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affiliates. In other cases,the investment options may make third party payments described below. When this occurs,AAG's
<br /> affiliates may receive additional compensation as a result of AAG's recommendations or allocations.These forms of additional
<br /> affiliate compensation are:
<br /> ❑ Proprietary investment funds. AAG's affiliates offer proprietary investment funds, and AAG may recommend or
<br /> allocate your assets to our affiliates'proprietary investment funds,including proprietary mutual funds and collective
<br /> investment trusts. These proprietary investment funds generate additional investment management fees to AAG's
<br /> family of companies.This is because AAG's affiliates provide investment management services to the proprietary fund
<br /> for services like administering, managing, and supervising these funds. For example, a plan participant using the
<br /> Services will pay advisory fees to AAG and indirectly to GWCM if Great-West Funds are included in the retirement
<br /> plan investment options,and AAG recommends an allocation to a Great-West Funds product.The fees paid to GWCM
<br /> for management of the Great-West Funds are included in the fund share price.
<br /> ❑ Proprietary insurance products.AAG's parent company,GWLA,offers proprietary insurance products for investment.
<br /> AAG may recommend or allocate your assets to different types of GWLA insurance products and funding agreements.
<br /> The majority of GWLA insurance products are annuity contracts that are structured either as a "generalaccount"
<br /> product or as a"separate account"product. If you invest in a general account product,which is an insurance product
<br /> backed by the general account of an insurance company, AAG's affiliates generate revenue by retaining
<br /> spread (which is the difference between actual earnings on contracts offered by the insurer),and the crediting rate declared
<br /> and guaranteed by the insurer through the contract. AAG's affiliates may also receive different types of fee income if you
<br /> invest in the general account or separate account products,and other third-party payments associated with investments held
<br /> in the separate account.
<br /> ❑ Third Party Payments. AAG's affiliates may receive payments from other firms,non-proprietary investment funds or
<br /> products,or providers,such as revenue sharing payments,in connection with the investments made pursuant to our
<br /> recommendation or investment management.
<br /> Conflicts related to increased use and promotion of the Services.
<br /> ❑ Increased advisory fee income. AAG's representatives may recommend that you use the Services. If you enroll in
<br /> certain Services,AAG will earn additional compensation.
<br /> ❑ Increased affiliate fee income. When you use the Services,AAG may recommend you increase contributions or utilize
<br /> other savings or investment strategies. AAG's affiliates provide a bundle of recordkeeping,trust,custody,brokerage,
<br /> investment and other related services to retirement plans and to IRA products. If you pay for these related services
<br /> through an arrangement where our affiliates charge a direct fee,AAG's affiliates may receive additional fees for these
<br /> services.These additional fees result from AAG's recommendations,because you may contribute,invest,or transact
<br /> in more assets with AAG's family of companies.
<br /> ❑ Representative Compensation. AAG has authorized GWFS, an affiliate of AAG, and its licensed agents and registered
<br /> representatives who are Empower Retirement employees (collectively referred to as "Agents")to solicit, refer and
<br /> market AAG's services. In addition to their salary,Agents may earn bonus compensation based upon engaging plan
<br /> sponsors to offer AAG's services. Other Agents and AAG representatives may be indirectly compensated through
<br /> bonus compensation, in addition to their salary,for communication,education and/or assisting participants to enroll
<br /> in AAG's Services. Compensation paid to Agents or AAG representatives does not increase the fees paid by the plan,
<br /> plan sponsor, participants and/or account holders. The incentive compensation an AAG representative receives
<br /> depends on position type, but generally is calculated based on Empower Retirement and/or GWLA profitability and
<br /> the achievement of individual performance goals that consider factors unrelated to an account holder's adoption of
<br /> investment products or services offered through Empower Retirement.
<br /> Agents and AAG representatives' individual performance goals and their related incentive compensation is based on a
<br /> combination of factors including the number and quality of customer engagements during the measurement period and the
<br /> amount of customer assets retained as result of the engagements. The rate of incentive compensation considers the total
<br /> amount of retained or accumulated assets,compared with the monthly asset goal,as determined by AAG on a periodic basis.
<br /> The asset goal is generally set on an annual basis and may differ by product or account type.Additional factors include certain
<br /> qualitative factors,such as leadership,teamwork,client experience,quality and efficiency of client interactions,and adherence
<br /> to corporate policies and regulatory standards.
<br /> AAG's affiliates may receive payments from other firms,non-proprietary investment funds or products,or providers,such
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