Overview
Bricktown Capital, LLC (“Bricktown”) was established December 17, 2021 as a subsidiary of Blue
Cross Blue Shield of Michigan (“BCBSM”) and began operating July 2022 BCBSM was
incorporated on September 6, 2013 and commenced business on January 1, 2014.
Bricktown is a domestic advisory services firm that provides comprehensive asset management
services including credit portfolio management, asset allocation solutions, derivatives solutions
and management, and other strategic and tactical portfolio management services to its parent
entity, subsidiaries and selected joint ventures majority owned by BCBSM. Bricktown utilizes
external managers for expertise in certain asset classes.
When we use the terms, “we” and “our” in this brochure, we are referring to Bricktown Capital,
LLC and the internal groups that support Bricktown.
Affiliated Accounts
Bricktown manages accounts on behalf of Bricktown’s affiliates as well as unaffiliated accounts.
We have an incentive to favor accounts of affiliates or our parent over others, creating a conflict
of interest. This is mitigated by managing our investment allocations and monitoring to ensure that
we manage all client accounts fairly and equitably.
Securities of the Same Class
Bricktown sometimes buys or sells or directs or recommends that a client buy or sell, securities of
the same kind or class that are
purchased or sold for another client, at prices that are different.
Although such pricing differences could appear as preferences for one client over another, our
trade execution in each case is driven by our consideration of a variety of factors consistent with
Bricktown’s duty to seek best execution.
There are times when Bricktown executes trades of securities of the same kind or class in one
direction for an account and in the opposite direction for another account, or we may determine
not to trade such securities in one or more accounts while trading for others. While such trades (or
a decision not to trade) could appear inconsistent for one client versus another, these decisions
generally result from differences in investment strategy, portfolio composition or client direction.
How we Address these Conflicts of Interest
Bricktown addresses potential conflicts of interest through disclosure and has designed policies to
mitigate conflicts as a result of our investments on behalf of our clients. Each quarter Bricktown’s
Investment Committee meets to review the investment performance of each client account for any
discrepancies. In addition, Bricktown has a Conflicts Committee that will address any real or
potential conflicts of interest.
As of December 31, 2023, Bricktown had a total of $9,949,828,000 in regulatory assets under
management.