# Carlos Borromeo Deputy Director Investments and Finance, and Chief Investment Officer, Arkansas Public Employees Retirement System (APERS). Address 124 W Capitol Ave., Suite 400, Little Rock AR 72201. Phone (501) 682-7864. Email [email protected]. Per the seed-list, characterized as the APERS CIO who is not involved in the Israel Bonds decision. The APERS R1 production refines this framing: Borromeo is procedurally involved as the IFSC packet curator and the FOIA-responsive substantive author, but the substantive Israel Bonds presentation and motion at the IFSC meeting were Brady's, not Borromeo's. ## The 11/5/2024 Election Day APERS meeting The 6/25/25 Auditor FOIA production captures the first documented Borromeo correspondence. On Tuesday, November 5, 2024 (Election Day), Lawrence Berman and Brad Young of DCI met with Borromeo and Ashley Golleher at APERS. Berman wrote to Borromeo and Golleher on 11/7/2024: "Thanks again for your kind hospitality, and for spending so much time with Brad and me on election day! I hope we were able to give you a better understanding of our firm and our products. We certainly appreciate you offer to introduce us to your fixed income managers." Berman followed up on 1/15/2025 asking Borromeo and Golleher to "send a letter of introduction to the managers you think make best sense for our products. I want to meet with them in person if possible." Borromeo's reply on 2/12/2025 is procedurally cautious: "Thank you for reaching out to APERS and my apologies for the delayed reply. I have shared your information with our investment managers for their review. If they determine there is an opportunity that aligns with the strategy they manage for APERS they will reach out as appropriate." ## The 12/10/2024 Mryyan FOIA: zero APERS Israel Bonds prior to 5/15/2025 The APERS R1 production now establishes the documentary baseline for APERS Israel Bonds exposure. On 12/10/2024 11:30 AM, Borromeo replied to APERS General Counsel Laura Gilson on the Mryyan FOIA submission of the same date: "Because the Development for Israel bonds, which are issued by the Development Company for Israel, are not tradable and must be held until maturity, since August 01, 2017, APERS/ASPRS/AJRS has made zero investments with the Development Company for Israel. Regarding CUSIP 46513YJH2, since August 1, 2017, APERS/ASPRS/AJRS has zero transactions with that specific CUSIP." The reply also documents that APERS administers ASPRS (Arkansas State Police Retirement System) and AJRS (Arkansas Judicial Retirement System) investments as a single unit ("APERS/ASPRS/AJRS"). ## The 5/14/2025 Stephens "fixed income eyes" consultation On 5/14/2025 12:24 PM, the day before the IFSC meeting, Borromeo emailed Stephens Capital Management's Bo Brister, Larry Middleton, and Seth Middleton with subject "Bonds" and a single-sentence body: "Bo I will need your fixed income eyes please / https://israelbonds.com/". Brister replied at 1:59 PM same day: "You bet. / Do we need to discuss?" The captured production thread ends there. The production contains no documented Stephens written analysis on Israel Bonds. Borromeo subsequently forwarded the entire thread to Fecher and Gilson on 5/28/2025 at 2:52 PM with the cover line "Laura here is an email string that I sent to Stephes [sic] re: Israel bonds" — implying responsiveness to a FOIA. APERS therefore sought no documented independent fixed-income analysis on Israel Bonds before the IFSC vote authorized the investment. ## The 5/8/2025 IFSC agenda email — Borromeo's contemporaneous structural framing On 5/8/2025 7:08 AM Borromeo emailed Fecher the proposed IFSC agenda for May 15. Borromeo's intentional curation: "Amy here is the agenda for the IFS meeting on the 15th, comments in the parenthesis is what I hope to achieve. / Secondary Infrastructure – Carlos will lead discussion. (I would like to add 3 new investment managers to the APERS lineup) / Private Credit discussion – Bo and team Stephens will lead the discussion (I didn't feel that we had the 'ok' to go ahead with P/C, so we are bringing in the firms with the knowledge) / HarbourVest – Ms. Melissa Cahill, Managing Director & Mr. Bill Cole, Principal / Neuberger Berman – Mr. Gabe Feghali, Client Advisor & Mr. Michael Schwartz, Managing Director & Mr. Will Proctor, Head of Sponsor Coverage / Israel Bonds – Mr. Jason Brady". Borromeo's framing acknowledges the asymmetry: Secondary Infrastructure has three competing managers under Callan's procured-search analytical framework; Private Credit has firms "with the knowledge" presenting; Israel Bonds has Brady alone as the entire presenter. See [[westrock-procedural-asymmetry]] and [[callan-analysis-asymmetry]]. ## The 5/15/2025 IFSC packet The IFSC packet (Packet_05 15 25.pdf, 69 pages, distributed by Fecher 5/14/2025 9:12 AM with corrected staff cc at 9:14 AM) contains: Borromeo's CIO Report (8 pages on Strategic Asset Allocation and Secondary Infrastructure overview), the Stephens Private Credit Refresher (7 pages), the HarbourVest Credit Secondaries presentation (11 pages), the Neuberger Berman Direct Lending presentation (8 pages), and the 32-page Callan Infrastructure Secondaries Search Finalists report dated May 12, 2025. The packet contains zero pages of Israel Bonds analytical material — no Callan memo, no Stephens memo, no Borromeo Israel Bonds analysis, no firm presentation, nothing. The Israel Bonds agenda item was Brady speaking only. The CIO Report establishes APERS asset allocation and structural posture: Strategic Asset Allocation Domestic Equity 39%, International Equity 17%, Fixed Income/Cash 21%, Private Markets 7%, Real Assets 16%. "The portfolio is currently overweight International Equity. The portfolio is underweight Credit/Fixed Income and Real Assets (overweight real estate). Private Credit will be a subset of the Credit/Fixed Income allocation. Secondary Infrastructure will be a subset of real assets." ## The 5/15/2025 Berman rate sheet exchange — same day as the vote At 3:13 PM on 5/15/2025 — about two hours after the 1:00 PM IFSC meeting that authorized $25-50M in Israel Bonds — Berman emailed Borromeo the May 15-31 2025 Institutional Rates sheet: "I wanted to share our new rates with you for your review. I believe the 3-year showing the best spread vs the benchmark UST coupons. These current rates are good until June 1, which would be the wire date to purchase any of these products." Borromeo replied at 3:19 PM (six minutes later): "Thank you / Much appreciated / I will ask you to be patient with me, I have a full plate. I promise to touch base soon." Berman replied at 3:31 PM: "Of course, Carlos, thank you again for the review." Stuart Garawitz and Bradley Young were cc'd throughout. The exchange documents real-time DCI–APERS coordination on rate confirmation immediately around the authorization vote. ## The 5/19/2025 Rollans FOI Request — internal review chain On 5/19/2025, in 19 minutes, Fecher drafted a response to John Rollans's APERS FOI request asking about Westrock Coffee and Israel sovereigns. Borromeo confirmed the draft response at 1:49 PM with: "You have answered correctly." Fecher then sent the response to Rollans at 1:51 PM. Borromeo's confirmation became the operational signoff on Fecher's external "$25-50 million authorized at last week's meeting" representation. ## Cross-system administrative role Borromeo's 12/10/2024 FOIA reply ("APERS/ASPRS/AJRS has made zero investments with the Development Company for Israel") establishes that Borromeo is the responsible Investment Officer for APERS, ASPRS, and AJRS as an integrated unit. The 5/15/2025 IFSC authorization for $25-50M in Israel Bonds therefore flows to ASPRS and AJRS via the same administrative pathway, without separate authorizing action by either system. Confirmed by the 6/11/2025 ASPRS and 6/12/2025 AJRS Board packets containing no separate Israel Bonds discussion item, and by the 3/13/2025 ASPRS minutes noting "APERS funds are co-invested with APERS." Borromeo is the unitary CIO for the three commingled funds. ## Chunk 2 (JUL 25 PDF) additions: APERS will purchase directly; Board left decision to staff Two findings from the post-IFSC-vote period sharpen Borromeo's role in the Israel Bonds matter. (1) **Borromeo is the direct purchaser of the APERS Israel Bonds.** Borromeo's 6/6/2025 11:07 AM reply to Wickline's questions: "#1, APERS intent is to purchase the bonds directly. Staff opinion is that there is not a need to incur management fees. #2, Staff anticipates the timing to be after the board meeting. The subcommittee authorized a range of $25 to $50. For duration and diversification purposes, as well as prudent risk management, I suspect the investments will be done over time, and not in a single transaction." Fecher's 6/9/2025 11:48 AM polished version to Wickline: "APERS intent is to purchase the bonds directly. With APERS Chief Investment Officer's experience in fixed income and credit markets, there is no need to incur management fees on this purchase." This contrasts directly with ATRS Resolution 2025-22 which authorized purchases through Reams Asset Management with a 3 bps fee. Borromeo himself is the APERS Israel Bonds direct purchaser, substituting his personal CIO experience for an external manager's analytical infrastructure. (2) **Borromeo treats the IFSC authorization as a delegation to staff.** Borromeo's 6/30/2025 1:35 PM email to Gilson on the Lenow FOIA follow-up: "I just had a video teams call regarding the Israel bond purchase. As of this email, no bonds have been purchased. The APERS investment team, custodian, and consultant met to discuss the back office details. Accounting, delivery, maturity, coupon payments, etc. ... I do not expect to see any contract negotiations. **This is something the Board specifically has told the investment team to execute. The Board has left the decision to the Investment staff.** If you did a search, the only emails you would find would be regarding setting up a date/time for today's call." The IFSC's 5/15/2025 authorization functions as an open-ended delegation to staff with no formal contract negotiation, no procurement-process requirements, and no Board-level deliberation post-authorization. (3) **Borromeo's 5/28/2025 representation to Gilson — "for myself, I do not have anything else"** — was made in response to Lenow's FOIA. Borromeo: "We can discuss, but, to answer your question, for myself, I do not have anything else." This representation was contradicted by the 5/14/2025 Borromeo-Stephens "fixed income eyes" thread (which Borromeo forwarded to Gilson and Fecher 3 hours later at 2:52 PM with the cover line "Laura here is an email string that I sent to Stephes re: Israel bonds") and by the 5/15/2025 Berman rate sheet exchange. The wiki documentary record now captures the gap between Borromeo's initial counsel-facing FOIA representation and the actual scope of his Israel-Bonds-related correspondence. (4) **Borromeo's procedural refusal to broker manager introductions across pension systems.** When HarbourVest Managing Director Melissa Cahill emailed Borromeo on 6/9/2025 seeking an introduction to Brady at ATRS for HarbourVest credit secondaries pitch, Borromeo replied 12:06 PM: "I would not do that / Perhaps you should meet with Jerry over there." Borromeo systematically declines to broker manager introductions across pension systems — same procedural caution as his 2/12/2025 reply to Berman. The systematic refusal is consistent across DCI/Berman (declined fixed-income manager introductions to APERS managers) and HarbourVest/Cahill (declined ATRS manager introduction). This procedural consistency contrasts with Borromeo's same-week direct purchase posture on Israel Bonds. (5) **Borromeo authored APERS investment-consulting-services RFQs.** Email 74 (Borromeo to Jason Clark at PERS of Mississippi, 2/19/2025 9:36 AM) attaches Borromeo's collection of investment-consulting-services RFP/RFQ samples from other state pension systems with cover note: "Jason here are the other state RFP/RFQ that I gathered when I was writing my RFQ." Borromeo had previously authored an APERS investment-consulting-services RFQ and had researched competitive RFP processes from Missouri LAGERS, Ohio State Teachers, Oklahoma PERS, and the ARTRS Sample DDQ. The procedural infrastructure for competitive procurement of investment-related services exists at APERS and Borromeo authored it. The same procedural infrastructure was not invoked for the Israel Bonds investment authorization itself. (6) **The 6/30/2025 BNY/DCI Operations Teams call.** Borromeo, Doolabh, Brian Shea (BNY Asset Services, Boston), Christopher Igo (BNY), Bill Mulvey (DCI VP Operations), Berman, and Young met on 6/30/2025 to plan the back-office mechanics of the APERS Israel Bonds purchase: accounting, delivery, maturity, coupon payments. The Mulvey-provided sample statement was the actual State Treasurer's-office Israel Bonds custodial statement dated 5/5/2025 showing the $55M position breakdown. BNY appears as the planned APERS Israel Bonds custodian via the existing BNY/Mellon APERS custodial relationship. ## Evidence > "Thanks again for your kind hospitality, and for spending so much time with Brad and me on election day! I hope we were able to give you a better understanding of our firm and our products. We certainly appreciate you offer to introduce us to your fixed income managers." > Lawrence Berman to Carlos Borromeo and Ashley Golleher, Introductions.pdf p.1, 11/7/2024 (quoted from later forward) > "Mr. Berman, Thank you for reaching out to APERS and my apologies for the delayed reply. I have shared your information with our investment managers for their review. If they determine there is an opportunity that aligns with the strategy they manage for APERS they will reach out as appropriate." > Carlos Borromeo to Lawrence Berman, RE Introductions.pdf p.1, 2/12/2025 > "Because the Development for Israel bonds, which are issued by the Development Company for Israel, are not tradable and must be held until maturity, since August 01, 2017, APERS/ASPRS/AJRS has made zero investments with the Development Company for Israel." > Carlos Borromeo to Laura Gilson, IB_FOIA_MAY_25_Reviewed.pdf p.623, 12/10/2024 11:30 AM > "Bo I will need your fixed income eyes please / https://israelbonds.com/" > Carlos Borromeo to Bo Brister, IB_FOIA_MAY_25_Reviewed.pdf p.2, 5/14/2025 12:24 PM > "Israel Bonds – Mr. Jason Brady" > Carlos Borromeo, IFSC agenda email to Amy Fecher, IB_FOIA_MAY_25_Reviewed.pdf p.587, 5/8/2025 7:08 AM > "Private Credit discussion – Bo and team Stephens will lead the discussion (I didn't feel that we had the 'ok' to go ahead with P/C, so we are bringing in the firms with the knowledge)" > Carlos Borromeo, IFSC agenda email to Amy Fecher, IB_FOIA_MAY_25_Reviewed.pdf p.587, 5/8/2025 7:08 AM > "Thank you / Much appreciated / I will ask you to be patient with me, I have a full plate. I promise to touch base soon" > Carlos Borromeo to Lawrence Berman, IB_FOIA_MAY_25_Reviewed.pdf p.28, 5/15/2025 3:19 PM > "You have answered correctly" > Carlos Borromeo to Amy Fecher, IB_FOIA_MAY_25_Reviewed.pdf p.10, 5/19/2025 1:49 PM ## Cross-References [[ashley-golleher]] APERS colleague who participated in the November 5, 2024 election day meeting [[lawrence-berman]] [[brad-young]] [[stuart-garawitz]] DCI representatives who met with Borromeo [[amy-fecher]] APERS Executive Director (Borromeo's principal) [[laura-gilson]] APERS General Counsel (Borromeo's FOIA-handling counterpart) [[bo-brister]] [[stephens-capital-management]] APERS investment manager Borromeo consults [[callan]] APERS investment consultant for the Infrastructure Secondaries Search [[jason-brady]] [[jim-hudson]] [[larry-walther]] [[daryl-bassett]] IFSC members [[apers-israel-bonds-authorization]] [[callan-analysis-asymmetry]] [[independent-credit-analysis-gap]] [[westrock-procedural-asymmetry]] [[auditor-as-dci-channel]] [[dci-promotional-pipeline]] concept pages [[apers-foia-r1-7-7-25]] [[auditor-foia-r2-jbrady]] source pages