Page 28 - DCAC November 2023 Files
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empower.com





          Delivery — training, oversight and credentials
          We are proud of all of our associates who service our   •  Training and monitoring help ensure representatives
          clients’ plans and take care of the people who         are accurately capturing and recording all elements of
          participate in them. Because we want to help people    each engagement.
          reach the retirement they imagine, we are committed    •  Key messages and updates are reinforced via team
          to properly training and registering our associates,   huddles and group communications.
          especially our representatives who provide
          best-interest recommendations.                        •  Best-interest representatives are trained to appropriately
                                                                 use non-discretionary tools to deliver recommendations
          Training                                               in each participant’s best interest.
          To help ensure compliance, Empower representatives go
          through extensive initial education and training as well as   Each representative is expected to complete ongoing
          follow-up instruction covering regulatory requirements,   training to help ensure compliance with regulations.
          advisory tools, and related processes and procedures.  Additionally, ad hoc training is required when tools or
                                                                documentation are updated.
          Such courses focus on:
                                                                Empower has established the following critical components
          •  The difference between education and               to help ensure compliance from an oversight perspective:
           recommendations/advice.
          •  When to advance an education discussion to a       •  Managers and quality assurance team members undergo
           best-interest engagement.                             increased monitoring and coaching.
          •  How to maintain an education/guidance conversation   •  Our call routing and authentication systems have been
           when not engaging in a best-interest analysis.        updated to help ensure best-interest calls are routed
                                                                 only to appropriate representatives.
          •  The tools used to provide product and/or
           investment advice.                                   •  Principals review and approve 100% of
                                                                 best-interest engagements.
          • How to conduct a proper fee-analysis comparison.
                                                                •  An oversight committee monitors Empower’s
          • Customer account record-retention procedures.        program, including advance methodologies, regulations

          This rigorous training enables our representatives to    and compliance.
          exceed expectations when communicating with participants   Credentials
          about recommendations and education. And while the    In addition to undergoing specific training, every Empower
          majority of the calls we receive are not advisory in nature,   representative providing best-interest recommendations
          our representatives are equipped to provide best-interest   is properly registered, carrying FINRA and state securities
          recommendations when appropriate.                     registrations, licenses, or credentials as required prior to

          We are committed to providing this level of service and   participant engagement.
          proud of the efforts we make to do so.                Industry knowledge and context are important to positive

          •  All service center and customer-facing representatives   participant experiences. That’s why all our representatives
           go through extensive training that includes role playing   are required to keep their registrations current even if
           designed to identify different discussion types, respective   they do not participate in best-interest discussions.
           roles and when to warm-transfer calls.
          •  Online and desktop aides have been created to
           help associates.








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