9AT: FUKOKU LIFE INTERNATIONAL (AMERICA) INC.

FUKOKU LIFE INTERNATIONAL (AMERICA) INC.

FUKOKU LIFE INTERNATIONAL (AMERICA) INC.

Adviser Profile

As of Date	04/27/2026
Registration	SEC, Approved, 01/03/2017
ADV Location	NEW YORK, NY, United States
Contact Info	212 xxxxxxx

AUM^*	327,695,193 2%
of that, discretionary	0
Number of Employees	6 20%
of those in investment advisory functions	5
Private Fund GAV^*	0
Avg Account Size	163,847,597 2%
SMA’s	Yes
Private Funds	0

Adviser Type

- Large advisory firm

Client Types

- Other

Advisory Activities

Compensation Arrangments

- A percentage of assets under your management

Reported AUM

364M 312M 260M 208M 156M 104M 52M

2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026

Discretionary

Non-discretionary

Private Funds

No private funds

Employees

Brochure Summary

Overview

Fukoku Life International (America) Inc. (“FLIA”) is owned by Fukoku Mutual Life Insurance Company (“FMLI”) and has been providing investment advisory services since 02/26/2002. FLIA provides nondiscretionary investment advice in a sub-advisory capacity to off-shore private funds (the “Funds”) managed by an off-shore unaffiliated investment manager (“Investment Manager”). The off-shore Funds are sub-funds of a Cayman registered open-ended exempt umbrella unit trust which is excluded from the definition of investment company under Section 3(c)1 or 3(c)7 under the Investment Company Act of 1940, as amended. For purposes of this ADV disclosure document, FLIA will refer to these entities as private Funds. The Funds are privately offered to institutional investors in Japan. FLIA provides investment advice related to U.S. equity securities and U.S. fixed income securities on behalf of the Funds. The investment objective of the Funds differ from each other. One seeks to maximize growth of equity securities only,

while the second Fund incorporates growth of equities along with the total return from fixed income securities over the long term. FLIA determines trends in overall market conditions by examining movements in interest rates and global stock markets in order to forecast the expected rate of return from equity and fixed income securities. Though FLIA renders investment advice pursuant to the stated investment objectives of the Funds, all trading and discretionary responsibilities lie with the off-shore Investment Manager. Additionally, FLIA provides monthly investment commentary, produces written reports, conducts telephone and/or video conferences and has meetings pertaining to the advice given for the Funds when so requested by the Investment Manager. FLIA monitors portfolio risk regularly and ensure compliance with the investment guidelines of the Funds, determined by the Investment Manager. As of December 31, 2023, FLIA managed approximately $307,064,064 in assets on a nondiscretionary basis.