Page 36 - DCAC Nov 2025 Files

Mutual Fund vs. CIT Comparison

Empower – American Funds EUPAC ISA

• ISA Constraints: This is a passive pass-thru vehicle and cannot impose restrictions on the
underlying CIT’s investments. The CIT should, however, practically mirror the mutual fund

in terms of holdings and allocations
• County of San Mateo makes up 0.31% of this ISA’s AUM. This passes Innovest’s due

diligence criteria.
• Inception date of April 1, 2023 does not meet Innovest’s 3-year track record criteria, but
the CIT it is fully invested in does with an inception date of May 13, 2019

Mutual Fund ISA

Assets Under Management $135.1 Billion $4.1 Billion

# of Holdings 345 333

# of Investors N/A 1,143

Inception Date 5/1/2009 4/1/2023 for ISA, 5/13/2019 for CIT

Similar Investment Constraints N/A Yes

Expense Ratio 0.47% 0.41%

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