Empower Advisory Group LLC

Item 5 — Fees and Compensation
Online Advice - Advisory Fees and Compensation:
There is no separate fee for OA.
Professional Management Program – Advisory Fees and Compensation:
Fees for PMP are negotiable on a plan sponsor-by-sponsor basis. Generally, Members in PMP pay EAG, on a
periodic basis, usually quarterly, in arrears, based on a percentage of assets managed in their retirement
plan account (up to 0.60%, typically declining for account balances greater than $100,000). The initial fee
schedule may be reduced depending upon the various option(s) selected by the plan sponsor for its
participants. Fees are subject to change and EAG may offer certain plan sponsors or Members discounted
fees or other promotional pricing.
Payment of Fees:
Fees for service setup may be assessed to the plan sponsor, the plan, or participants prior to the Services
being available for Member enrollment. Service setup fees may also be assessed if changes are made to the
plan. When adopting the Services, plan sponsors determine if these fees will be paid by the plan sponsor,
the plan, or Members. Annual platform fees may be invoiced to the client upon the Services being available
for enrollment and thereafter on the anniversary date of establishing the Services for the plan.
Additional Fees and Expenses:
Members invested in mutual funds, separate accounts, collective investment alternatives and other
investments may be subject to other fees, typically imposed by such investments. Fees, such as fund
operating expenses or redemption fees, may be imposed at the investment company level. Information
about the fees imposed by specific investment choices is available in the fund prospectuses or offering
memoranda for the securities. EAG may allocate Member assets to funds or investment alternatives with
these additional fees or costs. All securities transactions that occur as a result of the Services provided by
EAG, as described in this Brochure, are executed by Empower Financial Services, Inc. (EFSI), for which EFSI

may receive compensation in the form of 12b-1 fees and other compensation from mutual fund companies
and from the other investments that may be available as investment options.
A Member will pay advisory fees to EAG for PMP. Additional investment management fees are paid to ECM
if Empower Funds are included among the available investment options within a Member’s plan. The fees
paid to ECM are for management of the Empower Funds; these management fees are included in the fund
share price.
EAG and EFSI representatives may recommend that you use the Services. If you elect to use PMP, EAG will
earn additional compensation in the form of advisory fees. Also, EAG and EFSI representatives are eligible
for incentive compensation (including bonus payments), in addition to their salary, for communicating with,
educating and/or enrolling plan participants in the Services. The incentive or bonus compensation an EAG
or EFSI representative receives depends on position type, but generally is calculated based on Empower’s
profitability and the achievement of individual performance goals that may include factors unrelated to the
adoption of investment products or services offered through Empower or EAG, such as the Services. See
Item 10 and Item 14 for additional detail regarding these compensation arrangements and conflicts of
interest

Item 7 — Types of Clients
EAG is engaged by plan sponsor clients to provide investment advice to Members in their retirement plans for
which Empower provides recordkeeping services. Members typically must be considered residents of the
United States, the U.S. Virgin Islands, Guam, or Puerto Rico. The plan sponsor may apply additional
restrictions for participation due to plan or regulatory requirements. A Member account must have at least
$5 to receive the initial investment advice transaction.
EAG may also be engaged by individuals to provide investment advisory services within or alongside EAG’s
other advisory services and products, such as an Empower Premier IRA, an Empower Premier Investment
Account, Personal Strategy and Personal Strategy+ Advisory Services, Core Managed Account Advisory
Services, or certain brokerage accounts.
Item 8 — Method of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis and Investment Strategies:
FEA provides the analysis and investment strategies used in the OA and PMP Services. FEA utilizes proprietary
software to develop individualized recommendations for the allocation of assets within individual retirement
plan accounts. The methodology is designed to provide personalized and diversified investment
recommendations for Members, considering variables such as time horizon to retirement, risk tolerance,
outside assets and other personal circumstances. The methodology may also provide calculations for
retirement plan installment distribution amounts.
Methodology Overview:
FEA’s investment philosophy is guided by certain basic principles, including:
•   Developing diversified portfolios that feature a range of asset classes and market sectors;
•   Utilizing holdings that strike a balance between those that are the most cost-effective and those that we
    forecast may offer added return;
•   Maintaining investment strategies, and often individual investments, longer term;

•   Strategically reallocating investments as conditions warrant and as goals, time frames or other material
    realities of Members change; and
•   Periodically rebalancing as needed to ensure long-term commitment to overall strategies and allocation
    targets.
On a Member level, FEA’s recommended or managed portfolio allocations are driven by many factors. Some
of the key factors include:
•   Member investment objectives (i.e., growth, income, or a combination);
•   Member risk tolerance;
•   Member circumstances (time horizon, pensions, other household investments, state of residence, etc.);
•   Available investment securities within Member accounts; and
•   Forward-looking models of securities’ risk expected returns, and correlations.
FEA’s approach may also be informed by certain established academic research, such as Modern Portfolio
Theory and returns-based style analysis, as well as by established discoveries in behavioral finance.
Although FEA may recommend more frequent trading or holding assets short-term in certain circumstances,
frequent and/or short-term trading strategies are generally avoided. Based on that, it is anticipated that the
primary advice will reflect strategies geared towards consistent and long-term strategies and holding
periods. At times, however, there may be reasons to effect changes within an account. Reasons for
reallocations to new or different allocations, or for tweaking existing portfolios, may include:
•   Client-driven: Changes in Member objectives, preferences or data may necessitate a revised target
    allocation.
•   Rebalancing: When an asset category or particular investment product has experienced a material
    appreciation or decline in value beyond the assigned relative percentage for that asset category or
    investment product, the extra amount may be sold, and the proceeds invested in asset categories or
    investment products that have not appreciated as much or have declined in percentage.
•   Updated assessment of forward-looking returns, risks, and correlations: FEA regularly updates its risk and
    return models, which may affect its assessment of prospects at the level of macroeconomic factors, asset
    classes, and/or individual investments. These updates may lead to revised target allocations in Member
    accounts.
Consistent with its fiduciary duties, FEA’s policy is to exercise high levels of care and prudence in making and
implementing investment decisions for Member accounts. FEA typically employs validation tests and
operational, oversight and quality control procedures. However, FEA relies on a significant amount of data
from multiple sources and cannot guarantee that all relevant data are free from error. Certain data are
regularly presented to Members who are responsible for informing EAG of any inaccuracies in a timely
manner.
The methods of analysis and investment strategies applied to services offered to Members through the
workplace depend in part on their stated goals. For Members on the growth objective, the program
recommends portfolio allocation that is designed to maximize expected returns in a manner consistent with
the Member’s stated risk level. For Members on the income objective, the program recommends a portfolio
allocation designed to provide steady payouts in retirement in line with the Member’s needs, stated risk
tolerance and time horizon, among other factors.

Due to algorithms and the statistical nature of FEA’s process, a number of potential portfolios will satisfy
FEA’s criteria for an appropriate investment strategy and allocation. The optimal set of portfolios that offer
the highest expected return for various levels of risk is often referred to as the “efficient frontier.” The
efficient frontier is not a line, but instead is a thin band of portfolios with varying allocations. The portfolio
that is selected for implementation is the product of optimization enhancements developed by FEA, which
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