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ADVISED ASSETS GROUP, LLC (AAG) Form CRS Customer Relationship Summary, June 12, 2020

Introduction AAG is registered with the Securities and Exchange Commission (SEC) as an investment adviser. Investment advisory services and fees differ, and it is important for you to understand these differences. Investor.gov/CRS offers free and simple tools to research firms and financial professionals. It also provides educational materials about broker-dealers, investment advisers and investing. What Our advisory services include our asset allocation services using mutual funds and exchange investment traded funds (ETFs), managed portfolios from third-party investment managers and financial services and planning. Our website (listed below) provides a detailed description of our advisory services. advice can Depending on which service you select, our asset allocation services are either you “nondiscretionary” (we recommend investments to you, and you make the ultimate decision provide me? regarding the purchase or sale of investments) or “discretionary” (we make the ultimate investment decisions without your signoff). Available investments may include mutual funds, exchange-listed equity securities, commingled funds, separate accounts and insurance company-guaranteed investment contracts. The third-party managers (subadvisers) we engage will invest your account on a discretionary basis using mutual funds, ETFs and other securities. When you enroll in one of our discretionary services, we (or a subadviser) will maintain discretion to invest your assets among the available investment options for so long as you remain enrolled in the service. We monitor your advisory assets and may rebalance periodically (approximately quarterly). Our financial planning services are limited to preparation of a customized financial assessment only, based on the information you provide, and do not include ongoing monitoring. You must meet certain investment minimums to open some of our advisory accounts (as described on our website). For additional information about our investment advisory services, please see Form ADV, Part 2A brochures (Items 4 and 7). Conversation Starters: 1) Given my financial situation, should I choose an investment advisory service? Why or why not? 2) How will you choose investments to recommend to me? 3) What is your relevant experience, including your licenses, education and other qualifications? What do these qualifications mean? What fees The primary fees you pay are “asset-based” — a percentage of the assets invested in your will I pay? advisory account according to the fee schedule in your advisory agreement with us and as described on our website. This means that the more assets you invest in your account, the more you will pay in fees, and therefore we have an incentive to encourage you to increase your advisory account assets. In some of our advisory accounts, our advisory fee includes most transaction costs and fees paid to a broker-dealer or custodian that has custody of your assets. Depending on the level of trading in your account, these fees may cost more or less than if you were separately paying for each transaction. Our clients typically pay the advisory fee each quarter. Please see your advisory agreement for the payment frequency that applies to your account. You may also pay miscellaneous fees that your account’s record-keeper or custodian may charge, including wire fees, transfer fees, bank charges and other fees, as well as fees and expenses that are included in the expense ratios of certain of your investments (such as mutual funds, separate accounts, collective investment trusts and other investments). You will pay fees and costs whether you make or lose money on your investments. Fees and costs will reduce any amount of money you make on your investments over time. Please make sure you understand what fees and costs you are paying. For additional information about our advisory fees, please see Form ADV, Part 2A brochures (Item 5) and advisory agreements. Conversation Starter: Help me understand how these fees and costs might affect my investments. If I give you $10,000 to invest, how much will go to fees and costs, and how much will be invested for me?

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What are When we act as your investment adviser, we have to act in your best interest and not put our your legal interests ahead of yours. At the same time, the way we make money creates some conflicts obligations with your interests. You should understand and ask us about these conflicts because they to me when affect the recommendations we provide you. The conflicts may include: acting as my • Proprietary products: Our affiliates will earn fees, compensation and other benefits when investment you invest in a product that we or our affiliates advise, manage or sponsor, such as affiliated adviser? How mutual funds, stable value funds, CITs and annuity contracts. Based on which service you else does select, you may pay advisory fees to us and indirectly to our affiliate investment managers if your firm the funds and other products (stable value funds, collective investment funds or other make investments) they manage are included in your available investment options. Any fees paid to money, and our affiliated investment managers for management of the mutual funds are included in the what fund share price. conflicts of • Third-party payments: Our affiliates receive payments from third-party product sponsors and interest do managers (or their affiliates) when we recommend or sell certain products. you have? • Revenue sharing: Certain managers and sponsors (or their affiliates) share the revenue they earn with our affiliates when you invest in certain of their investment products (primarily mutual funds). Ultimately, the revenue and other benefits that AAG or its affiliates receive from these conflicts may influence the products and services that we recommend. For additional information about our conflicts of interest, please see Form ADV, Part 2A brochure. Conversation Starter: How might your conflicts of interest affect me, and how will you address them? How do your In addition to their salary, some of our representatives earn bonus compensation for financial communication, education and/or assisting participants to enroll in our services (bonuses do professionals not increase the fees you or your retirement plan (if appropriate) pays). For more information, make please review our Form ADV, Part 2A brochure. money? Do your Yes. Visit investor.gov/CRS for a free and simple search tool to research us and our financial financial professionals. Conversation Starter: As a financial professional, do you have any disciplinary professionals history? For what type of conduct? have legal or disciplinary history? Additional We are providing this summary, as required by SEC rules, as part of discussions that may Information encompass a variety of accounts and account types. Please consider this summary, and the more detailed information we will provide you, as part of these discussions. If you would like additional, up-to-date information or a copy of this disclosure, please call us at 855-756-4738. To find additional information about our advisory services, go to advisedassetsgroup.com. Conversation Starter: Who is my primary contact person? Is he or she a representative of an investment adviser or a broker-dealer? Who can I talk to if I have concerns about how this person is treating me?

RO1142347-0520

LDOM/MANUAL/SR 8901748 PIRADD 04/27/21 740501-01 MANUAL/DAES/SR 8451718 MANUAL/DAES/SR NO_GRPG/JTYL 8125207Page 4 of 34 PIRADD 11/19/2008/14/2006/14/2004/23/202007/28/20 740501-01 Page 4 NO_GRPG/TNERof 36 SR SR 7872631/MANUAL 8094021/MANUAL 7794901/MANUAL Page 12 of 38 PagePagePage 37 11 ofof 3827 Empower Premier IRA Traditional Individual Retirement Account (IRA) Disclosure Documents and Agreements

Thank you for your interest in our Empower Premier IRA Solution. Enclosed are the following documents for your review:

x IRA Fee Schedule x Advised Assets Group (AAG) Advisory Services Agreement1 x IRA Custodial Agreement x IRA Disclosure Statement x Great-West Privacy Policy x Business Continuity Plans x FINRA Investor Education and BrokerCheck Notification

For onlineonlineonline summary summarysummary prospectusesprospectuses prospectuses andand and otherother other importantimportantimportant important informationinformationinformation information aboutaboutabout about thethethe investment investmentinvestment the investment options optionsoptions options please pleaseplease visit visitpleaseour websiteourour visit websitewebsite atour www.empowerinvesting.com/ira atwebsiteatat www.empower-retirement.com/ira www.empower-retirement.com/ira www.empower-retirement.com/irawww.empower-retirement.com/ira at www.ira.gwrs.com. You. You may.. YouYou .may Youobtain may obtainmaymay statutoryobtain obtainobtain statutory statutory prospectuses statutorystatutory prospectuses prospectuses prospectusesprospectuses from yourfrom from regis- yourfromfromyour yourregisteredtered registeredrepresentative. representative.representative. representative. Please Please considerPlease Please consider consider the consider investment the investmentthe the investment objectives,investmentinvestment objectives, objectives, risks,objectives,objectives, risks, fees andfeesrisks, risks,risks, expensesand fees feesfees expenses andandand carefully expensesexpenses carefully before carefullyinvesting.before investing. before beforeYou can investing. Youinvesting. make can makeor You change You canor changecan make investment make investmentor changechange or elections change investmentinvestmentelections atinvestment any at electionstimeanyelections time afterelections after atatyour anyany your account at timetime accountany afterafter istime established yourisyour establishedafter accountaccount your by isaccountloggingby established logging on is toestablishedon your byto youryourlogginglogging account account accountby onon atlogging totowww.empowerinvesting.com/ira atatyouryour www.empower-retirement.com/irawww.empower-retirement.com/ira on accountaccount to your at ataccount www.empower-retirement.com/irawww.empower-retirement.com/ira at www.ira.gwrs.com or by callingor by calling1-866-317-6586. or by1-866-317-6586. or orcalling byby callingcalling 1-866-317-If an 1-866-1-866-investment If an investment election has not been made at the time your account is funded your assets will automatically be 317-6586.6586.electioninvestment If has an Ifelection notaninvestment investmentbeen has made not election beenelection at the madehas time has not at your not thebeen been accounttime made yourmade is accountat funded at the thethe time timeistimeyour funded your youryourassets account youraccountaccount will assets automatically is isis funded fundedfundedwill automatically youryour be invested assetsassets be in invested in the Great-WestGreat-West Government Money Market Fund, a default investment2 option. For information willthe Great-Westautomaticallyautomatically Governnment bebe investedinvested Money inin the the Great-WGreat-West MarketBancorp Fund,est Bank Money a defaultMaster Market investmentDemand Fund, aAccount option.default 2 For,investment a informationdefault investmentoption. about For this informationoption.about this For investment about information this optioninvestment about please this option click ilinvestment hereplease.$SHUVRQDOLGHQWL¿FDWLRQQXPEHU 3,1 ZLOOEHPDLOHGWR\RX A clickpersonal lioption k hhere pleaseidenti. A personal¿cation click l identi idnumberhere.¿ cation A(PIN) personal number will be identificationmailed (PIN) willto you be option.investmentsoon after For your informationoption application please about click is processed.this here investment. A personal This optionPIN identi will please givecation you click number access here (PIN). toA personalyour will account be mailedidenti via¿ cation tothe you website number soon afteror mailednumbersoon after to (PIN) you your soonwill application be after mailed you is application processed.to you soon isThis processed.after PIN you will application giveThis youPIN accesswill is giveprocessed. to your your access account This to PIN via your thewill account websitegive you via2 or (PIN) will2 be mailed to you soon after you application is processed. This PIN will give you access to your theyourphone website application. or phone is processed.2 This PIN will give you3 access to your account via the website or phone . accessaccount to via your the accountwebsite viaor phonethe website3. or phone . Please note, an investment in a money market fund is not insured or guaranteed by the Federal Deposit Insurance Corporation or any other government agency. Although the fund seeks to preserve the value of your investment at $1.00 per share, it is possible to lose money by investing in the fund.

Empower Retirement is required to ask if you want to add a trusted contact person to your account. By providing contact information for a trusted contact person(s), you authorize us to disclose account information to your trusted contact person(s) under the following circumstances: to address possible ¿QDQFLDO H[SORLWDWLRQ WR FRQ¿UP WKH VSHFL¿FV RI \RXU FXUUHQW FRQWDFW LQIRUPDWLRQ KHDOWK VWDWXV RU WKH LGHQWLW\RIDQ\OHJDOJXDUGLDQH[HFXWRUWUXVWHHRUKROGHURIDSRZHURIDWWRUQH\RUDVRWKHUZLVHSHUPLWWHG E\),15$5XOH )LQDQFLDO([SORLWDWLRQRI6SHFL¿HG$GXOWV 7RDGGDWUXVWHGFRQWDFWSHUVRQWR\RXU account, please call us at 1-866-317-6586. Owner Acknowledgments: I understand that Service Provider and Custodian are required to comply with the regulations and requirements RIWKH2I¿FHRI)RUHLJQ$VVHWV&RQWURO'HSDUWPHQWRIWKH7UHDVXU\ ³2)$&´ $VDUHVXOW6HUYLFH3URYLGHUDQG &XVWRGLDQFDQQRWFRQGXFWEXVLQHVVZLWKSHUVRQVLQDEORFNHGFRXQWU\RUDQ\SHUVRQGHVLJQDWHGE\2)$&DV DVSHFLDOO\GHVLJQDWHGQDWLRQDORUEORFNHGSHUVRQ)RUPRUHLQIRUPDWLRQSOHDVHDFFHVVWKH2)$&ZHEVLWHDW KWWSZZZWUHDVXU\JRYDERXWRUJDQL]DWLRQDOVWUXFWXUHRI¿FHV3DJHV2I¿FHRI)RUHLJQ$VVHWV&RQWURODVS[ ,QDGGLWLRQWKH86$3$75,27$FWRIUHTXLUHVDOO¿QDQFLDOLQVWLWXWLRQVWRREWDLQYHULI\DQGUHFRUG LQIRUPDWLRQWKDWLGHQWL¿HVHDFKSHUVRQZKRRSHQVDQDFFRXQW,PXVWSURYLGHP\QDPHDGGUHVVGDWHRI ELUWKDQGRWKHULQIRUPDWLRQWKDWZLOODOORZ6HUYLFH3URYLGHUDQG&XVWRGLDQWRLGHQWLI\PH,I,IDLOWRSURYLGH DOORIWKHUHTXLUHGLQIRUPDWLRQSURFHVVLQJRIP\DSSOLFDWLRQZLOOEHGHOD\HGXQWLODOORIWKHLQIRUPDWLRQKDV EHHQSURYLGHG,XQGHUVWDQGWKDW6HUYLFH3URYLGHUDQG&XVWRGLDQPD\XVHDWKLUGSDUW\LQIRUPDWLRQ SURYLGHUIRUYHUL¿FDWLRQSXUSRVHVDQGRUDVNIRUDFRS\RIP\GULYHU¶VOLFHQVHRURWKHULGHQWLI\LQJGRFXPHQWV

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Compliance With Internal Revenue Code,XQGHUVWDQGWKDWWKHPD[LPXPDPRXQW,PD\FRQWULEXWHWR WKLV,5$LVGHWHUPLQHGXQGHUWKH,QWHUQDO5HYHQXH&RGH WKH&RGH ,XQGHUVWDQGLWLVP\UHVSRQVLELOLW\ WRPRQLWRUP\WRWDODQQXDOFRQWULEXWLRQVWRDQ\DQGDOO,5$VDQGWRHQVXUH,GRQRWH[FHHGWKHDPRXQW SHUPLWWHG,I,H[FHHGWKHFRQWULEXWLRQOLPLW,DVVXPHIXOOUHVSRQVLELOLW\IRUDQ\WD[SHQDOW\RUFRVWVWKDW PD\EHLQFXUUHG

Owner Email Address%\SURYLGLQJ6HUYLFH3URYLGHUZLWKP\HPDLODGGUHVVGXULQJWKLV$SSOLFDWLRQ 3URFHVV,DFNQRZOHGJHDQGDJUHHWKDW,DPUHVSRQVLEOHIRULPPHGLDWHO\QRWLI\LQJ6HUYLFH3URYLGHURI any changes to my email address and I indemnify and hold harmless Service Provider for any failure to GRVR,DJUHHWRUHFHLYHYLDWKHHPDLODGGUHVV,SURYLGHGHPDLOQRWLFHVUHJDUGLQJHOHFWURQLFGRFXPHQWV UHODWHGWRP\(PSRZHU5HWLUHPHQW,5$5RWKDFFRXQWLQFOXGLQJZLWKRXWOLPLWDWLRQDFFRXQWVWDWHPHQWV DFWLYLW\FRQ¿UPDWLRQVXSGDWHVWRP\DFFRXQWDJUHHPHQWVWD[DQGRUUHJXODWRU\QRWLFHVRUGLVFORVXUHV DQGDQ\RWKHUHOHFWURQLFGRFXPHQWVZKLFK6HUYLFH3URYLGHURULWVDI¿OLDWHVSURYLGHQRZDQGRULQWKH IXWXUH,XQGHUVWDQGWKDW,PD\HOHFWWRQRORQJHUUHFHLYHHOHFWURQLFGHOLYHU\RIGRFXPHQWVE\SURYLGLQJ QRWL¿FDWLRQWR6HUYLFH3URYLGHU

1 AAG’s1 AAG’s Form Form ADV ADV Part Part II isII availableis available free free of chargeof charge online on-line (click (click here here to view to )view or upon) or upon request request by calling by calling AAG atAAG 844-302-2448 - or writing or writing AAG AAG at 8515 at: 8515East Orchard Road, Greenwood Village, CO 80111. East Orchard Road, Greenwood Village, CO 80111.

32 Access to KeyTalkKeyTalk andand thethe websitewebsite may may be be limited limited or or unavailable unavailable during during periods periods of ofpeak peak demand, demand, market market volatility, volatility, systems systems upgra upgrades/maintenancedes/maintenance or otheror other reasons. reasons. The The account account owner owner is responsibleis responsible for for keeping keeping your your PIN PIN confidential. con¿ dential. Please Please contact contact Great-West Retirement Retirement Solutions ResouCenterrce immediately Center if you immediatelysuspect any ifunauthorized you suspect use. any unauthorized use.

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Set-Up Fee $60$0 for initial deposits of $5,000 or less Transfer-In/Rollover-In Fee $0 OHVV WKDQ   $QQXDO$GPLQLVWUDWLRQ)HH LIDFFRXQWEDODQFHLVRU$0, if account balance is greater thanOHVV $30,0002 Transaction Fees $0 Asset Holding Fees $0 Account Closure Fee3 $0$50$75 Sales Load $0 Miscellaneous Fees Special Services, including but not limited to, wires, overnight delivery services, stop payments on checks, non-sufficient funds checks, and additional statement copies may be charged a separate fee. Advisory Services24 On-Line Investment Quarterly Annual Guidance Fee Fee No Fee No Fee

On-Line Investment Quarterly Annual Advice Fee Fee $6.25 $25

Managed Accounts Quarterly Annual Account Balance Fee Fee <$100,000 0.1375% 0.55% Next $150,000 0.1125% 0.45% Next $150,000 0.0875% 0.35% >$400,000 0.0625% 0.25%

Minimum Initial Investment5 $500.00$25,000$500

The Custodian and Service Provider reserve the right to change the Fee Schedule and Initial Investment, Distribution, and Account Balance Minimums upon 30 days’ written notice to the IRA owner.

1 I understand that funds may impose redemption fees on certain transfers, redemptions or exchanges if assets are held less than the period stated in the fund’s prospectus or other disclosure documents. I will refer to the fund’s prospectus) and/or disclosure documents for more information. 42 Managed account, guidance and advice services are offered by Advised Assets Group, LLC (AAG), and a federally registered investment adviser. More information can be found at www.adviserinfo.sec.gov,EERWVRQ$VVRFLDWHV,QFLVDUHJLVWHUHGLQYHVWPHQWDGYLVHUDQGLVQRWDI¿OLDWHGZLWK$$* its parent company Great-West Life & Annuity Insurance Company or any of its subsidiaries. Great-West Trust Company, LLC is a wholly owned subsidiary of Great-West Life & Annuity Insurance Company. 53 Certain Minimum exceptions Initial Investment may apply. Requirement may be waived for incoming rollover initiated due to mandatory distribution provisions under an eligible retirement plan. GWFS Equities, Inc. is a Member of the Securities Investor Protection Corporation (“SIPC”). You may obtain information about SIPC, including the SIPC brochure, by contacting SIPC. Securities Investor Protection Corporation 805 15th Street, N.W. Suite 800 Washington, D.C. 20005-2215 Email: [email protected] Tel: (202)371-8300 Information about SIPC is also available at www.sipc.org.

LDOM/MANUAL/SR 8901748 PIRADD 04/27/21 740501-01 MANUAL/DAES/SR 8451718 MANUAL/DAES/SR NO_GRPG/JTYL 8125207Page 7 of 34 PIRADD 11/19/2008/14/2006/14/2004/23/202007/28/20 740501-01 Page 7 NO_GRPG/TNERof 36 SR SR 7872631/MANUAL 8094021/MANUAL 7794901/MANUAL Page 12 of 38 PagePagePage 37 11 ofof 3827 Residents of the State of New York

Important Notice

Empower Premier IRA Default Investment Option

The Great-West Government Money Market Fund is the Empower Premier IRA default investment option (IRA Custodial Agreement §8.06) for Empower Premier IRA customers with an address of record in the State of New York*. Please review the Fund’s prospectus for information on the Fund.

Accordingly, information on and references to the Empower Guaranteed Income Fund as the default investment option in Empower Premier IRA documents and materials are not applicable to New York resident customers and are replaced with the Great-West Government Money Market Fund for New York customers. The Empower Guaranteed Income Fund is not available in the Empower Premier IRA to residents of the State of New York.

For information and materials on the Great-West Government Money Market Fund, access your account at www.www.empowerira.comempowerinvesting.com or call 866-317-6586 or call 866-317-6586 to speak to with speak an Empower with an Empower retirement retirement advisor. advisor.

* Address of record is determined when your Empower Premier IRA is established.

Carefully consider the investment option’s objectives, risks, fees and expenses. Contact Empower Retirement for a prospectus, summary prospectus for SEC registered products or disclosure document for unregistered products, if available, containing this information. Read each carefully before investing.

The Empower Guaranteed Income Fund is a general account group annuity contract or funding agreement issued by Great-West Life & Annuity Insurance Company, Corporate Headquarters: Greenwood Village, CO; or in New York, by Great-West Life & Annuity Insurance Company of New York, Home Office: New York, NY. The fund guarantees principal and credited interest for eligible participant-initiated withdrawals and transfers. Guarantees are subject to the terms and conditions of the contract and the claims-paying ability of the insurer. Depending on the terms of the contract, there may also be investment risks associated with certain plan sponsor actions, including, but not limited to, a termination of the contract that could result in a negative market value adjustment to the proceeds paid to the plan sponsor or an extended payment period.

RO1194899 6/1/2020

LDOM/MANUAL/SR 8901748 PIRADD 04/27/21 740501-01 MANUAL/DAES/SR 8451718 MANUAL/DAES/SR NO_GRPG/JTYL 8125207Page 8 of 34 PIRADD 11/19/2008/14/2006/14/2004/23/202007/28/20 740501-01 Page 8 NO_GRPG/TNERof 36 SR SR 7872631/MANUAL 8094021/MANUAL 7794901/MANUAL Page 12 of 38 PagePagePage 37 11 ofof 3827 Securities offered and/or distributed by GWFS Equities, Inc., Member FINRA/SIPC. GWFS is an af liate of Empower Retirement, LLC; Great- West Funds, Inc.; and registered investment advisers, Advised Assets Group, LLC and Personal Capital. This material is for informational purposes only and is not intended to provide investment, legal or tax recommendations or advice.

You could lose money by investing in a money market fund. Although the fund seeks to preserve the value of your investment at $1 per share, it cannot guarantee it will do so. An investment in the fund is not insured or guaranteed by the Federal Deposit Insurance Corporation or any other government agency. The fund’s sponsor has no legal obligation to provide financial support to the fund, and you should not expect the sponsor to provide financial support to the fund at any time.

LDOM/MANUAL/SR 8901748 PIRADD 04/27/21 740501-01 MANUAL/DAES/SR 8451718 MANUAL/DAES/SR NO_GRPG/JTYL 8125207Page 9 of 34 PIRADD 11/19/2008/14/2006/14/2004/23/202007/28/20 740501-01 Page 9 NO_GRPG/TNERof 36 SR SR 7872631/MANUAL 8094021/MANUAL 7794901/MANUAL Page 12 of 38 PagePagePage 37 11 ofof 3827 Disclosure Statement

For

Empower Guaranteed Income Fund

The Empower Guaranteed Income Fund (the “Fund”) is made available to the Empower Retirement IRA platform to fund the program (the “IRA Program” or “Program”) through a group funding agreement (the “Agreement”) issued by Great-West Life & Annuity Insurance Company to Great-West Trust Company, LLC , the provider of the Program and custodian of the Program assets.

Great-West Life & Annuity Insurance Company

Great-West Life & Annuity Insurance Company (the “Company”) certifies that Great-West Trust Company, LLC (and/or any successor trustee) is the custodian of the Program and the contract holder under the Agreement (the “Owner”), and that the Company holds the assets attributable to the Agreement in its general account. Pursuant thereto, the Company agrees to pay to the Owner on behalf of Program participants, as defined below, the interests hereinafter described, subject to the provisions of the Agreement. Owner or its designee is acting as the sponsor and administrator for the Program(s).

Account Holder

The account holder (“you,” or “Program Participant”) shall mean a participant in the IRA Program to whom interests in the Agreement are attributed. Your interest in the Agreement is computed and applied daily by Owner and will be provided to you, along with a list of your deposits, transfers and withdrawals, to and from the Fund, with your quarterly IRA Statement provided by Empower.

The Empower Guaranteed Income Fund

The Fund is the Program’s designated capital preservation option. The Agreement, as noted, supports the Fund, and is backed by the general account of the Company, which provides a guarantee of principal and interest.

Operation of the Fund

Deposits, Withdrawals and Transfers

Subject to any limitations required by the Internal Revenue Code, or any delays caused by temporary market disruptions, you may make deposits to, or effect transfers or withdrawals of all or partial amounts of your interest from, the Fund at any time. Program Participants will incur no charges, negative adjustments due to market changes, or penalties for such transfers or withdrawals; however, restrictions on transfers may be imposed for excessive trading activity. Your total interest in the Fund will be the “book value”, which shall mean all your

LDOM/MANUAL/SR 8901748 PIRADD 04/27/21 740501-01 MANUAL/DAES/SR 8451718 MANUAL/DAES/SR NO_GRPG/JTYL Page 8125207 10 of 34 PIRADD 11/19/2008/14/2006/14/2004/23/202007/28/20 740501-01 Page 10NO_GRPG/TNER of 36 SR SR 7872631/MANUAL 8094021/MANUAL 7794901/MANUAL Page 12 of 38 PagePagePage 37 11 ofof 3827 contributions, plus accrued interest, less transfers out and withdrawals taken. Deposits received in good order before 4 pm Eastern Time will be applied that business day (except for when the market is closed for holidays or as a result of any temporary market disruptions). Deposits received after 4 pm will be applied the next business day.

Notwithstanding the prior paragraph, the Company may at any time, restrict or refuse additional Deposits, in which case the Company and the Owner may mutually agree that Owner may offer a Competing Fund in its Program, subject to an Equity Wash, defined below under the Competing Funds section. The Company also may close the Fund to new Program Participants, upon 90 days’ advance written notice to Owner.

Competing Funds

Generally, no Competing Funds shall be permitted under the Program unless mutually agreed to by Company and Owner, or under certain circumstances (i.e., in the event of Fund termination over a book value settlement period, as described below). A Competing Fund is any of the following types of funds offered on the IRA platform:

(a) any fund with a known or periodically declared rate of interest;

(b) any money market fund;

(c) any bond fund with a duration of 3 years or less; or

(d) any investment option at any time offered under the Program that, unless otherwise agreed by Company, is a balanced fund that seeks to maintain 75% or more of its assets invested in investment grade U.S. fixed income assets that have a stated benchmark of less than three (3) years or long term objective of maintaining a duration of less than three (3) years; is a fund that has investment characteristics substantially similar or identical to the Fund; or is a fund that, in accordance with Company’s underwriting standards, Company has determined to be a Competing Fund.

If a Competing Fund is mutually agreed to, an “Equity Wash” provision must be in effect. An Equity Wash provision requires the Program Participant to first transfer any requested withdrawal amount to a non-competing fund and reside there for at least ninety (90) days prior to transferring the amount to a Competing Fund. If an Equity Wash provision is not feasible, then no Competing Fund will be permitted. The Owner will advise you if any Competing Fund becomes available.

Default option

Owner has selected the Fund as its default option for the Program, meaning that if you have not provided investment allocation instructions to Owner, the deposit will initially be swept into the Fund before being

LDOM/MANUAL/SR 8901748 PIRADD 04/27/21 740501-01 MANUAL/DAES/SR 8451718 MANUAL/DAES/SR NO_GRPG/JTYL Page 8125207 11 of 34 PIRADD 11/19/2008/14/2006/14/2004/23/202007/28/20 740501-01 Page 11NO_GRPG/TNER of 36 SR SR 7872631/MANUAL 8094021/MANUAL 7794901/MANUAL Page 12 of 38 PagePagePage 37 11 ofof 3827 allocated according to subsequent instructions you provide. You may choose to allocate all or a portion of your deposits to the Fund, or, alternatively, your Program advisor will make selections for you if you have elected a managed account program.

Guaranteed Minimum Interest Rate

The Fund offers a guaranteed minimum interest rate that is equal to 1.00% for the life of the Agreement.

Current or “Excess” Interest Credited Rate

The current or excess interest rate being credited to the Fund for any calendar year is posted on the IRA Program website. The excess rate that will apply for the following calendar year will be declared annually in advance by Company to Owner. The excess interest rate will never be less than the guaranteed minimum interest rate. Company will inform Owner at least 48 hours in advance of a change to the excess rate. Notification of such rate change will, in turn, be made available on the IRA Program website.

Fees and Expenses of the Fund

Any expenses incurred in operating the Fund, including fees for investment management, shall be reflected in the crediting rate. There are no explicit Fund charges to Program Participants, or penalties for withdrawals.

Amendment of the Agreement

The Agreement may be changed, modified or altered by mutual agreement in writing between the Owner and Company, without the prior approval of the Program Participants at any time. Owner will provide prompt notice of such changes to Program Participants.

Termination of the Fund

If either Owner or Company terminates the Fund, and provided either of the “book value settlement period” options is elected, Program Participants can continue to make deposits and effect withdrawals and transfers at book value during the book value settlement period. Depending upon the termination provision selected, either book value installment payments are made from the Company to the Owner over a period of five years prior to the date that the Company makes the final payment to Owner for distribution to Program Participants, or one lump sum book value payment is made by Company to Owner at the end of the five year book value settlement period. Company and Owner may mutually agree to permit the Program to offer a Competing Fund during the book value settlement period, subject to an Equity Wash provision, as described above in the Competing Funds section.

RO1175026-0520

LDOM/MANUAL/SR 8901748 PIRADD 04/27/21 740501-01 MANUAL/DAES/SR 8451718 MANUAL/DAES/SR NO_GRPG/JTYL Page 8125207 12 of 34 PIRADD 11/19/2008/14/2006/14/2004/23/202007/28/20 740501-01 Page 12NO_GRPG/TNER of 36 SR SR 7872631/MANUAL 8094021/MANUAL 7794901/MANUAL Page 12 of 38 PagePagePage 37 11 ofof 3827 ADVISED ASSETS GROUP, LLC ADVISORY SERVICES AGREEMENT Please read the following terms and conditions carefully before using or enrolling in any of the services described below. Your use of any service will signify your consent to be bound by the terms and conditions set forth in this Agreement. ABOUT US Advised Assets Group, LLC (“AAG”) is a registered investment adviser and wholly owned subsidiary of Great-West Life & Annuity Insurance Company (“Great-West”). AAG offers its services to retirement account recordkeepers for use by plan participants or to owners of an Empower Retirement Individual Retirement Account (“IRA”). Through these arrangements, AAG provides guidance, advisory, and management solutions to plan participants and IRA account holders. FEES FOR THE SERVICE Please see the Fee Supplement below for the specific fees for your service. IMPORTANT FOR RETIREMENT PLAN PARTICIPANTS Your plan sponsor or recordkeeper may have negotiated lower fees or different billing periods. Please review AAG's Form ADV Brochure and contact your plan sponsor or plan administrator to confirm your fees for Advisory Services and the applicable billing cycle. Retirement plan participants may also receive the Managed Account service for a trial period following your enrollment, after which the appropriate fee listed above will be assessed to your account. The type and duration of the trial period depends on your particular enrollment channel and the plan setup determined by your plan sponsor. Please contact your plan sponsor to determine if a trial period applies to your plan. You may contact your plan’s toll-free customer service number for the date of your Managed Account enrollment. Your acceptance of the terms and conditions of this Agreement constitutes your authorization for AAG to deduct the billing period fee. The fees are subject to change. AAG reserves the right to offer discounted fees or other promotional pricing. DESCRIPTION OF SERVICES AAG offers the following investment advisory services: Online Investment Guidance, Online Investment Advice, and Managed Account to retirement plan participants and to IRA account holders. Retirement plan participants may receive all or some of the services listed below as determined by the plan sponsor. If you are enrolled in multiple accounts with your employer, you must select the level of Advisory Service for each account. Please contact your plan’s toll-free customer service number for further details as to whether this applies to your account(s). Online Investment Guidance: Online Investment Guidance is geared toward users who wish to manage their own retirement accounts. Users are provided access to online guidance tools. Online Investment Advice: Online Investment Advice is geared toward users who wish to manage their own retirement plans while taking advantage of online guidance and investment advice. You are provided online guidance and investment advice for a personalized recommended investment portfolio. The recommended investment portfolio is based on information drawn from your account profile and from the investment options available to you. You may then implement the recommended investment portfolio and manage your retirement account online. AAG does not provide advice for, or recommend allocations of, individual stocks (including employer stock), self-directed brokerage accounts, guaranteed certificate funds, or employer-directed monies, or any other investment options that do not satisfy the methodology requirements of the Independent Financial Expert (“IFE”), even if they are available for investment in the plan. Managed Account: The Managed Account service is geared toward users who wish to have investment professionals select among the available investment options and manage their retirement accounts for them. You will receive a personalized investment portfolio that reflects your investment options and your retirement timeframe, life stages and overall financial picture, including assets held outside your account (if you elect to provide this information), which may be taken into consideration when determining the allocation of assets in your account. Generally, AAG will not provide advice for, recommend allocations of, or manage your outside accounts. Under the Managed Account service, AAG has discretionary authority over allocating your assets among the core investment options without your prior approval of each transaction. AAG is not responsible for either the selection or maintenance of the investment options available within your retirement account or IRA. If available in your account, AAG will not provide advice for, or recommend allocations of, individual stocks (including employer stock), self-directed brokerage accounts, guaranteed certificate funds, employer-directed monies, or any other investment options that do not satisfy the methodology requirements of the IFE, even if they are available for investment in the plan. Your balances in any of these investment options or vehicles may be liquidated, subject to your plan’s and/or investment provider’s restrictions. Managed Account assets in the core investment options will be monitored, rebalanced and reallocated periodically (approximately quarterly) by AAG, based on data resulting from the methodologies and software employed by the IFE, currently Morningstar Investment Management LLC (“Morningstar Investment Management”), to respond to market performance and to ensure optimal

NO_GRPG 574497/][GP19 STD MATOS ][04/19/21)( 740501-01 DOC ID: 631683041)( PIRADD 04/27/21 740501-01 LDOM/MANUAL/SRPage 3 of 8 8901748 Page 13 of 34 account performance over time. You will receive an account update statement annually and can update your personal information at any time by calling the plan’s toll-free customer service number or visiting the plan’s website. To determine which services are available to you, please refer to the communication materials provided by AAG or ask your plan sponsor.

INFORMATION FOR PARTICIPATION IN THE SERVICE Information Gathered to Provide the Service: You must provide all data that is necessary for AAG to perform its duties under this Agreement, including but not limited to: your date of birth, income, gender, and state of residence, which AAG may rely upon in providing the services to you. For each service described above, if the data supplied by you or your plan sponsor, if applicable, does not meet the methodology requirements, we will attempt to contact you for updated information. If this is not completed, your enrollment in the service may not be completed or may be terminated. If you participate in the Managed Account service, you will receive a Welcome Kit shortly after enrollment. You will also receive an Annual Kit each year, providing you with a detailed analysis of your account. Your Annual Kit will also confirm your personal data which is used to provide you with personalized account management. You are responsible for reviewing the Welcome and Annual Kits carefully and calling the plan’s toll free number immediately to update or correct any incorrect personal information. AAG will not be responsible for misallocation of assets or missed earnings due to incorrect personal information. You may provide updated information, at any time, regarding your retirement age, desired retirement income replacement, social security start date, other income and expenses, spousal and dependent information online or by calling the plan’s toll free number to speak to an investment adviser representative. The savings rate provided by your retirement plan recordkeeper may not include profit sharing, pensions or employer matches to your retirement plan(s). Please call the plan’s toll free number to verify these amounts. It is important that you update your personal data with AAG on a regular basis in order to ensure that your account management is suited to your needs and goals. ADDITIONAL INFORMATION FOR USERS OF THE SERVICE Methodology: The Advisory Services methodology is powered by Morningstar Investment Management. Morningstar Investment Management first builds stable, consistent asset allocation models at various risk levels. Based on Monte Carlo simulations of the user’s resources, liabilities, and human capital, an appropriate asset level portfolio is selected and a savings rate and retirement age are determined that best suits each user’s situation. The asset class level model portfolios are revisited annually. Investment options from the account’s menu are then selected to implement each asset-level model portfolio. These investment options are monitored and rebalanced periodically (approximately quarterly).

IMPORTANT: The projections or other information generated by the advisory service tool regarding the likelihood of various investment outcomes are hypothetical in nature, do not reflect actual investment results and are not guarantees of future results. Results may vary with each use and over time.

Additional Fees May Apply: Advisory Services fees do not include the fees and expenses charged by the investment options, including redemption fees. Redemption fees vary in amount and application by each applicable core investment option. It is possible that transactions in the Managed Account service may result in the imposition of a redemption fee on one or more investment options available in a plan. Additionally, any action undertaken by an individual who implements recommendations from Online Investment Advice or uses information provided through Online Investment Guidance may result in redemptions or other transaction fees. Any fees are deducted from the individual’s account balance. All securities transactions which occur as a result of the services provided by AAG are executed by GWFS Equities, Inc. (“GWFS”) for which GWFS may receive compensation in the form of 12b- 1 fees or other compensation from mutual fund companies or from the other investments available under the plan or available through the IRA. A participant will pay advisory fees for the Managed Account service and to Great-West Capital Management, LLC (“GWCM”) if Great- West Funds are included in the retirement plan investment options. The fees paid to GWCM for management of the Great- West Funds are included in the fund share price. Assets Managed: If you elect the Managed Account service, your eligible account balance will be allocated to the Managed Account service. You may not invest in other core investment options while also participating in the Managed Account service. Once enrolled in the Managed Account service, you will no longer be able to make investment allocation changes to your account online, via paper, or through your existing toll-free customer service number. This includes functionality for fund-to-fund transfers, changing fund allocations, or utilization of dollar cost averaging and/or rebalancer. Once enrolled, you retain full inquiry access to your account. You may also change contributions, take distributions and provide other updates to your personal information. Full access will be restored to your account as soon as administratively feasible after you cancel participation in the Managed Account service. Cancellation: You may cancel participation in the Managed Account service at any time online or by calling your plan’s toll-free customer service number. Once you have opted-out of the Managed Account service, you are responsible for managing your own account. In addition, your allocations and account balance (if applicable) will have already been established according to the

NO_GRPG 574497/][GP19 STD MATOS ][04/19/21)( 740501-01 DOC ID: 631683041)( PIRADD 04/27/21 740501-01 LDOM/MANUAL/SRPage 4 of 8 8901748 Page 14 of 34 Managed Account allocations. You will need to initiate your own allocation changes and/or transfers if you wish to change your investment allocations from the Managed Account allocations. Initial Allocation for IRA Account Holders: Upon receipt of your initial deposit or rollover into your IRA, your funds will be allocated to the default investment option specified in your custodial agreement. AAG will re-allocate your funds to your asset allocation portfolio as soon as administratively feasible after receiving your initial deposit. DISCLAIMERS AAG uses reasonable care, consistent with industry practice, in providing services to you. AAG, your plan sponsor and/or the recordkeeper or IRA account provider, as applicable, do not guarantee the future performance of your account or that the investments we recommend will be profitable. Investment return and principal value will fluctuate with market conditions, and you may lose money. The investments we may recommend or purchase for your account, if applicable, are subject to various risks, including, without limitation; business, market, currency, economic, and political risks. AAG does not provide advice for, recommend allocations of, or manage individual stocks (including employer stock), self-directed brokerage accounts, guaranteed certificate funds, or employer- directed monies, even if they are available for investment in your plan or IRA. We do not select the investment options available for investment in your plan or IRA. By recommending allocations among the available investment options, we are not endorsing the selection of particular investment options available in your plan or IRA. AAG, the plan sponsor and/or the recordkeeper or IRA account provider, as applicable, will not be liable to you for any loss caused by (1) our prudent, good faith decisions or actions, (2) following your instructions, or (3) any person other than AAG or its affiliates who provides services for your account. Neither AAG nor your plan sponsor will be liable to you for any losses resulting from your disclosure of your personal information or your PIN number to third parties even if the purpose of your disclosure is to enable such person to enroll you in, or cancel your enrollment in, Advisory Services. AAG is not responsible for voting proxies for the securities in your account. We do not guarantee that the services or any content will be delivered to you uninterrupted, timely, secure, or error-free. TO THE MAXIMUM EXTENT PERMITTED BY LAW, AAG DISCLAIMS ALL REPRESENTATIONS AND WARRANTIES, EXPRESS OR IMPLIED, WITH RESPECT TO THE SERVICES AND THE SERVICE CONTENT, AND ALL INFORMATION DERIVED FROM THEM, INCLUDING, BUT NOT LIMITED TO, IMPLIED WARRANTIES OF MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE, QUALITY, TIMELINESS, ACCURACY, AND IMPLIED WARRANTIES ARISING FROM COURSE OF PERFORMANCE OR COURSE OF DEALING. IN ADDITION, AAG DOES NOT WARRANT THAT THE SERVICE OR CONTENT CONTAINED IN IT WILL BE UNINTERRUPTED, ERROR FREE, FULLY AVAILABLE AT ALL TIMES OR THAT ANY INFORMATION OR OTHER MATERIAL ACCESSIBLE THROUGH THE SERVICE IS FREE OF ERRORS OR OTHER HARMFUL CONTENT. LIMITATION OF LIABILITY YOU UNDERSTAND THAT IN NO EVENT WILL THE PLAN SPONSOR, IF APPLICABLE, AAG OR ITS OFFICERS, DIRECTORS, SHAREHOLDERS, PARENTS, SUBSIDIARIES, AFFILIATES, EMPLOYEES, CONSULTANTS, AGENTS, LICENSORS OR ANY DATA PROVIDER BE LIABLE FOR ANY CONSEQUENTIAL, PUNITIVE, INCIDENTAL, SPECIAL OR INDIRECT DAMAGES, LOSS OF BUSINESS REVENUE OR LOST PROFITS, WHETHER IN AN ACTION UNDER CONTRACT, NEGLIGENCE OR ANY OTHER THEORY EVEN IF WE ARE ADVISED OF THE POSSIBILITY OF SUCH. INDEMNIFICATION You agree to indemnify, defend and hold harmless AAG and its officers, directors, shareholders, parents, subsidiaries, affiliates, employees, consultants, agents and licensors, your employer, the plan administrator and/or recordkeeper, plan sponsor, plan trustees, plan fiduciaries, their agents, employees, and contractors or IRA provider, as applicable, from and against any and all third party claims, liability, damages and/or costs (including but not limited to reasonable attorneys' fees) arising from your failure to comply with this Agreement, the information you provide us, your infringement of any intellectual property or other right of a third party, or from your violation of applicable law. GENERAL PROVISIONS AAG acknowledges that, as a registered investment adviser, it owes a fiduciary duty to participants with respect to investment advice it provides. AAG may not assign this Agreement (within the meaning of the Investment Advisors Act of 1940 ("Advisors Act")) without your consent. You may not assign this Agreement. Unless otherwise agreed to in your plan’s agreement with AAG, if applicable, this Agreement is entered into in Denver, Colorado and governed by and construed in accordance with the laws of the State of Colorado, without regard to its conflict of law provisions. You agree that proper forum for any claims under this Agreement shall be in the courts of the State of Colorado for Arapahoe County or the United States District Court, District of Colorado. If you are a participant in a retirement plan, please contact your plan sponsor to determine proper venue for actions brought under this agreement. The prevailing party shall be entitled to recovery of expenses, including reasonable attorneys’ fees. This agreement constitutes the entire Agreement between you and AAG with respect to the subject matter herein. You agree that any amounts owed to you arising under this contract shall incur interest no less than the current Federal Funds rate plus 3% per annum. If for any reason a provision or portion of this Agreement is found to be unenforceable, that provision of the Agreement will be enforced to the maximum extent permissible so as to affect the intent of the parties, and the remainder of this Agreement will continue in full force and effect. No failure or delay on the part of AAG in exercising any right or remedy with respect to a breach of

NO_GRPG 574497/][GP19 STD MATOS ][04/19/21)( 740501-01 DOC ID: 631683041)( PIRADD 04/27/21 740501-01 LDOM/MANUAL/SRPage 5 of 8 8901748 Page 15 of 34 this Agreement by you shall operate as a waiver thereof or of any prior or subsequent breach of this Agreement by you, nor shall the exercise of any such right or remedy preclude any other or future exercise thereof or exercise of any other right or remedy in connection with this Agreement. Any waiver must be in writing and signed by AAG. All terms and provisions of this Agreement will survive termination of the Agreement. This Agreement will automatically terminate upon termination of your plan’s agreement with AAG, or upon termination of your plan’s service agreement with its recordkeeper, if applicable. Nothing in this Agreement shall be construed to waive compliance with the Advisors Act, the Employee Retirement Income Security Act of 1974, as amended ("ERISA"), if applicable, or any applicable rule or order of the Department of Labor under ERISA. AAG shall not be liable for any delay or failure to perform its obligations hereunder if such delay or failure is caused by an unforeseeable event beyond its reasonable control, including without limitation: act of God; fire; flood; earthquake; labor strike; sabotage; fiber cut; embargoes; power failure; lightning; suppliers failures; act or omissions of telecommunications common carriers; material shortages or unavailability or other delay in delivery; government codes, ordinances, laws, rules, regulations or restrictions; war or civil disorder, or acts of terrorism. AAG reserves the right to modify this Agreement at any time. You agree to review this Agreement periodically so that you are aware of any such modifications. Your continued participation in Advisory Services shall be deemed to be your acceptance of the modified terms of this Agreement. This Agreement shall inure to the benefit of AAG's successor and assigns. Registered representatives of GWFS may provide wholesaling, direct sales, enrollment and/or communication services to retirement plans and their participants or account holders for which AAG may also provide its services. For this service, GWFS may receive fees either from the plan or from the investment provider (fund families). Participants/account holders in the Online Investment Advice or the Managed Account services may have allocations in the investment options that result in GWFS receiving compensation from the investment options. Allocations in the investment options are solely determined and based on Morningstar Investment Management’s software and not determinations made by AAG. The compensation paid by AAG to Morningstar Investment Management for Morningstar Investment Management’s proprietary software advice program does not vary based on the allocations made or recommended by Morningstar Investment Management. Because Morningstar Investment Management is unaffiliated with AAG and GWFS, AAG does not believe there is a conflict of interest. All securities transactions which occur as a result of the services provided by AAG as described in AAG’s Form ADV Part 2A are executed by GWFS for which it may receive compensation in the form of 12b-1 fees or other compensation from mutual fund companies or from the other investments that may be available as investment options. However, in all instances, AAG’s affiliation with GWFS is disclosed. INTELLECTUAL PROPERTY All content provided as part of Advisory Services, including without limitation names, logos, methodologies, and news or information provided by third parties, is protected by copyrights, trademarks, service marks, patents, or other intellectual property and proprietary rights and laws ("Intellectual Property") and may constitute trade secrets, as defined by applicable law. All such Intellectual Property is the property of their respective owners and no rights or licenses are granted to you as a result of your participation in Advisory Services. ABOUT ADVISED ASSETS GROUP, LLC AAG, a wholly owned subsidiary of Great-West Life & Annuity Insurance Company, is a registered investment adviser with the Securities and Exchange Commission. Since its inception, AAG has focused on establishing, refining and continually improving the process of investment planning for plan sponsors, plan participants and IRA account holders. By blending best practice investment approaches with personalized plan data and leading industry knowledge, AAG aspires to create effectively-built, diversified retirement solutions that maximize outcomes for plan participants while minimizing fiduciary risk to plan sponsors. Additional information about the services provided by AAG may be found in AAG’s Form ADV Part II, which is available free of charge on-line at www.adviserinfo.sec.gov or upon request by calling your plan’s toll free number listed in your communication materials or writing AAG at: 8515 East Orchard Road, Greenwood Village, Colorado 80111. Interest in Participant Transactions. AAG, its officers and employees may purchase securities for their own accounts and these securities may be the same as those recommended to, or invested for, you (e.g., shares of the same mutual fund). ABOUT MORNINGSTAR INVESTMENT MANAGEMENT AAG has teamed with Morningstar Investment Management, a recognized industry leader in asset allocation and investment analytics tools, to provide the underlying investment advice and portfolio management methodology that will power Advisory Services. Morningstar Investment Management is a leading independent provider of asset allocation, manager selection, and portfolio construction services. The company leverages its innovative academic research to create customized investment advisory solutions that help investors meet their goals. AAG reserves the right to replace the IFE in its sole discretion and without your approval. AAG will notify you of any fee changes resulting from the IFE being replaced. In the event AAG terminates its relationship with the current IFE and is unable to contract with a suitable replacement IFE, this Agreement shall automatically terminate upon written notice from AAG. Your investment line up and Managed Account allocations may include mutual funds issued by Great-West Funds and Putnam Investments or insurance products issued by Great-West, its parent company, or Great-West Life & Annuity Insurance Company of New York (“GW-NY”). Great-West Funds, Putnam Investments, their respective fund managers and GW-NY are affiliates of

NO_GRPG 574497/][GP19 STD MATOS ][04/19/21)( 740501-01 DOC ID: 631683041)( PIRADD 04/27/21 740501-01 LDOM/MANUAL/SRPage 6 of 8 8901748 Page 16 of 34 AAG. Morningstar Investment Management or its affiliates may provide asset allocation services for AAG affiliates for which fees may be paid. For the Great-West Funds offered within the Managed Account service, Morningstar Investment Management has agreed to waive these fees. For more information, please see the applicable fund prospectus. For retirement plan participants, the investment options in your retirement plan are selected solely by the plan or plan sponsor. ACCEPTANCE OF TERMS AND CONDITIONS OF ADVISORY SERVICES AGREEMENT If you agree to the terms and conditions set forth herein, you will be enrolled in the service you requested that is offered under Advisory Services. Your acceptance of the terms and conditions shall signify your consent to be bound by the applicable provisions of this Agreement, as they relate to the Online Investment Guidance, Online Investment Advice, or the Managed Account service. Please note that upon enrollment in the Managed Account service, any currently initiated transfers or transactions will be cancelled, unless the market has already closed for the day. If you do not agree to the terms and conditions set forth herein, you will not be enrolled in the service you requested that is offered under Advisory Services.

NO_GRPG 574497/][GP19 STD MATOS ][04/19/21)( 740501-01 DOC ID: 631683041)( PIRADD 04/27/21 740501-01 LDOM/MANUAL/SRPage 7 of 8 8901748 Page 17 of 34 SUPPLEMENT A FEES FOR THE SERVICE Fees for each service are shown below. The chart below reflects the applicable billing period and annual fee amount. Online Advice Quarterly Fee Annual Fee $0.00 $0.00

My Total Retirement Participant Account Balance Quarterly Fee Annual Fee < $100,000.00 0.1375% 0.55% Next $150,000.00 0.1125% 0.45% Next $150,000.00 0.0875% 0.35% > $400,000.01 0.0625% 0.25% For example, if your account balance subject to My Total Retirement is $50,000.00, the maximum annual fee is 0.55% of the account balance. If your account balance subject to My Total Retirement is $500,000.00, the first $100,000.00 will be subject to a maximum annual fee of 0.55% (quarterly 0.1375%), the next $150,000.00 will be subject to a maximum annual fee of 0.45% (quarterly 0.1125%), the next $150,000.00 will be subject to a maximum annual fee of 0.35% (quarterly 0.0875%), and any amounts over $400,000.00 will be subject to a maximum annual fee of 0.25% (quarterly 0.0625%). For example, the maximum quarterly fee for an account balance less than $100,000.00 (subject to maximum annual fee of 0.55%) would be 0.1375% quarterly, as demonstrated above.

Service fees will generally be debited from your account based on your Service Provider's Form ADV Brochure and the terms of service and billing period agreed upon by your plan sponsor; however, if you cancel participation in the service, the fee will be based on your participation in the service through the date of cancellation for asset-based fees. For dollar-based fees, the full billing period rate will be assessed notwithstanding the date of cancellation. If your plan terminates its agreement with your Service Provider or with its recordkeeper, the fee will be debited based on your participation in the service through the date of such termination. The fee you are charged depends on the plan you participate in, and in certain instances, the fees charged may actually be lower than the fee depicted.

NO_GRPG 574497/][GP19 STD MATOS ][04/19/21)( 740501-01 DOC ID: 631683041)( PIRADD 04/27/21 740501-01 LDOM/MANUAL/SRPage 8 of 8 8901748 Page 18 of 34 INDIVIDUAL RETIREMENT CUSTODIAL ACCOUNT AGREEMENT Form5305ͲAundersection408(a)oftheInternalRevenueCode. FORM(Rev.April2017) The depositor named on the application is establishing a Traditional determined in the year of the spouse’s death and reduced by individualretirementaccountundersection408(a)toprovideforhisor oneforeachsubsequentyear,or,ifdistributionsarebeingmade herretirementandforthesupportofhisorherbeneficiariesafterdeath. overtheperiodinparagraph(a)(iii)below,oversuchperiod. The custodian named on the application has given the depositor the (ii) the designated beneficiary is not the depositor’s surviving disclosurestatementrequiredbyRegulationssection1.408Ͳ6. spouse, the remaining interest will be distributed over the beneficiary’s remaining life expectancy as determined in the Thedepositorhasassignedthecustodialaccountthesumindicatedon yearfollowingthedeathofthedepositorandreducedbyone theapplication. for each subsequent year, or over the period in paragraph Thedepositorandthecustodianmakethefollowingagreement: (a)(iii)belowiflonger. ARTICLEI (iii)thereisnodesignatedbeneficiary,theremaininginterestwill Except in the caseof a rollover contributiondescribed insection402(c), be distributed over the remaining life expectancy of the 403(a)(4),403(b)(8),408(d)(3),or457(e)(16),anemployercontributionto depositor as determined in the year of the depositor’s death a simplified employee pension plan as described in section 408(k) or a andreducedbyoneforeachsubsequentyear. recharacterizedcontributiondescribedinsection408A(d)(6),thecustodian (b) If the depositor dies before the required beginning date, the willacceptonlycashcontributionsupto$5,500peryearfortaxyears2013 remaininginterestwillbedistributedinaccordancewithparagraph through2017.Forindividualswhohavereachedtheageof50bytheend (i) below or, if elected or there is no designated beneficiary, in oftheyear,thecontributionlimitisincreasedto$6,500peryearfortax accordancewithparagraph(ii)below. years 2013 through 2017. For years after 2017, these limits will be (i) Theremaininginterestwillbedistributedinaccordancewith increasedtoreflectacostͲofͲlivingadjustment,ifany. paragraphs(a)(i)and(a)(ii)above(butnotovertheperiodin ARTICLEII paragraph (a)(iii), even if longer), starting by the end of the The depositor’s interest in the balance in the custodial account is calendaryearfollowingtheyearofthedepositor’sdeath.If, nonforfeitable. however, the designated beneficiary is the depositor’s surviving spouse, then this distribution is not required to ARTICLEIII begin before the end of the calendar year in which the 1. No part of the custodial account funds may be invested in life depositorwouldhavereachedage70½.But,insuchcase,if insurance contracts, nor may the assets of the custodial account be thedepositor’ssurvivingspousediesbeforedistributionsare commingled with other property except in a common trust fund or required to begin, then the remaining interest will be commoninvestmentfund(withinthemeaningofsection408(a)(5)). distributedinaccordancewithparagraph(a)(ii)above(butnot overtheperiodinparagraph(a)(iii),eveniflonger),oversuch 2. Nopartofthecustodialaccountfundsmaybeinvestedincollectibles spouse’s designated beneficiary’s life expectancy, or in (withinthemeaningofsection408(m))exceptasotherwisepermitted accordance with paragraph (ii) below if there is no such by section 408(m)(3), which provides an exception for certain gold, designatedbeneficiary. silver,andplatinumcoins,coinsissuedunderthelawsofanystate,and certainbullion. (ii) The remaining interest will be distributed by the end of the calendaryearcontainingthefifthanniversaryofthedepositor’s ARTICLEIV death. 1. Notwithstanding any provision of this agreement to the contrary, the 4. If the depositor dies before his or her entire interest has been distributionofthedepositor’sinterestinthecustodialaccountshallbe distributed and if the designated beneficiary is not the depositor’s made in accordance with the following requirements and shall survivingspouse,noadditionalcontributionsmaybeacceptedinthe otherwise comply with section 408(a)(6) and the regulations account. thereunder, the provisions of which are herein incorporated by reference. 5. Theminimumamountthatmustbedistributedeachyear,beginning withtheyearcontainingthedepositor’srequiredbeginningdate,is 2. The depositor’s entire interest in the custodial account must be, or knownasthe“requiredminimumdistribution”andisdeterminedas begin to be, distributed not later than the depositor’s required follows. beginning date, April 1 following the calendar year in which the depositorreachesage70½.Bythatdate,thedepositormayelect,ina (a) Therequiredminimumdistributionunderparagraph2(b)forany manner acceptable to the custodian, to have the balance in the year,beginningwiththeyearthedepositorreachesage70½,is custodialaccountdistributedin:(a)Asinglesumor(b)Paymentsover the depositor’s account value at the close of business on aperiodnotlongerthanthelifeofthedepositororthejointlivesof December 31 of the preceding year divided by the distribution thedepositorandhisorherdesignatedbeneficiary. period in the uniform lifetime table in Regulations section 1.401(a)(9)Ͳ9.However,ifthedepositor’sdesignatedbeneficiary 3. Ifthedepositordiesbeforehisorherentireinterestisdistributedto ishisorhersurvivingspouse,therequiredminimumdistribution himorher,theremaininginterestwillbedistributedasfollows: forayearshallnotbemorethanthedepositor’saccountvalueat (a) Ifthedepositordiesonoraftertherequiredbeginningdateand: the close of business on December 31 of the preceding year divided by the number in the joint and last survivor table in (i) the designated beneficiary is the depositor’s surviving spouse, Regulations section 1.401(a)(9)Ͳ9. The required minimum the remaining interest will be distributed over the surviving distribution for a year under this paragraph (a) is determined spouse’s life expectancy as determined each year until such using the depositor’s (or, if applicable, the depositor and spouse’sdeath,orovertheperiodinparagraph(a)(iii)belowif spouse’s)attainedage(orages)intheyear. longer.Any interestremainingafter thespouse’s deathwill be distributed over such spouse’s remaining life expectancy as

LDOM/MANUAL/SR 8901748 PIRADD 04/27/21 740501-01 MANUAL/DAES/SR 8451718 MANUAL/DAES/SR NO_GRPG/JTYL Page 8125207 19 of 34 PIRADD 11/19/2008/14/2006/14/2004/23/202007/28/20 740501-01 Page 21NO_GRPG/TNER of 36 SR SR 7872631/MANUAL 8094021/MANUAL 7794901/MANUAL Page 12 of 38 PagePagePage 37 11 ofof 3827 (b) The required minimum distribution under paragraphs 3(a) and  We may permit you to appoint, through written notice 3(b)(i) for a year, beginning with the year following the year of acceptabletous,anauthorizedagenttoactonyourbehalfwith the depositor’s death (or the year the depositor would have respect to this agreement (e.g., attorneyͲinͲfact, executor, reached age 70½, if applicable under paragraph 3(b)(i)) is the administrator, investment manager), but we have no duty to account value at the close of business on December 31 of the determine the validity of such appointment or any instrument preceding year divided by the life expectancy (in the single life appointingsuchauthorizedagent.Wewillnotberesponsiblefor table in Regulations section 1.401(a)(9)Ͳ9) of the individual losses of any kind that may result from directions, actions, or specifiedinsuchparagraphs3(a)and3(b)(i). failures to act by your authorized agent, and you agree to (c) The required minimum distribution for the year the depositor reimburse us for any loss we may incur as a result of such reachesage70½canbemadeaslateasApril1ofthefollowing directions,actions,orfailurestoactbyyourauthorizedagent. year.Therequiredminimumdistributionforanyotheryearmust  Youwillhave60daysafteryoureceiveanydocuments,statements, bemadebytheendofsuchyear. orotherinformationfromustonotifyusinwritingofanyerrorsor 6. TheowneroftwoormoreTraditionalIRAsmaysatisfytheminimum inaccuracies reflected in these documents, statements, or other distribution requirements described above by taking from one information.Ifyoudonotnotifyuswithin60days,thedocuments, Traditional IRA the amount required to satisfy the requirement for statements, or other information will be deemed correct and anotherinaccordancewiththeregulationsundersection408(a)(6). accurate,andwewillhavenofurtherliabilityorobligationforsuch documents, statements, other information, or the transactions ARTICLEV describedtherein. 1. The depositor agrees to provide the custodian with all information necessary to prepare any reports required by section 408(i) and  By performing services under this agreement we are acting as Regulationssections1.408Ͳ5and1.408Ͳ6. your agent. You acknowledge and agree that nothing in this agreementwillbeconstruedasconferringfiduciarystatusupon 2. ThecustodianagreestosubmittotheInternalRevenueService(IRS) us. We will not be required to perform any additional services anddepositorthereportsprescribedbytheIRS. unless specifically agreed to under the terms and conditions of ARTICLEVI this agreement, or as required under the Code and the Notwithstandinganyotherarticleswhichmaybeaddedorincorporated, regulations promulgated thereunder with respect to IRAs. You the provisions of Articles I through III and this sentence will be agreetoindemnifyandholdusharmlessforanyandallclaims, controlling. Any additional articles inconsistent with section 408(a) and actions, proceedings, damages, judgments, liabilities, costs, and therelatedregulationswillbeinvalid. expenses,includingattorney’sfeesarisingfromorinconnection withthisagreement. ARTICLEVII  Totheextentwritteninstructionsornoticesarerequiredunder This agreement will be amended as necessary to comply with the this agreement, we may accept or provide such information in provisionsoftheCodeandtherelatedregulations.Otheramendments anyotherformpermittedbytheCodeorapplicableregulations maybemadewiththeconsentofthepersonswhosesignaturesappear including,butnotlimitedto,electroniccommunication. ontheapplication. 8.04 DisclosureofAccountInformation–Wemayuseagentsand/or ARTICLEVIII subcontractors to assist in administering your IRA. We may 8.01 Definitions–Inthispartofthisagreement(ArticleVIII),thewords release nonpublic personal information regarding your IRA to “you”and“your”meanthedepositor.Thewords“we,”“us,”and suchprovidersasnecessarytoprovidetheproductsandservices “our” mean the custodian. The word “Code” means the Internal made available under this agreement, and to evaluate our RevenueCode,and“regulations”meanstheTreasuryregulations. business operations and analyze potential product, service, or 8.02 NoticesandChangeofAddress–Anyrequirednoticeregarding processimprovements. this IRA will be considered effective when we send it to the 8.05 ServiceFees–Wehavetherighttochargeanannualservicefee intendedrecipientatthelastaddressthatwehaveinourrecords. orotherdesignatedfees(e.g.,atransfer,rollover,ortermination Anynoticetobegiventouswillbeconsideredeffectivewhenwe fee)formaintainingyourIRA.Inaddition,wehavetherighttobe actuallyreceiveit.You,ortheintendedrecipient,mustnotifyus reimbursedforallreasonableexpenses,includinglegalexpenses, ofanychangeofaddress. weincurinconnectionwiththeadministrationofyourIRA.We 8.03 RepresentationsandResponsibilities–Yourepresentandwarrant maychargeyouseparatelyforanyfeesorexpenses,orwemay to us that any information you have given or will give us with deduct the amount of the fees or expenses from the assets in respecttothisagreementiscompleteandaccurate.Further,you your IRA at our discretion. We reserve the right to charge any agree that any directions you give us or action you take will be additional fee after giving you 30 days’ notice. Fees such as properunderthisagreement,andthatweareentitledtorelyupon subtransferagentfeesorcommissionsmaybepaidtousbythird anysuchinformationordirections.Ifwefailtoreceivedirections parties for assistance in performing certain transactions with from you regarding any transaction, if we receive ambiguous respecttothisIRA. directionsregardinganytransaction,orifwe,ingoodfaith,believe  AnybrokeragecommissionsattributabletotheassetsinyourIRA thatanytransactionrequestedisindispute,wereservetherightto will be charged to your IRA. You cannot reimburse your IRA for takenoactionuntilfurtherclarificationacceptabletousisreceived thosecommissions. fromyouortheappropriategovernmentorjudicialauthority.We willnotberesponsibleforlossesofanykindthatmayresultfrom 8.06 Investment of Amounts in the IRA – You have exclusive your directions to us or your actions or failures to act, and you responsibilityforandcontrolovertheinvestmentoftheassetsof agreetoreimburseusforanylosswemayincurasaresultofsuch yourIRA.Alltransactionswillbesubjecttoanyandallrestrictions directions,actions,orfailurestoact.Wewillnotberesponsiblefor orlimitations,directorindirect,thatareimposedbyourcharter, any penalties, taxes, judgments, or expenses you incur in articlesofincorporation,orbylaws;anyandallapplicablefederal connectionwithyourIRA.Wehavenodutytodeterminewhether and state laws and regulations; the rules, regulations, customs your contributions or distributions comply with the Code, andusagesofanyexchange,marketorclearinghousewherethe regulations,rulings,orthisagreement. transaction is executed; our policies and practices; and this

LDOM/MANUAL/SR 8901748 PIRADD 04/27/21 740501-01 MANUAL/DAES/SR 8451718 MANUAL/DAES/SR NO_GRPG/JTYL Page 8125207 20 of 34 PIRADD 11/19/2008/14/2006/14/2004/23/202007/28/20 740501-01 Page 22NO_GRPG/TNER of 36 SR SR 7872631/MANUAL 8094021/MANUAL 7794901/MANUAL Page 12 of 38 PagePagePage 37 11 ofof 3827 agreement. After your death, your beneficiaries will have the  If we so choose, for any reason (e.g., due to limitations of our righttodirecttheinvestmentofyourIRAassets,subjecttothe charterorbylaws),wemayrequirethatabeneficiaryofadeceased same conditions that applied to you during your lifetime under IRAownertaketotaldistributionofallIRAassetsbyDecember31 thisagreement(including,withoutlimitation,Section8.03ofthis oftheyearfollowingtheyearofdeath. article). We will have no discretion to direct any investment in 8.08 Required Minimum Distributions – Your required minimum yourIRA.Weassumenoresponsibilityforrenderinginvestment distribution is calculated using the uniform lifetime table in advicewithrespecttoyourIRA,norwillweofferanyopinionor Regulationssection1.401(a)(9)Ͳ9.However,ifyourspouseisyour judgmenttoyouonmattersconcerningthevalueorsuitabilityof sole designated beneficiary and is more than 10 years younger any investment or proposed investment for your IRA. In the thanyou,yourrequiredminimumdistributioniscalculatedeach absenceofinstructionsfromyou,orifyourinstructionsarenotin yearusingthejointandlastsurvivortableinRegulationssection a form acceptable to us, we will have the right to hold any 1.401(a)(9)Ͳ9. uninvestedamountsincash,andwewillhavenoresponsibilityto investuninvestedcashunlessanduntildirectedbyyou.Wewill  Ifyoufailtorequestyourrequiredminimumdistributionbyyour notexercisethevotingrightsandothershareholderrightswith required beginning date, we can, at our complete and sole respect to investments in your IRA unless you provide timely discretion,doanyoneofthefollowing. writtendirectionsacceptabletous. ‡ Make no distribution until you give us a proper withdrawal  You will select the investment for your IRA assets from those request investments that we are authorized by our charter, articles of ‡ DistributeyourentireIRAtoyouinasinglesumpayment incorporation,orbylawstoofferanddoinfactofferforIRAs(e.g., ‡ DetermineyourrequiredminimumdistributionfromyourIRA term share accounts, passbook accounts, certificates of deposit, eachyearbasedonyourlifeexpectancy,calculatedusingthe money market accounts.) We may in our sole discretion make uniformlifetimetableinRegulationssection1.401(a)(9)Ͳ9,and available to you additional investment offerings, which will be paythosedistributionstoyouuntilyoudirectotherwise limitedtopubliclytradedsecurities,mutualfunds,moneymarket  We will not be liable for any penalties or taxes related to your instruments,andotherinvestmentsthatareobtainablebyusand failuretotakearequiredminimumdistribution. that we are capable of holding in the ordinary course of our business. 8.09 TerminationofAgreement,Resignation,orRemovalofCustodian– Either party may terminate this agreement at any time by giving 8.07 Beneficiaries–Ifyoudiebeforeyoureceivealloftheamountsin writtennoticetotheother.Wecanresignascustodianatanytime your IRA, payments from your IRA will be made to your effective30daysafterwesendwrittennoticeofourresignationto beneficiaries.Wehavenoobligationtopaytoyourbeneficiaries you.Uponreceiptofthatnotice,youmustmakearrangementsto untilsuchtimewearenotifiedofyourdeathbyreceivingavalid transfer your IRA to another financial organization. If you do not deathcertificate. completeatransferofyourIRAwithin30daysfromthedatewe  Youmaydesignateoneormorepersonsorentitiesasbeneficiary sendthenoticetoyou,wehavetherighttotransferyourIRAassets ofyourIRA.Thisdesignationcanonlybemadeonaformprovided toasuccessorIRAtrusteeorcustodianthatwechooseinoursole byoracceptabletous,anditwillonlybeeffectivewhenitisfiled discretion,orwemaypayyourIRAtoyouinasinglesum.Wewill withusduringyourlifetime.Eachbeneficiarydesignationyoufile not be liableforanyactions orfailurestoact onthepartofany withuswillcancelallpreviousdesignations.Theconsentofyour successortrusteeorcustodian,norforanytaxconsequencesyou beneficiaries will not be required for you to revoke a beneficiary mayincurthatresultfromthetransferordistributionofyourassets designation. If you have designated both primary and contingent pursuanttothissection. beneficiaries and no primary beneficiary survives you, the  If this agreement is terminated, we may charge to your IRA a contingentbeneficiarieswillacquirethedesignatedshareofyour reasonableamountofmoneythatwebelieveisnecessarytocover IRA.Ifyoudonotdesignateabeneficiaryorifallofyourprimary anyassociatedcosts,includingbutnotlimitedtooneormoreof and contingent beneficiaries predecease you, your estate will be thefollowing. thebeneficiary. ‡ Anyfees,expenses,ortaxeschargeableagainstyourIRA  AspousebeneficiarywillhaveallrightsasgrantedundertheCode ‡ Any penalties or surrender charges associated with the early orapplicableregulationstotreatyourIRAashisorherown. withdrawal of any savings instrument or other investment in  Wemayallow,ifpermittedbystatelaw,anoriginalIRAbeneficiary yourIRA (the beneficiary who is entitled to receive distributions from an  If we are a nonbank custodian required to comply with inherited IRA at the time of your death) to name successor Regulationssection1.408Ͳ2(e)andwefailtodosoorwearenot beneficiaries for the inherited IRA. This designation can only be keeping the records, making the returns, or sending the madeonaformprovidedbyoracceptabletous,anditwillonlybe statementsasarerequiredbyformsorregulations,theIRSmay effectivewhenitisfiledwithusduringtheoriginalIRAbeneficiary’s requireustosubstituteanothertrusteeorcustodian. lifetime. Each beneficiary designation form that the original IRA beneficiary files with us will cancel all previous designations. The  We may establish a policy requiring distribution of the entire consent of a successor beneficiary will not be required for the balanceofyourIRAtoyouincashorpropertyifthebalanceof original IRA beneficiary to revoke a successor beneficiary yourIRAdropsbelowtheminimumbalancerequiredunderthe designation. If the original IRA beneficiary does not designate a applicableinvestmentorpolicyestablished. successor beneficiary, his or her estate will be the successor beneficiary. In no event will the successor beneficiary be able to extendthedistributionperiodbeyondthatrequiredfortheoriginal IRAbeneficiary.

LDOM/MANUAL/SR 8901748 PIRADD 04/27/21 740501-01 MANUAL/DAES/SR 8451718 MANUAL/DAES/SR NO_GRPG/JTYL Page 8125207 21 of 34 PIRADD 11/19/2008/14/2006/14/2004/23/202007/28/20 740501-01 Page 23NO_GRPG/TNER of 36 SR SR 7872631/MANUAL 8094021/MANUAL 7794901/MANUAL Page 12 of 38 PagePagePage 37 11 ofof 3827 8.10 Successor Custodian – If our organization changes its name, GENERAL INSTRUCTIONS reorganizes,mergeswithanotherorganization (orcomesunder the control of any federal or state agency), or if our entire SectionreferencesaretotheInternalRevenueCodeunlessotherwisenoted. organization(oranyportionthatincludesyourIRA)isboughtby another organization, that organization (or agency) will PURPOSEOFFORM automaticallybecomethetrusteeorcustodianofyourIRA,but Form 5305ͲA is a model custodial account agreement that meets the onlyifitisthetypeoforganizationauthorizedtoserveasanIRA requirementsofsection408(a).However,onlyArticlesIthroughVIIhave trusteeorcustodian. been reviewed by the IRS. A Traditional individual retirement account 8.11 Amendments–Wehavetherighttoamendthisagreementatany (TraditionalIRA)isestablishedaftertheformisfullyexecutedbyboththe time. Any amendment we make to comply with the Code and individual(depositor)andthecustodian.Tomakearegularcontribution related regulations does not require your consent. You will be toaTraditionalIRAforayear,theIRAmustbeestablishednolaterthan deemedtohaveconsentedtoanyotheramendmentunless,within the due date of the individual’s income tax return for the tax year 30daysfromthedatewesendtheamendment,younotifyusin (excludingextensions).ThisaccountmustbecreatedintheUnitedStates writingthatyoudonotconsent. fortheexclusivebenefitofthedepositorandhisorherbeneficiaries. 8.12 WithdrawalsorTransfers–Allrequestsforwithdrawalortransfer DonotfileForm5305ͲAwiththeIRS.Instead,keepitwithyourrecords. willbeinwritingonaformprovidedbyoracceptabletous.The For more information on IRAs, including the required disclosures the methodofdistributionmustbespecifiedinwritingorinanyother custodian must give the depositor, see Pub. 590ͲA, Contributions to method acceptable to us. The tax identification number of the IndividualRetirementArrangements(IRAs),andPub.590ͲB,Distributions recipientmustbeprovidedtousbeforeweareobligatedtomakea fromIndividualRetirementArrangements(IRAs). distribution. Withdrawals will be subject to all applicable tax and other laws and regulations, including but not limited to possible DEFINITIONS earlydistributionpenaltytaxes,surrendercharges,andwithholding Custodian – The custodian must be a bank or savings and loan requirements. association, as defined in section 408(n), or any person who has the approvaloftheIRStoactascustodian. 8.13 TransfersFromOtherPlans–Wecanreceiveamountstransferred tothisIRAfromthetrusteeorcustodianofanotherIRA.Inaddition, Depositor – The depositor is the person who establishes the custodial we can accept rollovers of eligible rollover distributions from account. employerͲsponsored retirement plans as permitted by the Code. Wereservetherightnottoacceptanytransferordirectrollover. TRADITIONALIRAFORNONWORKINGSPOUSE Form 5305ͲA may be used to establish the IRA custodial account for a 8.14 LiquidationofAssets–Wehavetherighttoliquidateassetsinyour nonworkingspouse. IRA if necessary to make distributions or to pay fees, expenses, taxes,penalties,orsurrenderchargesproperlychargeableagainst ContributionstoanIRAcustodialaccountforanonworkingspousemustbe yourIRA.Ifyoufailtodirectusastowhichassetstoliquidate,we madetoaseparateIRAcustodialaccountestablishedbythenonworking willdecide,inourcompleteandsolediscretion,andyouagreeto spouse. notholdus liableforanyadverseconsequences thatresultfrom ourdecision. SPECIFIC INSTRUCTIONS 8.15 Restrictions on the Fund – Neither you nor any beneficiary may sell, transfer, or pledge any interest in your IRA in any manner ArticleIV–Distributionsmadeunderthisarticlemaybemadeinasingle whatsoever,exceptasprovidedbylaworthisagreement. sum,periodicpayment,oracombinationofboth.Thedistributionoption  The assets in your IRA will not be responsible for the debts, shouldbereviewedintheyearthedepositorreachesage70½toensure contracts,ortortsofanypersonentitledtodistributionsunderthis thattherequirementsofsection408(a)(6)havebeenmet. agreement. ArticleVIII–ArticleVIIIandanythatfollowitmayincorporateadditional 8.16 What Law Applies – This agreement is subject to all applicable provisionsthatareagreedtobythedepositorandcustodiantocomplete federal and state laws and regulations. If it is necessary to apply the agreement. They may include, for example, definitions, investment anystatelawtointerpretandadministerthisagreement,thelaw powers,votingrights,exculpatoryprovisions,amendmentandtermination, ofourdomicilewillgovern. removal of the custodian, custodian’s fees, state law requirements, beginning date of distributions, accepting only cash, treatment of excess  If any part of this agreement is held to be illegal or invalid, the contributions, prohibited transactions with the depositor, etc. Attach remainingpartswillnotbeaffected.Neitheryournorourfailureto additionalpagesifnecessary. enforceatanytimeorforanyperiodoftimeanyoftheprovisions  ofthisagreementwillbeconstruedasawaiverofsuchprovisions, oryourrightorourrightthereaftertoenforceeachandeverysuch provision.

LDOM/MANUAL/SR 8901748 PIRADD 04/27/21 740501-01 MANUAL/DAES/SR 8451718 MANUAL/DAES/SR NO_GRPG/JTYL Page 8125207 22 of 34 PIRADD 11/19/2008/14/2006/14/2004/23/202007/28/20 740501-01 Page 24NO_GRPG/TNER of 36 SR SR 7872631/MANUAL 8094021/MANUAL 7794901/MANUAL Page 12 of 38 PagePagePage 37 11 ofof 3827 DISCLOSURE STATEMENT

RIGHTTOREVOKEYOURIRA 2. TheapplicabledivisorgenerallyisdeterminedusingtheUniform YouhavetherighttorevokeyourIRAwithinsevendaysofthereceiptof Lifetime Table provided by the IRS. If your spouse is your sole thedisclosurestatement.Ifrevoked,youareentitledtoafullreturnof designatedbeneficiaryfortheentirecalendaryear,andismore the contribution you made to your IRA. The amount returned to you than 10 years younger than you, the required minimum would not include an adjustment for such items as sales commissions, distribution is determined each year using the actual joint life administrative expenses, or fluctuation in market value. You may make expectancyofyouandyourspouseobtainedfromtheJointLife this revocation only by mailing or delivering a written notice to the Expectancy Table provided by the IRS, rather than the life custodianattheaddresslistedontheapplication. expectancydivisorfromtheUniformLifetimeTable. Ifyousendyournoticebyfirstclassmail,yourrevocationwillbedeemed  WereservetherighttodoanyoneofthefollowingbyApril1ofthe mailedasofthepostmarkdate. yearfollowingtheyearinwhichyouturnage70½. If you have any questions about the procedure for revoking your IRA, (a) Make no distribution until you give us a proper withdrawal pleasecallthecustodianatthetelephonenumberlistedontheapplication. request REQUIREMENTSOFANIRA (b) DistributeyourentireIRAtoyouinasinglesumpayment A. CashContributions–Yourcontributionmustbeincash,unlessitisa rollovercontribution. (c) Determine your required minimum distribution each year based on your life expectancy calculated using the Uniform B. MaximumContribution–Thetotalamountyoumaycontributetoan Lifetime Table, and pay those distributions to you until you IRAforanytaxableyearcannotexceedthelesserof100percentof directotherwise yourcompensationor$5,500for2017and2018,withpossiblecostͲ ofͲliving adjustments each year thereafter. If you also maintain a  If you fail to remove a required minimum distribution, an RothIRA(i.e.,anIRAsubjecttothelimitsofInternalRevenueCode additionalpenaltytaxof50percentisimposedontheamountof Section (IRC Sec.) 408A), the maximum contribution to your therequiredminimumdistributionthatshouldhavebeentaken Traditional IRAs is reduced by any contributions you make to your butwasnot.YoumustfileIRSForm5329alongwithyourincome RothIRAs.YourtotalannualcontributiontoallTraditionalIRAsand taxreturntoreportandremitanyadditionaltaxestotheIRS. RothIRAscannotexceedthelesserofthedollaramountsdescribed 3. Your designated beneficiary is determined based on the aboveor100percentofyourcompensation. beneficiariesdesignatedasofthedateofyourdeath,whoremain C. ContributionEligibility–Youareeligibletomakearegularcontribution yourbeneficiariesasofSeptember30oftheyearfollowingthe toyourIRAifyouhavecompensationandhavenotattainedage70½by yearofyourdeath. theendofthetaxableyearforwhichthecontributionismade.  If you die on or after your required beginning date, distributions D. CatchͲUpContributions–Ifyouareage50orolderbythecloseofthe mustbemadetoyourbeneficiariesoverthelongerofthesinglelife taxableyear,youmaymakeanadditionalcontributiontoyourIRA.The expectancyofyourdesignatedbeneficiaries,oryourremaininglife maximumadditionalcontributionis$1,000peryear. expectancy.Ifabeneficiaryotherthanapersonorqualifiedtrustas E. Nonforfeitability–YourinterestinyourIRAisnonforfeitable. definedintheTreasuryRegulationsisnamed,youwillbetreatedas having no designated beneficiary of your IRA for purposes of F. EligibleCustodians–ThecustodianofyourIRAmustbeabank,savings determining the distribution period. If there is no designated andloanassociation,creditunion,orapersonorentityapprovedby beneficiary of your IRA, distributions will commence using your theSecretaryoftheTreasury. singlelifeexpectancy,reducedbyoneineachsubsequentyear. G. ComminglingAssets–TheassetsofyourIRAcannotbecommingled  Ifyoudiebeforeyourrequiredbeginningdate,theentireamount with other property except in a common trust fund or common remaininginyouraccountwill,attheelectionofyourdesignated investmentfund. beneficiaries,either H. Life Insurance – No portion of your IRA may be invested in life (a) bedistributedbyDecember31oftheyearcontainingthefifth insurancecontracts. anniversaryofyourdeath,or I. Collectibles–YoumaynotinvesttheassetsofyourIRAincollectibles (b) be distributed over the remaining life expectancy of your (within the meaning of IRC Sec. 408(m)). A collectible is defined as designatedbeneficiaries. any work of art, rug or antique, metal or gem, stamp or coin, alcoholicbeverage,orothertangiblepersonalpropertyspecifiedby  Ifyourspouseisyoursoledesignatedbeneficiary,heorshemust theInternalRevenueService(IRS).However,speciallymintedUnited electeitheroption(a)or(b)bytheearlierofDecember31ofthe States gold and silver coins, and certain stateͲissued coins are yearcontainingthefifthanniversaryofyourdeath,orDecember31 permissible investments. Platinum coins and certain gold, silver, oftheyearlifeexpectancypaymentswouldberequiredtobegin. platinum, or palladium bullion (as described in IRC Sec. 408(m)(3)) Yourdesignatedbeneficiaries,otherthanaspousewhoisthesole arealsopermittedasIRAinvestments. designated beneficiary, must elect either option (a) or (b) by J. RequiredMinimumDistributions–Youarerequiredtotakeminimum December 31 of the year following the year of your death. If no distributionsfromyourIRAatcertaintimesinaccordancewithTreasury electionismade,distributionwillbecalculatedinaccordancewith Regulation1.408Ͳ8.BelowisasummaryoftheIRAdistributionrules. option (b). In the case of distributions under option (b), distributions must commence by December 31 of the year 1. YouarerequiredtotakeaminimumdistributionfromyourIRAfor followingtheyearofyourdeath.Generally,ifyourspouseisthe theyearinwhichyoureachage70½andforeachyearthereafter. designated beneficiary, distributions need not commence until You must take your first distribution by your required beginning December31oftheyearyouwouldhaveattainedage70½,iflater. date,whichisApril1oftheyearfollowingtheyearyouattainage Ifabeneficiaryotherthanapersonorqualifiedtrustasdefinedin 70½.Theminimumdistributionforanytaxableyearisequaltothe theTreasuryRegulationsisnamed,youwillbetreatedashavingno amountobtainedbydividingtheaccountbalanceattheendofthe designatedbeneficiaryofyourIRAforpurposesofdeterminingthe prioryearbytheapplicabledivisor.

LDOM/MANUAL/SR 8901748 PIRADD 04/27/21 740501-01 MANUAL/DAES/SR 8451718 MANUAL/DAES/SR NO_GRPG/JTYL Page 8125207 23 of 34 PIRADD 11/19/2008/14/2006/14/2004/23/202007/28/20 740501-01 Page 25NO_GRPG/TNER of 36 SR SR 7872631/MANUAL 8094021/MANUAL 7794901/MANUAL Page 12 of 38 PagePagePage 37 11 ofof 3827 distribution period. If there is no designated beneficiary of your  If you do not know whether your employer maintains one of these IRA,theentireIRAmustbedistributedbyDecember31oftheyear plans or whether you are an active participant in a plan, check with containingthefifthanniversaryofyourdeath. youremployeroryourtaxadvisor.Also,theIRSFormWͲ2,Wageand Tax Statement, that you receive at the end of the year from your  AspousewhoisthesoledesignatedbeneficiaryofyourentireIRA employerwillindicatewhetheryouareanactiveparticipant. will be deemed to elect to treat your IRA as his or her own by either(1)makingcontributionstoyourIRAor(2)failingtotimely  Ifyouareanactiveparticipant,aresingle,andhaveMAGIwithinthe remove a required minimum distribution from your IRA. applicablephaseͲoutrangelistedbelow,thedeductibleamountofyour Regardless of whether or not the spouse is the soledesignated contribution isdeterminedasfollows. (1)Begin with theappropriate beneficiaryofyourIRA,aspousebeneficiarymayrolloverhisor phaseͲout range maximum for the applicable year (specified below) hershareoftheassetstohisorherownIRA. andsubtractyourMAGI;(2)dividethistotalbythedifferencebetween thephaseͲoutmaximumandminimum;and(3)multiplythisnumber  If we so choose, for any reason (e.g., due to limitations of our by the maximum allowable contribution for the applicable year, charterorbylaws),wemayrequirethatabeneficiaryofadeceased including catchͲup contributions if you are age 50 or older. The IRAownertaketotaldistributionofallIRAassetsbyDecember31 resultingfigurewillbethemaximumIRAdeductionyoumaytake.For oftheyearfollowingtheyearofdeath. example, if you are age 30 with MAGI of $63,000 in 2017, your  Ifyourbeneficiaryfailstoremovearequiredminimumdistribution maximumdeductiblecontributionis$4,950(the2017phaseͲoutrange afteryourdeath,anadditionalpenaltytaxof50percentisimposed maximum of $72,000 minus your MAGI of $63,000, divided by the ontheamountoftherequiredminimumdistributionthatshould differencebetweenthemaximumandminimumphaseͲoutrangelimits havebeentakenbutwasnot.YourbeneficiarymustfileIRSForm of$10,000,andmultipliedbythecontributionlimitof$5,500). 5329alongwithhisorherincometaxreturntoreportandremit  Ifyouareanactiveparticipant,aremarriedtoanactiveparticipantand anyadditionaltaxestotheIRS. youfileajointincometaxreturn,andhaveMAGIwithintheapplicable K. Qualifying Longevity Annuity Contracts and RMDs – A qualifying phaseͲout range listed below, the deductible amount of your longevityannuitycontract(QLAC)isadeferredannuitycontractthat, contributionisdeterminedasfollows.(1)Beginwiththeappropriate amongotherrequirements,mustguaranteelifetimeincomestarting phaseͲout maximum for the applicable year (specified below) and nolaterthanage85.ThetotalpremiumspaidtoQLACsinyourIRAs subtractyourMAGI;(2)dividethistotalbythedifferencebetweenthe mustnotexceed25percent(upto$125,000)ofthecombinedvalue phaseͲoutrangemaximumandminimum;and(3)multiplythisnumber ofyourIRAs(excludingRothIRAs).The$125,000limit issubjectto by the maximum allowable contribution for the applicable year, costͲofͲlivingadjustmentseachyear. including catchͲup contributions if you are age 50 or older. The  When calculating your RMD, you may reduce the prior year end resultingfigurewillbethemaximumIRAdeductionyoumaytake.For account value by the value of QLACs that your IRA holds as example, if you are age 30 with MAGI of $103,000 in 2017, your investments. maximum deductible contribution is $4,400 (the 2017 phaseͲout maximumof$119,000minusyourMAGIof$103,000,dividedbythe  For more information on QLACs, you may wish to refer to the IRS difference between the maximum and minimum phaseͲout limits of websiteatwww.irs.gov. $20,000,andmultipliedbythecontributionlimitof$5,500). INCOMETAXCONSEQUENCESOFESTABLISHINGANIRA  If you are an active participant, are married and you file a separate A. IRA Deductibility – If you are eligible to contribute to your IRA, the incometaxreturn,yourMAGIphaseͲoutrangeisgenerally$0–$10,000. amountofthecontributionforwhichyoumaytakeataxdeductionwill However,ifyoulivedapartfortheentiretaxyear,youaretreatedasa depend upon whether you (or, in some cases, your spouse) are an singlefiler. active participant in an employerͲsponsored retirement plan. If you  JointFilers SingleTaxpayers (andyourspouse,ifmarried)arenotanactiveparticipant,yourentire  TaxYear PhaseͲOutRange* PhaseͲOutRange* IRAcontributionwillbedeductible.Ifyouareanactiveparticipant(or  (minimum)(maximum) (minimum)(maximum) are married to an active participant), the deductibility of your IRA  2011 $90,000–110,000 $56,000–66,000 contribution will depend on your modified adjusted gross income  2012 $92,000–112,000 $58,000–68,000 (MAGI) and your tax filing status for the tax year for which the  2013 $95,000–115,000 $59,000–69,000 contributionwasmade.MAGIisdeterminedonyourincometaxreturn  2014 $96,000–116,000 $60,000–70,000 usingyouradjustedgrossincomebutdisregardinganydeductibleIRA  2015 $98,000–118,000 $61,000–71,000 contributionandcertainotherdeductionsandexclusions.  2016 $98,000–118,000 $61,000–71,000  2017 $99,000–119,000 $62,000–72,000  Definition of Active Participant. Generally, you will be an active  2018 $101,000–121,000 $63,000–73,000 participant if you are covered by one or more of the following employerͲsponsoredretirementplans.  *MAGIlimitsaresubjecttocostͲofͲlivingadjustmentseachyear. 1. Qualifiedpension,profitsharing,401(k),orstockbonusplan  The MAGI phaseͲout range for an individual that is not an active participant,butismarriedtoanactiveparticipant,is$186,000–$196,000 2. Qualifiedannuityplanofanemployer (for2017)and$189,000–$199,000(for2018).Thislimitisalsosubjectto 3. Simplifiedemployeepension(SEP)plan costͲofͲlivingincreasesfortaxyearsafter2018.Ifyouarenotanactive 4. Retirementplanestablishedbythefederalgovernment,astate, participant in an employerͲsponsored retirement plan, are married to or a political subdivision (except certain unfunded deferred someone who is an active participant, and you file a joint income tax compensationplansunderIRCSec.457) returnwithMAGIbetweentheapplicablephaseͲoutrangefortheyear, 5. TaxͲsheltered annuity for employees of certain taxͲexempt your maximum deductible contribution is determined as follows. organizationsorpublicschools (1)BeginwiththeappropriateMAGIphaseͲoutmaximumfortheyear 6. PlanmeetingtherequirementsofIRCSec.501(c)(18) andsubtractyourMAGI;(2)dividethistotalbythedifferencebetween 7. Savings incentive match plan for employees ofsmall employers the phaseͲout range maximum and minimum; and (3) multiply this (SIMPLE)IRAplanoraSIMPLE401(k)plan numberbythemaximumallowablecontributionfortheapplicableyear, includingcatchͲupcontributionsifyouareage50orolder.Theresulting figurewillbethemaximumIRAdeductionyoumaytake.

LDOM/MANUAL/SR 8901748 PIRADD 04/27/21 740501-01 MANUAL/DAES/SR 8451718 MANUAL/DAES/SR NO_GRPG/JTYL Page 8125207 24 of 34 PIRADD 11/19/2008/14/2006/14/2004/23/202007/28/20 740501-01 Page 26NO_GRPG/TNER of 36 SR SR 7872631/MANUAL 8094021/MANUAL 7794901/MANUAL Page 12 of 38 PagePagePage 37 11 ofof 3827  Youmustroundtheresultingdeductiontothenexthighest$10ifthe 1. RemovalBeforeYourTaxFilingDeadline.Anexcesscontribution numberisnotamultipleof10.Ifyourresultingdeductionisbetween maybecorrectedbywithdrawingtheexcessamount,alongwith $0and$200,youmayroundupto$200. the earnings attributable to the excess, before your tax filing deadline, including extensions, for the year for which the excess B. ContributionDeadline–ThedeadlineformakinganIRAcontributionis contributionwasmade.Anexcesswithdrawnunderthismethodis yourtaxreturnduedate(notincludingextensions).Youmaydesignate nottaxabletoyou,butyoumustincludetheearningsattributable a contribution as a contribution for the preceding taxable year in a to the excess in your taxable income in the year in which the manner acceptable to us. For example, if you are a calendarͲyear contributionwasmade.Thesixpercentexcesscontributionpenalty taxpayer and you make your IRA contribution on or before your tax taxwillbeavoided. filingdeadline,yourcontributionisconsideredtohavebeenmadefor theprevioustaxyearifyoudesignateitassuch. 2. RemovalAfter Your TaxFiling Deadline.Ifyouare correcting an excess contribution after your tax filing deadline, including  IfyouareamemberoftheArmedForcesservinginacombatzone, extensions, remove only the amount of the excess contribution. hazardous duty area, or contingency operation, you may have an Thesixpercentexcesscontributionpenaltytaxwillbeimposedon extendedcontributiondeadlineof180daysafterthelastdayserved the excess contribution for each year it remains in the IRA. An in the area. In addition, your contribution deadline for a particular excesswithdrawalunderthismethodwillonlybetaxabletoyouif taxyearisalsoextendedbythenumberofdaysthatremainedtofile thetotalcontributionsmadeintheyearoftheexcessexceedthe thatyear’staxreturnasofthedateyouenteredthecombatzone. annualapplicablecontributionlimit. This additional extension to make your IRA contribution cannot exceed the number of days between January 1 and your tax filing 3. CarryForwardtoaSubsequentYear.Ifyoudonotwithdrawthe deadline,notincludingextensions. excesscontribution,youmaycarryforwardthecontributionfora subsequent tax year. Todoso, youunderͲcontributefor thattax C. TaxCreditforContributions–Youmaybeeligibletoreceiveataxcredit yearandcarrytheexcesscontributionamountforwardtothatyear for your Traditional IRA contributions. This credit will be allowed in onyourtaxreturn.Thesixpercentexcesscontributionpenaltytax addition to any tax deduction that may apply, and may not exceed willbeimposedontheexcessamountforeachyearthatitremains $1,000inagivenyear.Youmaybeeligibleforthistaxcreditifyouare asanexcesscontributionattheendoftheyear. ‡ age18orolderasofthecloseofthetaxableyear,  You must file IRS Form 5329 along with your income tax return to ‡ notadependentofanothertaxpayer,and reportandremitanyadditionaltaxestotheIRS. ‡ notafullͲtimestudent. E. TaxͲDeferredEarnings–TheinvestmentearningsofyourIRAarenot  Thecreditisbaseduponyourincome(seechartbelow),andwillrange subject to federal income tax until distributions are made (or, in from0to50percentofeligiblecontributions.Inordertodeterminethe certaininstances,whendistributionsaredeemedtobemade). amount of your contributions, add all of the contributions made to yourTraditionalIRAandreducethesecontributionsbyanydistributions F. Nondeductible Contributions – You may make nondeductible thatyouhavetakenduringthetestingperiod.Thetestingperiodbegins contributionstoyourIRAtotheextentthatdeductiblecontributions twoyearspriortotheyearforwhichthecreditissoughtandendson arenotallowed.ThesumofyourdeductibleandnondeductibleIRA thetaxreturnduedate(includingextensions)fortheyearforwhichthe contributionscannotexceedyourcontributionlimit(thelesserofthe credit is sought. In order to determine your tax credit, multiply the allowablecontributionlimitdescribedpreviously,or100percentof applicable percentage from the chart below by the amount of your compensation).YoumayelecttotreatdeductibleIRAcontributions contributionsthatdonotexceed$2,000. asnondeductiblecontributions.

2017AdjustedGrossIncome*  Ifyoumakenondeductiblecontributionsforaparticulartaxyear,you Applicable must report the amount of the nondeductible contribution along Joint Headofa AllOther Percentage Return Household Cases withyourincometaxreturnusingIRSForm8606.FailuretofileIRS Form8606willresultina$50perfailurepenalty.  $1–37,000  $1–27,750  $1–18,500 50  $37,001–40,000  $27,751–30,000  $18,501–20,000 20  Ifyouoverstatetheamountofdesignatednondeductiblecontributions  $40,001–62,000  $30,001–46,500  $20,001–31,000 10 for any taxable year, you are subject to a $100 penalty unless  Over$62,000  Over$46,500  Over$31,000 0 reasonablecausefortheoverstatementcanbeshown.  G. TaxationofDistributions–ThetaxationofIRAdistributionsdepends 2018AdjustedGrossIncome* Applicable on whether or not you have ever made nondeductible IRA Joint Headofa AllOther Percentage contributions.Ifyouhaveonlymadedeductiblecontributions,allIRA Return Household Cases distributionamountswillbeincludedinincome.  $1–38,000  $1–28,500  $1–19,000 50  If you have ever made nondeductible contributions to any IRA, the  $38,001–41,000  $28,501–30,750  $19,001–20,500 20 followingformulamustbeusedtodeterminetheamountofanyIRA  $41,001–63,000  $30,751–47,250  $20,501–31,500 10  Over$63,000  Over$47,250  Over$31,500 0 distributionexcludedfromincome.  (AggregateNondeductibleContributions)   *Adjusted gross income (AGI) includes foreign earned income and  x (AmountWithdrawn)  =AmountExcludedFromIncome incomefromGuam,AmericaSamoa,NorthMarianaIslands,andPuerto  AggregateIRABalance Rico.AGIlimitsaresubjecttocostͲofͲlivingadjustmentseachyear.  NOTE:Aggregatenondeductiblecontributionsincludeallnondeductible D. Excess Contributions – An excess contribution is any amount that is contributions made by you through the end of the year of the contributedtoyourIRAthatexceedstheamountthatyouareeligible distribution that have not previously been withdrawn and excluded to contribute. If the excess is not corrected timely, an additional from income. Also note that the aggregate IRA balance includes the penaltytaxofsixpercentwillbeimposedupontheexcessamount.The totalbalanceofallofyourTraditionalandSIMPLEIRAsasoftheendof procedureforcorrectinganexcessisdeterminedbythetimelinessof theyearofdistributionandanydistributionsoccurringduringtheyear. thecorrectionasidentifiedbelow.

LDOM/MANUAL/SR 8901748 PIRADD 04/27/21 740501-01 MANUAL/DAES/SR 8451718 MANUAL/DAES/SR NO_GRPG/JTYL Page 8125207 25 of 34 PIRADD 11/19/2008/14/2006/14/2004/23/202007/28/20 740501-01 Page 27NO_GRPG/TNER of 36 SR SR 7872631/MANUAL 8094021/MANUAL 7794901/MANUAL Page 12 of 38 PagePagePage 37 11 ofof 3827 H. IncomeTaxWithholding–AnywithdrawalfromyourIRAissubject 1. Traditional IRAͲtoͲTraditional IRA Rollovers. Assets distributed to federal income tax withholding. You may, however, elect not to from your Traditional IRA may be rolled over to the same have withholding apply to your IRA withdrawal. If withholding is Traditional IRA or another Traditional IRA of yours if the appliedtoyourwithdrawal,notlessthan10percentoftheamount requirementsofIRCSec.408(d)(3)aremet.AproperIRAͲtoͲIRA withdrawnmustbewithheld. rolloveriscompletedifallorpartofthedistributionisrolledover I. EarlyDistributionPenaltyTax–IfyoureceiveanIRAdistributionbefore not later than 60 days after the distribution is received. In the you attain age 59½, an additional early distribution penalty tax of 10 caseofadistributionforafirstͲtimehomebuyerwheretherewas percentwillapplytothetaxableamountofthedistributionunlessone a delay or cancellation of the purchase, the 60Ͳday rollover ofthefollowingexceptionsapply.1)Death.Afteryourdeath,payments periodmaybeextendedto120days. made to your beneficiary are not subject to the 10 percent early  YouarepermittedtorolloveronlyonedistributionfromanIRA distributionpenaltytax.2)Disability.Ifyouaredisabledatthetimeof (Traditional,Roth,orSIMPLE)ina12Ͳmonthperiod,regardlessof distribution, you are not subject to the additional 10 percent early thenumberofIRAsyouown.Adistributionmayberolledoverto distribution penalty tax. In order to be disabled, a physician must the same IRA or to another IRA that is eligible to receive the determinethatyourimpairmentcanbeexpectedtoresultindeathorto rollover. For more information on rollover limitations, you may be of long, continued, and indefinite duration. 3) Substantially equal wishtoobtainIRSPublication590ͲB,DistributionsfromIndividual periodic payments. You are not subject to the additional 10 percent RetirementArrangements(IRAs),fromtheIRSorrefertotheIRS earlydistributionpenaltytaxifyouaretakingaseriesofsubstantially websiteatwww.irs.gov. equal periodic payments (at least annual payments) over your life expectancyorthejointlifeexpectancyofyouandyourbeneficiary.You 2. SIMPLEIRAͲtoͲTraditionalIRARollovers.Assetsdistributedfrom mustcontinuethesepaymentsforthelongeroffiveyearsoruntilyou your SIMPLE IRA may be rolled over to your Traditional IRA reach age 59½. 4)Unreimbursed medical expenses. If you take withoutIRSpenaltytaxprovidedtwoyearshavepassedsinceyou payments to pay for unreimbursed medical expenses that exceed a first participated in a SIMPLE IRA plan sponsored by your specified percentage of your adjusted gross income, you will not be employer.AswithTraditionalIRAͲtoͲTraditionalIRArollovers,the subject to the 10 percent early distribution penalty tax. For further requirementsofIRCSec.408(d)(3)mustbemet.AproperSIMPLE detailedinformationandeffectivedatesyoumayobtainIRSPublication IRAͲtoͲIRArolloveriscompletedifallorpartofthedistributionis 590ͲB, Distributions from Individual Retirement Arrangements (IRAs), rolled over not later than 60 days after the distribution is fromtheIRS.Themedicalexpensesmaybeforyou,yourspouse,orany received. dependentlistedonyourtaxreturn.5)Healthinsurancepremiums.If  YouarepermittedtorolloveronlyonedistributionfromanIRA youareunemployedandhavereceivedunemploymentcompensation (Traditional,Roth,orSIMPLE)ina12Ͳmonthperiod,regardlessof for12consecutiveweeksunderafederalorstateprogram,youmaytake thenumberofIRAsyouown.Adistributionmayberolledoverto paymentsfromyourIRAtopayforhealthinsurancepremiumswithout the same IRA or to another IRA that is eligible to receive the incurring the 10 percent early distribution penalty tax. 6) Higher rollover. For more information on rollover limitations, you may education expenses. Payments taken for certain qualified higher wishtoobtainIRSPublication590ͲB,DistributionsfromIndividual education expenses for you, your spouse, or the children or RetirementArrangements(IRAs),fromtheIRSorrefertotheIRS grandchildren of you or your spouse, will not be subject to the 10 websiteatwww.irs.gov. percentearlydistributionpenaltytax.7)FirstͲtimehomebuyer.Youmay takepaymentsfromyourIRAtousetowardqualifiedacquisitioncostsof 3. EmployerͲSponsoredRetirementPlanͲtoͲTraditionalIRARollovers. buyingorbuildingaprincipalresidence.Theamountyoumaytakefor You may roll over, directly or indirectly, any eligible rollover this reason may not exceed a lifetime maximum of $10,000. The distribution from an eligible employerͲsponsored retirement plan. paymentmustbeusedforqualifiedacquisitioncostswithin120daysof An eligible rollover distribution is defined generally as any receivingthedistribution.8)IRSlevy.PaymentsfromyourIRAmadeto distributionfromaqualifiedretirementplan,403(a)annuity,403(b) theU.S.governmentinresponsetoafederaltaxlevyarenotsubjectto taxͲsheltered annuity, 457(b) eligible governmental deferred the 10 percent early distribution penalty tax. 9) Qualified reservist compensation plan, or federal Thrift Savings Plan unless it is a distributions. If you are a qualified reservist member called to active required minimum distribution, hardship distribution, part of a dutyformorethan179daysoranindefiniteperiod,thepaymentsyou certain series of substantially equal periodic payments, corrective takefromyourIRAduringtheactivedutyperiodarenotsubjecttothe distributionsofexcesscontributions,excessdeferrals,excessannual 10percentearlydistributionpenaltytax. additions and any income allocable to the excess, deemed loan distribution, dividends on employer securities, the cost of life  YoumustfileIRSForm5329alongwithyourincometaxreturntothe insurancecoverage,oradistributionofRothelectivedeferralsfrom IRStoreportandremitanyadditionaltaxesortoclaimapenaltytax a401(k),403(b),governmental457(b),orfederalThriftSavingsPlan. exception.  Ifyouelecttoreceiveyourrolloverdistributionpriortoplacingitin J. Rollovers and Conversions – Your IRA may be rolled over to another an IRA, thereby conducting an indirect rollover, your plan IRA,SIMPLEIRA,oraneligibleemployerͲsponsoredretirementplanof administratorgenerallywillberequiredtowithhold20percentof yours, may receive rollover contributions, or may be converted to a yourdistributionasapaymentofincometaxes.Whencompleting Roth IRA, provided that all of the applicable rollover and conversion therollover,youmaymakeupoutofpockettheamountwithheld, rulesarefollowed.Rolloverisatermusedtodescribeamovementof and roll over the full amount distributed from your employerͲ cash or other property to your IRA from another IRA, or from your sponsored retirement plan. To qualify as a rollover, your eligible employer’s qualified retirement plan, 403(a) annuity, 403(b) taxͲ shelteredannuity,457(b)eligiblegovernmentaldeferredcompensation rolloverdistributiongenerallymustberolledovertoyourIRAnot plan, or federal Thrift Savings Plan. The amount rolled over is not laterthan60daysafteryoureceivethedistribution.Inthecaseof subject to taxation or the additional 10 percent early distribution a plan loan offset due to plan termination or severance from penalty tax. Conversion is a term used to describe the movement of employment,thedeadlineforcompletingtherolloverisyourtax TraditionalIRAassetstoaRothIRA.Aconversiongenerallyisataxable return due date (including extensions) for the year in which the event.Thegeneralrolloverandconversionrulesaresummarizedbelow. offsetoccurs.Alternatively,youmayclaimthewithheldamountas These transactions are often complex. If you have any questions income,andpaytheapplicableincometax,andifyouareunder regardingarolloverorconversion,pleaseseeacompetenttaxadvisor. age 59½, the 10percent early distribution penalty tax (unless an exceptiontothepenaltyapplies).

LDOM/MANUAL/SR 8901748 PIRADD 04/27/21 740501-01 MANUAL/DAES/SR 8451718 MANUAL/DAES/SR NO_GRPG/JTYL Page 8125207 26 of 34 PIRADD 11/19/2008/14/2006/14/2004/23/202007/28/20 740501-01 Page 28NO_GRPG/TNER of 36 SR SR 7872631/MANUAL 8094021/MANUAL 7794901/MANUAL Page 12 of 38 PagePagePage 37 11 ofof 3827  Asanalternativetotheindirectrollover,youremployergenerally 9. RolloversofSettlementPaymentsFromBankruptAirlines.Ifyou must give you the option to directly roll over your employerͲ are a qualified airline employee who has received a qualified sponsored retirement plan balance to an IRA. If you elect the airline settlement payment from a commercial airline carrier direct rollover option, your eligible rollover distribution will be undertheapprovalofanorderofafederalbankruptcycourt,you paid directly to the IRA (or other eligible employerͲsponsored are allowed to roll over up to 90 percent of the proceeds into retirementplan)thatyoudesignate.The20percentwithholding yourTraditionalIRAwithin180daysafterreceiptofsuchamount, requirementsdonotapplytodirectrollovers. orbyalaterdateifextendedbyfederallaw.Ifyoumakesucha 4. BeneficiaryRolloversFromEmployerͲSponsoredRetirementPlans. rollover contribution, you may exclude the amount rolled over Ifyouareaspouse,nonspouse,orqualifiedtrustbeneficiaryofa fromyourgrossincomeinthe taxableyearinwhichtheairline deceased employerͲsponsored retirement plan participant, you settlement payment was paid to you. For further detailed maydirectlyrolloverinheritedassetsfromaqualifiedretirement information and effective dates you may obtain IRS Publication plan,403(a)annuity,403(b)taxͲshelteredannuity,or457(b)eligible 590ͲA, Contributions to Individual Retirement Arrangements governmentaldeferredcompensationplantoaninheritedIRA.The (IRAs),fromtheIRSorrefertotheIRSwebsiteatwww.irs.gov. IRA must be maintained as an inherited IRA, subject to the 10.RolloversofExxonValdezSettlementPayments.Ifyoureceivea beneficiarydistributionrequirements. qualified settlement payment from Exxon Valdez litigation, you 5. TraditionalIRAͲtoͲSIMPLEIRARollovers.Assetsdistributedfrom may roll over the amount of the settlement, up to $100,000, your Traditional IRA may be rolled over to a SIMPLE IRA if the reducedbytheamountofanyqualifiedExxonValdezsettlement requirementsofIRCSec.408(d)(3)aremetandtwoyearshave income previously contributed to a Traditional or Roth IRA or passed since you first participated in a SIMPLE IRA plan eligibleretirementplaninpriortaxableyears.Youwillhaveuntil sponsoredbyyouremployer.AproperTraditionalIRA to SIMPLE yourtaxreturnduedate(notincludingextensions)fortheyearin IRArolloveriscompletedifallorpartofthedistributionisrolled which the qualified settlement income is received to make the overnotlaterthan60daysafterthedistributionisreceived.Ǧ Ǧ In rollovercontribution.Toobtainmoreinformationonthistypeof thecaseofadistributionforafirst timehomebuyerwherethere rollover,youmaywishtovisittheIRSwebsiteatwww.irs.gov. wasadelayorcancellationofthepurchase,the60 dayrollover 11.RolloverofIRSLevy.Ifyoureceivearefundofeligibleretirement Ǧ periodmaybeextendedto120days. planassetsthathadbeenwrongfullylevied,youmayrolloverthe Ǧ  YouarepermittedtorolloveronlyonedistributionfromanIRA amountreturnedupuntilyourtaxreturnduedate(notincluding (Traditional,Roth,orSIMPLE)ina12 monthperiod,regardlessof extensions)fortheyearinwhichthemoneywasreturned. thenumberofIRAsyouown.Adistributionmayberolledoverto 12.WrittenElection.AtthetimeyoumakearollovertoanIRA,you Ǧ the same IRA or to another IRA that is eligible to receive the mustdesignateinwritingtothecustodianyourelectiontotreat rollover. For more information on rollover limitations, you may thatcontributionasarollover.Oncemade,therolloverelection obtain IRS Publication 590ͲB, Distributions from Individual isirrevocable. RetirementArrangements(IRAs),fromtheIRSorrefertotheIRS websiteatwww.irs.gov. K. TransferDuetoDivorce–IfalloranypartofyourIRAisawardedto your spouse or former spouse in a divorce or legal separation 6. TraditionalIRAͲtoͲEmployerͲSponsoredRetirementPlanRollovers. proceeding,theamountsoawardedwillbetreatedasthespouse’s Youmayrollover,directlyorindirectly,anytaxableeligiblerollover IRA (and may be transferred pursuant to a courtͲapproved divorce distributionfromanIRAtoyourqualifiedretirementplan,403(a) decreeorwrittenlegalseparationagreementtoanotherIRAofyour annuity, 403(b) taxͲsheltered annuity, or 457(b) eligible spouse),andwillnotbeconsideredataxabledistributiontoyou.A governmentaldeferredcompensationplanaslongastheemployerͲ transferisataxͲfreedirectmovementofcashand/orpropertyfrom sponsoredretirementplanacceptssuchrollovercontributions. oneTraditionalIRAtoanother. 7. TraditionalIRAͲtoͲRothIRAConversions.IfyouconverttoaRoth L. Recharacterizations–IfyoumakeacontributiontoaTraditionalIRA IRA,theamountoftheconversionfromyourTraditionalIRAtoyour and later recharacterize either all or a portion of the original RothIRAwillbetreatedasadistributionforincometaxpurposes, contributiontoaRothIRAalongwithnetincomeattributable,youmay andisincludibleinyourgrossincome(exceptforanynondeductible electtotreattheoriginalcontributionashavingbeenmadetotheRoth contributions). Although the conversion amount generally is IRA. The same methodology applies when recharacterizing a included in income, the 10 percent early distribution penalty tax contribution from a Roth IRA to a Traditional IRA. For tax years willnotapplytoconversionsfromaTraditionalIRAtoaRothIRA, beginning before January 1, 2018, if you have converted from a regardless of whether you qualify for any exceptions to the 10 Traditional IRA to a Roth IRA you may recharacterize the conversion percentpenaltytax.Ifyouareage70½orolderyoumustremove along with net income attributable back to a Traditional IRA. The your required minimum distribution before converting your deadlineforcompletingarecharacterizationisyourtaxfilingdeadline TraditionalIRA. (including any extensions) for the year for which the original 8. Qualified HSA Funding Distribution. If you are eligible to contributionwasmadeorconversioncompleted.However,effectivefor contributetoahealthsavingsaccount(HSA),youmaybeeligible tax years beginning after December 31, 2017, you may not to take a oneͲtime taxͲfree qualified HSA funding distribution recharacterizeaRothIRAconversion. fromyourIRAanddirectlydepositittoyourHSA.Theamountof the qualified HSA funding distribution may not exceed the LIMITATIONSANDRESTRICTIONS maximum HSA contribution limit in effect for the type of high A. SEPPlans–Underasimplifiedemployeepension(SEP)planthatmeets deductible health plan coverage (i.e., single or family coverage) the requirements of IRC Sec. 408(k), your employer may make thatyouhaveatthetimeofthedeposit,andcountstowardyour contributions to your IRA. Your employer is required to provide you HSA contribution limit for that year. For further detailed withinformationthatdescribesthetermsofyouremployer’sSEPplan. information,youmaywishtoobtainIRSPublication969,Health B. Spousal IRA – If you are married and have compensation, you may SavingsAccountsandOtherTaxͲFavoredHealthPlans. contributetoanIRAestablishedforthebenefitofyourspouseforany year prior to the year your spouse turns age 70½, regardless of whetherornotyourspousehascompensation.Youmaymakethese

LDOM/MANUAL/SR 8901748 PIRADD 04/27/21 740501-01 MANUAL/DAES/SR 8451718 MANUAL/DAES/SR NO_GRPG/JTYL Page 8125207 27 of 34 PIRADD 11/19/2008/14/2006/14/2004/23/202007/28/20 740501-01 Page 29NO_GRPG/TNER of 36 SR SR 7872631/MANUAL 8094021/MANUAL 7794901/MANUAL Page 12 of 38 PagePagePage 37 11 ofof 3827 spousalcontributionsevenifyouareage70½orolder.Youmustfilea F. DisasterRelatedRelief–Ifyouqualify(forexample,yousustained jointincometaxreturnfortheyearforwhichthecontributionismade. an economic loss due to, or are otherwise considered affected by, certain IRS designated disasters), you may be eligible for favorable  TheamountyoumaycontributetoyourIRAandyourspouse’sIRAis tax treatment on distributions, rollovers, and other transactions thelesserof100percentofyourcombinedeligiblecompensationor involving your IRA. Qualified disaster relief may include penaltyͲtax $11,000for2017and2018.ThisamountmaybeincreasedwithcostͲ free early distributions made during specified timeframes for each ofͲliving adjustments each year. However, you may not contribute disaster, the ability to include distributions in your gross income morethantheindividualcontributionlimittoeachIRA. ratablyovermultipleyears,theabilitytorolloverdistributionstoan  Ifyourspouseisage50orolderbythecloseofthetaxableyear,andis eligible retirement plan without regard to the 60Ͳday rollover rule, otherwise eligible, you may make an additional contribution to your andmore.Foradditionalinformationonspecificdisasters,including spouse’sIRA.Themaximumadditionalcontributionis$1,000peryear. a complete listing of disaster areas, qualification requirements for C. DeductionofRolloversandTransfers–Adeductionisnotallowed relief,andallowabledisasterͲrelatedIRAtransactions,youmaywish forrolloverortransfercontributions. to obtain IRS Publication 590ͲB, Distributions from Individual Retirement Arrangements (IRAs), from the IRS or refer to the IRS D. GiftTax–TransfersofyourIRAassetstoabeneficiarymadeduring websiteatwww.irs.gov. yourlifeandatyourrequestmaybesubjecttofederalgifttaxunder IRCSec.2501. E. SpecialTaxTreatment–Capitalgainstreatmentand10Ͳyearincome averagingauthorizedbyIRCSec.402donotapplytoIRAdistributions. F. Prohibited Transactions – If you or your beneficiary engage in a prohibitedtransactionwithyourIRA,asdescribedinIRCSec.4975, yourIRAwillloseitstaxͲdeferredstatus,andyoumustincludethe valueofyouraccountinyourgrossincomeforthattaxableyear.The followingtransactionsareexamplesofprohibitedtransactionswith your IRA. (1) Taking a loan from your IRA (2) Buying property for personaluse(presentorfuture)withIRAassets(3)Receivingcertain bonusesorpremiumsbecauseofyourIRA. G. Pledging–IfyoupledgeanyportionofyourIRAascollateralfora loan,theamountsopledgedwillbetreatedasadistributionandwill beincludedinyourgrossincomeforthatyear. OTHER A. IRSPlanApproval–ArticlesIthroughVIIoftheagreementusedto establishthisIRAhavebeenapprovedbytheIRS.TheIRSapprovalis adeterminationonlyastoform.Itisnotanendorsementoftheplan inoperationoroftheinvestmentsoffered. B. AdditionalInformation–ForfurtherinformationonIRAs,youmaywish toobtainIRSPublication590ͲA,ContributionstoIndividualRetirement Arrangements(IRAs),orPublication590ͲB,DistributionsfromIndividual Retirement Arrangements (IRAs), by calling 800ͲTAXͲFORM, or by visitingwww.irs.govontheInternet. C. Important Information About Procedures for Opening a New Account–Tohelpthegovernmentfightthefundingofterrorismand money laundering activities, federal law requires all financial organizationstoobtain,verify,andrecordinformationthatidentifies each person who opens an account. Therefore, when you open an IRA,youarerequiredtoprovideyourname,residentialaddress,date of birth, and identification number. We may require other informationthatwillallowustoidentifyyou. D. Qualified Reservist Distributions – If you are an eligible qualified reservist who has taken penaltyͲfree qualified reservist distributions fromyourIRAorretirementplan,youmayrecontributethoseamounts toanIRAgenerallywithinatwoͲyearperiodfromyourdateofreturn. E. QualifiedCharitableDistributions–Ifyouareage70½orolder,you maytaketaxͲfreeIRAdistributionsofupto$100,000peryearand have these distributions paid directly to certain charitable organizations. Special tax rules may apply. For further detailed informationyoumayobtainIRSPublication590ͲB,Distributionsfrom IndividualRetirementArrangements(IRAs),fromtheIRSorreferto theIRSwebsiteatwww.irs.gov.

LDOM/MANUAL/SR 8901748 PIRADD 04/27/21 740501-01 MANUAL/DAES/SR 8451718 MANUAL/DAES/SR NO_GRPG/JTYL Page 8125207 28 of 34 PIRADD 11/19/2008/14/2006/14/2004/23/202007/28/20 740501-01 Page 30NO_GRPG/TNER of 36 SR SR 7872631/MANUAL 8094021/MANUAL 7794901/MANUAL Page 12 of 38 PagePagePage 37 11 ofof 3827 EmpowerEmpower Retirement Premier IRA Disclosure Disclosure 2019

This document contains a summary of paymentpayments or or other other compensati compensationon that that Great-West Great-West Trust Trust Company, Company, Great-West Great-West /LIH $QQXLW\,QVXUDQFH&RPSDQ\RUWKHLUDI¿OLDWHV ³*UHDW:HVLife & Annuity Insurance Company or their affiliates (“Great-West”)W´ PD\UHFHLYHLQFRQQHFWLRQVZLWKWKH(PSRZHU may receive in connection with the Empower 3UHPLHU,5$SODWIRUPDQGWKHVHUYLFHVSURYLGHGWR(PSRZHU3UHPLRetirement IRA platform and the services provided to Empower RetirementHU,5$DFFRXQWV3OHDVHUHIHUWR\RXU(PSRZHU IRA accounts. Please refer to your 3UHPLHU,5$DFFRXQWDJUHHPHQWVDQGLQYHVWPHQWIXQGSURVSHFWXVHVEmpower Retirement IRA account agreements and investment fund DQGGLVFORVXUHGRFXPHQWVIRUPRUHLQIRUPDWLRQprospectuses and disclosure documents for RQIHHVDQGFRVWVDVVRFLDWHGZLWK\RXU(PSRZHU3UHPLHU,5$DFFRmore information on fees and costs associated with your Empower RetirementXQW IRA account.

Investment Fund Service Fees Great-West has entered into agreements with certain investment funds or their affiliates (including advisors, administrators or transfer agents, and underwriters) whereby Great-West provides shareholder services and receives compensation from the investment fund or its affiliates based on assets invested in the fund on its platforms. This compensation may include fees for administrative and other expenses and/or fees paid under a plan of distribution under SEC Rule 12b-1 (12b-1 fees). On average, Great-West receives an annual rate up to sixty basis points on the Empower Retirement IRA platform. The fees received by Great-West are part of the fees already paid to the investment fund as disclosed in the prospectus or similar disclosure document, and are not in addition to fees being charged by the investment fund. Generally, fees and expenses included in the investment fund’s expense ratio are deducted at regular intervals from the investment’s assets.

Additional Investment Fund Compensation: Great-West may receive additional revenue as a finder's fee from non-affiliated investment funds as described in the investment fund’s prospectus. Great-West may also receive additional revenue in the form of conference sponsorship fees from non-affiliated investment fund companies to defray training and education costs of staff.

Empowering Fund Partnership: Great-West Life & Annuity Insurance Company receives payments from some investment fund families through the Empowering Fund Partnership Program (“EFPP”). Under the EFPP, fund families receive several services based on the EFPP tier in which they participate. These services are provided directly to fund families and include: (i) consideration for inclusion in Empower products developed for some segments of the retirement and IRA market, (ii) inclusion on the Empower Select investment platform, which is available in the small plan recordkeeping market, (iii) a waiver of the connectivity fee described below, (iv) enhanced marketing opportunities, (v) additional reporting capabilities, (vi) collaboration in thought leadership opportunities, (vii) access to meetings with Empower leadership, Empower staff, and the third party advisory and brokerage firms through whom Empower distributes its services, and (viii) access to conferences put on by Empower and Great-West Financial. The yearly fees for EFPP participation are $1,000,000 for tier 1, $500,000 for tier 2, and $250,000 for tier 3. These fees do not vary based on an Empower client’s use of the funds offered by the fund family.

Fund Partners Tier 1 Fund Families Tier 2 Fund Families Tier 3 Fund Families AB Funds Alger Funds Goldman Sachs Funds American Century Investments Blackrock Funds Pioneer Investments American Funds1 Federated Investor Funds Schwab Funds Great-West Funds 2 Fidelity Investments Virtus Mutual Funds Natixis Funds3 Franklin Templeton Investments Putnam Investments2 Invesco Funds  1American Funds’ 2019 EFPP fee was paid through cash and other consideration. 2Great-West Funds and Putnam Investments participate in the EFPP due to their affiliation with Great-West Life & Annuity Insurance Company. 3Natixis also includes: AEW, ASG, Gateway, Loomis Sayles, McDonnell, Mirova, Oakmark and Vaughan Nelson.

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Great-West Life & Annuity Insurance Company also receives payments from fund families through a connectivity program (the “Connectivity Program”). The Connectivity Program charges fund families for the cost of administering funds on Empower investment platforms, and for building and maintaining data connections between Empower and the fund family. In 2019, the Connectivity Program charges $1,000 per investment fund used on recordkeeping and IRA investment platforms.

Connectivity Program Connectivity Program Connectivity Program Aberdeen FMI Funds Parnassus Investments American Beacon Funds GMO Funds PNC Funds AMG Guggenheim Principal Artisan Partners Harbor Funds Segall, Bryant & Hamill Baron Funds Hartford Funds Standard Insurance BMO Funds Ivy Funds Summit Global Investments BNY Mellon JAG Funds TD Ameritrade* Brandes Investment Partners Jensen Third Avenue Funds BTS Funds JOHCM Funds Thompson Plumb Buffalo Funds John Hancock Funds TIAA-CREF Cambiar Investors Lazard Tocqueville Carillon Funds Mainstay Funds Torray Causeway Manning & Napier Touchstone Investments Cohen & Steers MetLife Transamerica IDEX Columbia Threadneedle Morgan Stanley Tweedy Browne Davis Select Advisors Morley Funds Victory Funds Delaware Funds Nationwide Voya Financial Driehaus Mutual Funds Neuberger Berman Weitz Funds DWS Nuveen Westwood Investment Mgmt William Blair Wilmington Trust*

*The Connectivity Program fee is waived for collective investment trusts created by some investment advisory firms who have relationships with Empower.

 4Legg Mason Global Asset Management also includes: ClearBridge, EnTrustPermal, QS, Royce and Western Asset Management.

LDOM/MANUAL/SR 8901748 PIRADD 04/27/21 740501-01 MANUAL/DAES/SR 8451718 MANUAL/DAES/SR NO_GRPG/JTYL Page 8125207 30 of 34 PIRADD 11/19/2008/14/2006/14/2004/23/202007/28/20 740501-01 Page 32NO_GRPG/TNER of 36 SR SR 7872631/MANUAL 8094021/MANUAL 7794901/MANUAL Page 12 of 38 PagePagePage 37 11 ofof 3827 PRIVACY NOTICE REV 6/2020

What does Great-West Life & Annuity Insurance Company (Empower Retirement) do with your FACTS personal information?

Financial companies choose how they share your personal information. Federal law gives consumers the right WHY? to limit some but not all sharing. Federal law also requires us to tell you how we collect, share and protect your personal information. Please read this notice carefully to understand what we do.

The types of personal information we collect and share depend on the product or service you have with us. This information can include: • Social Security number and account balances. WHAT? • Retirement assets and transaction history. • Employment information and income. When you are no longer our customer, we continue to share your information as described in this notice.

$OOȴQDQFLDOFRPSDQLHVQHHGWRVKDUHFXVWRPHUVȇSHUVRQDOLQIRUPDWLRQWRUXQWKHLUHYHU\GD\EXVLQHVVΖQWKH HOW? VHFWLRQEHORZZHOLVWWKHUHDVRQVȴQDQFLDOFRPSDQLHVFDQVKDUHWKHLUFXVWRPHUVȇSHUVRQDOLQIRUPDWLRQWKH reasons Empower Retirement chooses to share and whether you can limit this sharing.

REASONS WE CAN SHARE YOUR DOES EMPOWER CAN YOU LIMIT PERSONAL INFORMATION RETIREMENT SHARE? THIS SHARING?

For our everyday business purposes — such as to process your transactions, maintain your account(s), Yes No respond to court orders and legal investigations, or report to credit bureaus

For our marketing purposes — Yes No WRR΍HURXUSURGXFWVDQGVHUYLFHVWR\RX

)RUMRLQWPDUNHWLQJZLWKRWKHUȴQDQFLDOFRPSDQLHV No :HGRQȇWVKDUH

)RURXUDIȴOLDWHVȇHYHU\GD\EXVLQHVVSXUSRVHV— Yes No information about your transactions and experiences

)RURXUDIȴOLDWHVȇHYHU\GD\EXVLQHVVSXUSRVHV— No :HGRQȇWVKDUH information about your creditworthiness

)RUQRQDIȴOLDWHVWRPDUNHWWR\RX No :HGRQȇWVKDUH

QUESTIONS? Call toll-free at 833-346-7283 or go to HPSRZHUUHWLUHPHQWFRPSULYDF\

LDOM/MANUAL/SR 8901748 PIRADD 04/27/21 740501-01 MANUAL/DAES/SR 8451718 MANUAL/DAES/SR NO_GRPG/JTYL Page 8125207 31 of 34 PIRADD 11/19/2008/14/2006/14/2004/23/202007/28/20 740501-01 Page 33NO_GRPG/TNER of 36 SR SR 7872631/MANUAL 8094021/MANUAL 7794901/MANUAL Page 12 of 38 PagePagePage 37 11 ofof 3827 WHO WE ARE

Who is providing Companies owned by Great-West Life & Annuity Insurance Company. A list of companies is WKLVQRWLFH" provided at the end of this notice.

WHAT WE DO

How does Empower To protect your personal information from unauthorized access and use, we use security 5HWLUHPHQWSURWHFWP\ measures that comply with federal law. These measures include physical, technical and SHUVRQDOLQIRUPDWLRQ" procedural safeguards, such as building and system security and personnel training.

We collect your personal information, for example, when you: • Provide account information or apply for a loan. How does Empower • Enter into an investment advisory contract or seek advice about your investments. 5HWLUHPHQWFROOHFWP\ SHUVRQDOLQIRUPDWLRQ" • Tell us about your investment or retirement portfolio. :HDOVRFROOHFW\RXUSHUVRQDOLQIRUPDWLRQIURPRWKHUVVXFKDVFUHGLWEXUHDXVDɝOLDWHVRU other companies.

Federal law gives you the right to limit only: • 6KDULQJIRUDIȴOLDWHVȇHYHU\GD\EXVLQHVVSXUSRVHVȃLQIRUPDWLRQDERXW :K\FDQȇWΖOLPLW your creditworthiness. DOOVKDULQJ" • $IȴOLDWHVIURPXVLQJ\RXULQIRUPDWLRQWRPDUNHWWR\RX • 6KDULQJIRUQRQDIȴOLDWHVWRPDUNHWWR\RX State laws and individual companies may give you additional rights to limit sharing.

DEFINITIONS

&RPSDQLHVUHODWHGE\FRPPRQRZQHUVKLSRUFRQWURO7KH\FDQEHȴQDQFLDODQG QRQȴQDQFLDOFRPSDQLHV $IȴOLDWHV • 2XUDɝOLDWHVLQFOXGHFRPSDQLHVZLWKWKH(PSRZHU(PSRZHU5HWLUHPHQWRU*UHDW:HVW QDPHVDVOLVWHGEHORZDQGRWKHUȴQDQFLDOFRPSDQLHVVXFKDV$GYLVHG$VVHWV*URXS//& DQG(PSRZHU5HWLUHPHQW//&

&RPSDQLHVQRWUHODWHGE\FRPPRQRZQHUVKLSRUFRQWURO7KH\FDQEHȴQDQFLDODQG 1RQDIȴOLDWHV QRQȴQDQFLDOFRPSDQLHV • (PSRZHUGRHVQRWVKDUHZLWKQRQDɝOLDWHVVRWKH\FDQPDUNHWWR\RX

$IRUPDODJUHHPHQWEHWZHHQQRQDIȴOLDWHGȴQDQFLDOFRPSDQLHVWKDWWRJHWKHUPDUNHWȴQDQFLDO Joint marketing products or services to you. • (PSRZHUGRHVQȇWMRLQWO\PDUNHW

WHO IS PROVIDING THIS NOTICE?

Great-West Life & Annuity Insurance Company; The Great-West Life Assurance Company (U.S. operations); Great-West Life & Annuity Insurance Company of New York; Great-West Financial Retirement Plan Services, LLC; Advised Assets Group, LLC; GWFS Equities, Inc.; The Canada Life Assurance Company (U.S. operations); Empower Retirement, LLC; Great-West Life & Annuity Insurance Company of South Carolina; Great-West Capital Management, LLC; Great-West Funds, Inc.; and Great-West Trust Company, LLC

GEN-FLY-WF-152743-0620 (577655)

LDOM/MANUAL/SR 8901748 PIRADD 04/27/21 740501-01 MANUAL/DAES/SR 8451718 MANUAL/DAES/SR NO_GRPG/JTYL Page 8125207 32 of 34 PIRADD 11/19/2008/14/2006/14/2004/23/202007/28/20 740501-01 Page 34NO_GRPG/TNER of 36 SR SR 7872631/MANUAL 8094021/MANUAL 7794901/MANUAL Page 12 of 38 PagePagePage 37 11 ofof 3827 BUSINESS CONTINUITY PLAN NOTICE

GWFS Equities, Inc., a subsidiary of Great-West Life & Annuity Insurance Company and affiliate of Great- West Life & Annuity Insurance Company of New York* (“the Company”) and Empower Retirement, LLC, maintains a comprehensive business continuity plan designed to respond reasonably and effectively to events that lead to significant business disruption, such as natural disasters, power outages, or other events of varying scope. This plan defines critical functions and systems, alternate work locations, vital books and records, and staff resources, and provides for the continuation of business operations with minimal impact, depending on the severity and scope of the disruption. The plan is reviewed and tested no less than once annually to ensure that the information in the plan is kept current and that documented recovery and continuity strategies adequately support its business operations. Of utmost importance to the plan is the ability for customers to maintain access to securities accounts and assets in those accounts.

In the event that one of the contact centers or back office operation facilities becomes unavailable for any reason, calls would be re-routed to one of the firm’s alternative contact center or operations facilities.

In the event of a significant business disruption to the primary office and/or data center, access to customer accounts will be provided via the Company’s Web site and voice response system, operated from an alternative data center. Customer service will continue to be provided by re-routing telephone calls to a contact center located in one or more alternative sites located outside of the region. Secure work from home solutions are available for all staff.

While no contingency plan can eliminate the risk of business interruption, or prevent temporary delays with account access, the firm’s continuity plan is intended to mitigate all reasonable risk and resume critical business operations within 24 hours or the next business day, whichever is later.

* Record keeping and administrative services are provided by Empower Retirement, LLC, and in New York, Great-West Life & Annuity Insurance Company of New York, or one of its subsidiaries or affiliates. Securities offered in your account may be offered through another broker/dealer firm other than GWFS Equities, Inc., a wholly owned subsidiary of Great-West Life & Annuity Insurance Company. Please contact your investment provider for more information if needed.

This disclosure is subject to modification at any time. The most current version of this disclosure can be found on the Web site or can be obtained by requesting a written copy by mail.

BCP – GWFS Customer Notice (Ed. Feb. 2021)

1 PIRADD 04/27/21 740501-01 LDOM/MANUAL/SR 8901748 Page 33 of 34 FINRA Investor Education and BrokerCheck Noti¿ cation Our relationship with you is important to us, so we want to make sure you are aware that important investor information regarding your rights and responsibilities is available through the FINRA web site at www.finra.org. From that site, you can also research the professional backgrounds of current and former broker dealer firms and representatives registered with FINRA to conduct securities business via the FINRA BrokerCheck tool. FINRA BrokerCheck is a free resource you can use to conduct that research and can help you make an informed decision as to the firms and representatives with whom you choose to engage in a business relationship. This information is obtained through form filings that registered representatives, brokerage firms and regulators complete as part of the securities industry registration and licensing process. Through BrokerCheck you can:

‡ Search for both representatives and brokerage firms ‡ Obtain online delivery of a background report ‡ View explanatory information to help you better understand the content provided ‡ See links of additional resources and tools To get started, go to http://www.finra.org/Investors/ToolsCalculators/BrokerCheck/ and click on the Start Search button. This website also allows you to submit questions you have about BrokerCheck via email. Alternatively, you can learn more about BrokerCheck by calling FINRA’s BrokerCheck Hotline 1-800-289-9999. The hours of operation are Monday through Friday from 8 a.m. to 8 p.m., Eastern Time. Thank you.

Ed. Oct/2011

Depending on the terms of the IRA, your assets may be transferred to the appropriate state if no activity occurs in your account within the time period specified by state law.

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