Millennial Advisers is an SEC Registered Investment Adviser formed in 2013 as a New York registered limited liability company (LLC). The firm is wholly owned by JPED Holdings LLC which is owned by Edward Daigneau (Partner), John Parmigiani (Managing Partner) and Kay Johnson (Partner). Millennial Advisers provides investment advisory services to individuals and entities. Allied Millennial Partners, LLC (“Allied”) is an affiliated broker dealer; also wholly owned by JPED Holdings LLC. While Millennial Advisers may recommend clients use Allied as their broker/dealer, this is not a requirement. Millennial Advisers acts as a fiduciary. That means Millennial Advisers places the financial concerns of its clients ahead of its own and aims to act in the best interests of the client. Millennial Advisers offers its clients investment strategies based upon the client’s investment objectives and risk tolerance. Client accounts generally do not have minimum account size requirements. The following paragraphs describe our services and fees. Please refer to the description of each investment advisory service listed below for information on our advisory services. As used in this Brochure, the words “we,” “our” and “us” refer to Millennial Advisers and the words “you,” “your” and “client” refer to you as either a client or prospective client of our firm. Also, you may see the term Investment Advisory Representative (“IAR”) throughout this Brochure. Each of our available custodians is self-clearing, and therefore we use the terms “custodian” and “clearing firm” interchangeably throughout this document. Millennial’s advisory services are made available to retail clients through individuals associated with Millennial as IARs. For more information about the IAR who provides advisory services to the client, clients should refer to the Brochure Supplement for the IAR. The Brochure Supplement

is a separate document that is provided by the IAR along with this Brochure before or at the time a client engages the IAR. If a client did not receive a Brochure Supplement for the IAR, the client should contact the IAR or Millennial’s Compliance Department. As of December 31, 2023, we had approximately $39,513,416 of client assets under our management on a discretionary basis. Millennial Advisers provides investment advisory services in the following areas:
• Millennial Advisers offers investment advisory services in accounts held at one of our custodians. As part of these services, we offer you advice, discuss your investment objectives, and regularly monitor your accounts to help you achieve those goals. When discretionary authority is granted by a client, the IAR may, but is not required to contact you prior to placing a trade in your account. Millennial Advisers’ discretionary authority does not preclude a client from self-directing activity in their account. If a client makes an investment decision to buy, sell or hold securities in their account, Millennial Advisors will not monitor or exercise discretion on that position on an ongoing basis. Clients may place restrictions on investing in certain securities or certain types of securities by providing those instructions to the IAR in writing.
• Millennial Advisers provides certain non-discretionary advisory services to affiliated private funds in accordance with the Private Fund Advisory Agreement between Millennial Advisers and each Fund Series. Millennial Advisors does not provide continuous and regular monitoring to the Fund Series. Millennial Advisers does not solicit sales of the Private Funds; any such solicitation is made by Allied Millennial Partners, LLC, the affiliated broker-dealer and placement agent for the Funds. Millennial Advisers does not offer wrap accounts or collect wrap fees.