# Empower Financial Services Inc. X-17A-5 (2026-02-26) — Broker-dealer annual report

- Company: Empower Financial Services Inc.
- Form: X-17A-5
- Filed: 2026-02-26
- Period: 2025-12-31
- Accession: 0000765936-26-000003
- CIK: 765936
- File #: 8-33854
- Type: Broker-dealer
- Material weakness: No
- Auditor: Deloitte & Touche LLP
- Auditor location: Denver, CO
- Contact: Danica Athanassiou
- Phone: 303-737-3856
- Email: danica.athanassiou@empower.com
- Website: empower.com
- Signed by: Robert Ettinger (Vice President & Treasurer)

Original filing: https://www.sec.gov/Archives/edgar/data/765936/000076593626000003/a2025empowerfinancialservi.pdf

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U NI T E D S T A T E S S E C U RI TI E S A N D E X C H A N G E C O M MI S SI O N W as hi n gt o n, D. C. 2 0 5 4 9

O M B A P P R O V AL O M B Nu m b er: 3 2 3 5- 0 1 2 3 Ex pir es: N o v . , 2 0 2 6 Esti m at e d av er a g e bur d e n h o urs p er res p o ns e: 1 2

> S E C FIL E N U M B E R 8-33854

# A N N U AL R E P O R T S F O R M X 1 7 A - 5 P A R T III

| I<br>nf<br>or<br>m<br>ati<br>o<br>n R<br>e<br>q<br>uir<br>e<br>d P<br>urs<br>u<br>a<br>nt t                                                                                                                                                                                  | F<br>A<br>CI<br>N<br>G P<br>A<br>G<br>E<br>o R<br>ul<br>es 1<br>7<br>a<br>5, 1<br>7<br>a<br>1<br>2, a<br>n<br>d 1<br>8<br>a<br>7 u<br>n<br>d                                                                                    | er t<br>h<br>e S<br>ec<br>uriti<br>es E<br>xc<br>h<br>a<br>n<br>g<br>e Act of 1<br>9<br>3<br>4                                                                                       |
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| FILI<br>N<br>G F<br>O<br>R T<br>H<br>E P<br>E<br>RI<br>O<br>D B<br>E<br>GI<br>N<br>NI<br>N                                                                                                                                                                                   | 01/01/25<br>G _<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_ A<br>N<br>D E                                                                                               | 12/31/25<br>N<br>DI<br>N<br>G _<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_                                             |
|                                                                                                                                                                                                                                                                              | M<br>M/<br>D<br>D/<br>Y<br>Y                                                                                                                                                                                                    | M<br>M/<br>D<br>D/<br>Y<br>Y                                                                                                                                                         |
|                                                                                                                                                                                                                                                                              | A. R<br>E<br>GI<br>S<br>T<br>R<br>A<br>N<br>T I<br>D<br>E<br>N<br>TI<br>FI<br>C<br>A<br>TI<br>O<br>N                                                                                                                            |                                                                                                                                                                                      |
| N<br>A<br>M<br>E O<br>F FI<br>R<br>M: _<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_                                                                                                                                                                     | Empower Financial Services, Inc.<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_                                                    | _<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_                                        |
| T<br>Y<br>P<br>E O<br>F R<br>E<br>GI<br>S<br>T<br>R<br>A<br>N<br>T (c<br>h<br>eck all a<br>p<br>Br<br>ok<br>er<br>d<br>e<br>al<br>er<br>S<br>ec<br>urit<br>y<br>■<br>C<br>h<br>ec<br>k h<br>er<br>e if r<br>es<br>p<br>o<br>n<br>d<br>e<br>nt is als<br>o a                  | plic<br>a<br>bl<br>e b<br>ox<br>es):<br>b<br>as<br>e<br>d s<br>w<br>a<br>p d<br>e<br>al<br>er<br>M<br>aj<br>or s<br>n O<br>T<br>C d<br>eriv<br>ativ<br>es d<br>e<br>al<br>er                                                    | ec<br>urity<br>b<br>as<br>e<br>d s<br>w<br>a<br>p p<br>artici<br>p<br>a<br>nt                                                                                                        |
| A<br>D<br>D<br>R<br>E<br>S<br>S O<br>F P<br>RI<br>N<br>CI<br>P<br>AL PL<br>A<br>C<br>E O<br>F B                                                                                                                                                                              | U<br>SI<br>N<br>E<br>S<br>S: (<br>D<br>o n<br>ot us<br>e a P.<br>O. b<br>ox n                                                                                                                                                   | o.)                                                                                                                                                                                  |
| Seventh Floor - 8515 East Orchard Road<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_                                                                                           | _<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_                                                                                             | _<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_                                   |
|                                                                                                                                                                                                                                                                              | (<br>N<br>o. a<br>n<br>d Str<br>e<br>et)                                                                                                                                                                                        |                                                                                                                                                                                      |
| Greenwood Village<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_                                                                                                                | CO<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_                                                                                       | 80111<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_                          |
| (<br>Cit<br>y                                                                                                                                                                                                                                                                | (<br>St<br>at<br>e)                                                                                                                                                                                                             | (<br>Zi<br>p C<br>o<br>d<br>e)                                                                                                                                                       |
| P<br>E<br>R<br>S<br>O<br>N T<br>O C<br>O<br>N<br>T<br>A<br>C<br>T<br>WI<br>T<br>H R<br>E<br>G<br>A                                                                                                                                                                           | R<br>D T<br>O T<br>HI<br>S FILI<br>N<br>G                                                                                                                                                                                       |                                                                                                                                                                                      |
| Danica Athanassiou<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_                                                                                                               | 303-737-3856<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_                                                                             | danica.athanassiou@empower.com<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_ |
| (<br>N<br>a<br>m<br>e)                                                                                                                                                                                                                                                       | (<br>Ar<br>e<br>a C<br>o<br>d<br>e – T<br>el<br>e<br>p<br>h<br>o<br>n<br>e N<br>u<br>m<br>b<br>er)                                                                                                                              | (<br>E<br>m<br>ail A<br>d<br>dr<br>ess)                                                                                                                                              |
|                                                                                                                                                                                                                                                                              | B. A<br>C<br>C<br>O<br>U<br>N<br>T<br>A<br>N<br>T I<br>D<br>E<br>N<br>TI<br>FI<br>C<br>A<br>TI<br>O                                                                                                                             | N                                                                                                                                                                                    |
| I<br>N<br>D<br>E<br>PE<br>N<br>D<br>E<br>N<br>T P<br>U<br>BLI<br>C A<br>C<br>C<br>O<br>U<br>N<br>T<br>A<br>Deloitte & Touche LLP<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_ | N<br>T w<br>h<br>os<br>e r<br>e<br>p<br>orts ar<br>e c<br>o<br>nt<br>ai<br>n<br>e<br>d i<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_ | n t<br>his fili<br>n<br>g<br>*<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_ |
| (<br>N<br>a<br>m                                                                                                                                                                                                                                                             | e – if i<br>n<br>divi<br>d<br>u<br>al, st<br>at<br>e l<br>ast, first,<br>a<br>n<br>d mi<br>d<br>dl                                                                                                                              | e n<br>a<br>m<br>e)                                                                                                                                                                  |
| 1601 Wewatta Street, Suite 400<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_                                                                                                   | Denver<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_                                                                              | CO<br>80202-3492<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_                    |
| (<br>A<br>d<br>dr<br>ess)                                                                                                                                                                                                                                                    | (<br>Cit<br>y)                                                                                                                                                                                                                  | (<br>St<br>at<br>e)<br>(<br>Zi<br>p C<br>o<br>d<br>e)                                                                                                                                |
| 10/20/2003<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_                                                                                                                       | _<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_                                                                                        | ID 34<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_                               |
| (<br>D<br>at<br>e of R<br>e<br>gistr<br>ati<br>o<br>n wit<br>h PC<br>A<br>O<br>B)<br>(if a<br>p<br>plic                                                                                                                                                                      | a<br>bl<br>e)                                                                                                                                                                                                                   | (<br>P<br>C<br>A<br>O<br>B R<br>e<br>gistr<br>ati<br>o<br>n N<br>u<br>m<br>b<br>er, if a<br>p<br>plic<br>a<br>bl<br>e)                                                               |
|                                                                                                                                                                                                                                                                              | F<br>O<br>R O<br>F<br>FI<br>CI<br>AL U<br>S<br>E O<br>NL<br>Y                                                                                                                                                                   |                                                                                                                                                                                      |

\* Cl ai ms f or ex e m pti o n fr o m t h e r e q uir e m e nt t h at t h e a n n u al r e p orts b e c o v er e d by t h e r e p orts of a n i n d e p e n d e nt p u blic acc o u nt a nt m ust b e s u p p ort e d b y a st at e m e nt of f acts a n d circ u mst a nc es r eli e d o n as t h e b asis of t h e ex e m pti o n. S e e 1 7 C F R 2 4 0. 1 7 a 5( e)( 1)(ii), if a p plic a bl e.

P ers o ns w h o ar e t o r es p o n d t o t h e c oll ecti o n of i nf or m ati o n c o nt ai n e d i n t his f or m ar e n ot r e q uir e d t o r es p o n d u nl ess t h e f or m dis pl a ys a c urr e ntl y v ali d O M B c o ntr ol n u m b er.

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# O A T H O R A F FI R M A TI O N

| I, _<br>_<br>_<br>_<br>__<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>Robert Ettinger    | _<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_ | _<br>_<br>_<br>_<br>_<br>_<br>_<br>_, s<br>w<br>e<br>ar (<br>or affir<br>m) t<br>h<br>at, t<br>o t<br>h<br>e b<br>est of my k<br>n<br>o<br>wl<br>e<br>d<br>g<br>e a<br>n<br>d b<br>eli                                                                                                                                                        | ef, t<br>h<br>e |
|-----------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------|
| fi<br>n<br>a<br>nci<br>al r<br>e<br>p<br>ort<br>p<br>ert<br>ai<br>ni<br>n<br>g<br>t<br>o<br>t                                                       | h<br>e<br>fir<br>m<br>of                  | _<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_,<br>Empower Financial Services, Inc. | as<br>of        |
| December 31,<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_<br>_ | _<br>_<br>_, 2<br>_<br>_<br>_<br>_<br>025 | _, is tr<br>u<br>e a<br>n<br>d c<br>orr<br>ect. I f<br>urt<br>h<br>er s<br>w<br>e<br>ar (<br>or affir<br>m) t<br>h<br>at n<br>eit<br>h<br>er t<br>h<br>e c<br>o<br>m<br>p<br>a<br>n<br>y n                                                                                                                                                    | or a<br>ny      |

p art n er, offic er, dir ect or , or e q uiv al e nt p ers o n, as t h e c as e m a y b e, h as a n y pr o pri et ar y i nt er est i n a n y acc o u nt cl assifi e d s ol el y as t h at of a c ust o m er .

Si g n at ur e: \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ Titl e: \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ Vice President & Treasurer

T his fili n g \* \* co nt ai ns (c h ec k all a p plic a bl e bo x es):

- ☐ (a) St at e m e nt of fi n a nci al c o n diti o n.
- ☐ (b) N ot es t o c o ns oli d at e d st at e m e nt of fi n a nci al c o n diti o n.
- ☐ (c) St at e m e nt of i nc o m e (l oss) or, if t h er e is ot h er c o m pr e h e nsi v e i nc o m e i n t h e p eri o d(s) pr es e nt e d, a st at e m e nt of c o m pr e h e nsi v e i nc o m e ( as d efi n e d i n § 2 1 0. 1 -0 2 of R e g ul ati o n S -X) .
- ☐ ( d) St at e m e nt of c as h fl o ws.
- ☐ ( e) St at e m e nt of c h a n g es i n st oc k h ol d ers' or p art n ers' or s ol e pr o pri et or's e q uit y.
- ☐ (f) St at e m e nt of c h a n g es i n li a biliti es s u b or di n at e d t o cl ai ms of cr e dit ors.
- ☐ ( g) N ot es t o c o ns oli d at e d fi n a nci al st at e m e nts.
- ☐ (h) C o m p ut ati o n of n et c a pit al u n d er 1 7 C F R 2 4 0. 1 5c 3 -1 or 1 7 C F R 2 4 0. 1 8 a 1, as a p plic a bl e.
- ☐ (i) C o m p ut ati o n of t a n gi bl e n et w ort h u n d er 1 7 C F R 2 4 0. 1 8 a -2.
- ☐ (j) C o m p ut ati o n f or d et er mi n ati o n of c ust o m er r es er v e r e q uir e m e nts p urs u a nt t o Ex hi bit A t o 1 7 C F R 2 4 0. 1 5c 3 -3.
- ☐ ( k) C o m p ut ati o n f or d et er mi n ati o n of s ec urit y-b as e d s w a p r es er v e r e q uir e m e nts p urs u a nt t o Ex hi bit B t o 1 7 C F R 2 4 0. 1 5c 3 -3 or Ex hi bit A t o 1 7 C F R 2 4 0. 1 8 a -4, as a p plic a bl e.
- ☐ (l) C o m p ut ati o n f or D et er mi n ati o n of P A B R e q uir e m e nts u n d er Ex hi bit A t o § 2 4 0. 1 5c 3 3.
- ☐ (m) I nf or m ati o n r el ati n g t o p oss essi o n or c o ntr ol r e q uir e m e nts f or c ust o m ers u n d er 1 7 C F R 2 4 0. 1 5c 3 -3.
- ☐ (n) I nf or m ati o n r el ati n g t o p oss essi o n or c o ntr ol r e q uir e m e nts f or s ec urit y -b as e d s w a p c ust o m ers u n d er 1 7 C F R 2 4 0. 1 5c 3 -3( p)( 2) or 1 7 C F R 2 4 0. 1 8 a -4, as a p plic a bl e.
- ☐ (o) R ec o ncili ati o ns, i ncl u di n g a p pr o pri at e ex pl a n ati o ns, of t h e F O C U S R e p ort wit h c o m p ut ati o n of n et c a pit al or t a n gi bl e n et w ort h u n d er 1 7 C F R 2 4 0. 1 5c 3 -1, 1 7 C F R 2 4 0. 1 8 a -1, or 1 7 C F R 2 4 0. 1 8 a -2, as a p plic a bl e, a n d t h e r es er v e r e q uir e m e nts u n d er 1 7 C F R 2 4 0. 1 5c 3 -3 or 1 7 C F R 2 4 0. 1 8 a -4, as a p plic a bl e, if m at eri al diff er e nc es exist, or a st at e m e nt t h at n o m at eri al diff er e nc es exist.
- ☐ (p) S u m m ar y of fi n a nci al d at a f or s u bsi di ari es n ot c o ns oli d at e d i n t h e st at e m e nt of fi n a nci al c o n diti o n.
- ☐ (q) O at h or affir m ati o n i n acc or d a nc e wit h 1 7 C F R 2 4 0. 1 7 a-5, 1 7 C F R 2 4 0. 1 7 a -1 2, or 1 7 C F R 2 4 0. 1 8 a -7, as a p plic a bl e .
- ☐ (r) C o m pli a nc e r e p ort i n acc or d a nc e wit h 1 7 C F R 2 4 0. 1 7 a -5 or 1 7 C F R 2 4 0. 1 8 a -7, as a p plic a bl e.
- ☐ (s) Ex e m pti o n r e p ort i n acc or d a nc e wit h 1 7 C F R 2 4 0. 1 7 a 5 or 1 7 C F R 2 4 0. 1 8 a -7, as a p plic a bl e.
- ☐ (t) I n d e p e n d e nt p u blic acc o u nt a nt's r e p ort b as e d o n a n ex a mi n ati o n of t h e st at e m e nt of fi n a nci al c o n diti o n.
- ☐ (u) I n d e p e n d e nt p u blic acc o u nt a nt's r e p ort b as e d o n a n ex a mi n ati o n of t h e fi n a nci al r e p ort or fi n a nci al st at e m e nts u n d er 1 7 C F R 2 4 0. 1 7 a -5, 1 7 C F R 2 4 0. 1 8 a -7, or 1 7 C F R 2 4 0. 1 7 a -1 2, as a p plic a bl e.
- ☐ (v) I n d e p e n d e nt p u blic acc o u nt a nt's r e p ort b as e d o n a n ex a mi n ati o n of c ert ai n st at e m e nts i n t h e c o m pli a nc e r e p ort u n d er 1 7 C F R 2 4 0. 1 7 a -5 or 1 7 C F R 2 4 0. 1 8 a -7, as a p plic a bl e.
- ☐ (w) I n d e p e n d e nt p u blic acc o u nt a nt's r e p ort b as e d o n a r evi e w of t h e ex e m pti o n r e p ort u n d er 1 7 C F R 2 4 0. 1 7 a 5 or 1 7 C F R 2 4 0. 1 8 a -7, as a p plic a bl e.
- ☐ (x) S u p pl e m e nt al r e p orts o n a p pl yi n g a gr e e d-u p o n pr o ce d ur es, i n acc or d a nc e wit h 1 7 C F R 2 4 0. 1 5c 3 -1 e or 1 7 C F R 2 4 0. 1 7 a -1 2, as a p plic a bl e.
- ☐ ( y) R e p ort d escri bi n g a n y m at eri al i n a d e q u aci es f o u n d t o exist or f o u n d t o h a v e exist e d si nc e t h e d at e of t h e pr evi o us a u dit, or a st at e m e nt t h at n o m at eri al i n a d e q u aci es exist, u n d er 1 7 C F R 2 4 0. 1 7 a -1 2( k).
- ☐ (z) Ot h er: \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_ \_
- \* \* T o r e q u est c o nfi d e nti al tr e at m e nt of c ert ai n p orti o ns of t his fili n g, s e e 1 7 C F R 2 4 0. 1 7 a -5( e)( 3) or 1 7 C F R 2 4 0. 1 8 a -7( d)( 2), as a p plic a bl e.

{2}------------------------------------------------

# **Empower Financial Services, Inc. (a wholly-owned subsidiary of Empower Annuity Insurance Company of America)**

*(SEC I.D. No. 8-33854) Financial Statements and Supplemental Schedules as of and for the Year Ended December 31, 2025 and Report of Independent Registered Public Accounting Firm* 

*Filed Pursuant to Rule 17a-5(e)(3)* as a PUBLIC DOCUMENT

{3}------------------------------------------------

| REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM                                                                    | 1  |
|----------------------------------------------------------------------------------------------------------------------------|----|
| FINANCIAL STATEMENTS AS OF AND FOR THE YEAR ENDED DECEMBER 31, 2025<br>Statement of Financial Condition<br>                | 3  |
| Statement of Income<br>                                                                                                    | 4  |
| Statement of Stockholder's Equity<br>                                                                                      | 5  |
| Statement of Cash Flows                                                                                                    | 6  |
| FOOTNOTES                                                                                                                  |    |
| Note 1 - Organization and Basis of Presentation                                                                            | 7  |
| Note 2 - Significant Accounting Policies and New Accounting Pronouncements                                                 | 7  |
| Note 3 - Related Party Transactions                                                                                        | 11 |
| Note 4 - Fair Value Measurements                                                                                           | 12 |
| Note 5 - Income Taxes<br>                                                                                                  | 13 |
| Note 6 - Regulatory Requirements                                                                                           | 13 |
| Note 7 - Contingencies                                                                                                     | 14 |
| Note 8 - Segment Information                                                                                               | 14 |
| SUPPLEMENTAL SCHEDULES AS OF DECEMBER 31, 2025                                                                             |    |
| Schedule (h) - Computation of Net Capital for Brokers and Dealers Pursuant to Rule 15c3-1                                  | 15 |
| Schedule (j) - Computation for Determination of Reserve Requirements for Brokers and Dealers Pursuant to<br>Rule 15c3-3(e) | 16 |
| Schedule (m) - Information Relating to the Possession or Control for Brokers and Dealers Pursuant to Rule<br>15c3-3(b)     | 17 |
|                                                                                                                            |    |

{4}------------------------------------------------

# REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

To the Board of Directors and Stockholder Empower Financial Services, Inc. 8515 East Orchard Road Greenwood Village, Colorado 80111

# Opinion on the Financial Statements

We have audited the accompanying statement of financial condition of Empower Financial Services, Inc. (the "Company" or "EFSI") (a wholly-owned subsidiary of Empower Annuity Insurance Company of America) as of December 31, 2025, and the related statements of income, stockholder's equity, and cash flows for the year then ended, and the related notes (collectively referred to as the "financial statements"). In our opinion, the financial statements present fairly, in all material respects, the financial position of the Company as of December 31, 2025, and the results of its operations and its cash flows for the year then ended in conformity with accounting principles generally accepted in the United States of America.

# Basis for Opinion

These financial statements are the responsibility of the Company's management. Our responsibility is to express an opinion on the Company's financial statements based on our audit. We are a public accounting firm registered with the Public Company Accounting Oversight Board (United States) (PCAOB) and are required to be independent with respect to the Company in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB.

We conducted our audit in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement, whether due to error or fraud.

Our audit included performing procedures to assess the risks of material misstatement of the financial statements, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statements. Our audit also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statements. We believe that our audit provides a reasonable basis for our opinion.

# Emphasis of a Matter

The Company engages in various related-party transactions with affiliates under common control as discussed in Note 3 to the financial statements. The accompanying financial statements are not necessarily indicative of the conditions that would have existed or the results of operations that would prevail if the Company had been operated as an unaffiliated company. Our opinion is not modified with respect to this matter.

{5}------------------------------------------------

# Report on Supplemental Schedules

The accompanying supplemental schedules (h), (j), and (m) (collectively "the supplemental schedules") have been subjected to audit procedures performed in conjunction with the audit of the Company's financial statements. The supplemental schedules are the responsibility of the Company's management. Our audit procedures included determining whether the supplemental schedules reconcile to the financial statements or the underlying accounting and other records, as applicable, and performing procedures to test the completeness and accuracy of the information presented in the supplemental schedules. In forming our opinion on the supplemental schedules, we evaluated whether the supplemental schedules, including their form and content, are presented in compliance with Rule 17a-5 under the Securities Exchange Act of 1934. In our opinion, such schedules are fairly stated, in all material respects, in relation to the financial statements as a whole.

/s/ Deloitte & Touche LLP

Denver, Colorado February 26, 2026

We have served as the Company's auditor since 1985.

{6}------------------------------------------------

### (A wholly-owned subsidiary of Empower Annuity Insurance Company of America)

Statement of Financial Condition

As of December 31, 2025

| Assets                                                |                   |
|-------------------------------------------------------|-------------------|
| Cash and cash equivalents                             | \$<br>31,530,894  |
| Cash segregated under federal regulations             | 8,198,301         |
| Fixed maturity investments - trading, at fair value   | 1,772,887         |
| Fees receivable                                       | 61,739,011        |
| Deferred income taxes                                 | 26,836            |
| Other assets                                          | 180,682           |
| Total assets                                          | 103,448,611       |
| Liabilities and stockholder's equity                  |                   |
| Accounts payable and accrued expenses                 | 8,345,573         |
| Due to affiliates                                     | 77,637,328        |
| Total liabilities                                     | 85,982,901        |
| Contingencies (see Note 7)                            |                   |
| Stockholder's equity                                  |                   |
| Common stock, no par value, 10,000 shares authorized; |                   |
| 4,000 shares issued and outstanding                   | 2,200,000         |
| Additional paid-in capital                            | 12,168,491        |
| Retained earnings                                     | 3,097,219         |
| Total stockholder's equity                            | 17,465,710        |
| Total liabilities and stockholder's equity            | \$<br>103,448,611 |

{7}------------------------------------------------

(A wholly-owned subsidiary of Empower Annuity Insurance Company of America)

Statement of Income

For the Year Ended December 31, 2025

| Revenues:                           |                 |
|-------------------------------------|-----------------|
| Administration fees                 | \$ 409,089,976  |
| Commissions                         | 2,299,501       |
| Investment income                   | 2,671,273       |
| Other income                        | 7,034,586       |
| Investment gains, net               | 109,025         |
| Total revenues                      | 421,204,361     |
| Expenses:                           |                 |
| Service level agreement expenses    | 405,249,353     |
| General and administrative expenses | 13,598,757      |
| Total expenses                      | 418,848,110     |
| Income before income taxes          | 2,356,251       |
| Income tax expense                  | 561,487         |
| Net income                          | \$<br>1,794,764 |
|                                     |                 |

{8}------------------------------------------------

(A wholly-owned subsidiary of Empower Annuity Insurance Company of America) Statement of Stockholder's Equity For the Year Ended December 31, 2025

|                            | Additional   |    |           |         |            |          |           |    |            |  |
|----------------------------|--------------|----|-----------|---------|------------|----------|-----------|----|------------|--|
|                            | Common Stock |    |           | Paid-In |            | Retained |           |    |            |  |
|                            | Shares       |    | Amount    |         | Capital    |          | Earnings  |    | Total      |  |
| Balance, January 1, 2025   | 4,000        | \$ | 2,200,000 | \$      | 12,168,491 | \$       | 1,302,455 | \$ | 15,670,946 |  |
| Net income                 | —            |    | —         |         | —          |          | 1,794,764 |    | 1,794,764  |  |
| Balance, December 31, 2025 | 4,000        | \$ | 2,200,000 | \$      | 12,168,491 | \$       | 3,097,219 | \$ | 17,465,710 |  |

{9}------------------------------------------------

### (A wholly-owned subsidiary of Empower Annuity Insurance Company of America)

Statement of Cash Flows

For the Year Ended December 31, 2025

| Cash flows from operating activities:                                                                     |                  |
|-----------------------------------------------------------------------------------------------------------|------------------|
| Net income                                                                                                | \$<br>1,794,764  |
| Adjustments to reconcile net income to net cash used by operating activities:                             |                  |
| Amortization of premium on investments                                                                    | 11,274           |
| Investment (gains) losses, net                                                                            | (109,025)        |
| Deferred income taxes                                                                                     | 38,536           |
| Changes in operating assets and liabilities:                                                              |                  |
| Fees receivable                                                                                           | 7,087,348        |
| Other assets                                                                                              | 1,054,775        |
| Accounts payable and accrued expenses                                                                     | 8,046,080        |
| Due to/from affiliates                                                                                    | (48,615,031)     |
| Net cash used in operating activities                                                                     | (30,691,279)     |
| Cash flows from investing activities:                                                                     |                  |
| Proceeds from sales, maturities and redemptions of fixed maturity investments                             | 318,211          |
| Net cash provided by investing activities                                                                 | 318,211          |
| Net decrease in cash, cash equivalents and segregated cash                                                | (30,373,068)     |
| Cash, cash equivalents and segregated cash, beginning of year                                             | 70,102,263       |
| Cash, cash equivalents and segregated cash, end of year                                                   | \$<br>39,729,195 |
| Supplemental disclosure of cash flow information:<br>Net cash paid during the year for state income taxes | \$<br>2,000      |

{10}------------------------------------------------

(A wholly-owned subsidiary of Empower Annuity Insurance Company of America) **Notes to the Financial Statements**

### **1. Organization and Basis of Presentation**

### *Organization*

Empower Financial Services, Inc. (the "Company") is a non-clearing broker-dealer that provides a broad range of financial instruments, mutual fund and insurance products, and other financial services to institutional and retail brokerage customers. The Company is registered as a general securities firm and acts as an introducing brokerage firm in the offer and sale of debt and equity securities, including municipal securities, which are cleared on a fully disclosed basis through third party broker-dealers. The Company is exempt from the provisions of Rule 15c3-3 of the Securities Exchange Act of 1934 (the "Rule"), as the Company satisfies the conditions for exemption appearing in paragraphs (k)(2)(i) and (k)(2)(ii) of the Rule. See supplemental schedule (j) and supplemental schedule (m) accompanying the financial statements.

The Company is a wholly-owned subsidiary of Empower Annuity Insurance Company of America ("EAICA"), which is a wholly-owned subsidiary of Empower Holdings, LLC ("EHL"). EHL is a direct wholly-owned subsidiary of Great West Lifeco U.S. ("Lifeco U.S.") and an indirect wholly-owned subsidiary of Great-West Lifeco Inc. ("Lifeco"), a Canadian holding company.

The Company is registered with the Securities and Exchange Commission ("SEC") and the Financial Industry Regulatory Authority ("FINRA").

### *Basis of presentation*

The financial statements include the accounts of the Company and are prepared in accordance with accounting principles generally accepted in the United States of America ("U.S. GAAP"). The Company and its affiliates have significant interdependencies and related party transactions, as described in Note 3. The accompanying financial statements have been prepared from the separate records maintained by the Company and may not be indicative of the financial position or the results of operations that would have existed if the Company had been operated as an unaffiliated company.

### *Use of estimates*

The preparation of financial statements in conformity with U.S. GAAP requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities and disclosure of contingent assets and liabilities at the date of the financial statements and the reported amounts of revenues and expenses during the reported period. Significant estimates may include the valuation of investments in the absence of quoted market values and the valuation of deferred tax assets or liabilities. Actual results could differ from those estimates.

### **2. Significant Accounting Policies and New Accounting Pronouncements**

### *Cash and cash equivalents*

Cash includes amounts in demand deposit accounts. Cash equivalents include highly liquid investments that are readily convertible into cash and are not subject to significant risk from fluctuations in interest rates.

### *Cash segregated under federal regulations*

The Company is subject to the Rule, which requires segregation of cash or qualified securities for the exclusive benefit of retirement plans, institutional or brokerage clients.

{11}------------------------------------------------

# (A wholly-owned subsidiary of Empower Annuity Insurance Company of America)

# **Notes to the Financial Statements**

### *Fixed maturity investments - trading, at fair value*

The Company classifies its fixed maturity investments as trading which are carried at fair value with changes in fair value reported in investment gains (losses), net within the statement of income. Premiums and discounts are recognized as a component of investment income using the effective interest method. Realized gains and losses are determined on a specific identification basis and included in investment gains (losses), net.

The recognition of income on certain investments is dependent upon market conditions, which may result in prepayments and changes in amounts to be earned. Prepayments on all mortgage-backed securities are monitored monthly and amortization of the premium and/or the accretion of the discount associated with the purchase of such securities are adjusted by such prepayments.

### *Fees receivable*

Fees receivable primarily relate to amounts receivable from customers as a result of trades or contracts which are unsettled as of the year ended December 31, 2025. These balances include mutual fund fee revenue accrual amounts. Fees are generally invoiced quarterly and due within 30 days. The Company records an allowance for expected credit losses in an amount that represents the portion of the receivable that the Company does not expect to be collected. At December 31, 2025, all receivables were expected to be collected and there was no provision for credit losses.

### *Other assets*

Other assets consist primarily of prepaid expenses, investment income accrued, and miscellaneous assets arising from the normal course of business. Prepaid expenses and deposits are recorded at cost and amortized over the related service period. Investment income accrued represents amounts earned but not yet received as of the reporting date. Other assets are reviewed periodically for recoverability and are recorded at amounts expected to be realized.

### *Fair value*

Certain assets are recorded at fair value on the Company's statement of financial condition. The Company defines fair value as the price that would be received to sell an asset or paid to transfer a liability in the principal or most advantageous market for the asset in an orderly transaction between market participants on the measurement date. The Company categorizes its assets measured at fair value on a recurring basis into a three-level hierarchy, based on the priority of the inputs to the respective valuation technique. The fair value hierarchy gives the highest priority to quoted prices in active markets for identical assets (Level 1) and the lowest priority to unobservable inputs (Level 3). The Company's assets recorded at fair value on a recurring basis have been categorized based upon the following fair value hierarchy:

- Level 1 inputs utilize observable, quoted prices (unadjusted) in active markets for identical assets that the Company has the ability to access at the measurement date. Financial assets utilizing Level 1 inputs include certain money market funds.
- Level 2 inputs utilize other than quoted prices included in Level 1 that are observable for the asset, either directly or indirectly. Level 2 inputs include quoted prices for similar assets in active markets and inputs other than quoted prices that are observable for the asset, such as interest rates and yield curves that are observable at commonly quoted intervals. The fair values for some Level 2 securities are obtained from pricing services. The inputs used by the pricing services are reviewed at least quarterly or when the pricing vendor issues updates to its pricing methodology. For fixed maturity investments, inputs include benchmark yields, reported trades, broker-dealer quotes, issuer spreads, two-sided markets, benchmark securities, bids, evaluated bids, offers and reference data including market research publications. Additional inputs utilized for U.S. Agency Pools classified as Level 2 are FINRA reported trades, To Be Announced ("TBA") prices and monthly payment information.

{12}------------------------------------------------

# (A wholly-owned subsidiary of Empower Annuity Insurance Company of America)

### **Notes to the Financial Statements**

• Level 3 inputs are unobservable and include situations where there is little, if any, market activity for the asset.

In certain cases, the inputs used to measure fair value may fall into different levels of the fair value hierarchy. In such cases, the level in the fair value hierarchy within which the fair value measurement in its entirety falls has been determined based on the lowest level input that is significant to the fair value measurement in its entirety. The Company's assessment of the significance of a particular input to the fair value measurement in its entirety requires judgment and considers factors specific to the asset.

Overall, transfers between levels are attributable to a change in the observability of inputs. Assets are transferred to a lower level in the hierarchy when a significant input cannot be corroborated with market observable data. This may occur when market activity decreases and underlying inputs cannot be observed, current prices are not available, and/ or when there are significant variances in quoted prices, thereby affecting transparency. Assets are transferred to a higher level in the hierarchy when circumstances change such that a significant input can be corroborated with market observable data. This may be due to a significant increase in market activity including recent trades, a specific event, or one or more significant input(s) becoming observable.

### *Due to/from affiliates*

Due to affiliates includes non-interest bearing amounts which are limited to proceeds of administration fees collected and due upon receipt of such fees. Due from affiliates includes non-interest bearing intercompany balances resulting from the settlement of routine operating transactions, and are due upon demand.

### *Accounts payable and accrued expenses*

Accounts payable and accrued expenses represents the Company's obligations arising from the ordinary course of broker-dealer operations and are recorded at their estimated settlement amounts. These balances primarily consist of trade suspense payables for investment activity in process at period end, pending wire transfers, and investment security clearing payables due to clearing firms and other counterparties.

### *Revenue from contracts with customers*

Revenue from contracts with customers includes administration fees, commission income and other income. The recognition and measurement of revenue is based on the assessment of individual contract terms. Significant judgment is required to determine whether performance obligations are satisfied at a point in time or over time; how to allocate transaction prices where multiple performance obligations are identified; when to recognize revenue based on the appropriate measure of the Company's progress under the contract; whether revenue should be presented gross or net of certain costs; and whether constraints on variable consideration should be applied due to uncertain future events.

### *Administration fees*

Administration fees are recognized when earned and include mutual fund service fees and fees for other asset-based financial services provided to clients by the Company on behalf of the funds. Administrative fees primarily include mutual fund 12b-1 revenue, shareholder servicing, reporting, and other administrative mutual fund service revenue. The Company earns mutual fund service fees for shareholder and administration services based upon the daily balances of client assets invested in the funds or participant counts. Administration fees may vary with changes in the balances of client assets due to market fluctuations or client activity. Administration fees that are transactional in nature are earned at a point in time, while recurring fees for services performed are earned over time, generally monthly or quarterly.

{13}------------------------------------------------

# **Empower Financial Services, Inc.** (A wholly-owned subsidiary of Empower Annuity Insurance Company of America) **Notes to the Financial Statements**

### *Commission income*

As an introducing brokerage firm, the Company earns commission revenues generated from the buying and selling of securities on behalf of its customers. Commissions and related clearing expenses are recorded on the trade date (the date that the third-party broker-dealer fills the trade order by finding and contracting with a counterparty and confirms the trade with the customer). The Company recognizes that the performance obligation is satisfied on the trade date as that is when the underlying financial instrument or purchaser is identified, the pricing is agreed upon and the risks and rewards of ownership of the securities have been transferred to/from the customer.

### *Other income*

Other income includes revenue that is earned when the Company's affiliate entity, Empower Trust Company, transitions the administration of certain individual retirement account (IRAs) to a third-party administrator and when the Company, as the introducing firm, executes principal transactions through its third-party broker-dealer. These amounts are recognized in revenue upon satisfaction of the performance obligation by transferring control over the goods or service to its customers.

### *Investment income*

Investment income consists primarily of interest income from directly held cash equivalents and fixed maturity investments, which is recognized when earned.

### *Investment gains (losses), net*

Realized and unrealized investment gains and losses are reported as a component of revenues and are determined on a specific identification basis.

### *Service level agreement expenses*

Service level agreement expenses generally includes services provided by affiliate companies to the Company, primarily Empower Retirement, LLC ("Empower"). These services support the workplace solutions and personal wealth management products distributed by affiliate companies. These costs are expensed as related services are received.

### *General and administrative expenses*

General and administrative expenses consist primarily of corporate and shared service charges, brokerage clearing expenses, regulatory related expenses, software and computer charges. These costs are expensed as related services are received.

### *Income taxes*

The Company is included in a consolidated income tax return filed by Lifeco U.S. ("US Consolidated Group"). Income taxes are recorded using an asset and liability approach that, among other provisions, requires the recognition of deferred tax assets and liabilities for the expected future tax consequences of temporary differences in amounts that have been recognized in the Company's financial statements and tax returns. In estimating future tax consequences, all expected future events (other than the enactments or changes in the tax laws or rules) are considered. A valuation allowance is provided to the extent that it is more likely than not that deferred tax assets will not be realized.

The Company accounts for income taxes on the modified separate return method on its separate company financial statements. Under this method, current and deferred tax expense or benefit is determined on a separate return basis but

{14}------------------------------------------------

## (A wholly-owned subsidiary of Empower Annuity Insurance Company of America)

### **Notes to the Financial Statements**

consideration is given to taxable income or losses from other members of the US Consolidated Group in evaluating the realizability of its deferred tax assets.

The method of settling income tax payables and receivables among the US Consolidated Group is subject to a written agreement ("Tax Sharing Agreement") approved by the Board of Directors, whereby settlement is made on a separate return basis (i.e. the amount that would be due to or from the jurisdiction had an actual separate company return been filed) except for the current utilization of any net operating losses and other tax attributes by members of the US Consolidated Group which can lead to receiving a payment when none would be received from the jurisdiction had a real separate company return been required. As such, the Company recognizes a current tax benefit to the extent that net operating losses off-set taxable income of affiliates. Losses that are not utilized create a deferred tax asset.

### *Recently adopted accounting standards*

In 2025, the Company adopted ASU No. 2023-09, *Improvements to Income Tax Disclosures,* which requires disaggregated information about a reporting entity's effective tax rate reconciliation as well as information on income taxes paid. As required by this update, the Company has enhanced the income tax disclosures related to the income tax rate reconciliation, and by disaggregating income taxes paid between federal and state jurisdictions. Refer to the accompanying statement of cash flows and Note 5 for additional information.

### *Accounting guidance issued but not adopted*

In November 2024, the FASB issued ASU 2024-03, *Disaggregation of Income Statement Expenses*, which requires disaggregation of certain expense captions into specified categories in disclosures within the footnotes to the financial statements. The ASU is effective for all public business entities for fiscal years beginning after December 15, 2026. The Company is currently evaluating the impact of this update on its financial statement disclosures.

### *Subsequent events*

Management has evaluated subsequent events for potential recognition or disclosure in the Company's financial statements through February 26, 2026, the date on which the Company's financial statements were issued.

### **3. Related Party Transactions**

The Company provides trading, administrative, and other financial services for certain affiliates and receives corporate support and administrative services from certain affiliates as outlined in the table below. Under the Company's service level agreement with Empower, certain expenses are not allocated to the Company but are retained at Empower, as follows:

| Description                                                                                                                                                                                                                           | Related Party                                    | Year ended<br>December 31, 2025 | Statement of Income<br>Location                 |
|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------|---------------------------------|-------------------------------------------------|
| Provided shareholder and administration services. At<br>December 31, 2025, the Company had an outstanding<br>accounts receivable balance from Empower Funds for<br>\$0.4 million included in fees receivable on the<br>balance sheet. | Empower Funds, Inc. (1)                          | \$                              | 2,362,182 Administration fees                   |
| Provided trading services to certain underlying funds<br>and/or mutual funds of and on behalf of its affiliates.<br>Earned administration fees for shareholder services<br>and administrative services provided to those              | Empower(2)                                       | \$                              | 404,801,562 Service level<br>agreement expenses |
| underlying funds and/or mutual funds. Passed revenue<br>through to affiliates net of certain general and<br>administrative expenses incurred.                                                                                         | Mullin TBG Insurance<br>Agency Services, LLC (3) | \$                              | 447,791 Service level<br>agreement expenses     |

(1) An open-end management investment company, which is a related party of EAICA

(2) A wholly-owned subsidiary of Empower Services Holdings US, LLC

(3) A wholly-owned subsidiary of EAICA

{15}------------------------------------------------

### (A wholly-owned subsidiary of Empower Annuity Insurance Company of America)

### **Notes to the Financial Statements**

The following table summarizes amounts due to affiliates:

| Related party                                                          | Indebtedness<br>Due date |              | December 31, 2025 |            |
|------------------------------------------------------------------------|--------------------------|--------------|-------------------|------------|
| Empower                                                                | On account               | Upon receipt | \$                | 72,896,370 |
| EAICA                                                                  | On account               | Upon receipt | \$                | 2,782,072  |
| Lifeco U.S.                                                            | On account               | Upon receipt | \$                | 1,008,416  |
| Empower Life & Annuity Insurance<br>Company of New York ("ELAINY") (1) | On account               | Upon receipt | \$                | 301,382    |
| Empower Annuity Insurance Company<br>("EAIC") (1)                      | On account               | Upon receipt | \$                | 540,763    |
| Others                                                                 | On account               | Upon receipt | \$                | 108,325    |
| Total                                                                  |                          |              | \$                | 77,637,328 |

(1) A wholly-owned subsidiary of EAICA

Based on the relationships discussed above and in Note 1, the accompanying financial statements are not necessarily indicative of the conditions that would exist or the results of operations that would prevail if the Company were operated as an unaffiliated entity.

### **4. Fair Value Measurements**

The following table presents the Company's financial assets carried at fair value on a recurring basis by fair value hierarchy category:

|                             | Assets measured at fair value on a recurring basis |                                                                            |    |                                                     |    |                                                    |    |            |
|-----------------------------|----------------------------------------------------|----------------------------------------------------------------------------|----|-----------------------------------------------------|----|----------------------------------------------------|----|------------|
|                             | December 31, 2025                                  |                                                                            |    |                                                     |    |                                                    |    |            |
| Assets                      |                                                    | Quoted prices in<br>active markets<br>for identical<br>assets<br>(Level 1) |    | Significant other<br>observable inputs<br>(Level 2) |    | Significant<br>unobservable<br>inputs<br>(Level 3) |    | Total      |
| Cash equivalents            | \$                                                 | 30,550,150                                                                 | \$ | —                                                   | \$ | —                                                  | \$ | 30,550,150 |
| Fixed maturity investments: |                                                    |                                                                            |    |                                                     |    |                                                    |    |            |
| U.S. agency mortgage-backed |                                                    | —                                                                          |    | 1,772,887                                           |    | —                                                  |    | 1,772,887  |
| Total assets                | \$                                                 | 30,550,150                                                                 | \$ | 1,772,887                                           | \$ | —                                                  | \$ | 32,323,037 |

The methods and assumptions used to estimate the fair value of the Company's financial assets carried at fair value on a recurring basis are as follows:

### *Cash equivalents*

The fair value of cash equivalents, which consists of highly liquid money market securities, is based upon unadjusted quoted market prices.

### *Fixed maturity investments*

The fair values for fixed maturity investments are generally based upon evaluated prices from independent pricing services. Fair value estimates are made at a specific point in time, based on available market information and judgments about financial instruments, including estimates of the timing and amounts of expected future cash flows and the credit standing of the issuer or counterparty.

Investment gains (losses), net within the statement of income represents the net unrealized gains on fixed maturity investments still held at December 31, 2025.

{16}------------------------------------------------

### (A wholly-owned subsidiary of Empower Annuity Insurance Company of America)

### **Notes to the Financial Statements**

### **5. Income Taxes**

The expense for income taxes is comprised of the following for the year ended December 31, 2025:

| Current expense          | \$<br>522,951 |
|--------------------------|---------------|
| Deferred expense         | 38,536        |
| Total income tax expense | \$<br>561,487 |

The following table presents a reconciliation between the statutory federal income tax rate and the Company's effective federal income tax rate for the year ended December 31, 2025:

| Statutory federal income tax rate         | 21.0 % |
|-------------------------------------------|--------|
| Income tax effect of:                     |        |
| State income taxes net of federal benefit | 2.8 %  |
| Effective federal income tax rate         | 23.8 % |

In 2025, state and local income taxes in California, Massachusetts, Minnesota, and New York comprise more than 50% of state and local income taxes of federal income tax effect.

Deferred income taxes represent the tax effect of the differences between the book and tax bases of assets and liabilities. The income tax effect of temporary differences, which give rise to deferred tax assets as of December 31, 2025, consists of investment deferred tax assets that were immaterial.

The Company files income tax returns in the U.S. federal jurisdiction and various states. With few exceptions, the Company is no longer subject to U.S. federal income tax examinations by tax authorities for years 2018 and prior. The Company does not expect significant increases or decreases to unrecognized tax benefits relating to federal, state, or local audits.

Included in due to affiliates at December 31, 2025 is approximately \$1.0 million of income taxes payable to affiliates related to the consolidated income tax return filed by Lifeco U.S. and certain subsidiaries.

On July 4, 2025, the One Big Beautiful Bill Act (the "Act") was signed into law. The Act's tax related provisions do not materially impact the Company's overall income tax position.

The Company does not have any foreign operations as of the year ended December 31, 2025 and therefore is not subject to the tax on Global Intangible Low-Taxed Income.

### **6. Regulatory Requirements**

The Company is subject to the Uniform Net Capital Rule ("Rule 15c3-1") of the SEC. The Company computes net capital in accordance with the Alternative Standard as prescribed under Rule 15c3-1(a)(1)(ii). The Alternative Standard requires minimum net capital of \$250,000 or 2% of aggregate debit items, whichever is greater. Rule 15c3-1 also prohibits withdrawals of equity or the payment of dividends if net capital would be less than 120% of the minimum requirement or if net capital would be less than 5% of aggregate debit items. At December 31, 2025, the Company had net capital of approximately \$14.0 million which was approximately \$13.8 million in excess of its required net capital of \$250,000.

{17}------------------------------------------------

# **Empower Financial Services, Inc.** (A wholly-owned subsidiary of Empower Annuity Insurance Company of America) **Notes to the Financial Statements**

### **7. Contingencies**

From time to time, the Company may be threatened with, or named as a defendant in, lawsuits, arbitrations, and administrative claims. Any such claims that are decided against the Company could harm the Company's business. The Company is also subject to periodic regulatory audits, inspections and investigations which could result in fines or other disciplinary actions. The Company accrues a charge when management determines that it is probable that a liability has been incurred and the amount of loss can be reasonably estimated. When a loss is probable and reasonably estimable, the Company records an accrual based on the reasonably estimable loss or range of loss. The Company regularly evaluates current information available to it to determine whether an accrual should be established or adjusted. The ultimate outcome of legal proceedings involves judgments, estimates, and inherent uncertainties and cannot be predicted with certainty. Unfavorable outcomes in such matters may result in a material impact on the Company's financial position, results of operations, or cash flows.

On August 29, 2025, the SEC filed a settled administrative proceeding, which included the Company. The proceeding summarized that, from July 2019 through December 2022, certain affiliated retirement plan advisors did not fully and fairly disclose compensation programs to plan participants considering enrollment in the managed account service. The Company paid a portion of the settlement, \$0.8 million, to an affiliate company. The Company's settlement expense was recognized in general and administrative expenses and an equal offset amount was reflected in service level agreement expenses in the statement of income, resulting in no net impact to the Company's net income during 2025. There will be no additional impact to the Company's consolidated financial position, results of operations, or cash flows.

The Company is involved in other various legal and regulatory proceedings that arise in the ordinary course of business. In the opinion of management, after consultation with counsel, the likelihood of loss from the resolution of these proceedings is remote and/or the loss is not reasonably estimable.

### **8. Segment Information**

The Company's chief operating decision maker ("CODM") has been identified as its Board of Directors, which includes the Chief Executive Officer, and other members of management. The CODM reviews results at a consolidated level only and the Company does not distinguish between products or services provided for the purpose of making decisions about resource allocation and performance assessment. Therefore, the Company has only one operating segment and one reportable segment. As a single reportable segment entity, the Company's segment performance measure is net income. The accounting policies of the single reportable segment are the same as those described in the significant accounting policies in Note 2. For the year ended December 31, 2025, one customer represented greater than 10% of total revenue, accounting for 30% of total revenue. Significant segment expenses are separately presented in the Company's statement of income. Other segment items within net income include income tax expense. All of the Company's revenues are derived from within the United States. Therefore, no geographical segments are presented.

{18}------------------------------------------------

### (A wholly-owned subsidiary of Empower Annuity Insurance Company of America) Computation of Net Capital for Brokers and Dealers Pursuant to Rule 15c3-1 Under the Securities Exchange Act of 1934 December 31, 2025

|  | Net Capital |
|--|-------------|
|--|-------------|

| Total stockholder's equity                                                  |    | 17,465,710  |
|-----------------------------------------------------------------------------|----|-------------|
| Deduct stockholder's equity not allowable for net capital                   |    | –           |
| Total stockholder's equity qualified for net capital                        |    | 17,465,710  |
| Deduct non-allowable assets:                                                |    |             |
| Mutual funds concessions receivable older than 30 days                      |    | (406,962)   |
| Other miscellaneous assets                                                  |    | (2,222,414) |
| Other deductions and/or charges                                             |    | (100,000)   |
| Net capital before haircuts on securities positions (tentative net capital) |    | 14,736,334  |
| Deduct haircuts on securities                                               |    | (693,983)   |
| Net Capital                                                                 |    | 14,042,351  |
| Alternate net capital requirement                                           |    |             |
| Minimum dollar net capital requirement of reporting broker or dealer        | \$ | 250,000     |
| Excess net capital                                                          |    | 13,792,351  |
| Net capital in excess of 120% of the minimum net capital requirement        |    | 13,742,351  |

There were no material differences between the computation of net capital above as compared to amounts reported by Empower Financial Services, Inc. in its unaudited Form X-17a-5 Part IIA as of December 31, 2025, filed with the Financial Industry Regulatory Authority, Inc. on January 27, 2026.

{19}------------------------------------------------

(A wholly-owned subsidiary of Empower Annuity Insurance Company of America) Computation of Determination of Reserve Requirements for Brokers and Dealers Pursuant to Rule 15c3-3 Under the Securities Exchange Act of 1934 As of December 31, 2025

The Company is exempt from the provisions of Rule 15c3-3 under the Securities Exchange Act of 1934, in that the Company's activities are limited to those set forth in the conditions for exemption appearing in paragraphs (k)(2)(i) and (k)(2)(ii) of the Rule.

{20}------------------------------------------------

(A wholly-owned subsidiary of Empower Annuity Insurance Company of America) Information Relating to the Possession or Control for Brokers and Dealers Pursuant to Rule 15c3-3 under the Securities Exchange Act of 1934 As of December 31, 2025

The Company is exempt from the possession or control requirements of Rule 15c3-3 under the Securities Exchange Act of 1934, in that the Company's activities are limited to those set forth in the conditions for exemption appearing in paragraphs (k)(2)(i) and (k)(2)(ii) of the Rule.


Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.
