# State Treasurer's-Office Israel Bonds Holdings ($60M post-Feb 2026, breakdown by Treasurer era) The Arkansas State Treasurer's office held approximately $55 million in Israel Bonds from May 1, 2025 (the Thurston-era ladder purchase) through January 31, 2026, and approximately $60 million from February 15, 2026 onward following the second Thurston-era purchase. The 7/7/25 APERS R1 production captured the original mid-May 2025 BNY-format holdings statement (as a "sample" sent by DCI VP Operations Bill Mulvey to BNY/APERS on 6/30/2025 in connection with the planned APERS Israel Bonds purchase), establishing the CUSIP-level breakdown by Treasurer era. The Treasury R3 (2-19-26) production produces the Computershare Bondholder Statement at 6/30/2025 (cross-confirming the CUSIP-level breakdown) and documents the Feb 17 2026 $10M purchase that brought the position to $60M. The State Treasurer's-office Israel Bonds custodial relationship is with Computershare via the IsraelBondsDirect platform (not BNY directly). Holder Account Number C0018477645. The statement dated 5/5/2025 captures the position immediately after the Thurston-era $20M purchases that closed on 5/1/2025. ## Holdings by CUSIP and Treasurer era **Milligan Treasurer-era purchases ($25M total)**: | CUSIP | Series/Maturity | Coupon | Maturity | Purchase Date | Amount | |---|---|---|---|---|---| | 46513JHA2 | 11TH JUBILEE FIX 10Y | 2.83% | 2030/01/01 | 15 Jan 2020 | $10,000,000 | | 46514TZG6 | 8TH INSTITUTIONAL JUBILEE FIX 5Y | 1.35% | 2026/02/01 | 01 Feb 2021 | $5,000,000 | | 46514TQN1 | 12TH JUBILEE FIX 5Y | 1.92% | 2026/10/01 | 15 Oct 2021 | $5,000,000 | | 46514TZZ4 | 10TH INSTITUTIONAL JUBILEE FIX 5Y | 2.07% | 2026/10/01 | 15 Oct 2021 | $5,000,000 | Subtotal Milligan: $25,000,000. **Walther Treasurer-era purchase ($10M)**: | CUSIP | Series/Maturity | Coupon | Maturity | Purchase Date | Amount | |---|---|---|---|---|---| | 46514AM22 | 11TH INSTITUTIONAL JUBILEE FIX 3Y | 5.40% | 2026/11/01 | 01 Nov 2023 | $10,000,000 | Subtotal Walther: $10,000,000. **Thurston Treasurer-era purchases ($30M total across two purchase events; both structured as multi-CUSIP transactions)**: **Thurston purchase #1 — May 1, 2025 ($20M structured as 3Y/5Y ladder, post-4/15/2025 Capitol meeting with Berman):** | CUSIP | Series/Maturity | Coupon | Maturity | Purchase Date | Amount | |---|---|---|---|---|---| | 46514X2P3 | 12TH INSTITUTIONAL JUBILEE FIX 3Y | 4.66% | 2028/05/01 | 01 May 2025 | $10,000,000 | | 46514X3P2 | 12TH INSTITUTIONAL JUBILEE FIX 5Y | 5.17% | 2030/05/01 | 01 May 2025 | $10,000,000 | **Thurston purchase #2 — February 15, 2026 ($10M single-tenor, post-2/1/2026 $5M maturity reinvestment plus $5M new money from Berman's "add funds to this maturity" upsell):** | CUSIP | Series/Maturity | Coupon | Maturity | Purchase Date | Amount | |---|---|---|---|---|---| | 46515DSQ6 | 13TH INSTITUTIONAL JUBILEE FIX 5Y | 4.93% | 2031/02/01 | 15 Feb 2026 (settlement); 17 Feb 2026 (wire) | $10,000,000 | Subtotal Thurston: $30,000,000. **Total as of February 15, 2026: $60,000,000.** **Position trajectory June 2025 - February 2026:** | Date | Event | Position | |---|---|---| | 6/30/2025 | Bondholder Statement (7 CUSIPs) | $55,000,000 | | 12/31/2025 | A1 Investment Recap snapshot (stable through year-end) | $55,170,751 to $55,347,194 book value + accrued (no principal change) | | 2/1/2026 | 8th Institutional CUSIP 46514TZG6 $5M 1.35% 5Y maturity (Milligan-era position from 2/1/2021 issuance) | $50,000,000 | | 2/15/2026 | 13th Institutional CUSIP 46515DSQ6 $10M 4.93% 5Y new purchase issued | $60,000,000 | The 2/15/2026 settlement / 2/17/2026 wire reflects the Sunday 2/15 issue date plus Monday 2/16 Presidents Day federal holiday pushing wire execution to Tuesday 2/17. **Cumulative position composition as of 2/15/2026** ($60M across 7 CUSIPs): | CUSIP | Coupon | Maturity | Amount | Treasurer Era | |---|---|---|---|---| | 46513JHA2 | 2.83% | 1/1/2030 | $10,000,000 | Milligan | | 46514TQN1 | 1.92% | 10/1/2026 | $5,000,000 | Milligan | | 46514TZZ4 | 2.07% | 10/1/2026 | $5,000,000 | Milligan | | 46514AM22 | 5.40% | 11/1/2026 | $10,000,000 | Walther | | 46514X2P3 | 4.66% | 5/1/2028 | $10,000,000 | Thurston (purchase #1) | | 46514X3P2 | 5.17% | 5/1/2030 | $10,000,000 | Thurston (purchase #1) | | 46515DSQ6 | 4.93% | 2/1/2031 | $10,000,000 | Thurston (purchase #2) | Per-Treasurer-era residual: Milligan $20M (was $25M before 2/1/2026 maturity); Walther $10M; Thurston $30M. ## Substantive observations The $55M total matches Brady's 5/15/2025 IFSC statement to APERS exactly ("the state treasurer's office recently purchased of $20 million in Israel bonds, so the office now holds about $55 million in Israel bonds" per Mike Wickline's 5/15/2025 Arkansas Democrat-Gazette article). The breakdown documents: (1) **Milligan-era purchases were stretched out across 21 months** (Jan 2020, Feb 2021, Oct 2021 twice). Coupon rates 1.35% to 2.83% reflect the low-rate environment of 2020-2021. The 11TH JUBILEE FIX 10Y purchased Jan 2020 is the longest-dated position and matures January 2030. (2) **Walther-era purchase was a single $10M institutional position** in November 2023, three months after Walther became Treasurer in August 2023. The 5.40% coupon reflects the 2023 high-rate environment. (3) **Thurston purchase #1 — May 1 2025 — was structured as a 3-year-plus-5-year ladder, not a single tenor.** The $20M was split as $10M at 4.66% 3Y (CUSIP 46514X2P3, maturity 5/1/2028) plus $10M at 5.17% 5Y (CUSIP 46514X3P2, maturity 5/1/2030). Berman's 4/16/2025 12:06 PM email to Pulley pre-validated the structure ("you were planning to bring the portfolio up to $55M, with the purchase of 3 and 5 year paper. That would be a total purchase of $20M"). Pulley's 4/16/2025 2:20 PM order email confirmed the ladder ("Pencil us in for $10MM of the 3yr 4.66% along with $10MM of the 5yr 5.17%"). The 6/30/2025 Computershare Bondholder Statement and the 5/5/2025 DCI Payment Validation document both cross-confirm the ladder composition. Berman's 4/17/2025 1:48 PM thank-you to Amy Fecher framed the purchase at the aggregate level ("The State Treasurer made another significant investment ($20M) in our bonds after our meeting with his team this week") without breaking out the ladder structure. (4) **The 4/15/2025 Berman Capitol meeting therefore directly caused $20M in Treasurer's-office bond purchases.** The Capitol tour Spadoni and Brady orchestrated produced a documented financial transaction outcome. Per Brady's 5/15/2025 IFSC statement, Thurston disclosed the purchase to the State Board of Finance on 5/12/2025, two weeks before the IFSC's APERS authorization vote. The Treasurer's-office track record was Brady's primary case-in-chief at the IFSC. (5) **Thurston purchase #2 — February 15 2026 — followed the same operational pathway with Berman cold solicitation, Treasury same-day acceptance, and rapid execution.** Berman's 1/14/2026 2:31 PM email to Pulley pitched reinvestment of the upcoming 2/1/2026 $5M maturity AND upsold added funds ("if you wanted to add funds to this maturity, we would of course be more than happy to discuss that as well!"). Pulley accepted in approximately 2 hours and 12 minutes (Pulley's ~4:30-ish PM reply confirmed book-entry settlement preference). The $10M order doubled the maturing $5M position. The CUSIP 46515DSQ6 5-Year at 4.93% was the Feb 1-14 2026 settlement-window CUSIP for the 13th Series Institutional Jubilee Fixed Rate Bonds. (6) **The pattern of Israel Bonds buying acceleration across the four Treasurer eras** (Milligan: $25M over 21 months; Walther: $10M single Nov 2023 transaction; Thurston purchase #1: $20M May 2025 ladder; Thurston purchase #2: $10M Feb 2026 single-tenor) documents Thurston as the most active Israel Bonds buyer per unit time of any documented Treasurer era. Thurston's $30M across 9.5 months (May 2025 - Feb 2026) translates to approximately $38M annualized — substantially above Milligan's $14M/year cadence and equal to or exceeding Walther's $10M-in-one-transaction cadence. The Thurston cadence sustains and extends the APERS-side $25-50M authorization Brady cited the Treasurer's-office track record as case-in-chief for. ## Provenance of the holdings statement The CUSIP-level breakdown comes from the actual State Treasurer's-office holdings statement sent by DCI VP Operations Bill Mulvey to BNY (Christopher Igo, Brian Shea) and APERS (Borromeo, Doolabh) on 6/30/2025 1:31 PM as a "sample statement" demonstrating the format APERS would receive after purchasing Israel Bonds. The statement was attached to Email 11 in the JUL 25 PDF (the "sample statement for Israel Bonds" attachment, "SAMPLE STATEMENT BOOK OR CERT.pdf"). The use of the actual State Treasurer's holdings as a sample statement to demonstrate format has the secondary effect of disclosing the Treasurer's complete Israel Bonds portfolio to the APERS investment team and BNY. The wiki's documentary record of the Treasurer's-office Israel Bonds holdings is therefore precise to the dollar and CUSIP, sourced from a DCI-provided custodial statement rather than from any public Treasurer's-office disclosure. ## Cross-references [[john-thurston]] [[larry-walther]] [[dennis-milligan]] the three Treasurers whose purchases compose the $55M position [[bill-mulvey]] DCI VP Operations who provided the sample statement [[bny]] [[carlos-borromeo]] APERS-side recipients of the sample statement [[lawrence-berman]] DCI sales lead whose 4/17/2025 thank-you to Fecher independently confirms the Thurston $20M post-meeting purchase [[auditor-multi-official-capitol-tour]] the Capitol tour that produced the Thurston $20M purchase [[apers-israel-bonds-authorization]] the parallel APERS IFSC action Brady cited the Treasurer's-office track record as case-in-chief for [[apers-foia-r1-7-7-25]] source page ## Treasury R1 7-7-25 production: cross-confirmation and operational mechanics The Treasury R1 batch independently cross-confirms the CUSIP-level breakdown at the DCI Operations Approval level and documents the operational mechanics that produced the position. **The 5/5/2025 DCI Payment Validation document** (Order ORD-2087155, Operations Approver Steven Hill, Approved status) confirms the Thurston May 2025 portion: $10M 3-year (Pay Date 5/1/2028, Issue Date 5/1/2025, Report Number 2025-667-12IIB03FX-2193057-2) and $10M 5-year (Pay Date 5/1/2030, Issue Date 5/1/2025, Report Number 2025-667-12IIB05FX-2193057-1). The 4.66% and 5.17% coupons from the April 15-30 2025 Rate Sheet match the BNY sample-statement coupons exactly. **The operational chain that produced the Thurston purchase** is now documented end-to-end. The order placement sequence: - 4/15/2025: Berman-Thurston Capitol meeting at 11:30 AM in Treasury State Capitol conference room Suite 220 (Sandra Blount scheduling, Brad Young attending alongside Berman) - Pre-4/16: Berman-Huffman phone conversation in which Huffman sets the $55M portfolio target ("I just talked to Bill Huffman, and he told me you were planning to bring the portfolio up to $55M") - 4/16/2025 12:06 PM: Berman emails Pulley the rate sheet with the Huffman-validated target embedded - 4/16/2025 2:20 PM: Pulley orders $10M 3-year + $10M 5-year ("Pencil us in for $10MM of the 3yr 4.66% along with $10MM of the 5yr 5.17%") - 4/21/2025 9:04 AM: Pulley emails Huffman the QIB Accredited Investor Letter for signature - 4/22/2025 10:47 AM: Gladden transmits the signed Accredited Investor Letter to Berman - 5/1/2025: Wire executed; bonds issued - 5/5/2025: DCI Payment Validation Operations Approval (Steven Hill, ORD-2087155) - 5/12/2025: Thurston reports the purchase to the State Board of Finance ("Regarding foreign investments, we have purchased Israeli bonds in amounts consistent with our historical levels") **The operational mechanics for the Walther-era November 2023 $10M purchase** are also documented. The 11/1-11/2/2023 wire-pending thread captures the cross-team troubleshooting of a BofA "DOMESTIC WIRE HOLD" that delayed the wire from 11/1/2023 to 11/2/2023 03:04 AM. Berman pressured the Treasury team with "If not received today, have to cancel the transaction" before reconciliation occurred. Gladden, Pulley, Mark Ng, Mulvey, and BofA's wire operations team coordinated to clear the hold. **Custodial pathway evolution.** Prior to April 2025, Treasury held its Israel Bonds positions in certificate form via BNY/DTC vault custody. The April 2025 Book Entry migration (Kilgore's policy-review concurrence, Mulvey's coordination with Gladden) shifted the post-2025 positions to Computershare's IsraelBondsDirect Book Entry recordkeeping platform. The sample statement Mulvey provided to BNY/APERS on 6/30/2025 reflects the mixed certificate/Book Entry format of the Treasurer's-office account post-migration ("a sample statement that holds 4 bonds, 2 in book entry, two in certificate form"). The wiki's prior breakdown is therefore now operationally complete: the documented purchases, the documented operational pathways, the documented custodial transition. The framing "consistent with our historical levels" Thurston used in his 5/12/2025 SBOF remarks is descriptively inaccurate against the actual cadence (Milligan $25M over 21 months at ~$5M/year average; Walther single $10M in Nov 2023; Thurston single $20M in May 2025 = 4x historical average annual cadence). ## "Israel Internal Credit overview 10-8-24.docx" referenced The Treasury R1 batch includes Pulley's 12/11/2024 2:41 PM FOIA-response attachment list, which references an "Israel Internal Credit overview 10-8-24.docx" file. The Treasury R2 (9-23-25) production resolves the document text. The full analysis is at [[treasury-internal-credit-analysis]]; the relevant content for this holdings concept page is the document's Conclusion: the Treasury investment team recommended HOLDING existing positions and allowing the $17M maturing in first-half 2025 to roll off, with no new bond purchases. The Thurston May 2025 $20M purchase overrode this internal recommendation, adding $20M rather than allowing the position to decline. ## Treasury R2 9-23-25 production: the complete Treasury Israel Bonds purchase cadence dating to March 2018 The Treasury R2 production produces the full chronological Computershare Bondholder Statements from 12/31/2018 through 6/30/2025, plus the Interest Advice statements from 5/1/2018 through 5/1/2025. The complete documentary record of Treasury Israel Bonds purchases is now in the wiki, substantially extending the wiki's prior framing of Treasury Israel Bonds activity. **The full Treasury Israel Bonds purchase chronology:** | Settle Date | Maturity | Coupon | Amount | CUSIP | Treasurer | Status as of 6/30/2025 | |---|---|---|---|---|---|---| | 01 Mar 2018 | 03/01/2020 | 2.73% | $20,000,000 | 46513XL40 | Milligan | Matured 3/1/2020 | | 15 Jan 2019 | 01/01/2021 | 3.11% | $30,000,000 | 46514AB57 | Milligan | Matured 1/1/2021 | | 15 Jan 2020 | 01/01/2025 | 2.33% | $5,000,000 | 46513JEA5 | Milligan | Matured 1/1/2025 | | 15 Jan 2020 | 01/01/2025 | 2.48% | $5,000,000 | 46513JQZ7 | Milligan | Matured 1/1/2025 | | 15 Jan 2020 | 01/01/2030 | 2.83% | $10,000,000 | 46513JHA2 | Milligan | Held | | 15 May 2020 | 05/01/2023 | 1.57% | $8,000,000 | 46513JCJ8 | Milligan | Matured 5/1/2023 | | 15 May 2020 | 05/01/2025 | 2.03% | $7,000,000 | 46513JRH6 | Milligan | Matured 5/1/2025 | | 01 Feb 2021 | 02/01/2024 | 0.73% | $5,000,000 | 46514TMV7 | Milligan | Matured 2/1/2024 | | 01 Feb 2021 | 02/01/2026 | 1.35% | $5,000,000 | 46514TZG6 | Milligan | Held | | 15 Oct 2021 | 10/01/2026 | 1.92% | $5,000,000 | 46514TQN1 | Milligan | Held | | 15 Oct 2021 | 10/01/2026 | 2.07% | $5,000,000 | 46514TZZ4 | Milligan | Held | | 01 Nov 2023 | 11/01/2026 | 5.40% | $10,000,000 | 46514AM22 | Walther | Held | | 01 May 2025 | 05/01/2028 | 4.66% | $10,000,000 | 46514X2P3 | Thurston (purchase #1, ladder) | Held | | 01 May 2025 | 05/01/2030 | 5.17% | $10,000,000 | 46514X3P2 | Thurston (purchase #1, ladder) | Held | | 15 Feb 2026 | 02/01/2031 | 4.93% | $10,000,000 | 46515DSQ6 | Thurston (purchase #2) | Held | **Cumulative purchases by Treasurer era:** - **Milligan era: $105 million across 6 settlement dates (March 2018 through October 2021).** The first March 2018 purchase ($20M 2Y) is the earliest documented Treasury Israel Bonds purchase. Milligan-era residual at end of Milligan tenure (January 2023): $55M (after the $20M 3/2020 maturity and $30M 1/2021 maturity). Milligan-era residual at the time of the BNY/Mulvey sample statement (mid-2025): $25M (after additional 2023, 2024, and 2025 maturities). - **Lowery era: $0.** Mark Lowery served as Treasurer briefly after Milligan from January 2023 until his death in late July 2023. No Israel Bonds purchases occurred during the Lowery era. - **Walther era: $10 million (single November 2023 purchase).** Walther served as Treasurer from August 3, 2023 (post-Lowery death appointment) through January 2025. The November 2023 $10M 3-year position at 5.40% was the only Israel Bonds purchase during Walther's tenure. Walther's 10/28/2023 Democrat-Gazette announcement framed the purchase in biblical-Christian-Zionist terms ("Those who bless Israel will be blessed, and those who curse Israel will be cursed"). - **Thurston era: $30 million across two purchases (May 2025 ladder + February 2026 single-tenor).** Thurston took office January 14, 2025. **Purchase #1** came four months into his term, two weeks after the 4/15/2025 Capitol meeting with Berman: a $20M laddered transaction composed of $10M 3-year at 4.66% (CUSIP 46514X2P3) and $10M 5-year at 5.17% (CUSIP 46514X3P2), both settle date 5/1/2025. **Purchase #2** came 9.5 months later, on the heels of the 2/1/2026 $5M maturity (8th Institutional CUSIP 46514TZG6) and Berman's 1/14/2026 cold solicitation with explicit upsell pitch: a $10M 5-year at 4.93% (CUSIP 46515DSQ6), settle date 2/15/2026, wire executed 2/17/2026. The Feb 2026 purchase **doubled the maturing position** ($5M → $10M new) and brought the cumulative Treasury Israel Bonds residual to $60M. **Cumulative purchases across all three Treasurer eras: $145M.** **Cumulative maturities through 2/15/2026: $85M** (the $80M through 6/30/2025 plus the 2/1/2026 $5M 8th Institutional maturity). **Residual position as of 2/15/2026: $60M.** ## Refinement of the "consistent with historical levels" framing The wiki's R1 framing of Thurston's 5/12/2025 SBOF "consistent with our historical levels" remarks as "4x the historical average annual cadence" was based on the wiki's prior framing of Milligan-era purchases as "$25M residual = $5M/year average over 21 months." The corrected R2 framing: - **Milligan-era per-purchase amounts ranged $5M-$30M (median $10M, mean $17.5M).** Specifically: $20M (3/2018), $30M (1/2019), $20M cumulative across 3 positions (1/2020), $15M cumulative across 2 positions (5/2020), $10M cumulative across 2 positions (2/2021), $10M cumulative across 2 positions (10/2021). Average per settlement event: $17.5M. - **Thurston's $20M is consistent with the Milligan-era per-purchase cadence in dollar terms.** The descriptively accurate critique pivots from "4x historical average annual cadence" (imprecise per the new data) to substantive grounds. - **The substantively accurate critique is multiple:** (a) The Thurston purchase came after a 17-month gap during which only a single $10M Walther purchase occurred; (b) The Thurston purchase contradicted the 10/8/2024 internal credit recommendation to HOLD positions and not add bonds; (c) The Thurston purchase was preceded by the 4/15/2025 Berman Capitol meeting and the Berman-Huffman target-setting phone conversation; (d) The Thurston purchase was not preceded by a documented re-evaluation of the internal credit-team recommendation. The wiki's prior "4x annual cadence" framing is corrected. The substantively accurate framing emphasizes the internal-recommendation-override pathway documented at [[treasury-internal-credit-analysis]]. ## Pre-Gladden Treasury Israel Bonds account ATTN The Bondholder Statements chronology documents [[autumn-sanson]] as the Treasury Israel Bonds account ATTN from the earliest documented 12/31/2018 statement through statements addressed to "STATE CAPITOL SUITE 220" (the pre-2021 Treasurer's-office location). The transition to Gladden as ATTN at the post-relocation "1401 W CAPITOL STE 275" address (Victory Building) occurs at the 12/31/2021 statement. Sanson's substantive role at Treasury during the 2018-2021 period is not documented; the wiki entity page [[autumn-sanson]] notes the documentary point-of-contact role. ## Treasury R3 2-19-26 production: the Feb 17 2026 second Thurston-era purchase The Treasury R3 (2-19-26) production captures the fourth documented Thurston-era Israel Bonds purchase end-to-end. The Wire Confirm 2-17-26_Redacted.pdf documents the $10M Bank of America outgoing wire to ComputershareInc aaf SOI WirePurch on 2/17/2026 9:37 AM CST, Beneficiary Information "Arkansas State Treasury, Israel Jubilee Bond - 5 Year." The wire was input by Treasury cash-management staff Kathie Insalaco (klinsalaco) and approved by Janice Cohens (jcohens) under dual control at 9:34/9:36 AM CST. The Redacted communications.pdf in the same production preserves the full transaction chronology from Berman's 1/14/2026 2:31 PM cold solicitation to Pulley through Pulley's same-day acceptance (2 hours 12 minutes later), Jimenez's 2/2/2026 order-confirmation email with CUSIP/rate/maturity details, Gladden's 2/3/2026 signed accredited investor letter return, Bradley Young's 2/12/2026 wire-timing confirmation, and Gladden's 2/17/2026 wire-confirmation email to Young. The transaction settled in book-entry form via DCI's IsraelBondsDirect platform. The Feb 2026 purchase is **the second documented substantive override** of the 10/8/2024 internal Treasury credit recommendation to HOLD positions. The Conclusion of that document predicted "the $17M to roll off in the first half of 2025 and the $20M maturing calendar year 2026" would allow the position to decline. The 2/1/2026 $5M maturity was the first 2026 maturity roll-off the document predicted. Instead of allowing the position to decline, Treasury doubled the position with a $10M new purchase ($5M maturity rolled off + $10M new = net +$5M deployment). Combined with the May 2025 override (-$7M + $20M = net +$13M), the cumulative override deployment is **+$18M of new money on top of the maturity-roll-off baseline since the 10/8/2024 HOLD recommendation.** The wiki [[treasury-internal-credit-analysis]] concept page is extended to incorporate the Feb 2026 second-instance override; the institutional pattern that Damon Dortch articulated on 12/6/2024 ("We buy them to make a political statement and usually at the direction of the elected Treasurer") is institutionally durable across two purchase cycles. ## R3 cross-confirmation: 6/30/2025 Bondholder Statement at the certificate-vs-book-entry custody level The Treasury R3 production includes the 8/20/2025-printed Computershare Bondholder Statement for "ARKANSAS STATE TREASURER, ATTN CELESTE GLADDEN" documenting the 6/30/2025 position. The statement format documents the **certificate-form versus book-entry-form custodial split** at the CUSIP level: - **Certificate-form positions ($35M total)**: 46513JHA2 ($10M Milligan 1/15/2020), 46514TZG6 ($5M Milligan 2/1/2021, since matured 2/1/2026), 46514TQN1 ($5M Milligan 10/15/2021), 46514TZZ4 ($5M Milligan 10/15/2021), 46514AM22 ($10M Walther 11/1/2023). These are pre-April-2025-Book-Entry-migration positions held in BNY/DTC vault as physical certificates. - **Book-entry-form positions ($20M total)**: 46514X2P3 ($10M Thurston 5/1/2025 3Y), 46514X3P2 ($10M Thurston 5/1/2025 5Y). These are post-April-2025-Book-Entry-migration positions held in Computershare's IsraelBondsDirect platform. The Feb 2026 purchase (CUSIP 46515DSQ6) is the second post-migration purchase and is held in book-entry form per Pulley's 1/14/2026 confirmation to Berman. Treasury's book-entry positions after 2/15/2026 will total $30M (the two Thurston #1 ladder positions plus the Thurston #2 single-tenor position); certificate-form positions decline to $30M (Milligan-era 46513JHA2 + 46514TQN1 + 46514TZZ4 + Walther 46514AM22, after the 2/1/2026 maturity of 46514TZG6). The April 2025 Book Entry custodial migration is approaching majority-of-portfolio status as the older certificate-form positions mature off and new book-entry purchases accumulate. ## Refinement of the "consistent with historical levels" framing (extended through Feb 2026) The 5/12/2025 Thurston SBOF "consistent with our historical levels" framing was challenged by the R2 production data (Milligan-era per-purchase amounts $10M-$30M, mean $17.5M; Thurston purchase #1 $20M within the Milligan-era per-purchase range). The R3 production extends this analysis: - **Thurston purchase #2** at $10M is below the Milligan-era per-purchase mean of $17.5M but above the Walther single $10M precedent. - **Cadence across the two Thurston purchases** is 9.5 months apart (5/1/2025 and 2/15/2026). This is roughly comparable to the Milligan-era cadence (March 2018; January 2019; January 2020; May 2020; February 2021; October 2021) which averaged approximately 9 months between purchase events. The two-Thurston-purchase cadence does NOT exceed the Milligan-era cadence in time terms. - **Cumulative Thurston deployment** at $30M across 9.5 months equals approximately $38M annualized — above the Milligan-era $14M/year average but below the Milligan peak years (2018 and 2019 each saw single purchases of $20M-$30M). The substantively accurate critique is still the internal-credit-recommendation-override pathway, not the cadence. Whether Thurston repeats the SBOF "consistent with historical levels" framing for the Feb 2026 purchase is a future ingest target. [[treasury-foia-r1-7-7-25]] [[treasury-foia-r2-9-23-25]] [[treasury-foia-r3-2-19-26]] source pages [[state-treasurer-israel-bonds-operations]] concept page on the end-to-end operational pathway [[october-2024-treasurer-israel-prayer-ceremony]] the Walther-era political-solidarity event preceding the documented Israel Internal Credit overview document [[treasury-internal-credit-analysis]] the substantive 10/8/2024 internal credit overview and its override by the Thurston purchase [[steve-pulley]] [[bill-huffman]] [[celeste-gladden]] [[autumn-sanson]] Treasurer's-office principals in the operational pathway [[steven-hill]] DCI Operations Approver on the 5/5/2025 Payment Validation ## Tensions This concept page surfaces 1 first-class tension filed as a tension page per the Hegelion layer documented at [[methodology]] § II. - [[T012 - Thurston Consistent with Historical Levels Framing]] — the contested mechanism is whether Thurston's 5/12/2025 SBOF disclosure framing ("the Treasury purchased Israeli bonds in amounts consistent with our historical levels") is descriptively accurate against the full historical record. Statement A: descriptively accurate at the per-event-amount cadence (Milligan-era median $10M, mean $17.5M; Thurston $20M within range; 9.5-month gap matches Milligan-era ~9-month cadence). Statement B: descriptively accurate at the narrow per-event-amount level but operationally misleading against the full institutional context (17-month interval between Walther Nov 2023 and Thurston May 2025, the 10/8/2024 internal HOLD recommendation, the 4/15/2025 Berman Capitol meeting and Berman-Huffman target-setting). *Framing tension. Status: open.*