Carlton Fields, P.A.

Carlton Fields, P.A. practices law in California through Carlton Fields, LLP.

ATTORNEYS AT LAW 1625 Eye Street, NW | Suite 800 Washington, DC  20006 202.965.8100 | fax 202.965.8104 www.carltonfields.com Atlanta Florham Park Hartford Los Angeles Miami Minneapolis New York Orlando Tallahassee Tampa Washington, DC West Palm Beach

April 22, 2026

Empower Annuity Insurance Company of America

8515 East Orchard Road

Greenwood Village, CO 80111

Re:  FutureFunds Series Account

Post-Effective Amendment No. 67 to the Registration Statement on Form N-4

File Nos. 2-89550 and 811-03972

Ladies and Gentlemen:

We have acted as counsel to Empower Annuity Insurance Company of America, a

Colorado corporation, regarding the federal securities laws applicable to the issuance and sale of

the contracts described in the above-referenced registration statement.  We hereby consent to the

reference to our name under the caption “Legal Matters” in the statement of information filed as

part of the above-referenced registration statement. In giving this consent, we do not admit that

we are in the category of persons whose consent is required under Section 7 of the Securities Act

of 1933.

Very truly yours,

/s/ Carlton Fields, P.A.

Carlton Fields, P.A.