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Empower Institutional Separate Accounts (ISAs) Pros & Cons





                                     Pros                                                                  Cons


                                  •   Cost savings                                                       •   Lack of robust information for ISAs available

                                                                                                             online creating an inability for participants to
                                  •   The potential of improved net of fees                                  do their own research outside of Empower

                                      performance
                                                                                                         •   Cash flow differences between the mutual

                                  •   From a participant’s viewpoint, ISAs operate                           fund and ISA can create discrepancies in
                                      very similar to mutual funds or CITs                                   returns, sometimes favoring the mutual fund



                                                                                                         •   Inability to see and track the fee breakdown
                                                                                                             between the asset manager and Empower

                                                                                                             –    Empower is collecting additional revenue
                                                                                                                  that cannot be traced



                                                                                                         •   If ISA assets drop below what Empower

                                                                                                             requires to operate the fund without a loss,
                                                                                                             Empower will map the ISA assets to a similar

                                                                                                             ISA
                                                                                                             –    The client is provided a 90-day notice



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