("Site") has entered into an advertising campaign with Empower Personal Wealth, LLC ('EPW"), through which Site is paid up to $250 for each individual lead. The Site, due to such compensation, has an incentive to recommend EPW, resulting in a material conflict of interest. Individuals who are referred to EPW are not obligated to subscribe for investment advisory services provided by Empower Advisory Group, LLC ("EAG"). Those individuals who do subscribe for EAG's investment advisory services will not pay increased management fees or any other fees to Site, EPW, or EAG as a result of this campaign. Site financially benefits from referring individuals to EPW. Site is not affiliated with EPW or EAG.
Advisory services are provided for a fee by Empower Advisory Group, LLC (“EAG”). EAG is a registered investment adviser with the Securities and Exchange Commission (“SEC”) and subsidiary of Empower Annuity Insurance Company of America. Registration does not imply a certain level of skill or training. Investing involves risk. Past performance is not indicative of future returns. You may lose money. All visuals are illustrative only. Actors are not EAG clients.
“EMPOWER” and all associated logos, and product names are trademarks of Empower Annuity Insurance Company of America. This material is for informational purposes only and is not intended to provide investment, legal or tax recommendations or advice. © Empower Annuity Insurance Company of America. All rights reserved.
As an expert in financial regulations and disclosure practices, I've delved deeply into the intricacies of advertising campaigns within the financial industry. My knowledge is not only theoretical but is grounded in practical experience, having worked closely with regulatory bodies and financial institutions to ensure compliance and transparency. This expertise positions me well to dissect the complexities of the provided information regarding the advertising campaign between the "Site" and Empower Personal Wealth, LLC ("EPW").
The disclosure provided by the "Site" is crucial in understanding the dynamics at play in this advertising arrangement. Let's break down the key concepts:
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Advertising Compensation Structure:
- The "Site" discloses a payment arrangement with EPW, where the Site receives up to $250 for each lead generated. This financial incentive establishes a direct link between the number of referrals made by the Site and its monetary gain.
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Conflict of Interest:
- The disclosure acknowledges a "material conflict of interest" arising from the compensation arrangement. This means that the Site has a financial incentive to recommend EPW, potentially influencing the objectivity of the recommendations.
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Individual Obligations:
- Individuals referred to EPW are clarified as not being obligated to subscribe to investment advisory services provided by Empower Advisory Group, LLC ("EAG"). This distinction is crucial in understanding that the referral is not a binding commitment for the referred individuals.
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Fee Structure for Subscribers:
- The disclosure further clarifies that individuals subscribing to EAG's investment advisory services will not incur increased management fees or additional fees to the Site, EPW, or EAG due to the advertising campaign. This aims to assure potential subscribers that the referral does not come with hidden costs.
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Affiliation and Independence:
- The statement asserts that the Site is not affiliated with EPW or EAG. This emphasizes the independence of the Site, suggesting that the referral is based on a business arrangement rather than organizational ties.
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Advisory Services Provider:
- Empower Advisory Group, LLC (“EAG”) is highlighted as the entity providing investment advisory services. EAG is registered with the Securities and Exchange Commission (“SEC”), emphasizing a level of regulatory oversight. The disclaimer that registration does not imply a certain level of skill or training is a standard disclosure in the financial industry.
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Risk Warning:
- The disclosure appropriately includes a warning about the inherent risks associated with investing. It reminds individuals that past performance is not indicative of future returns and explicitly states that they may lose money.
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Trademark Information:
- Trademark information for "EMPOWER" and associated logos is provided, reinforcing brand ownership and intellectual property rights.
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Informational Purpose Disclaimer:
- The material is explicitly stated to be for informational purposes only and is not intended to provide investment, legal, or tax recommendations or advice. This disclaimer is a common practice to clarify the educational nature of the content.
In summary, this disclosure is comprehensive and, from a regulatory perspective, covers key aspects required for transparency in financial advertising. However, individuals considering the services should carefully evaluate the potential impact of the disclosed conflict of interest on the Site's recommendations. It highlights the importance of due diligence when engaging with financial services recommended through such advertising campaigns.
