Eligible Indirect Compensation Disclosure for Plans in the ...

1 Eligible Indirect Compensation Disclosure for Plans in the RecordkeeperDirect -Multifund Program Under Department of Labor regulations, Indirect Compensation may be considered Eligible Indirect Compensation (EIC) if a written Disclosure is provided to the plan administrator. This Disclosure must include (i) the existence of the Indirect Compensation , (ii) the services provided, (iii) the amount of the fee, an estimate of the fee or the formula used to calculate the fee and (iv) the identification of the parties paying and receiving the Compensation . This document either provides disclosures of Indirect Compensation or refers you to another Disclosure document that was provided to you previously or is available at The following are the types of Indirect Compensation that may have been received by (i) your plan's third-party administration (TPA) firm, (ii).

2 Your plan's recordkeeper, Capital research and Management Company,SM (iii) Capital Bank and Trust Company,SM (iv). the firm of your plan's financial professional, (v) the issuer of the annuity contract, Great-West Life & Annuity Insurance Company or Great-West Life & Annuity Insurance Company of New York, and (vi) the distributor of the annuity contract, American Funds Distributors, Inc. Compensation Received by Your Plan's TPA Soft Dollars Your TPA may receive payments from the plan's investment To the extent that Capital research and Management Company options for services provided to your plan and described in receives soft dollars, the prospectuses and statements of your TPA service agreement.

3 These amounts will vary additional information for each one of the American Funds depending on the unit class selected. Please see Exhibit C available at , and the in the RecordkeeperDirect-Multifund Recordkeeping Services additional Disclosure beginning on page 3, describe these Agreement for information about these payments. soft dollars. Compensation Received by Capital research Compensation Received by Capital Bank and Management Company and Trust Company Indirect Compensation that may have been received by As custodian for your plan, Capital Bank and Trust Company Capital research and Management Company includes: receives float revenue from earnings on uncashed checks issued from the plan and plan assets received by Capital Bank and Trust Recordkeeping Payments Company that cannot be invested on the date of receipt.

4 Float accrues at a money market rate of return. Capital research and Management Company may receive payments from your plan's investment options for recordkeeping services provided to your plan. The amount paid, if any, from Compensation Received by Your Plan's the investment options for recordkeeping services will vary Financial Professional depending on the unit class selected. Further information If your plan's financial professional is acting as a registered regarding recordkeeping services and related payments, representative of a broker-dealer, your plan's investment options including the amount paid, is found in Exhibits A and C, may make payments directly to your financial professional's broker- respectively, in the RecordkeeperDirect-Multifund dealer firm.

5 The amount of such payments, if any, depends on the Recordkeeping Services Agreement. specific unit class selected for your plan. Please see Exhibit C in the RecordkeeperDirect-Multifund Recordkeeping Services Agreement 01/18. 1 of 8. for information about these payments, including the amount, if any, Compensation Received by the Distributor paid to your financial professional's broker-dealer firm. The amount The distributor, American Funds Distributors, Inc., which is an paid, if any, is reported on the Schedule A. affiliate of Capital research and Management Company, receives These payments compensate your financial professional's broker- of the average daily balance of assets in the plan's group dealer firm for plan and participant services that may include: annuity.

6 This amount compensates the distributor for the marketing providing information regarding plan investment options, and distribution of the contracts. Effective April 1, 2017, these conducting ongoing plan reviews and delivering participant amounts are paid on a quarterly basis; previous payments were education. made on a monthly basis. Compensation Received by the Issuer The issuer of the group annuity contract(s), Great-West Life & The Indirect Compensation described above may qualify as Annuity Insurance Company or Great-West Life & Annuity Eligible Indirect Compensation . If you have any questions about Insurance Company of New York, will receive on the this information or believe that any of the service provider average daily balance of assets in the variable investments of Compensation described in this Disclosure does not meet the the plan's group annuity contract(s).

7 This amount compensates criteria for Eligible Indirect Compensation , please contact us. the issuer for administrative services associated with the group annuity contract(s). Effective April 1, 2017, these amounts are paid on a quarterly basis; previous payments were made on a monthly basis. 01/18. 2 of 8. Calendar Year 2017 Soft Dollar Disclosure Supplement Capital research and Management Company This Disclosure supplement provides information regarding CRMC assesses the reasonableness of commissions in light of soft dollars received by Capital research and Management the total brokerage and investment research services provided Company ( CRMC ) in 2017 relating to the investment by your by each particular broker-dealer.

8 In valuing the brokerage and retirement plan in the American Funds, managed by CRMC. investment research services that CRMC receives from broker- This information may be used for purposes of completing dealers in connection with its good faith determination of Schedule C (Service Provider Information) to Form 5500. Further reasonableness, CRMC takes various factors into consideration, information can be found in the prospectuses and statements of including the quantity, quality and usefulness of the services additional information for each one of the American Funds provided to it. In 2017, approximately 25% of commissions on (available at ) under the heading equity trades paid by the American Funds to broker-dealers Fund Information.

9 Were attributable to brokerage and/or investment research services. These commissions were either paid directly to the CRMC places orders with broker-dealers for the American broker-dealer or to another third-party research provider through Funds portfolio transactions. In selecting broker-dealers, a commission sharing arrangement. Please note that, depending CRMC seeks to obtain best execution (the most favorable on various factors, a higher percentage of the commissions on total price reasonably attainable under the circumstances) for equity trades paid by an individual fund may be attributable to the funds' portfolio transactions, taking into account a variety brokerage and/or investment research services.

10 Of factors. Subject to best execution, CRMC may consider investment research and/or brokerage services provided to In 2017, CRMC may have received investment research services CRMC in placing orders for the funds' portfolio transactions. from the broker-dealers listed below. To the extent CRMC received See the attached Best Execution Policy that was in effect during investment research services from broker-dealers not listed 2017 for additional information. below, such research was not deemed to be of material value. 2 XIDEAS B&K Securities Ltd. (Batlivala & Karani) Bucephalus research 7 PARK DATA B. Riley & Co., LLC Buckingham research Group Incorporated (The).