# DCI Arkansas Limited Registration Arkansas is one of only two US jurisdictions where the Development Corporation for Israel's broker-dealer registration is explicitly limited to a single product. Per the Web CRD Organization Registration Status display, DCI's Arkansas registration is "Limited - BONDS FOR THE STATE OF ISRAEL" effective June 25, 1984. North Dakota holds the only other documented same-category restriction: "Limited - STATE OF ISRAEL BONDS ONLY" effective March 17, 1970. The Arkansas registration restriction is the operative state-regulatory framing of DCI as a single-issuer broker-dealer that has governed DCI's Arkansas operations for 42 years. The single-issuer restriction is structurally significant for the wiki's [[independent-credit-analysis-gap]] analysis. A broker-dealer that is explicitly licensed by the state Securities Department to sell only one issuer's bonds is, by the terms of its state registration, not in the business of comparative-instrument analysis, multi-issuer credit research, or alternative-investment recommendation. Arkansas regulators have known and enforced for 42 years that DCI sells only State of Israel bonds and nothing else. The institutional framing the wiki documents at the Arkansas pension systems' adoption pathway — DCI's Berman/Young pitch decks, the 5/15/2025 APERS IFSC Brady-presenter motion, the 6/2/2025 ATRS Board Resolution 2025-22 — operates against a state-regulatory backdrop in which DCI's role as a single-product seller is the structurally documented baseline. ## The 50-state registration record The Web CRD Organization Registration Status at ASD-152 documents DCI's broker-dealer registration in all 50 US states plus DC, PR, and VI. The verbatim status entries by jurisdiction (effective dates): | Jurisdiction | Status | Effective | |---|---|---| | SEC | Approved | 04/25/1955 | | FINRA | Approved | 12/09/1983 | | AL | Approved | 12/19/1983 | | AK | Approved | 04/19/1974 | | **AZ** | **Limited** | **01/24/1980** | | **AR** | **Limited - BONDS FOR THE STATE OF ISRAEL** | **06/25/1984** | | CA | Approved | 02/21/1984 | | CO | Approved | 12/20/1983 | | CT | Approved | 01/11/1985 | | DE | Approved | 01/04/1984 | | DC | Approved | 09/15/1984 | | FL | Approved | 07/02/1984 | | GA | Approved | 12/22/1983 | | HI | Approved | 03/30/1959 | | ID | Approved | 12/27/1983 | | IL | Approved | 04/25/1984 | | IN | Approved | 12/15/1983 | | IA | Approved | 07/12/1983 | | KS | Approved | 06/01/1955 | | KY | Approved | 12/21/1983 | | LA | Approved | 05/23/1983 | | ME | Approved | 03/16/1984 | | MD | Approved | 10/28/1962 | | MA | Approved | 05/21/1996 | | MI | Approved | 12/19/1983 | | MN | Approved | 12/16/1983 | | MS | Approved | 01/05/1984 | | MO | Approved | 06/05/1984 | | MT | Approved | 01/09/1984 | | NE | Approved | 05/14/1984 | | NV | Approved | 12/28/1983 | | NH | Approved | 05/10/1999 | | NM | Approved | 12/13/1983 | | NY | Approved | 04/03/1987 | | NC | Approved | 06/05/1984 | | **ND** | **Limited - STATE OF ISRAEL BONDS ONLY** | **03/17/1970** | | OH | Approved | 12/20/1983 | | OK | Approved | 05/17/1955 | | OR | Approved | 01/01/1982 | | PA | Approved | 02/28/1977 | | PR | Approved | 11/14/1990 | | RI | Approved | 01/31/1984 | | SC | Approved | 12/16/1983 | | SD | Approved | 12/16/1983 | | TN | Approved | 02/19/1959 | | TX | Approved | 03/21/1984 | | UT | Approved | 06/17/1996 | | VT | Approved | 02/13/1984 | | VI | Approved | 05/19/2008 | | VA | Approved | 12/13/1983 | | WA | Approved | 12/28/1983 | | WV | Approved | 12/01/1961 | | WY | Approved | 07/11/1984 | > ASD-152_Registration-Status-CRD.pdf, pages 1-2 47 jurisdictions are "Approved" (general broker-dealer status). Three jurisdictions are "Limited": - **AR**: "Limited - BONDS FOR THE STATE OF ISRAEL" (06/25/1984) - **ND**: "Limited - STATE OF ISRAEL BONDS ONLY" (03/17/1970) - **AZ**: "Limited" (01/24/1980), restriction terms not specified in the Web CRD display The Arkansas and North Dakota restrictions are the only two with explicit text identifying State of Israel bonds as the single permitted product. North Dakota's restriction is 14 years older than Arkansas's; AZ's restriction is 4 years older than AR's, but AZ's restriction text is not documented in the production. Eight jurisdictions show registration effective dates older than 1980 (SEC, FINRA-equivalent, HI, KS, MD, OK, TN, WV) but all eight are "Approved" rather than "Limited"; ND's 1970 restriction is the earliest documented Limited state. ## The Types-of-Business code that operationally substitutes for state limits Outside of the AR/ND/AZ explicit restrictions, DCI's single-issuer status is documented at the FINRA-level through its Types-of-Business filing per ASD-155: > [!evidence] ASD-155_Types-of-Business-CRD.pdf, page 1 > "Item # 12Q | Description: Broker or dealer selling securities of only one issuer or associate issuers (other than mutual funds) | Code: BIA" Code 12Q is DCI's only entered Types-of-Business code. The category text ("Broker or dealer selling securities of only one issuer or associate issuers (other than mutual funds)") operates as DCI's self-disclosed business scope across all 50 state registrations and the SEC/FINRA federal registrations. The AR and ND explicit Limited status entries are state-regulator restatements of what the FINRA 12Q code already documents. The structural distinction: AR's and ND's Limited restrictions are state-regulator-imposed; the 12Q Types-of-Business code is DCI-self-disclosed. The 47 other "Approved" jurisdictions did not impose explicit single-product registration limits but DCI's self-disclosed 12Q code operates as the functional equivalent at the FINRA-supervisory level. ## DCI has no Arkansas physical presence DCI's AR-Limited registration coexists with no documented Arkansas physical presence. Per ASD-006 Arkansas Form BR Branch Offices and ASD-153 Schedule E Branch Offices, no DCI branch office is currently registered in Arkansas. The wiki's [[development-corporation-for-israel]] entity page documents DCI's New York headquarters at 641 Lexington Avenue (current) and the Atlanta Southeast Regional Office that operates Brad Young's territory; neither location is in Arkansas. The 6 AR-registered DCI broker-dealer agents documented at ASD-151 ([[lawrence-berman]], [[brad-young]], [[stuart-garawitz]], [[jacqueline-miron]], [[nir-fisher]], [[samuel-libchaber]]) are all registered to act as DCI agents in Arkansas but none is documented as physically based in Arkansas. Berman is based in New York; Young is based in Atlanta; the other four agents' physical locations are not documented in the production. The combination — AR Limited registration to Israel Bonds + no AR branch office + no AR-based agents — operationally means DCI's Arkansas business is conducted by out-of-state registered persons under the Section 3(e) principal-designation requirement documented at [[dci-1986-arkansas-suspension]]. The wiki's documented DCI-Arkansas interactions (the November 2024 Berman/Young Little Rock visit, the April 2025 multi-official Capitol tour, the May 2025 Thurston purchase coordination, the 5/15/2025 APERS IFSC, the 6/2/2025 ATRS Board) all involve out-of-state DCI personnel operating in Arkansas as state-registered agents under DCI's Limited registration. ## Connection to the independent-credit-analysis gap The AR single-issuer Limited registration structurally reinforces the [[independent-credit-analysis-gap]] finding. A broker-dealer whose state registration explicitly limits its operations to selling one issuer's securities cannot, structurally, be expected to provide independent credit analysis on alternatives to that one issuer's securities. The 12Q Types-of-Business code reinforces the same point at the FINRA level. The "exceeding the scope of their securities licensure" framing Mark White used in his 7/2/2025 Lenow response (documented at [[auditor-foia-r3-3-3-26]]) applies at a different level — Aon's general-securities-licensure scope — but the structural inverse applies to DCI: DCI's Arkansas securities licensure is exclusive to one issuer's securities, so DCI cannot structurally provide comparative-credit analysis even if it wished to. The structural finding bears on the wiki's documented institutional pattern across the Arkansas Israel Bonds adoption pathway: Berman serves as both seller (DCI Limited registration scope) and as primary analytical-content provider to Arkansas state government purchasers (the rate sheets, the economic overview decks, the 1/15/2025 Rothenberg briefing, the Israel Ministry of Finance directive context documented at [[development-corporation-for-israel]]). The seller-as-analyst dual role is structurally guaranteed by DCI's registration scope: there is no independent analyst inside DCI's Limited-scope universe because the scope is limited to one product. The Treasury Investment Policy's exemption of Israel Bonds from credit rating requirements since July 2017 (documented at [[treasury-internal-credit-analysis]]) creates a parallel structural gap on the buyer side: the Arkansas Treasurer's-office Investment Policy does not require independent credit ratings for Israel Bonds purchases, and DCI's AR Limited registration does not provide independent credit analysis on alternatives. The combination produces a purchaser-and-seller pair in which neither side is structurally configured to perform independent credit analysis on Israel Bonds. The Treasury's October 2024 internal credit memo (the only documented internal Treasury credit work on Israel Bonds across the wiki's productions) was authored by Pulley and recommended HOLD; the wiki's documented purchase pattern subsequently overrode the HOLD recommendation in May 2025 and February 2026 per [[state-treasurer-israel-bonds-holdings]]. ## Connection to the 12Q single-issuer Types-of-Business code DCI's 12Q Types-of-Business code at ASD-155 is the firm's self-disclosed business scope. The 12Q category is FINRA's standardized code for "Broker or dealer selling securities of only one issuer or associate issuers (other than mutual funds)." DCI's single-entry 12Q filing operates as the analog of the AR/ND Limited registrations at the federal regulatory level: DCI has voluntarily self-categorized as a single-issuer broker-dealer with no other documented Types-of-Business activities (no investment-advisor business per the "No IA Record" line at ASD-152 and ASD-155; no general broker-dealer activity beyond the 12Q scope). The 12Q code is structurally distinct from the more common broker-dealer Types-of-Business codes (general securities, mutual funds, options, government securities, municipal securities, etc.) that other Arkansas-registered broker-dealers carry. The wiki has no comparable Types-of-Business documentation on other Arkansas state-government securities counterparties (BNY Mellon, Stephens, Bank of America Merrill Lynch, Reams Asset Management); the Arkansas pension systems' general-securities-dealer counterparty pool operates under broader scope codes than DCI's 12Q. DCI's 12Q is the structurally narrowest scope on the Arkansas pension systems' counterparty roster. ## Implications for AR Securities Department oversight authority The AR Limited registration grants the AR Securities Department continuing supervisory authority over DCI's Arkansas operations. The Department's documented exercise of that authority is concentrated in two episodes: - The 1986 procedural-compliance suspension and reinstatement (Order 86-27-S and Order 86-27a-S) documented at [[dci-1986-arkansas-suspension]] - Routine registration maintenance through periodic Form CRS filings (ASD-007, ASD-112), Form BR filings (ASD-006), and Acknowledgement Forms (ASD-001, 1987; ASD-004, 2023) The AR Securities Department's supervisory authority under the AR Securities Act extends to: - Investigation of DCI sales practices in Arkansas - Examination of DCI institutional sales to Arkansas accredited investors under Reg D - Coordination with the Arkansas State Treasurer's office, the Arkansas State Board of Finance, and the State Auditor's office on Israel Bonds purchase activity - Investigation of DCI's compliance with the Section 3(e) principal-designation requirement on an ongoing basis - Enforcement of the AR-specific Limited-to-Israel-Bonds scope on DCI's Arkansas sales activity The Arkansas Securities Department FOIA production at [[securities-foia-r1-4-20-26]] does NOT document any post-1986 substantive supervisory engagement by the AR Securities Department on the above categories of authority. The post-1986 oversight, if any, is not preserved in the 155 ASD files; the documented post-1986 record is registration maintenance and routine filings only. Whether the AR Securities Department has investigated, examined, or coordinated on DCI's Arkansas state-government Israel Bonds sales pattern is not knowable from the production. ## Cross-references [[securities-foia-r1-4-20-26]] source page [[development-corporation-for-israel]] DCI entity page (AR Limited registration documented in DCI regulatory profile) [[dci-1986-arkansas-suspension]] companion concept page on the 1986 procedural-compliance suspension orders [[dci-finra-disclosure-events]] companion concept page on DCI's 4 FINRA Current Disclosure Summary occurrences [[independent-credit-analysis-gap]] structurally reinforced by the AR Limited registration finding (a single-issuer state-licensed dealer cannot structurally provide independent credit analysis on its single product) [[treasury-internal-credit-analysis]] companion concept page on the 10/8/2024 Treasury HOLD memo and the May 2025 / February 2026 overrides [[state-treasurer-israel-bonds-holdings]] companion concept page on the AR Treasury's $135M cumulative / $60M residual Israel Bonds position [[atrs-resolution-2025-22]] [[apers-israel-bonds-authorization]] companion concept pages on the 2025 Arkansas pension systems' adoption pathway ## Tensions This concept page is documentary-inventory and surfaces no first-class tensions. The page documents settled registration-scope records preserved in the Arkansas Securities Department's FOIA production: the 50-state Web CRD Organization Registration Status (ASD-152), the FINRA Types-of-Business 12Q code (ASD-155), and the Arkansas Form BR and Schedule E branch-office records (ASD-006 and ASD-153). The AR-Limited-to-Israel-Bonds registration scope is unambiguous in the Tier-1 record, the 12Q self-disclosed business scope is unambiguous, and the absence of any documented Arkansas physical presence is unambiguous in the production. The downstream connections the page documents (the seller-as-analyst structural feature, the Treasury Investment Policy credit-rating exemption, the purchaser-and-seller analytical-gap pair) are tracked at [[independent-credit-analysis-gap]] and [[treasury-internal-credit-analysis]] where the underlying contestations live. The structural-characterization contestation on the 1986 Arkansas regulatory record is tracked at [[T032 - DCI 1986 Arkansas Suspension Substantive vs Pro Forma]] on the companion concept page [[dci-1986-arkansas-suspension]]. See [[methodology]] § II for the criteria distinguishing documentary-inventory pages from concept pages that surface contested mechanisms.