# SFOF and the State Financial Officer Network The Israel Bonds adoption pattern in Arkansas, as documented in the FOIA productions to date, sits inside a broader national infrastructure organized around the State Financial Officers Foundation (SFOF). This concept page documents what the materials show about that infrastructure and its relationship to the Arkansas events. ## What SFOF is SFOF is a 501(c)(3) non-profit headquartered in Shawnee, Kansas, with Dr. OJ Oleka as CEO. Its self-description in newsletter materials identifies it as "the only organization solely focused on educating and building relationships with free-market, fiscally conservative statewide elected financial officials across the country." Its mission statement is "to drive fiscally sound public policy, by partnering with key stakeholders and educating Americans on the role of responsible financial management in a free market economy." Its constituency is state treasurers, auditors, and analogous elected fiscal officers. Per the [[sfof]] entity page, the organization explicitly framed its 11/4/2024 newsletter to Milligan in terms of state treasurer races: "State treasurers oversee state investments, such as public pension funds, making them responsible for deciding if their respective states will incorporate ESG strategies into their portfolios." ## What the SFOF newsletter to Milligan establishes The 11/4/2024 newsletter from Oleka to Milligan, sent the day before the 2024 general election, made Pennsylvania Treasurer Stacy Garrity's 10/12/2023 $20 million Israel Bonds investment the featured case study. The narrative packaging combined two rationales in adjacent sentences: > "Garrity invested $20 million in Israeli bonds on Oct. 12, 2023, saying it was important 'to show our support at a time when the people of Israel are facing horrific terrorism.' Garrity said the bonds are a good investment because they 'pay above-market returns and they've never defaulted.'" The first sentence is a political-solidarity rationale ("to show our support"). The second is a pecuniary rationale ("above-market returns... never defaulted"). The newsletter format presents both as simultaneously valid, without distinguishing them or acknowledging tension between them. This is the framing distributed to SFOF's network of conservative state financial officers, including Milligan. The opposing-candidate framing is also captured in the same newsletter, providing the contrary view in the documentary record: > "McClelland has argued Garrity politicized the state's investments with foreign policy considerations. She said there are 'too many factors when you're dealing with a foreign country that you cannot control for.' McClelland says she would use the state's investments to promote stricter human rights and environmental standards in corporate supply chains." The newsletter thus places three distinct positions on state Israel Bonds investment in front of Milligan in a single document: political solidarity (Garrity's stated reason), pecuniary justification (Garrity's defense), and politicization concern (McClelland's critique). ## What the timing establishes The SFOF newsletter timing is the load-bearing fact. Brady's outreach to ATRS and APERS executive directors was 10/23/2024. The SFOF newsletter reached Milligan on 11/4/2024. The Arkansas in-person Berman meetings were planned for November 4-7 or November 28-29 per Amy Fecher's reply. So Milligan's office was actively setting up the Arkansas pension Israel Bonds outreach in the same two-week window in which a national peer organization sent him the model case study with both political and pecuniary rationales packaged together. The materials in the FOIA productions to date do not establish that Milligan adopted the Garrity model consciously or as a template. What they establish is that the Garrity model was placed in his inbox by SFOF at precisely the moment the Arkansas pension outreach was being initiated. The Arkansas Israel Bonds adoption that followed (June 2025 Resolution 2025-22 authorizing up to $50 million) parallels the Garrity precedent in structure: a state-level Israel Bonds purchase by a Republican-controlled state office originating outside the pension fund's normal investment-recommendation process. ## What the materials do not establish Whether Oleka, Garrity, or other SFOF leadership communicated with Milligan beyond the single newsletter is not documented in the R1/R2-era materials. (The Treasury R3 production now resolves the prior open question of SFOF's institutional financial relationship with DCI — see "Treasury R3 2-19-26 production: DCI is an institutional SFOF financial sponsor" section below.) Whether the Garrity model functioned as the actual template for the Arkansas approach is not knowable from the documentary record alone. The Arkansas approach (Auditor's-office political channel, pension fund executive director recommendation, Board approval with one dissent) shares structural features with the Pennsylvania approach (state treasurer political solidarity rationale, sole-fiduciary investment authority) but also differs in important respects (Pennsylvania Treasurer has unilateral investment authority; Arkansas pension Board action requires eight affirmative votes). The newsletter's "Dear Tina" salutation (a mailmerge artifact addressing the wrong name in correspondence to Milligan) is a notable production-side detail. It indicates the newsletter is templated communication to a list of state financial officers, not personalized to any individual recipient. The implication is that the same Garrity framing reached an unspecified larger set of state financial officers nationwide. ## Connection to the SFOF disclaimer SFOF's newsletter contains a 501(c)(3) compliance disclaimer at the bottom: "All views, positions, opinions, statements, and recommendations expressed at any State Financial Officers Foundation (SFOF) event or provided in any SFOF print or digital publication or email should not be construed as an endorsement for, or opposition to, any candidate, potential candidate, political party, or PAC by SFOF." Despite this disclaimer, the newsletter's substantive treatment of the Garrity-McClelland Pennsylvania race is asymmetric: Garrity's positions are presented favorably (with sympathetic quotes about Israel solidarity and bond performance), while McClelland's critique is contextualized as politicization concern. The juxtaposition supports a specific implied position even while the disclaimer formally denies endorsement. This is a 501(c)(3)-compliance editorial structure familiar from issue advocacy organizations. ## Investigative implications This concept page documents one specific instance of a national network promoting state Israel Bonds adoption to a specific Arkansas official. Whether similar SFOF distribution reached the State Treasurer (statutory ATRS Investment Committee member) or the State Bank Commissioner (statutory ATRS Investment Committee member) is not documented in this batch but is a follow-up FOIA target. Whether SFOF distributed Israel Bonds advocacy materials to other Arkansas officials, or to APERS, ASHERS, ASPRS, LOPFI staff or board members, is also unknown from this batch. ## Update from the 6/25/25 Brady production The Auditor's own R2 FOIA production substantially expands what is documented about the SFOF network. Three updates matter for this concept page. First, **Milligan is a past chair of SFOF** per his own speech draft. The earlier framing of the 11/4/2024 SFOF newsletter to Milligan as templated mailmerge to a list of state financial officers understated his organizational standing. He is not a peripheral recipient; he is a former national leader of the organization that distributes the Garrity case study and the broader Israel Bonds investment-promotion content to the state financial officer constituency. Second, **SFOF runs a parallel sign-on letter operation** documented at [[sfof-policy-letter-operation]]. Israel Bonds adoption is not the only or primary SFOF activity. The same network that put the Garrity Israel Bonds case in front of Milligan also coordinates monthly sign-on letters to federal officials on Tesla, anti-ESG, anti-CCP, debanking, USTR, and other federal regulatory matters. The Israel Bonds investment-promotion track and the federal-policy-advocacy letter track run in parallel through the same SFOF leadership (CEO Oleka, EVP Wall) and reach the same constituency of approximately 22 state financial officers. Third, **the network has an explicitly Trump-administration alignment**. Oleka's "100 Days In: How Trump Is Rewriting the Rules of Financial Freedom" (4/30/2025) frames SFOF and the Trump administration as policy partners. Brady's draft of Milligan's SFOF speech tells the SFOF audience: "if we 'Conservatives' in this room will lock arms and join forces, with Republicans in control of the White House, House and Senate." The 501(c)(3) endorsement disclaimer SFOF appends to its emails is in textual tension with the substantive partisan alignment. The Garrity Israel Bonds case study is presented to a network whose self-identification is as conservative state financial officers aligned with the federal Republican policy agenda. The "to show our support" framing for Israel Bonds adoption sits inside a broader political identity formation, not a free-floating financial recommendation. ## Evidence > [!evidence] SFOF newsletter self-description, Pre-Election Update from the States - 4 nov 24.pdf p.6 > "We are the only organization solely focused on educating and building relationships with free-market, fiscally conservative statewide elected financial officials across the country." > [!evidence] SFOF newsletter, Pre-Election Update from the States - 4 nov 24.pdf p.3 > "State treasurers oversee state investments, such as public pension funds, making them responsible for deciding if their respective states will incorporate ESG strategies into their portfolios. Additionally, both treasurers and auditors commonly have roles implementing and enforcing pro- or anti-ESG laws and regulations and ensuring funds are invested in the best interests of beneficiaries." > [!evidence] SFOF newsletter, Pre-Election Update from the States - 4 nov 24.pdf p.4, 11/4/2024 > "Garrity invested $20 million in Israeli bonds on Oct. 12, 2023, saying it was important 'to show our support at a time when the people of Israel are facing horrific terrorism.' Garrity said the bonds are a good investment because they 'pay above-market returns and they've never defaulted.'" > [!evidence] SFOF newsletter, Pre-Election Update from the States - 4 nov 24.pdf p.4-5 > "McClelland has argued Garrity politicized the state's investments with foreign policy considerations. She said there are 'too many factors when you're dealing with a foreign country that you cannot control for.'" > [!evidence] SFOF newsletter mailmerge salutation to Milligan, Pre-Election Update from the States - 4 nov 24.pdf p.1, 11/4/2024 > "Dear Tina" > [!evidence] OJ Oleka invitation captured in Milligan Recoverable-Items/Deletions, You're invited! SFOF Event at NYSE!.pdf p.1, 6/13/2025 > "You are cordially invited to join SFOF and Prospr Aligned on July 1 and 2 at the iconic New York Stock Exchange for a bell-ringing event, private NYSE tour, and an SFOF-hosted lunch. There will also be numerous other networking opportunities!" > [!evidence] OJ Oleka, You're invited! SFOF Event at NYSE!.pdf p.1, 6/13/2025 > "Led by Commissioner of Revenue Adam Crum, our friends in Alaska have been actively working to develop an Alaska-focused ETF—one that includes Alaska-based businesses and industries that benefit Alaskans and Alaskan businesses—rather than funds and companies that actively work against the interests of the people of the Last Frontier state. This is a complete and total game-changer." > [!evidence] Stacy Peterson (Director of Communications, Arkansas Auditor of State) to Adam Schwend (SFOF Director of Public Policy), Re Policy Zoom_1.pdf p.1, 6/4/2025 3:23 PM > "Attached are two articles detailing Auditor Milligan's recent work on the two pension boards he sits on which recently voted to invest up to $50 million apiece in Israeli bonds. Feel free to pass along to any member states you think might be interested. The Auditor has very good contacts with the development corporation in case any other states are interested in learning more." ## Tensions This concept page is the documentary surface for one open tension: - [[T044 - SFOF Network Peer Professional Network vs Coordinated Political-Direction-of-Investment Vehicle]] — does SFOF function as a peer professional network of state financial officers operating within standard 501(c)(3) state-officer-association norms, or as a coordinated political-direction-of-investment vehicle that channels specific investment products into state pension and treasury funds through a sponsor-funded multi-state infrastructure. Statement A reads the network as professional-association with diversified programming and member-decision-discretion preserved; Statement B reads the bidirectional Garrity-Pennsylvania-to-Arkansas-to-other-states pattern, the 2020 DCI-as-SFOF-sponsor finding, the multi-entity SFOF + SFOF Action + Prospr Aligned + State Leadership infrastructure, and the Peterson 6/4/2025 model-replication-broker offer as evidence of coordinated political-direction-of-investment. Status: open. ## Update from the R2 Milligan production: the SFOF alumni private-sector successor network The R2 Milligan production ([[auditor-foia-r2-milligan]]) documents that the SFOF network has a for-profit private-sector counterpart in the alumni firms of former SFOF leadership. Two pieces of evidence develop this pattern. First, **Prospr Aligned launched on 1/7/2025 as a for-profit successor to Kreifels's SFOF role**. Derek Kreifels, who co-founded SFOF and served as its CEO for twelve years, formally launched Prospr Aligned as an investment-services consulting firm with the same constituency (public pension funds, state treasurers, institutional investors). The launch press release reached Milligan directly via Mailchimp distribution. The firm's services (proxy voting consulting, manager analysis, corporate engagement) target current state pension officials and overlap with both ATRS's contemporaneous Egan-Jones proxy services contracting and the policy work SFOF nonprofit continues to do. The Public Fiduciary Network Kreifels launched in 2024 under SFOF (a coalition representing over $3 trillion AUM) is referenced in the Prospr Aligned launch materials as the basis for the firm's mission. The nonprofit organizing infrastructure and the for-profit consulting engagement are linked through Kreifels personally. See [[derek-kreifels]] [[prospr-aligned]]. Second, **the SFOF Spring National Meeting functions as a pension-investment introduction venue**. The 4/28/2025 Rob Phillips (Abacus Global Management) email to Milligan and Brady with subject "Thank you + SFOF follow up" confirms that the SFOF Spring meeting was the venue at which Abacus executives Jay Jackson and Rob Phillips met with the Arkansas Auditor's-office contingent and pitched Abacus life settlements as an Arkansas pension investment. Phillips's framing — "your interest in Abacus as an investment for Arkansas' pension funds" — characterizes the Auditor's-office attendees as having affirmatively responded to the pitch. This is a second investment-product introduction (after DCI Israel Bonds) running through the SFOF network. See [[rob-phillips]] [[abacus-global-management]] [[sfof-policy-letter-operation]]. The composite picture is that SFOF, as a 501(c)(3) state-financial-officer network, functions as both a political-advocacy organization (sign-on letters, policy zooms, see [[sfof-policy-letter-operation]]) and a relationship-formation venue for private-sector firms seeking to place investment products with state pension funds. The Israel Bonds adoption pattern is one instance within this broader pattern. The pecuniary fiduciary duty required by Act 498 and BP4 Section D.3 ([[pecuniary-frame-act-498]]) applies to investment-recommendation processes that route through these alternative networks just as it applies to the formal Aon-and-Franklin-Park investment-consultant track. ## Update from R2 Milligan chunk 4: the SFOF + Prospr Aligned NYSE event and the Alaska ETF The R2 Milligan chunk 4 ingest adds a third documented investment-product launch reaching Milligan through the SFOF channel. OJ Oleka's 6/13/2025 invitation captured in Milligan's Recoverable-Items/Deletions ([[auditor-foia-r2-milligan]] Chunk 4) announces a SFOF + Prospr Aligned cohosted NYSE event on 7/1-7/2/2025 launching an Alaska-focused ETF developed by Alaska Commissioner of Revenue Adam Crum. The agenda is a NYSE bell-ringing event, a private NYSE tour, and an SFOF-hosted lunch. Travel costs handled like SFOF national conferences. Three structural facts new to this concept page emerge from the NYSE event. First, **SFOF and Prospr Aligned are formal cohosts** of an investment-product launch celebration at the New York Stock Exchange. The "alumni successor" framing of the 1/7/2025 Prospr Aligned launch and the "stated partnership" framing of Wall's 12/19/2024 SFOF departure note are operationalized in a joint NYSE event approximately six months later. The Prospr Aligned + SFOF partnership is therefore not nominal: it produces NYSE-platform joint events. See [[prospr-aligned]]. Second, **the Alaska ETF is a third documented investment product reaching Milligan through the SFOF channel**. Before chunk 4 the documented products were (a) Development Corporation for Israel bonds (which reached ATRS and APERS Board action stage) and (b) Abacus Global Management life settlements ([[abacus-global-management]], pitched 4/28/2025 at the SFOF Spring meeting). Chunk 4 adds (c) the Alaska-focused ETF cohosted by SFOF and Prospr Aligned. The pattern is consistent: state-financial-officer-network events serve as introduction venues for investment products to be placed with state pension funds. Adam Crum (Alaska Commissioner of Revenue) is a new figure in the SFOF state-financial-officer network alongside Pennsylvania (Garrity), Arkansas (Milligan), and Oklahoma (Russ). Third, **the Alaska ETF product description uses Arkansas-style boycott-list framing**. The Oleka description — "industries that benefit Alaskans and Alaskan businesses—rather than funds and companies that actively work against the interests of the people of the Last Frontier state" — structurally parallels the boycott-list framing in [[atrs-investment-policy-bp4]] Section B (Arkansas anti-BDS list) and Section C (Act 937 of 2025 CCP prohibitions). The Alaska ETF appears to operationalize the same investment-policy logic in vehicle form: a positive-screen ETF anchored on jurisdiction-based exclusions of "hostile" entities. The SFOF network is therefore not only promoting state Israel Bonds adoption to its constituency; it is also coordinating with private-sector partners (Prospr Aligned, NYSE-listed ETF vehicles) on positive-screen exclusion-based investment products that mirror the state-level boycott-list authority Oleka's 11/14/2024 mobilization referenced. See [[sfof-policy-letter-operation]] for the 11/14 mobilization. Milligan's mailbox copy of the NYSE invitation ended up in Recoverable-Items/Deletions, indicating he deleted it. Whether deletion signals non-attendance, calendar cleanup, or another workflow is not addressable from the file alone; the R2 batch ends 6/18/2025 so post-deletion behavior cannot be traced. The 4/18/2025 Prospr Aligned mailmerge to Milligan also documented in chunk 4 (announcing Kreifels's "Pension Industrial Complex" panel at the SFOF Spring National Meeting alongside Jerry Bowyer, Vident CEO Vince Birley, and Oklahoma State Treasurer Todd Russ) extends the network footprint: a sitting state treasurer (Russ) joins Prospr Aligned in publicly-staged panel programming. See [[prospr-aligned]] for the panel composition. ## Update from the Peterson custodian production: the Arkansas Auditor's office as an active SFOF Israel Bonds export node The Peterson custodian production ([[auditor-foia-r2-stacy-peterson]]) documents two structural developments to this concept page. First, **the Auditor's-office October 2024 Israel Solidarity Operation preceded the SFOF Garrity case-study distribution by four weeks**. The Peterson production captures the Auditor's-office Christian-Zionist solidarity campaign — mailed letter to Israeli Ambassador Herzog, Capitol Rotunda press conference at the National Association of Christian Lawmakers event, YouTube video, direct emails to DCI senior leadership and the Israeli Embassy — occurring 10/2-10/7/2024. The SFOF newsletter distributing the Stacy Garrity Pennsylvania $20 million Israel Bonds case study reached Milligan on 11/4/2024. The dual-rationale framing — political-religious solidarity ("to show our support") in adjacent sentences with pecuniary justification ("pay above-market returns and they've never defaulted") — was therefore operationally familiar in the Arkansas Auditor's office before SFOF distributed it as a national template. The Peterson-drafted, Milligan-approved Capitol Rotunda speech text uses the same dual structure: "As a Christian, I have supported Israel all my life... during my tenure we purchased some $85 million in bonds supporting Israel." See [[october-2024-israel-solidarity-operation]]. Second, **Stacy Peterson operationalized the Auditor's office as an active SFOF Israel Bonds export node on 6/4/2025**. Two days after the 6/2 ATRS Board approval of Resolution 2025-22, Peterson emailed SFOF Director of Public Policy Adam Schwend ([email protected]) with two articles documenting the Arkansas pension Israel Bonds vote attached. Peterson's message: "Attached are two articles detailing Auditor Milligan's recent work on the two pension boards he sits on which recently voted to invest up to $50 million apiece in Israeli bonds. Feel free to pass along to any member states you think might be interested. The Auditor has very good contacts with the development corporation in case any other states are interested in learning more." The Arkansas adoption that completed in June 2025 is therefore not the terminus of the SFOF Israel Bonds investment-promotion track; it is positioned by the Auditor's office itself as the next case study after the 2023 Pennsylvania case, with Milligan's office offering itself to other SFOF member states as a DCI-relationship broker. The 6/4 date — the same day as the SFOF Policy Zoom that Milligan deleted from his calendar (per [[auditor-foia-r2-milligan]] chunk 1) and that other Auditor's-office staff received as the post-vote Policy Zoom invite — places Peterson's outbound article forward in close temporal proximity to the post-vote SFOF Policy Zoom programming. Whether Peterson's article-forward was distributed by Schwend to additional SFOF member states is a follow-up FOIA target across state lines. The SFOF state-financial-officer network is therefore documented in this concept page as a fully bidirectional channel: SFOF distributes investment-promotion content to member states (Garrity case study to Milligan 11/4/2024), and member states distribute their adoption case studies back to SFOF for further redistribution (Peterson 6/4/2025 article forward to Schwend). The Garrity-Milligan two-state precedent is the documented pattern as of the FOIA production cutoff; whether additional states have adopted the pattern in response to Peterson's 6/4 offer is not knowable from this batch. ## Update from R2 residual sub-batches: SFOF Communications-Specialist channel and the Auditor's-office Chief of Staff routing The Corrigan custodian production at [[auditor-foia-r2-residual]] adds a Communications-Specialist outreach channel to the documented SFOF network footprint. On 12/20/2024 9:37 AM SFOF Communications Specialist Ryan Chavers ([email protected], 13851 W. 63rd Street Suite 405, Shawnee, KS) emailed CEO Dr. OJ Oleka the SFOF Communications Questionnaire ("Please take a moment to fill out this survey to help us tailor our support to meet your office's needs effectively"). Within thirty minutes the email had reached Melissa Corrigan at the Auditor's office; Corrigan (as Chief of Staff) forwarded to Stacy Peterson (Director of Communications) at 10:07 AM asking "Did you get the email below?" Peterson replied at 10:11 AM "Nope. Do you want me to respond?" Two structural findings emerge. First, Chavers is a fourth named SFOF operational staff member alongside Oleka (CEO), Wall (then EVP Policy), and Slayton (Director of Operations). The Communications-Specialist role represents a dedicated SFOF function for managing routine communications-channel relationships with member-office Communications Directors. Second, the routine SFOF Communications channel reached the Auditor's office at the **Chief of Staff tier** first, not at the Director of Communications tier. Peterson was not on Chavers's direct distribution as of late December 2024 despite her Director of Communications role and her own 2/14/2025 statement to Slayton that she has "worked with SFOF for several years on behalf of" Milligan. Peterson's documented SFOF role was via engagement with Oleka, Slayton, Schwend, and Wall — the policy and operations principals — rather than via the routine Communications-Specialist distribution. The Chavers survey first hit Corrigan, then was routed downward. The implication for the SFOF network concept is that SFOF maintains differentiated outreach channels by recipient role at member offices: policy and operations principals receive direct engagement from Oleka/Wall/Slayton/Schwend, while routine communications matters route through Chavers to Chief of Staff offices first. The Auditor's office, with both Chief of Staff (Corrigan) and Director of Communications (Peterson) roles in the documented [[auditor-office-org-structure]], has internal-routing dynamics that reflect the SFOF tiered outreach model. ## Cross-References [[sfof]] [[oj-oleka]] [[stacy-garrity]] entities [[derek-kreifels]] [[prospr-aligned]] [[rob-phillips]] [[abacus-global-management]] SFOF alumni / private-sector counterparts that reach Milligan via this network [[dennis-milligan]] recipient of the SFOF newsletter and the parallel private-sector materials [[pecuniary-frame-act-498]] companion concept page on the rationale framing tension [[auditor-as-dci-channel]] companion concept page on the parallel DCI institutional channel [[sfof-policy-letter-operation]] companion concept page on the SFOF sign-on letter operation and the Spring National Meeting [[stacy-peterson]] Auditor's-office Director of Communications who operationalized the Arkansas office as an active SFOF Israel Bonds export node on 6/4/2025 [[adam-slayton]] SFOF Director of Operations who functions as a state-financial-officer-to-state-financial-officer broker through member-office Communications Directors [[october-2024-israel-solidarity-operation]] companion concept page documenting the Arkansas Auditor's-office Christian-Zionist solidarity campaign that preceded the SFOF Garrity case-study distribution by four weeks [[jason-rapert]] [[national-association-of-christian-lawmakers]] organizational venue of the parallel Christian-Zionist framing in Arkansas [[melissa-corrigan]] Auditor's-office Chief of Staff who first received the SFOF Communications-Specialist survey at the office-receiving tier [[auditor-foia-r1-milligan]] [[auditor-foia-r2-milligan]] [[auditor-foia-r2-stacy-peterson]] [[auditor-foia-r2-residual]] source pages ## Treasury R3 2-19-26 production: DCI is an institutional SFOF financial sponsor The Treasury R3 (2-19-26) production includes a 12/17/2020 letter on State Financial Officers Foundation letterhead from Dennis Milligan as incoming 2021 SFOF National Chair to "SFOF Family." The letter's primary purpose is Milligan's pre-chair-installation gratitude letter to "every sponsor" listed by name on the second-paragraph sponsor list. **The sponsor list names "Development Corporation for Israel" among 21 enumerated institutional sponsors:** > [!evidence] End of Year Letter from Treasurer Milligan.pdf, 12/17/2020 (emphasis added) > Specifically, thank you to: Public Trust Advisors, Federated Hermes, iTEDIUM, Mastercard, American Council of Life Insurers, Academy Securities, Ascensus, Clearwater Analytics, EVERFI, Fidelity, OpenGov, Pomerantz, LLP, Singularis Group, Visa, EnTrust Global, **Development Corporation for Israel**, Claimfound, Arabesque, KKR, J.P. Morgan, and Robbins Geller Rudman & Dowd, LLP. **This resolves the prior open question** ("Whether SFOF has any institutional or financial relationship with DCI is not documented in this batch") from the original R1 framing of this concept page. **DCI is documented as an institutional financial sponsor of SFOF as of 2020**, alongside major US financial institutions (Fidelity, J.P. Morgan, KKR, Federated Hermes, Visa, Mastercard) and other state-government-services vendors (Public Trust Advisors, OpenGov, EVERFI, Ascensus). The sponsor enumeration includes both substantial financial services firms and DCI as a peer. The structural significance is substantial: (1) **SFOF's Israel Bonds investment-promotion track (Garrity case study, post-vote Arkansas case study, NYSE/Alaska ETF venue) is documented as funded in part by DCI itself.** The "to show our support" framing for Israel Bonds adoption that SFOF distributes to state financial officers (per the 11/4/2024 Garrity newsletter) is structurally a promotion of an investment product whose issuer (DCI) is paying SFOF sponsorship fees. The 501(c)(3) endorsement disclaimer SFOF appends to its emails operates as a regulatory compliance shield around what is operationally a sponsor-funded investment-promotion campaign. (2) **The Auditor's-office Israel Bonds export operation (Peterson 6/4/2025 forward to Schwend offering "very good contacts with the development corporation") is documented as occurring inside a sponsorship relationship.** Peterson's offer to broker DCI introductions for other SFOF member states is a state-government office facilitating sponsor-product distribution within a sponsor-funded network. The bidirectional channel this concept page previously documented (SFOF distributes Garrity case study to Milligan; Auditor's office distributes Arkansas case study back to SFOF for redistribution) is now documented as occurring inside a structural conflict — the issuer of the investment product being promoted is funding the promotional network. (3) **Milligan's standing as SFOF past chair operates in the context of DCI sponsorship of the organization he chaired.** Milligan was SFOF National Chair for 2021, the same calendar year in which the 12/17/2020 sponsor letter was sent. His incoming-chair gratitude letter expressly thanks DCI by name. Milligan's long-documented "long-standing personal relationship with Lawrence Berman" (per the seed-list framing) overlaps with his formal SFOF Chair-and-Past-Chair relationship with DCI as institutional SFOF sponsor. (4) **The other named sponsors include several firms with documented investment-product introductions to Milligan through the SFOF channel.** The 2020 sponsor list includes EnTrust Global (named in the 2/22/2021 Kreifels invitation to Milligan to attend an EnTrust Global panel at SFOF Virtual Conference); KKR (a major private-equity firm whose products Aon and Franklin Park frequently recommend to Arkansas public pension funds); Visa and Mastercard (named in the Brady SFOF Spring 2025 speech draft as policy partners); and OpenGov (the financial-reporting platform Treasury used per the R3 Steven Kilgore 1/14/2021 OpenGov reporting email). The SFOF sponsorship list is a documented pipeline of firms whose products subsequently reach state public pension and treasury offices. (5) **The asymmetric editorial treatment in SFOF newsletters of pro-Israel-Bonds positions versus anti-Israel-Bonds critique (the Garrity-vs-McClelland framing this concept page already documents) is now contextualized.** The newsletter is content produced inside a sponsorship relationship; the sponsor is the issuer of the investment product being promoted. The disclaimer-versus-substance tension this concept page previously noted has a structural mechanism in the sponsor-funded-content pattern. The R3 finding does not implicate any particular individual or organization in fraud or impropriety; sponsorships of 501(c)(3) organizations by issuers of regulated investment products are legal under federal nonprofit law. The structural finding is that **SFOF's Israel Bonds investment-promotion track operates inside a documented sponsor-funded relationship with the issuer of the bonds being promoted**, and the Arkansas Auditor's office's Israel-Bonds-promotion activity through SFOF channels (Peterson 6/4/2025 outbound article forward, Milligan past-chair standing, Brady SFOF Spring 2025 speech with DCI-derived content) occurs inside that sponsor relationship. ### 2020 SFOF National Leadership Team and Board of Directors documented in the End of Year Letter masthead The Dec 17 2020 letter's left navigation documents the 2020-2021 era SFOF org chart: **National Leadership Team (2021):** - President: Derek Kreifels (SFOF) - National Chair: Dennis Milligan (Arkansas State Treasurer) - National Vice Chair: John Murante (Nebraska State Treasurer) - Past National Chair: Kelly Mitchell (Indiana State Treasurer) - Auditor At-Large: John "JB" McCuskey (West Virginia State Auditor) - Staff Representative: Lorran Ferguson (Kentucky Deputy Chief of Staff) **Board of Directors:** - President: John Hart - Vice President: Bridgett Wagner - Secretary/Treasurer: Seth Metcalf - Members at Large: Jimmy Kemp, Lisa B. Nelson, Ron Crane, Derek Kreifels The 2020 SFOF org chart predates the post-2024 transitions (Kreifels departing to Public Fiduciary Network 2024 / Prospr Aligned 2025; OJ Oleka assuming CEO). The wiki documentary record now spans the Kreifels-led 2020-2021 era and the Oleka-led 2024-2025 era at the org-chart level. [[treasury-foia-r3-2-19-26]] source page documenting the End of Year Letter and the DCI-sponsor finding [[dennis-milligan]] entity page documenting the 2021 SFOF National Chair role