. For
those who elect this feature, PMP manages the Member’s portfolio to balance between income and
growth, seeking to protect the ability of the account to generate future income. Income Beyond
Retirement also seeks to provide additional flexibility for a Member by allowing Members to
determine the portion of their account to be managed on a standard “growth” objective and,
separately, the portion to be managed on an “income” objective. Income+ and Income Beyond
Retirement seek to manage investments and to create payouts that could continue into the
Member’s early 90s. Upon request, in addition to managing the investment allocations in such
accounts, EAG will work with the plan provider to calculate and facilitate withdrawals from the
Member’s plan account post-retirement.
Members pay no additional fees for the Income Beyond Retirement or Income+ features, and, if
available, they can transition to an Income Beyond Retirement/Income+ portfolio either
automatically (upon eligibility) or at their request (as defined, in part, by the agreement between
EAG and the relevant plan sponsor). An account balance is maintained for an optional out-of-plan
annuity purchase. An in-plan annuity need not be included in a plan’s investment lineup for a plan
sponsor to offer Income+ to its participants. While EAG may provide general educational information
regarding an out-of-plan annuity, it does not sell or distribute annuities and does not receive any
compensation related to out-of-plan annuity purchases. Affiliates of EAG may offer or sell annuities.
Income Beyond Retirement and Income+ availability is subject to establishment of certain data
connectivity arrangements between EAG and the applicable plan provider and is subject to
applicable retirement plan provisions related to plan withdrawals.
As part of the suite of advisory services available to participants in employer-sponsored retirement
plans described above, EAG may provide plan participants with a “Retirement Evaluation.” The
Retirement Evaluation is delivered in printed or electronic format to specified plan participants who
have not enrolled in the service, and is designed to communicate some (or all) of the following
information:
• A summary of the current value of the plan participant’s plan account;
• A forecast of how much the plan account investments, and other investments that plan
participants submit for analysis, might be worth at retirement;
• Whether a change is suggested to the plan participant’s contribution rate, their portfolio’s risk
and diversification, unrestricted company stock holdings, target date usage, and/or investment
style and allocation;
• Investment proposals; and
• A projection of the plan participant’s annual income at retirement, based on how much the plan
account, Social Security, and certain other benefit accounts could provide.
Once enrolled in PMP, Members delegate certain account management functions to EAG. As a result
of the delegation, the following functions are no longer available to the Member: functionality for
fund-to-fund transfers, fund change allocations, and/or the rebalancing tool. Members in PMP retain
full-inquiry access to their account and may still request certain services from Empower, including
approval for loans and distribution withdrawals.
EAG does not manage restricted investments or Member assets held in a brokerage account under
the retirement plan. However, the disclosure of any of these types of investments held by the
Member may influence the recommendations provided on the managed assets. .
Termination of Services:
Members may cancel their participation in PMP at any time by calling EAG at the toll-free customer service
number.
After cancellation of PMP, the Member will have the ability to make allocation and investment option
changes to their account, usually within one to two business days following cancellation, subject to applicable
investment restrictions. Accordingly, the plan participant’s asset allocation will remain the same as
established in PMP at the time of the cancellation, unless and until the plan participant affirmatively and
unilaterally changes their asset allocation after cancellation.
Information:
The use and storage of any information, including, without limitation, an individual’s personal and non-
public information, account number, password, identification, portfolio information, and account balances
is provided at the individual’s sole risk and responsibility. The individual is responsible for providing and
maintaining the communications equipment (including personal computers and modems) and telephone or
other services required for accessing and using electronic or automated services. The individual is also
responsible for all communications service fees and charges incurred when accessing these services. EAG
shall not bear any responsibility for either errors or failures caused by the malfunction of any computer,
communication systems, computer viruses, or related problems that may be associated with the use of the
services.
Assets Under Management:
With respect to the services provided by EAG, as of December 31, 2023:
Discretionary investment management among all services
(including the PMP described herein) in the amount of:
$116,502,429,608
Non-discretionary investment advisory services among all
services in the amount of:
$17,776,730,753
Total discretionary and non-discretionary investment
management and advisory services in the amount of:
$134,279,160,181