# ATRS Pre-Existing Indirect Israel Sovereign Exposure Prior to the 6/2/2025 Board action authorizing direct purchases of up to $50 million in Israel Bonds, ATRS already held indirect exposure to Israel sovereign debt through a passive index fund managed by State Street Global Advisors. The exposure as of 11/30/2024 was approximately $868,000 per the ATRS share calculation, characterized by ATRS staff in subsequent disclosures as "approximately $1 million." The exposure sits inside the SSgA U.S. Aggregate Bond Index NL Fund, internal alias CMX6. The fund had 54 participants as of 11/30/2024, with the top five participants representing 50.09 percent of fund assets. ATRS's participation was 17.6 percent. The fund as a whole held fourteen State of Israel sovereign CUSIPs and one AID-Israel bond at that snapshot date. The fourteen Israel sovereign positions span maturities from 2026 to 2120 (a 96-year bond) with coupons from 2.50 percent to 5.75 percent. Aggregate fund-level market value of Israel sovereigns was approximately $4.93 million. ATRS's pro rata share at 17.6 percent was approximately $868,000. The detailed CUSIP listing is in the companion source page [[ssga-cmx6-2024-11-30]]. The exposure was first surfaced at ATRS in December 2024 in response to the Badria Mryyan FOIA. Mark White on 12/10/2024 told Mryyan ATRS had "no direct investment" in DCI Israel Bonds. After a phone call with Mryyan on 12/11/2024, White asked Rod Graves to check pooled fund holdings. Graves identified the SSgA CMX6 fund and reported ATRS's 17.6 percent participation. White transmitted the holdings spreadsheet to Mryyan on 12/12/2024 with the note that the fund-level figures did not represent ATRS's ownership interest. In May 2025 the figures resurfaced in the run-up to the Board action. Graves on 5/15/2025 corrected an internal estimate from $800,000 to "around $1 million," catching a missed line in the spreadsheet. White used "approximately $1 million" in his 5/19/2025 reply to ATRS retiree John Rollans and the same figure in his clarifications to reporter Mike Wickline. This exposure is structurally distinct from the bonds being sold by the Development Corporation for Israel. The fourteen State of Israel CUSIPs in the SSgA fund are USD-denominated SEC-registered sovereign issues acquired in the institutional secondary market by the index manager. They are not DCI's "Israel Bonds" product, which is a separate retail-and-institutional channel sold directly by DCI under the FINRA member-dealer authority of Development Corporation for Israel. Matt Waz of Raymond James drew the same distinction on 5/28/2025 when describing 16 SEC-registered and 3 RegS bonds in the institutional secondary market. The pre-existing exposure is consequential to the analysis of the 6/2/2025 Board decision in two ways. First, it shows that ATRS already had market-priced, passively held exposure to Israel sovereign credit risk through a low-cost diversified index. The new $50 million direct mandate is additive to this exposure, not corrective of an absence. Second, it creates a baseline against which the structure, cost, and credit characteristics of the new direct DCI Israel Bonds purchases can be compared. The DCI Premium Jubilee bonds Reams identified for the new mandate carry a $1 million minimum increment per bond and are offered only in 5-, 10-, and 15-year maturities, distinct from the diverse maturity ladder already held passively. ## Evidence > [!evidence] Mark White to Badria Mryyan, Emails1.pdf p.11, 12/10/2024 > "I'm aware of the Israel bonds issued by the Development Corporation for Israel, and no, we do not have any direct investment in those bonds." > [!evidence] Rod Graves to Mark White, Emails1.pdf p.29, 12/11/2024 > "Please see attached. ATRS is roughly 17.6% of the collective fund." > [!evidence] Rod Graves to Mark White, Emails3.pdf p.9, 5/15/2025 > "Direct holdings total around $19 million as of 5/14/25. We also have an estimated $5 million invested in Israel through our passive global index funds." > [!evidence] Rod Graves to Mark White, Emails3.pdf p.12, 5/15/2025 > "Sorry! I missed one on the excel sheet. Make the estimate around $1 million." > [!evidence] SSgA CMX6 cover sheet, Email1Attachment.xlsx, 11/30/2024 > "Number of Participants in Fund: 54. % of Assets Represented by Top 5 Investors: 50.09" ## Cross-References [[ssga-cmx6-2024-11-30]] source page with the full CUSIP listing [[mark-white]] [[rod-graves]] [[badria-mryyan]] [[mike-wickline]] [[john-rollans]] entities [[atrs-resolution-2025-22]] companion concept page on the new direct mandate this exposure pre-dates [[independent-credit-analysis-gap]] companion concept page [[atrs-foia-r1-staff-emails]] source page ## Tensions This concept page is documentary-inventory and surfaces no first-class tensions. It catalogs ATRS's pre-existing indirect Israel sovereign exposure via the SSgA U.S. Aggregate Bond Index NL Fund (CMX6) as of 11/30/2024 — the fourteen State of Israel CUSIPs spanning maturities from 2026 to 2120, the fund-level aggregate market value, ATRS's 17.6 percent pro-rata participation, and the December 2024 Mryyan-FOIA-surfaced disclosure chronology. The page documents Mark White's 12/10/2024 "no direct investment" framing being subsequently refined to acknowledge $1M of indirect exposure via the SSgA index fund (plus the separate $19M of direct equity-and-fixed-income holdings in Israeli companies that White itemized to Wickline on 5/14-5/15). These are documented refinements rather than competing readings of the same evidence. The downstream framing question — whether the new $50M direct Resolution 2025-22 mandate is "additive" to a small pre-existing exposure (innocuous portfolio diversification) or a substantive shift requiring independent credit analysis — is filed against [[independent-credit-analysis-gap]] rather than originating here. See [[methodology]] § II for the criteria distinguishing documentary-inventory pages from concept pages that surface contested mechanisms.