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Participation or Interest in Client Transactions Affiliate EFSI effects Securities Transactions for Advisory Clients Registered representatives of EFSI may provide wholesaling, direct sales, enrollment, and/or communication services to retirement plans and their participants for which EAG may also provide its services. In return, EFSI may receive fees from either the plan or the investment provider (fund families). All securities transactions which occur as a result of EAG's services, as described in this Brochure, are executed by EFSI. EFSI 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 plan investment options. In all instances, EAG's affiliation with these entities is disclosed. Allocations in the investment options are solely determined and based on Morningstar Investment Management's software and not determinations made by EAG. The compensation paid by EAG 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 EAG and EFSI, EAG does not believe there is a conflict of interest. Affiliate EAIC or ELAINY Proprietary Investments Investment options into which participant or accountholder assets may be allocated, pursuant to the OA or the MA services may be through a fixed and variable deferred annuity issued by EAIC or ELAINY. Because Morningstar Investment Management is unaffiliated with EAG, EAIC, ELAINY and their affiliates, EAG does not believe there is a conflict of interest. However, in all instances, EAG's affiliation with EAIC and/or EAIC's affiliates, as applicable, will be disclosed. Item 12—Brokerage Practices Brokerage Selection; Best Execution For retirement plans, the plan sponsor or its agent selects the broker -dealer used by the retirement plan and determines the reasonableness of the compensation. EAG does not select or recommend broker -dealers for stock transactions or self -directed brokerage accounts and does not determine the reasonableness of broker -dealer's compensation. Transactions recommended by Morningstar Investment Management for the Service are processed by EAG's affiliated recordkeeper, Empower, and generally executed through EFSI. Soft Dollar Practices As a matter of policy, EAG does not utilize research or other products or services from third parties in connection with client securities transactions on a soft -dollar commission basis. Directed Brokerage The plan sponsor may elect to offer brokerage services to participants in the retirement plan. EAG does not participate in such decisions and does not provide recommended portfolios or investment recommendations on assets held in a brokerage account under the retirement plan. Trade Aggregation EAG does not bunch orders or engage in block trades to execute equity orders for clients. Client accounts are generally held intrust per regulatory requirements. Further, most trades are mutual funds where trade aggregation does provide any additional client benefits. Item 13 — Review of Accounts At least annually, EAG personnel review the methodologies used by Morningstar Investment Management to power the OIG, OA, and MA services to ensure that they are consistent with investment advisory best practices, current technology, applicable law, and the terms of the agreement between EAG and Morningstar Investment Management. Neither EAG nor Morningstar Investment Management review the personal financial information of participants as provided by the participants or the Plan Sponsor and do not assume responsibility for any incomplete or erroneous 17 City Council 19 — 95 9/19/2023