# Auditor's Office as DCI Channel The Auditor of State's office in this batch operates as the scheduling, access, and political-cover intermediary between Development Corporation for Israel sales staff and Arkansas pension system executive directors. Two operational moments document this role. The first is the 10/23/2024 Brady outreach. Chief Deputy Auditor Jason Brady emailed APERS executive director Amy Fecher and ATRS executive director Mark White directly to set up meetings between the two systems and "Larry," subsequently identified as DCI National Managing Director Lawrence Berman. Brady's framing is explicit: the Auditor was contacted by a representative of Israel Bonds and asked to arrange the meetings, and Brady was making the request "On the Auditors behalf." Brady wrote that other meetings for Larry were also being arranged but "your meetings are Larry's priority." The combination of state office staff coordinating calendar, the explicit prioritization of the seller's institutional sales pipeline, and the cc'ing of Auditor Milligan and the Auditor's office staff member Wendy Spadoni is direct evidence of a state-office workflow built around the seller's needs. The second is the 4/11/2025 in-person meeting. Auditor Milligan personally signed the email confirming the 4/15/2025 meeting at his Capitol office in Room 230 with Berman and DCI Southeast Regional Executive Director Brad Young. The bios of both DCI representatives were attached. Brady was again named as the contact for any rescheduling. The State Capitol office became the venue for a sales meeting between DCI institutional sales staff and ATRS executive leadership, with the Auditor as host. These two moments document a pattern in which a sitting constitutional officer's own office functions as the access mechanism for an out-of-state institutional bond sales operation seeking to place product with public pension funds. The Auditor's prior advocacy as Treasurer of State for Israel Bonds-enabling legislation, referenced in Brady's 10/23/2024 message, is the policy backdrop. The current role is procedural facilitation. The Spadoni custodian production reframes this concept in two important ways. First, the Auditor's relationship with Berman is not a recent procedural channel but a long-standing personal one. Per Brady's 4/7/2025 letter draft for Milligan: "I worked with and have know Mr. Berman and Israel Bonds since my time in the State Treasury when the Legislature allowed me to purchase bonds of Israel." Milligan personally purchased Israel bonds during his Treasurer tenure (a step beyond the prior framing that he merely "requested the legislature to pass legislation"), and he has had a personal working relationship with Berman since that time. The Auditor's-office channel is the activation of a long-standing personal relationship between the Auditor and the seller, not an arms-length procedural arrangement. Second, the channel scope is much larger than the two pension systems alone. The April 14-15, 2025 Capitol tour Spadoni and Brady orchestrated for Berman and Young included eight scheduled meetings spanning both pension executive directors, both presiding officers of the legislature (Speaker Evans, President Pro Tempore Hester), the State Treasurer (Thurston), and two cabinet secretaries (Bassett at Labor/Licensing, Hudson at DFA). The November 2024 trip included an attempted but declined meeting with Governor Sanders. The companion concept page [[auditor-multi-official-capitol-tour]] develops the trip in detail. The Auditor's-office channel was not a narrow pension-investment focused operation; it was a broad coordinated outreach across multiple branches and offices of Arkansas state government. The materials in this batch do not document what was discussed at the 4/15/2025 meeting, what materials were exchanged, or whether Brady or Spadoni attended. They do document the choreography that led ATRS executive director Mark White from "no direct investment in those bonds" on 12/10/2024 to a 5/8/2025 instruction to Rod Graves to prepare a $50 million Board ask, with the 4/15 Capitol meeting as the inflection point. ## Channel scope is not single-product: Abacus Global Management The R2 Milligan production ([[auditor-foia-r2-milligan]]) adds evidence that the Auditor's-office channel introduces multiple investment products, not only DCI Israel Bonds. Rob Phillips, SVP at Abacus Global Management (NASDAQ: ABL, life settlements), emailed Dennis Milligan and Jason Brady on 4/28/2025 5:56 PM with the subject "Thank you + SFOF follow up." The body confirms that Abacus executive Jay Jackson, Phillips, Milligan, and Brady met "last week" (the SFOF Spring National Meeting week of April 22-24) and that Milligan and Brady expressed "interest in Abacus as an investment for Arkansas' pension funds." The Abacus pitch through the SFOF networking circuit parallels the DCI Israel Bonds pitch through the personal-relationship-and-Capitol-tour circuit. Both products reach Milligan and Brady; both rely on SFOF-adjacent infrastructure (SFOF Spring meeting in one case, the long-standing personal Berman relationship plus the SFOF newsletter and policy operation in the other); both treat the Auditor's office as an active investment-recommendation channel for the Arkansas pension systems despite the Auditor's lack of formal investment authority over those systems. See [[rob-phillips]] [[abacus-global-management]] [[sfof-state-financial-officer-network]] for the network through which the second pitch traveled. The Auditor's office is therefore best characterized not as "Auditor's Office as DCI Channel" but as an investment-introduction node for products that travel through the SFOF-adjacent state-financial-officer network. DCI Israel Bonds is the documented product that reached the Board action stage. Abacus is documented as a second product whose disposition is unknown from the available batches. Whether other products have similarly used the Auditor's office as an introduction venue is a follow-up FOIA target. ## The Peterson custodian production: the channel was active 16 days before Brady's 10/23/2024 outreach The Peterson custodian production ([[auditor-foia-r2-stacy-peterson]]) reframes the chronology of the Auditor's-office DCI channel by establishing that the channel was already active on October 7, 2024 — sixteen days before Brady's 10/23/2024 formal pension outreach to ATRS and APERS executive directors. Three pieces of evidence support this finding. First, **Stacy Peterson (Director of Communications, APR) emailed Lawrence Berman directly on 10/7/2024 at 3:48 PM** under subject "A message from Arkansas Auditor Dennis Milligan" with Milligan BCC'd. Berman replied at 4:50 PM the same day with the entire DCI senior leadership cc'd: Dani Naveh (DCI President & CEO), Stuart Garawitz, Shiri Stern, Ethan Behling, and Bradley Young. Berman's framing — "your support and friendship," "He is truly one of a kind, and we are forever grateful to him and your whole team" — documents an established institutional relationship, not a first contact. Peterson's separate same-day email to the Israeli Embassy consular section addressed to Ambassador Michael Herzog establishes a parallel diplomatic-channel touchpoint. Second, **the channel was operating in support of the Auditor's-office October 2024 Israel Solidarity Operation**, a multi-channel public-facing Christian-Zionist campaign Peterson designed in coordination with Sen. Jason Rapert's National Association of Christian Lawmakers. The campaign components include the mailed Israel Solidarity Letter to Ambassador Herzog (10/3 mailing, Brady-approved, Spadoni-formatted on Auditor's letterhead), the Capitol Rotunda press conference 10/7 (the NACL-convened event at which Milligan delivered Peterson's draft remarks), and the "I stand with Israel" YouTube video produced by Kurt Underwood under Peterson's direction (https://youtu.be/oPGl3ir_Bn4). The Auditor's-office DCI channel and the Christian-Zionist public-solidarity channel were not separate parallel operations; they were coordinated, with the DCI senior leadership receiving the Auditor's-office solidarity content directly and responding with grateful institutional language. See [[october-2024-israel-solidarity-operation]] for the campaign in full. Third, **Milligan's own public Capitol Rotunda speech credits his Treasurer-era 2015-2017 work with the Israeli development corporation and Sen. Rapert as the policy-and-relationship origin of Arkansas state Israel Bonds investment**: "Soon after I took that office back in 2015, I was approached by an Israeli development corporation about the potential of bringing legislation to Arkansas that would allow the state to invest in bonds from Israel. I connected the developers with Sen. Rapert, and through that connection Act 644 was born. It was enacted in 2017, and during my tenure we purchased some $85 million in bonds supporting Israel." Milligan's public account therefore situates the Auditor-DCI relationship at approximately a decade in standing, predating his Auditor tenure entirely. The channel framing was already operationally familiar in the Treasurer's office before Milligan moved to the Auditor's office in 2023. ## R2 residual sub-batches: physical-correspondence and Treasury-coordination dimensions The R2 residual sub-batches at [[auditor-foia-r2-residual]] add two findings to the channel concept. First, **the channel has a physical-correspondence dimension layered onto the email channel**. Brad Young (Executive Director, DCI Southeast Regional) sent Milligan a handwritten thank-you card on DCI letterhead in roughly December 2024, following his 12/17/2024 email asking Milligan for "a good mailing address." The card's text — "your support and passion for Israel and Israel Bonds is second to none. I am very thankful and fortunate that we have friends like you. It is critical to our success and to Israel's future" — refines Young's documented role from logistical regional director to relationship-builder. The "we will keep you posted" framing establishes ongoing DCI-to-Milligan reporting as the channel norm. The card is the only handwritten correspondence from DCI senior staff in the wiki's documentary record. Layered with the email and Capitol-tour channels, the physical correspondence completes a three-tiered engagement strategy: email cadence (broadcast and personalized DCI promos), in-person hosting (the November 5 trip and the April Capitol tour), and physical correspondence (Brad Young's handwritten card). Second, **the channel was already coordinating Treasury-side participation in DCI delegation visits as of 10/28/2024**. The Brady-Burleson iMessage at [[auditor-foia-r2-residual]] documents Brady requesting Treasury Deputy Kenneth Burleson on October 28, 2024 to set up a five-minute Treasurer Thurston hello-handshake-photo on Election Day, plus a 30-minute substantive meeting with Burleson and Bill Huffman. The text refines the wiki's prior framing of the 4/15/2025 Capitol office Thurston-Berman meeting (documented at [[auditor-multi-official-capitol-tour]]) as the first Treasurer-DCI contact: the Auditor's office was already coordinating Treasury access for Berman six months earlier, on Election Day 2024. Whether the requested Thurston/Huffman/Burleson meetings actually occurred on November 5 is not knowable from this text; the request is documented, the response is not. The channel's documented scope therefore expands from the eight April 2025 Capitol meetings to also include the November 5, 2024 Election Day multi-agency trip Brady was orchestrating across the Auditor's, Treasurer's, ATRS, and APERS offices. ## Peterson's 6/4/2025 SFOF model-replication offer The post-vote dimension of the channel is also documented in the Peterson production. Two days after the 6/2/2025 ATRS Board action, Peterson emailed SFOF Director of Public Policy Adam Schwend two articles documenting the Arkansas pension Israel Bonds vote and offered: "The Auditor has very good contacts with the development corporation in case any other states are interested in learning more." The Auditor's-office DCI channel is therefore documented as functioning bidirectionally: as a receiving channel for DCI sales (October 2024 to June 2025) and as an exporting channel for the Arkansas model to other SFOF member states (June 2025 onward). See [[sfof-state-financial-officer-network]] for the export-channel dimension. ## Evidence > [!evidence] Jason Brady to Amy Fecher and Mark White, Emails1.pdf p.1, 10/23/2024 > "The Auditor has been contacted by a representative of Israel Bonds and asked if he would arrange a meeting with both of you and your investment teams in November to visit. On the Auditors behalf, I am making that request of you." > [!evidence] Jason Brady, Emails1.pdf p.1, 10/23/2024 > "your meetings are Larry's priority" > [!evidence] Dennis Milligan to Mark White, Emails3.pdf p.1, 4/11/2025 > "Mr. White, Thank you for agreeing to meet with Israel Bonds representatives Mr. Larry Berman, National Managing Director, and Mr. Brad Young, Executive Director - Southeast Regional Office on Tuesday, April 15, 2025, at 10:00 a.m. in my office located in room 230 of the State Capitol. For your convenience, I am attaching the biographies for both gentlemen." ## Cross-References [[jason-brady]] [[dennis-milligan]] [[wendy-spadoni]] Auditor's-office staff acting as channel [[lawrence-berman]] [[brad-young]] DCI institutional sales staff being channeled [[mark-white]] [[amy-fecher]] [[john-thurston]] pension and treasury officials being introduced [[brian-evans]] [[les-warren]] [[bart-hester]] [[daryl-bassett]] [[jim-hudson]] additional Arkansas officials in the channel scope [[sarah-huckabee-sanders]] [[erica-freeman]] Governor's office (declined the November 2024 outreach) [[board-colleague-conflict]] companion concept page on Milligan's dual role as Auditor advocate and ATRS Board member [[dci-promotional-pipeline]] companion concept page on parallel direct DCI marketing [[auditor-multi-official-capitol-tour]] companion concept page on the April 2025 trip's full scope [[rob-phillips]] [[abacus-global-management]] second-product evidence of the channel's multi-product scope [[sfof-state-financial-officer-network]] [[sfof-policy-letter-operation]] companion concept pages on the SFOF networking circuit through which Abacus reached the channel [[stacy-peterson]] Auditor's-office Director of Communications who designed the October 2024 Israel Solidarity campaign and operates the SFOF model-replication outbound offer [[jason-rapert]] [[national-association-of-christian-lawmakers]] [[michael-herzog]] [[october-2024-israel-solidarity-operation]] new entities and concept from the Peterson production extending the channel's documented chronology [[kenneth-burleson]] [[bill-huffman]] Treasury Deputies the channel coordinated with on Election Day 2024 [[atrs-foia-r1-staff-emails]] [[auditor-foia-r1-spadoni]] [[auditor-foia-r2-milligan]] [[auditor-foia-r2-stacy-peterson]] [[auditor-foia-r2-residual]] [[apers-foia-r1-7-7-25]] source pages ## APERS-side cross-confirmation: Brady as IFSC member and motion-maker (7/7/25 production) The 7/7/25 APERS R1 production refines this concept page in three ways. First, the Auditor's-office DCI channel is documented to extend into APERS at the level of formal Board-subcommittee participation. Brady serves on the APERS Investment Finance Subcommittee in Auditor Milligan's seat (parallel to his ATRS Board designee role). At the 5/15/2025 IFSC meeting Brady made the Israel Bonds motion himself ("He said he would like to make a motion for the subcommittee to authorize the system's staff to invest a minimum of $25 million in Israel bonds" per Mike Wickline's 5/15/2025 article). This is the strongest direct documented evidence of the channel: not Brady arranging meetings or facilitating access, but Brady substantively driving the pension-system authorization vote himself in his Auditor's-office capacity sitting on the pension Board. Second, Wendy Spadoni (Auditor's-office Executive Assistant) is documented on the IFSC packet distribution cc list, parallel to Sharon Mahoney for Hudson (DFA) and Anita Chance for Bassett (ADLL). The Auditor's office is therefore systematically routed APERS IFSC materials independently of any other channel — a structural distribution-level instantiation of the Auditor's-office DCI channel into APERS Board governance. Third, the channel's bidirectional information flow includes APERS staff Carlos Borromeo's 5/15/2025 same-day acknowledgment of Berman's rate sheet at 3:19 PM (the IFSC meeting was at 1:00 PM the same day; Berman sent rates at 3:13 PM; Borromeo acknowledged at 3:19 PM). Stuart Garawitz and Brad Young were cc'd on the chain. The channel is therefore not just an Auditor's-office-to-DCI access mechanism but a coordinated information-flow loop wherein DCI and the APERS CIO synchronize around the authorization vote in real time. The combined evidence sharpens the channel concept from "scheduling, access, and political-cover intermediary" to "scheduling, access, political-cover intermediary, plus formal pension-board membership performing motion-making in the seller's interest." Brady's IFSC motion at APERS is the documented apex of the channel. ## Treasury R1 7-7-25 production: a second parallel DCI channel exists at the Treasurer's office The Treasury R1 batch establishes that DCI's institutional sales operation maintains a parallel direct channel into the Arkansas Treasurer's office, distinct from the Auditor's-office channel. The Treasurer's-office channel: - Originates with Berman's direct relationships with Steve Pulley (Senior Investment Officer, since 2023) and Celeste Gladden (wire operations, since 2023), maintained through Walther-era institutional-customer engagement - Extends in Thurston era to Bill Huffman (Chief Deputy Treasurer, by April 2025) for portfolio-target-setting, and Sandra Blount (Executive Assistant to Thurston, by April 2025) for direct meeting scheduling - Bypasses the Auditor's-office channel for substantive transactions: the 4/16/2025 Berman rate-sheet pitch was sent directly to Pulley with no Auditor's-office cc; Pulley's order placement and Huffman's QIB letter signing involved no Auditor's-office routing; the 4/15/2025 meeting scheduling was direct Berman-to-Blount correspondence The wiki's prior framing of the Auditor's office as "the" DCI channel into Arkansas state government is therefore refined. DCI maintains at least two documented channels: 1. **The Auditor's-office channel** (Spadoni-Brady-Milligan): focuses on access-coordination, multi-officer Capitol tours, SFOF-network political infrastructure, and pension-board motion-making (via Brady's APERS IFSC seat and ATRS Board designee role); originates from Milligan-Berman personal relationship dating from Milligan Treasurer years 2. **The Treasurer's-office channel** (Pulley-Gladden-Huffman-Blount): focuses on transactional execution, established-institutional-customer relationship management, holiday correspondence cadence, and direct portfolio-target conversations with Chief Deputy Treasurer level; originates from Berman's direct customer relationship with Treasury investment staff dating from at least November 2023 The two channels reinforce each other in the documented April 2025 Capitol tour: the Auditor's-office channel orchestrated the multi-official tour bringing Berman/Young to Arkansas; the Treasurer's-office channel completed the resulting $20M Thurston purchase via Berman's direct Huffman/Pulley/Gladden coordination over the following two weeks. Whether DCI maintains additional parallel direct channels at other Arkansas state agencies (the State Bank Commissioner Susannah Marshall is documented as absent from Israel Bonds correspondence; the DFA Hudson, Speaker Evans, President Pro Tempore Hester relationships are documented only at the Capitol-tour level) is a follow-up question. The structural significance is that the "channel" concept extends beyond the Auditor's-office's institutional locus to a multi-institution DCI access network with both intermediary-coordinator nodes (Auditor's office) and direct-customer nodes (Treasurer's office). The Pulley-Berman 2023 working relationship documented in the Treasury R1 batch predates the Brady-Berman wiki-documented institutional relationship by at least one year, establishing the Treasurer's-office channel as institutionally prior to the Auditor's-office channel in the wiki documentary record. [[treasury-foia-r1-7-7-25]] source page [[steve-pulley]] [[celeste-gladden]] Treasurer's-office channel principals dating from 2023 [[bill-huffman]] [[sandra-blount]] Treasurer's-office channel principals added in April 2025 [[state-treasurer-israel-bonds-operations]] companion concept page on the Treasurer's-office operational pathway the channel executes through [[october-2024-treasurer-israel-prayer-ceremony]] Walther-era political-solidarity event documenting the political-rationale framework supporting the Treasurer's-office channel ## Auditor R3 3-3-26 production: post-vote Brady-Berman direct correspondence and personal-AOL routing The Auditor R3 production at [[auditor-foia-r3-3-3-26]] extends the channel concept with two substantive post-vote findings. **The 7/12/2025 Brady-Berman direct correspondence.** Brady's Sent-Items contains `The Arkansas times article` (Sat 7/12/2025 6:54 AM CDT), Brady to [email protected]. The body is the bare Arkansas Times URL plus "Sent from my iPhone." Brady forwarded the published Lenow article to the DCI National Managing Director within 15 hours of publication, with no substantive commentary. This is the first documented post-vote Brady-Berman direct outbound; it operationally confirms that the Brady-Berman working relationship continues into the post-vote period. The 7/12 forward is the personal-relationship-driven element of the channel manifesting in the post-vote operational coordination. Brady's documentary obligation to brief DCI's National Managing Director on adversarial press coverage runs through the established channel. **The Milligan personal AOL routing pattern.** Brady forwarded Mark White's 7/11/2025 3:55 PM ATRS Board notification of the Arkansas Times article publication to Milligan at his personal AOL address `[email protected]` at 7/11/2025 7:28 PM CDT from his iPhone. The same Milligan personal AOL address documented at [[stacy-peterson]] for the 10/4/2024 Israel solidarity speech approval. Second documented instance of Brady-Milligan personal-account routing on Israel Bonds business. The personal-AOL routing has the substantive operational consequence of moving correspondence outside the Auditor's-office FOIA-search perimeter. Personal-domain accounts are not subject to FOIA at the agency level. The Auditor's-office channel therefore operates with a documented personal-account-routing escape hatch for sensitive correspondence; the wiki's [[auditor-foia-r2-residual]] documentation of Brady-Spadoni text-message coordination (the "send this email to she Senator from the dm account" Brady-to-Spadoni Dotson ghost-writing) is structurally parallel. The combined evidence — personal-AOL routing for ATRS Board correspondence, text-message ghost-writing under "DM" signature, the auditor@ shared-mailbox routing patterns documented at [[auditor-foia-r2-residual]], Brady's iPhone-as-primary-routing-device pattern across the R3 production — establishes that the Auditor's-office channel for Israel Bonds correspondence operates through multiple parallel routing paths beyond the agency-domain email channel. ## The DFA channel as structurally distinct alternative: ASHERS routing The ASHERS production at [[ashers-foia-r1-3-27-26]] documents a structurally distinct DCI distribution channel that is operationally separate from the Auditor's-office-channel: the DFA channel, mediated by [[andy-babbitt]] as DFA Deputy Director and State Controller. The 4/15/2025 Capitol tour bilateral with DFA Secretary Hudson at the Auditor's office Room 230 (one of the eight bilaterals documented at [[auditor-multi-official-capitol-tour]]) included Babbitt, and the next morning Babbitt initiated the "Virtual Introductions" email from his DFA address to ASHERS Executive Secretary [[robyn-smith]], cc'ing Berman and Young. The introduction email includes Babbitt's own DCI-promotional framing in his own voice ("Development Corporation for Israel/Israel Bonds ranks among Israel's most valued economic and strategic resources, with a record of proven success spanning over 70 years..."), tracking the DCI institutional-sales pitch language documented at [[dci-promotional-pipeline]]. The DFA channel produced a categorically distinct outcome from the Auditor's-office channel: - The Auditor's-office channel reached ATRS (Brady seed → adoption Resolution 2025-22) and APERS (same Brady seed → IFSC authorization 5/15/2025) with sustained Berman re-engagement and eventual adoption. - The DFA channel reached ASHERS (Babbitt introduction → Berman single pitch → Smith no reply) with no sustained re-engagement and passive-non-engagement decline. The same DCI representatives (Berman, Young) executed the same opening move (warm introduction plus the APPROVED PPT 2.6.25 JH.pdf pitch deck) across both channels. The categorical outcome difference is not in DCI's sales technique but in the receiving channel's institutional anchoring. The Auditor's-office channel had Brady's preexisting Milligan-Berman personal relationship as the operative anchor; the DFA channel had Babbitt's first-meeting-day-old institutional contact with Berman as the operative anchor. The structurally distinct outcome documented at [[ashers-declined-pitch-control-case]] establishes that the channel routing — not DCI's pitch content or quality — is the operative variable distinguishing adopting from non-adopting Arkansas pension systems. The DFA channel's documented operational mechanic also is structurally distinct from the Auditor's-office channel's. The Auditor's-office channel deploys Brady as the persistent intermediary who runs follow-up coordination, drafts ghost-written Milligan correspondence, orchestrates Capitol tours, attends APERS meetings as Milligan proxy, and routes documents through personal-AOL accounts. The DFA channel deployed Babbitt for a single introduction email; the production captures no documented Babbitt-Berman-Smith re-engagement, no documented Babbitt sustained involvement, no documented DFA-side Capitol-tour-orchestration analogue. The DFA channel is documented as a one-shot introduction without sustained follow-through; the Auditor's-office channel is documented as a multi-year persistent intermediary apparatus. ## Tensions This concept page surfaces 1 first-class tension filed as a tension page per the Hegelion layer documented at [[methodology]] § II. - [[T013 - Brady APERS IFSC Motion as Channel-Apex vs Designated-Member Role]] — the contested mechanism is the operative institutional framing of Brady's 5/15/2025 APERS IFSC motion to authorize $25-50M in Israel Bonds. Statement A: the motion is the documented apex of the Auditor's-office DCI channel, fusing channel-coordination role with formal pension-board membership performing motion-making in the seller's interest. Statement B: the motion is the designated APERS IFSC member exercising the proper member role under the IFSC's deliberative structure (six members including three cabinet-or-designee seats by institutional design). *Framing tension. Status: open.*