Our Business. Milliman, Inc. was founded in 1947. It is one of the largest consulting and actuarial firms in the world. Milliman, Inc. offers specialized consulting services in employee benefits, healthcare, life insurance and financial services, property and casualty insurance and investments. Milliman, Inc. is a privately held company, owned by more than 460 active employees. No one individual owns more than 1% of Milliman, Inc. Milliman FRM, which began conducting business in 1998 as a part of Milliman, Inc. and was organized as a limited liability company and a wholly owned subsidiary of Milliman, Inc. in 2011, provides the investment advisory services described in this Brochure. Milliman, Inc. has another registered adviser entity, Milliman Advisors, LLC, providing advisory services to institutions including banks or thrift institutions, pension and profit-sharing plans, and other corporations or business entities principally in connection with defined contribution and defined benefit retirement plans, endowments, foundations and post-retirement benefits. Milliman, Inc. established this entity in 2018 and transferred its registration to this entity. We will be glad to provide more information on Milliman FRM or on Milliman Advisors, LLC. You can also find more information about Milliman Advisors, LLC and Milliman FRM at www.milliman.com and www.adviserinfo.sec.gov. Hedging and Asset Allocation Advisory Services – Institutional Clients. Milliman FRM offers hedging and asset allocation advisory services to institutional clients. These services are provided to life insurers, pensions, endowments, banks, fund managers, reinsurers, and trusts who are interested in using our investment models for their portfolios. These services include performing option pricing calculations on assets or liabilities, preparing illustrative financial projections of hedging strategies selected by the client, placing hedging trades with brokers as agent for our clients, providing other administrative support for the rebalancing of hedge positions and allocations among different asset classes, and rebalancing for market conditions. We tailor services to the needs of individual clients by obtaining each client’s individual risk tolerance and investment objectives, which are used to create an individualized client strategy. Clients’ risk preferences and investment objectives are memorialized in an investment policy statement and an investment services agreement, the terms of which are negotiated with each client. The policy, including the consequences of the application of that policy, are reviewed with clients and by Milliman FRM management and updated as needed. Clients may impose restrictions on the specific securities or hedge assets, or types of securities or hedge assets, in which we invest. Advisory and Sub-Advisory Services – Funds and SMAs. Milliman FRM provides services as an investment adviser or sub-adviser, to mutual funds, exchange-traded funds (“ETFs”), unit investment trusts (“UITs”), funds offered through bank collective investment trusts (“CITs”), and other exchange-traded products (“ETPs”). The strategy exercised for each product is designed to meet a particular investment goal. In the case of sub-advisory services, the primary adviser to the fund is usually responsible for the selection of underlying investments for the fund, and we manage strategies for the various funds’ assets based on the investment goals and objectives as outlined in each of the funds’ offering documents; such services may be provided by way of asset allocation or by constructing a hedge overlay. Milliman Financial Risk Management LLC (“Milliman FRM”) Form ADV: Part 2A Page 5 Milliman FRM also provides administrative services

to funds, including the supervision of administrative, clerical, recordkeeping and bookkeeping services provided to funds by the custodian. You should refer to each product’s offering documents, as applicable, for important information regarding objectives, investments, time-horizon, risks, fees, and additional disclosures. Prior to making any investment, you should carefully review these documents for a comprehensive understanding of the terms and conditions applicable for investment in the fund. Investments in certain funds for which we provide services are currently available only to investors through employee benefit plans, insurance companies, and financial advisers. Milliman FRM also offers portfolio services through participation in unified managed accounts (“UMA”) and separately managed accounts (“SMA”). A unified managed account is a privately managed portfolio of various types of investment vehicles pooled together to suit investors’ needs and varying objectives. A separately managed account is a portfolio of individually owned investment vehicles that can be tailored to fit the client’s investing preferences. Where Milliman FRM is the sub-advisor, the primary adviser is responsible for selecting investments for the client’s overall portfolio which correspond to their selected investment strategy. We may participate in SMA programs by constructing strategies for individual client accounts using futures, ETFs, or other assets that correspond to a client’s selected investment strategy. Client Assets. For certain clients, we provide risk management services in the form of a hedge overlay; although our risk management services are applied to the entire portfolio, Milliman FRM only has discretionary authority over the hedge overlay portion of the portfolio. For other clients, we manage the underlying investments as well, and as such have discretionary authority over the entire portfolio including the hedge overlay.
• Market Value of Client Assets Managed by Milliman FRM. The market value of the portion of Client Assets that we directly manage was $42,694,955,656 as of December 31, 2023.
• Market Value of Milliman FRM Clients’ Total Portfolio Assets. At times the term ‘Client Assets’ may be used to refer to the market value of all clients’ total portfolio assets subject to Milliman FRM’s risk management services. The market value of the portfolios on which we provided risk management services was $162,108,001,876 as of December 31, 2023
• Notional Value of Portion of Portfolio Managed by Milliman FRM. In the commodity futures industry, it is typical to calculate the value of a client’s derivative portfolio assets using the assets’ notional value, rather than market value. We may at times use notional value as a measure of client assets. Other Services. In addition to the investment advisory services discussed above, we provide the following services:
• Actuarial consulting. We provide actuarial consulting services to clients.
• Software development. We develop proprietary software for use with our hedging advisory services, which we license to certain clients for a monthly or annual fee.
• Index development. Milliman FRM has worked with index providers, such as S&P Dow Jones Indices LLC (“S&P DJI”), MerQube, and NASDAQ, Inc., to develop indices. These indices seek to provide benchmarks for insurance companies and benchmarks to be used within the risk managed funds universe. In addition, Milliman FRM may provide advisory Milliman Financial Risk Management LLC (“Milliman FRM”) Form ADV: Part 2A Page 6 or sub-advisory services to companies whose products or funds track the indices; the services and fees for these services are discussed in further detail below. Certain fee and compensation structure restrictions may apply.