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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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