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Managed Account Service Under the MA service,participant/account holder assets in the investment options are monitored,rebalanced and reallocated on a periodic(approximately quarterly)basis by AAG, based on Morningstar Investment Management's software program.On an annual basis, based on the individual's birth date,those enrolled in the MA service will receive an Annual Kit containing an account update and forecast statement. Morningstar Investment Management updates the capital market assumptions underlying their methodology used to construct the asset classes, at least annually, then makes changes to the portfolio allocations,as necessary.The portfolios are also monitored on a regular basis on current portfolio allocations and adjustments are made as necessary. Reporting to Clients Participants/account holders enrolled in the MA service receive a MA Welcome Kit shortly after enrollment and an account update at least annually. Participants/account holders enrolled in OA can review their accounts and generate their own reports at any time. Individuals are encouraged to update significant changes to their personal information or make changes to investment options online, or via the appropriate toll-free customer service number. In addition, all individuals receiving Services are provided quarterly account statements generated by the plan's recordkeeper. Item 14—Client Referrals and Other Compensation AAG does not pay cash or other compensation to outside solicitors for referrals to the Empower Premier IRA. AAG may pay cash compensation or referral fees to unaffiliated firms for soliciting and referring plan sponsors and their participants to enroll in AAG's Services. Any compensation paid by AAG for solicitation activities is pursuant to a written agreement and is paid in compliance with applicable law. AAG has authorized GWFS, an affiliate of AAG, and its licensed agents and registered representatives who are Empower Retirement employees (collectively referred to as "Agents") to solicit, refer and market AAG's services. In addition to their salary,Agents may earn bonus compensation based upon engaging plan sponsors to offer AAG's services. Other Agents and AAG representatives may be indirectly compensated through bonus compensation, in addition to their salary, for communication, education and/or assisting participants to enroll in AAG's Services. Compensation paid to Agents or AAG representatives does not increase the fees paid by the plan,plan sponsor,participants and/or account holders. Agents and AAG representatives' individual performance goals and their related incentive compensation is based on a combination of factors including the number and quality of customer engagements during the measurement period and the amount of customer assets retained as result of the engagements. The rate of incentive compensation considers the total amount of retained or accumulated assets,compared with the monthly asset goal,as determined by AAG on a periodic basis. The asset goal is generally set on an annual basis and may differ by product or account type. Additional factors include certain qualitative factors,such as leadership,teamwork,client experience,quality and efficiency of client interactions,and adherence to corporate policies and regulatory standards. Item 15-Custody AAG does not maintain actual custody of its clients'cash,bank accounts,or securities.Pursuant to Rule 206(4)-2 of the Advisers Act as amended,AAG is deemed to have constructive custody with respect to certain client funds and securities.This is because an affiliated party is the custodian and directed or discretionary trustee of certain retirement plan accounts. In addition to annual audits,these accounts,are subject to surprise custody verifications by an independent public accountant each year,as required by Rule 206(4)-2. If applicable, AAG's clients receive periodic account statements (at least quarterly) from their custodian and should carefully review these statements.Certain clients may have assets held by unaffiliated custodians. item 16—Investment Discretion AAG provides discretionary investment management services for those plan participants/account holders who enroll and participate in the MA service;AAG does not offer or engage in discretionary investment services for either OIG or OA. The MA service is a professional,flexible asset management program that utilizes data from the methodologies and proprietary software program developed and employed by its IFE, Morningstar Investment Management.To provide the MA service to plan participants and IRA holders, AAG retains discretionary authority over the allocation of available investment options 18