# Dennis Milligan Auditor of State of Arkansas. Previously served as Treasurer of State, during which time per the 10/23/2024 Brady email he "requested the legislature to pass legislation that would allow the state or at least the treasurer of state to invest in Israel bonds." Holds a statutory seat on the ATRS Board of Trustees. Email address [email protected]; the staff messages copying him use Wendy Spadoni at the same domain. Per ATRS Board Policy 1 Section XIII the State Auditor is the statutory ex officio member of the ATRS Operations Committee, not the Investment Committee. The Operations Committee considers proposals for the adoption, amendment, and repeal of laws, rules, and policies and considers legislative proposals. The Investment Committee, under Section XII, is composed of five Board appointees, the Board Chair ex officio, the State Treasurer, and the State Bank Commissioner. The two committees are mutually exclusive in substantive jurisdiction per BP1 Section XII(d) and Section XIII(d). Milligan therefore initiated and advocated for an investment proposal whose substantive consideration belonged to the Investment Committee, on which he is not a statutory member. He nonetheless voted on the final action as a full Board member. In this batch Milligan appears in two operational roles. First, he is the principal whose office initiated contact between DCI and the Arkansas pension systems, as documented in Brady's 10/23/2024 outreach copying him. Second, he hosted the in-person sales meeting on 4/15/2025 at the State Capitol Room 230 with DCI National Managing Director Lawrence Berman and DCI Southeast Regional Executive Director Brad Young. Milligan signed the 4/11/2025 confirmation email to Mark White that arranged that meeting. The bios for Berman and Young were attached to that email. In Mark White's 5/22/2025 ATRS Board preview email, Milligan is referred to as "Our Board colleague, State Auditor Dennis Milligan." White writes that Milligan "is asking the Board to consider making an investment in Israel Bonds" and notes that he had made the same request to the APERS Board's Investment Committee the previous week, where it was approved at $25 million to $50 million. The Board preview thus documents Milligan acting in two capacities: as the originator and external advocate of the proposal, and as a sitting Board member whose vote will help decide it. ## Treasury R2 9-23-25 production: Milligan-era cumulative Israel Bonds purchases of $105 million The Treasury R2 production produces the complete Computershare Bondholder Statements documenting Milligan-era Israel Bonds purchase activity. The wiki's prior framing of Milligan-era Israel Bonds purchases ($25M, "2020-2021") was based on the RESIDUAL position attributable to Milligan-era purchases at the time of the BNY/Mulvey sample statement (mid-2025), not on cumulative Milligan-era purchase activity. **Milligan-era cumulative Israel Bonds purchases: $105 million across 6 settlement dates spanning March 2018 through October 2021.** | Settle Date | Maturity | Coupon | Amount | CUSIP | |---|---|---|---|---| | 01 Mar 2018 | 03/01/2020 | 2.73% | $20,000,000 | 46513XL40 | | 15 Jan 2019 | 01/01/2021 | 3.11% | $30,000,000 | 46514AB57 | | 15 Jan 2020 | 01/01/2025 | 2.33% | $5,000,000 | 46513JEA5 | | 15 Jan 2020 | 01/01/2025 | 2.48% | $5,000,000 | 46513JQZ7 | | 15 Jan 2020 | 01/01/2030 | 2.83% | $10,000,000 | 46513JHA2 | | 15 May 2020 | 05/01/2023 | 1.57% | $8,000,000 | 46513JCJ8 | | 15 May 2020 | 05/01/2025 | 2.03% | $7,000,000 | 46513JRH6 | | 01 Feb 2021 | 02/01/2024 | 0.73% | $5,000,000 | 46514TMV7 | | 01 Feb 2021 | 02/01/2026 | 1.35% | $5,000,000 | 46514TZG6 | | 15 Oct 2021 | 10/01/2026 | 1.92% | $5,000,000 | 46514TQN1 | | 15 Oct 2021 | 10/01/2026 | 2.07% | $5,000,000 | 46514TZZ4 | The March 1, 2018 first purchase ($20M 2-year at 2.73%) is the earliest documented Treasury Israel Bonds purchase, settling under Milligan's Treasurer tenure approximately 8 months after the 2017 enactment of Act 644 of 2017 (the Arkansas Israel Bonds enabling legislation Milligan personally initiated). Brady's 10/23/2024 outreach attributed Act 644 to Milligan's pre-existing relationship with Berman from his Treasurer years; the March 2018 first purchase establishes the operational implementation of that relationship within the first months of Israel Bonds being legally available to the Arkansas Treasurer. Milligan-era cumulative purchases of $105M across 44 months (March 2018 - October 2021) substantially exceeds the wiki's prior framing of "$25M, 2020-2021." The corrected cumulative framing has implications for the broader investigation: the Milligan-era Israel Bonds operational infrastructure was a substantial multi-year program operationally active from 2018 onward, not a peripheral initiative limited to 2020-2021. The personal Berman-Milligan working relationship documented at [[auditor-as-dci-channel]] from Treasurer years includes 6 settlement dates and approximately a quarter-billion-dollar cumulative purchase volume. The full chronological Treasury Israel Bonds purchase cadence is documented at [[state-treasurer-israel-bonds-holdings]] and the substantive override of the 10/8/2024 internal credit recommendation by the Thurston May 2025 purchase is documented at [[treasury-internal-credit-analysis]]. [[treasury-foia-r2-9-23-25]] source page The materials in this batch do not contain Milligan's voting record on the 6/2/2025 ATRS Board action or any record of recusal. The Graves 6/3/2025 message to Gar Chung characterizing the outcome as "all investment related items were approved as presented" does not break out vote counts. The Milligan custodian production from the same FOIA response (cataloged at [[auditor-foia-r1-milligan]]) adds substantial new evidence about his role. On 11/4/2024, the day before the 2024 general election and twelve days after Brady's outreach to ATRS and APERS, Milligan received a newsletter from OJ Oleka, CEO of the State Financial Officers Foundation, featuring Pennsylvania Treasurer Stacy Garrity's $20 million Israel Bonds investment as the model case study with the combined political-solidarity rationale ("to show our support at a time when the people of Israel are facing horrific terrorism") and pecuniary rationale ("pay above-market returns and they've never defaulted") packaged together. The companion concept page [[sfof-state-financial-officer-network]] addresses this national infrastructure. The newsletter's "Dear Tina" salutation indicates templated mailmerge distribution to a list of state financial officers, of which Milligan is one. On 2/18/2025 Milligan received a personally-addressed email from Stuart Garawitz, DCI Vice President of National Sales, transmitting the State of Israel Economic Summary PowerPoint. Cc on the email was Ana Torres at DCI. The email closes "Thank you again for all your support and I look forward to speaking with you soon," indicating an ongoing personal sales relationship between Garawitz and Milligan distinct from the broadcast-distribution version sent through Behling on 2/13/2025. Milligan's mailbox also received approximately forty-two DCI promotional emails between January and June 2025, addressed personally to "Dennis Milligan." This parallels the cadence and content of the DCI promotional pipeline that reached Mark White and Rod Graves at ATRS. On 5/22/2025 Milligan personally received Mark White's Board preview email naming him as "Our Board colleague... asking the Board to consider making an investment in Israel Bonds." He had ten days before the 6/2 vote to clarify or object to that characterization. The materials do not document any such clarification or objection. On 6/6/2025 White issued a board canvass for Israel-Bonds-responsive emails in connection with the second Jennifer Lenow FOIA. Milligan or his staff responded by exporting the 51-file production this entity-page update is drawn from on 6/10/2025. That production reflects what Milligan or his staff judged responsive on that date. The Spadoni custodian production adds two material findings about Milligan personally. First, the 4/7/2025 letter Brady drafted for Milligan's signature contains the disclosure: "I worked with and have know Mr. Berman and Israel Bonds since my time in the State Treasury when the Legislature allowed me to purchase bonds of Israel." This refines the prior framing in Brady's 10/23/2024 outreach (which said only that the Auditor in his Treasurer time "requested the legislature to pass legislation"). Milligan personally purchased Israel bonds during his Treasurer tenure, and he has had a personal working relationship with Lawrence Berman since that time. The Auditor's-office channel is therefore not a neutral-intermediary role; it is the activation of a long-standing personal relationship between the Auditor and the DCI institutional sales lead. Second, Milligan personally hosted the April 14-15, 2025 Capitol tour at his Room 230 office, signing meeting confirmation emails to eight different Arkansas officials (Fecher at APERS, Evans and Warren at the House, Bassett at Labor/Licensing, Hester at Senate leadership, White at ATRS, Thurston at Treasury, Hudson at DFA). The companion concept page [[auditor-multi-official-capitol-tour]] details the tour. Milligan's previously-attempted November 2024 trip included an outreach to Governor Sarah Huckabee Sanders' office that Erica Freeman declined. The Auditor's own R2 FOIA production (6/25/25) at [[auditor-foia-r2-jbrady]] adds three further substantive findings about Milligan. First, **Milligan is a past chair of the State Financial Officers Foundation**, per Brady's draft of Milligan's own SFOF Spring National Meeting speech: "I also have the honor of being a past chair of SFOF." This is a national leadership position in the same 501(c)(3) network that distributed the Stacy Garrity Israel Bonds case study to him in November 2024. The earlier framing of Milligan as a recipient of an SFOF newsletter understated his organizational standing. Second, **Milligan delivered a speech to the SFOF Spring National Meeting on Thursday, April 24, 2025 at 10:45 AM at Omni Orlando ChampionsGate**, nine days after the Berman/Young Capitol tour and approximately five weeks before the ATRS Board action. Brady drafted the speech (topic: Unclaimed Property recovery, not Israel Bonds). The speech draft includes the explicitly partisan framing "let's be honest, if we 'Conservatives' in this room will lock arms and join forces, with Republicans in control of the White House, House and Senate." Third, **Milligan signed multiple SFOF sign-on letters** to federal officials in the documented period: Tesla letter to AG Bondi, SEC/DOL ESG letter, USTR letter, China Divestment Letter, National Debt Letter, CCP delisting letter, and others (see [[sfof-policy-letter-operation]]). His name appears in the published signature lists. Milligan's documented institutional position is therefore: sitting trustee on at least the ATRS Board (and per the APERS Board distribution list captured in Brady's 6/6/2025 forward, also on the APERS Board); statutory ex officio Operations Committee member at ATRS; statutory member of the Arkansas State Board of Finance ([[arkansas-state-board-of-finance]]); past chair and active speaker at SFOF; signer of multiple SFOF sign-on letters to federal officials. ## R2 Milligan custodian production (6/25/25 FOIA) additions The R2 Milligan custodian production ([[auditor-foia-r2-milligan]]) is the IT-conducted full-mailbox export covering the same period as the R1 35-minute rushed canvass. It adds four substantive findings about Milligan. First, **Milligan personally registered for and attended the 1/15/2025 DCI economic briefing with Israeli Accountant General Yali Rothenberg**. Three DCI emails to [email protected] document the registration (1/13 Zoom link), reminder (1/15 morning), and post-briefing thank-you (1/15 4:01 PM, "Thank you for your participation"). The R1 batch documented only Brady's calendar acceptance; R2 establishes that Milligan personally attended. The briefing was four months before he brought the Israel Bonds proposal to the ATRS Board, and Garawitz's 2/18 follow-up email opens with a quote from the same briefing. Second, **the Auditor's office received a personally-targeted launch press release from Prospr Aligned on 1/7/2025**, a new for-profit investment-services consulting firm founded by Derek Kreifels, former CEO and co-founder of SFOF. Kreifels is past CEO of the same nonprofit organization Milligan is a past chair of. The firm's service lines (proxy voting consulting, manager analysis, corporate engagement) target current state pension officials. See [[derek-kreifels]] and [[prospr-aligned]]. Third, **the Auditor's office is an investment-recommendation channel for at least one product beyond DCI Israel Bonds**. Rob Phillips of Abacus Global Management (NASDAQ: ABL, life settlements) emailed Milligan and Brady on 4/28/2025 with subject "Thank you + SFOF follow up," referencing "your interest in Abacus as an investment for Arkansas' pension funds." The 4/28 timing positions the pitch as follow-up from the SFOF Spring National Meeting where Milligan spoke. The Auditor's-office channel is therefore not single-product (DCI Israel Bonds only) but a broader investment-introduction pipeline reaching multiple firms through the SFOF networking circuit. See [[rob-phillips]] and [[abacus-global-management]]. Fourth, **the April 14-15 Capitol tour was scheduled with at least one earlier configuration**. Milligan's deleted-items folder contains a superseded calendar invite for 4/14/2025 9:00-9:30 AM titled "Meeting with Larry Berman, Dennis Milligan, Jason Brady and possibly Bart Hester," location Room 230, mandatory participants Hudson, Milligan (twice), Brady. The final tour schedule disaggregated this meeting into separate slots (Fecher at 9:00 4/14, Speaker meeting at 9:45 4/14, Hester at 8:00 4/15, Hudson at 2:00 PM 4/15 at DFA). Milligan deleted the earlier version. The disaggregation choice was therefore a deliberate revision from a smaller batched-meeting structure rather than the original plan. The R2 batch also cross-confirms that the 1/23/2025 ATRS Board preview email for the 2/3/2025 meeting had no Israel Bonds content. The Israel Bonds proposal had not entered the ATRS Board agenda as of late January 2025 despite the active Auditor's-office outreach and DCI marketing pipeline. The Peterson custodian production ([[auditor-foia-r2-stacy-peterson]]) further reframes the chronology. On 10/7/2024 — sixteen days before Brady's 10/23/2024 pension outreach — the Auditor's office was already in active direct email contact with DCI senior leadership through Peterson's outreach to Lawrence Berman, drawing a same-day reply from Berman with Dani Naveh (DCI President & CEO), Stuart Garawitz, Shiri Stern, Ethan Behling, and Bradley Young all cc'd. Berman's framing "support and friendship" and "we are forever grateful to him and your whole team" documents an established institutional relationship between the Auditor and DCI predating the formal pension outreach. The same day, Milligan delivered remarks at the National Association of Christian Lawmakers press conference at the Arkansas State Capitol Rotunda (drafted by Peterson, approved by Milligan from his personal AOL account [email protected] on 10/4/2024). The speech text in Milligan's voice is the most direct public account in the wiki of the policy-and-relationship origin of Arkansas state Israel Bonds investment: "As a Christian, I have supported Israel all my life. The Bible tells us that our Jewish friends are God's chosen people, and I believe that it's my Christian duty to support you all. Prior to being elected as State Auditor, I served as Treasurer of State for 8 years. Soon after I took that office back in 2015, I was approached by an Israeli development corporation about the potential of bringing legislation to Arkansas that would allow the state to invest in bonds from Israel. I connected the developers with Sen. Rapert, and through that connection Act 644 was born. It was enacted in 2017, and during my tenure we purchased some $85 million in bonds supporting Israel." The original 10/4 Milligan-approval draft said "$95 million" and "State of Israel"; the 10/7 delivery draft revised down to "$85 million" and "nation of Israel." See [[october-2024-israel-solidarity-operation]] for the campaign chronology and [[jason-rapert]] for the legislator Milligan publicly credited with sponsoring Act 644 of 2017. The Peterson production also adds that Peterson is the Auditor's-office Director of Communications (APR), functioning in parallel to Brady (policy substance, letter signing) and Spadoni (scheduling, logistics) as the third operational principal in the Auditor's-office Israel Bonds and SFOF coordination. Peterson herself stated in her 2/14/2025 introduction to SFOF Director of Operations Adam Slayton that she "worked with SFOF for several years on behalf of" Milligan. The Auditor's-office radio show Milligan "occasionally gets asked to host" in Little Rock is one venue Peterson scripts and coordinates with SFOF on substantive content. See [[stacy-peterson]]. Two days after the 6/2/2025 ATRS Board action, Peterson emailed SFOF Director of Public Policy Adam Schwend with two articles documenting the Arkansas pension Israel Bonds vote and offered: "The Auditor has very good contacts with the development corporation in case any other states are interested in learning more." Milligan's office, through Peterson, is therefore documented as an active SFOF Israel Bonds export node within 48 hours of the ATRS vote, not merely a recipient of SFOF Israel Bonds promotion. See [[sfof-state-financial-officer-network]]. Milligan's Outlook calendar in the R2 production adds further institutional-touchpoint evidence. Thirteen SFOF Policy/National Policy Zoom invites span 10/9/2024 to 6/18/2025 in his calendar (more than the nine Brady's batch captured). The 4/15/2025 Hudson meeting that Spadoni's R1 schedule placed at 2:00 PM was actually at 3:00 PM at Auditor's Room 230 (with Spadoni as mandatory attendee), refining the documented Capitol-tour timeline. The 3/26/2025 State Board of Finance meeting (labeled "Treasurer of State's Zoom Meeting" in Milligan's calendar) places Milligan in the same Zoom meeting as State Bank Commissioner Susannah Marshall — the first calendar-confirmed institutional intersection between the two statutory ATRS Investment Committee members. The 4/16/2025 "Record Video for SFOF" calendar entry documents Milligan recording a video for SFOF in Kurt Underwood's office, six days before the SFOF Spring National Meeting opened. Four Auditor's-office staff (Milligan, Brady, Spadoni, Melissa Corrigan) attended the Spring meeting per the calendar invite. The R2 Milligan chunk 4 ingest (Advertisements + Recoverable-Items) adds a post-vote deletion-pattern finding about Milligan personally. The Recoverable-Items/Deletions folder captures items Milligan affirmatively deleted from his mailbox: the 6/8/2025 DCI "$5 BILLION for Israel" post-vote milestone promo, the 6/5/2025 DCI eShalom Bond promo, the 6/13/2025 SFOF NYSE event invitation from OJ Oleka (cohosted with Prospr Aligned for an Alaska-focused ETF launch on 7/1-7/2/2025), the 6/17/2025 SFOF Policy Zoom reminder, and the 6/18/2025 SFOF Policy Zoom invite. The Recoverable-Items/Purges folder additionally captures a second instance of the 6/18 Policy Zoom invite. Chunk 1 documented Milligan's deletion of the 6/4 SFOF Policy Zoom invite (the first post-vote Policy Zoom, two days after the ATRS Board action); chunk 4 extends the pattern to the 6/13 NYSE invite and the 6/18 Policy Zoom. Across the 6/4 through 6/18 window — the immediate aftermath of the ATRS Board action and the period during which Mark White issued the 6/6 board canvass for Israel-Bonds-responsive emails ([[auditor-foia-r1-milligan]]) — Milligan affirmatively deleted at least five SFOF and DCI items from his mailbox. Whether the deletion behavior reflects routine inbox management, non-attendance signaling on the SFOF Policy Zoom and NYSE event, or a sensitivity to the post-vote documentary trail is not knowable from the deletion record alone. The fact that Outlook's Recoverable-Items retention layer captured these deletions for the FOIA production is documentary; the motivation is not. Chunk 4 also confirms that Milligan personally received the 6/13 SFOF/Prospr Aligned NYSE invitation announcing the Alaska ETF launch, extending the documented set of investment products reaching him through the SFOF channel to three (DCI Israel Bonds, Abacus life settlements, Alaska ETF). See [[sfof-state-financial-officer-network]]. A separate chunk 4 finding documents that Prospr Aligned sent Milligan a second mailmerge on 4/18/2025 (one week before the SFOF Spring National Meeting) announcing CEO Derek Kreifels's appearance on a "Pension Industrial Complex" panel at the meeting alongside Vident CEO Vince Birley, Jerry Bowyer, and Oklahoma State Treasurer Todd Russ. See [[prospr-aligned]]. ## R2 residual sub-batches additions The four residual sub-batches at [[auditor-foia-r2-residual]] add three findings about Milligan's relational and operational footprint. First, **Milligan received a handwritten thank-you card on DCI letterhead from Brad Young in late December 2024**. The card (scan_Redacted - undated card to Dennis.pdf) is on the Israel Bonds wave-logo letterhead with the corporate identifier "DEVELOPMENT CORPORATION FOR ISRAEL MEMBER FINRA" and signed by Young (Executive Director, Southeast Regional) at his Atlanta phone numbers. The handwritten body thanks Milligan for "warm and wonderful hospitality during Larry and my trip to Little Rock" — the November 5, 2024 Election Day Berman/Young Arkansas trip — and frames the personal relationship explicitly: "Dennis, your support and passion for Israel and Israel Bonds is second to none. I am very thankful and fortunate that we have friends like you. It is critical to our success and to Israel's future." The card closes with Christmas/New-Year well-wishes and "Until next time (hopefully soon)," dating it to roughly December 2024 and anticipating what becomes the April 14-15, 2025 Capitol tour. The card is the most direct documentary evidence in the wiki of DCI senior staff personally cultivating Milligan as a relationship-driven institutional sales target, layered onto the email-channel evidence at [[dci-promotional-pipeline]]. The card follows logically on Brad Young's 12/17/2024 mailing-address email to Milligan's auditor@ address (sent To: Auditor Dennis Milligan with body greeting "Jason," interpretable as a misdirected email Young intended for Brady, or alternatively as a parallel outreach to Milligan's office). Second, **Milligan's office was the central node of an Election Day 2024 multi-agency Berman/Young trip**. The Brady-Burleson 10/28/2024 iMessage requested Treasurer Thurston do a 5-min hello and Bill Huffman and Kenneth Burleson give Berman 30 minutes on November 5, 2024, alongside Brady's already-scheduled ATRS Mark White meeting at 10 AM and APERS Borromeo meeting at 1:30 PM. Spadoni's undated planner page documenting "Larry Berman / Amy Fetcher APERS / Nov. 5th 1:30-2:30 / Mark White ARTRS / Nov. 5th 10-11:00" cross-confirms the schedule. Whether Thurston/Huffman/Burleson actually met Berman is not documented; the requests are. The trip Milligan hosted in late October 2024 attempting to schedule a Sanders meeting (per [[sarah-huckabee-sanders]] and [[erica-freeman]]) was therefore one component of a broader multi-agency Election Day Berman trip Brady was orchestrating across the Auditor's, Treasurer's, ATRS, and APERS offices. Third, **the [email protected] shared mailbox functions as the office's central receiving channel**. The shared mailbox holds the cross-confirmed Brady 10/23/2024 seed email, Amy Fecher's 19-minute reply (a previously-undocumented finding), Mark White's 5:03 PM reply (in Deleted-Items), Peterson's 10/3/2024 forward of the Israeli Ambassador letter to Rapert, Brad Young's 12/17/2024 mailing-address email, and 17 calendar items mirroring Milligan's own Outlook calendar. The shared mailbox's centralized routing means external correspondence to Milligan (including the 6/4/2025 Terry Hansen "Anti-Palestinianism in American politics" citizen letter reaching the auditor@ alias as a CC) flows through a shared infrastructure that Corrigan as Chief of Staff monitors. The Hansen letter reached the office two days after the 6/2 ATRS Board action; its disposition was deletion in Corrigan's mailbox view. Whether Milligan personally engaged with the letter is not documented. ## Evidence > "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.'" > SFOF newsletter from OJ Oleka to Dennis Milligan, Pre-Election Update from the States - 4 nov 24.pdf p.4, 11/4/2024 > "Dear Dennis, Last year was a challenging one for Israel, but despite all challenges, the Jewish State rose to the occasion... Thank you again for all your support and I look forward to speaking with you soon." > Stuart Garawitz to Dennis Milligan, Israel Bonds State of Israel Economic Summary - 18 feb 25.pdf p.1, 2/18/2025 > "I worked with and have know Mr. Berman and Israel Bonds since my time in the State Treasury when the Legislature allowed me to purchase bonds of Israel. I know we both share a very deep love and respect for the State of Israel." > Jason Brady drafting letter for Dennis Milligan signature, April 7, 2025 - 2.pdf p.1, 4/7/2025 > "Many of my colleagues know me but for those who do not, I am the Auditor of State in Arkansas in my first term. However, prior to that, I was the Treasurer of State for Arkansas for two or 8 years. I also have the honor of being a past chair of SFOF." > Brady draft of Milligan SFOF speech, update sfof speech.pdf p.1, 4/3/2025 > "let's be honest, if we 'Conservatives' in this room will lock arms and join forces, with Republicans in control of the White House, House and Senate, and if we are willing to play ball with the US Treasury, I feel strongly we can get this done" > Brady draft of Milligan SFOF speech, update sfof speech.pdf p.1, 4/3/2025 > "Auditor Milligan will be speaking starting at 10:45 am on Thursday, April 24th." > Adam Slayton (SFOF Director of Operations) to Wendy Spadoni, FW Auditor Milligan - Presentation Time.pdf p.1, 4/14/2025 > "The remaining two (2) members [of the Operations Committee] shall be the State Auditor and the Secretary of Education upon their respective acceptance of their appointments." > Board Policy 1 Section XIII(a)(3), BoardPolicy_01.pdf p.8 > "Unless related to a stated purpose of the Investment Committee, all matters that are a stated purpose of the Operations Committee or Audit Committee shall not be within the purview of the Investment Committee." > Board Policy 1 Section XII(d), BoardPolicy_01.pdf p.8 > "the Auditor in his time as treasurer of state requested the legislature to pass legislation that would allow the state or at least the treasurer of state to invest in Israel bonds" > Jason Brady to Amy Fecher and Mark White, Emails1.pdf p.1, 10/23/2024 > "Mr. White, Thank you for agreeing to meet with Israel Bonds representatives Mr. Larry Berman, National Managing Director, and Mr. Brad Young, Executive Director - Southeast Regional Office on Tuesday, April 15, 2025, at 10:00 a.m. in my office located in room 230 of the State Capitol." > Dennis Milligan to Mark White, Emails3.pdf p.1, 4/11/2025 > "Our Board colleague, State Auditor Dennis Milligan, is asking the Board to consider making an investment in Israel Bonds. These are government bonds issued and guaranteed by the nation of Israel. The Auditor made a similar request last week to the Arkansas Public Employee Retirement System, and their Board's Investment Committee approved an investment of between $25 and $50 million." > Mark White Board preview, Emails3.pdf p.28, 5/22/2025 > "Thank you for your participation in Israel Bonds' Private & Exclusive Economic Briefing on Israel's 2025 Outlook, with Accountant General of Israel's Ministry of Finance, Yali Rothenberg." > Israel Bonds to Dennis Milligan, Thank You - Private & Exclusive Economic Briefing.pdf p.1, 1/15/2025 4:01 PM > "Dennis / Jason – Great to catch up last week... Thank you also for your interest in Abacus as an investment for Arkansas' pension funds." > Rob Phillips (Abacus Global Management) to Dennis Milligan and Jason Brady, Thank you + SFOF follow up.pdf p.1, 4/28/2025 > "As a Christian, I have supported Israel all my life. The Bible tells us that our Jewish friends are God's chosen people, and I believe that it's my Christian duty to support you all. Prior to being elected as State Auditor, I served as Treasurer of State for 8 years. Soon after I took that office back in 2015, I was approached by an Israeli development corporation about the potential of bringing legislation to Arkansas that would allow the state to invest in bonds from Israel. I connected the developers with Sen. Rapert, and through that connection Act 644 was born. It was enacted in 2017, and during my tenure we purchased some $85 million in bonds supporting Israel." > Milligan 10/7/2024 Capitol Rotunda speech (Peterson 10/7/2024 8:06 AM Underwood-distribution delivery draft; the 10/4/2024 Milligan-approval draft said $95 million and "State of Israel"), speech.pdf p.1 > "Good job!! Sent from my iPhone" > Dennis Milligan from [email protected] to Stacy Peterson approving the 10/7 speech, Re Israel Speech for Monday.pdf p.1, 10/4/2024 1:20 PM > "This is a wonderful message, Stacy. I will reach out to the Auditor directly, but please let him know how deeply we appreciate his support and friendship. He is truly one of a kind, and we are forever grateful to him and your whole team." > Lawrence Berman to Stacy Peterson (CC: Dani Naveh, Stuart Garawitz, Shiri Stern, Ethan Behling, Bradley Young), RE A message from Arkansas Auditor Dennis Milligan.pdf p.1, 10/7/2024 4:50 PM (16 days before Brady's 10/23/2024 pension outreach) ## Cross-References [[jason-brady]] Milligan's Chief Deputy and operational point of contact [[lawrence-berman]] [[brad-young]] DCI representatives Milligan hosted at the State Capitol [[stuart-garawitz]] [[ana-torres]] DCI institutional sales contacts who worked Milligan personally [[oj-oleka]] [[sfof]] [[stacy-garrity]] national network of conservative state financial officers promoting Israel Bonds adoption to Milligan [[mark-white]] [[amy-fecher]] pension system executive directors targeted by the outreach [[auditor-as-dci-channel]] concept page [[board-colleague-conflict]] concept page on Milligan's dual role as Board member and advocate [[atrs-board-governance-structure]] concept page on the Investment Committee versus Operations Committee distinction [[trustee-fiduciary-and-conflict-rules]] concept page on the Code of Conduct binding all trustees [[sfof-state-financial-officer-network]] concept page on the national infrastructure that reached Milligan [[wendy-spadoni]] Auditor's-office Executive Assistant who orchestrated the 4/14-15 Capitol tour for Milligan [[john-thurston]] State Treasurer who Milligan scheduled into the tour as statutory ATRS Investment Committee member [[brian-evans]] [[les-warren]] [[bart-hester]] [[daryl-bassett]] [[jim-hudson]] additional officials Milligan hosted on the tour [[sarah-huckabee-sanders]] [[erica-freeman]] Governor's office (declined the November 2024 attempt) [[auditor-multi-official-capitol-tour]] concept page on the April tour Milligan hosted [[susannah-marshall]] State Bank Commissioner and statutory ATRS Investment Committee colleague who has not appeared in any documented Israel Bonds correspondence [[carlos-borromeo]] APERS CIO who met with Berman on the previously-undocumented November 5, 2024 election day trip [[arkansas-state-board-of-finance]] state finance body Milligan participates in alongside Treasurer, Bank Commissioner, DFA Secretary, and others [[sfof-policy-letter-operation]] companion concept page on the SFOF sign-on letter operation Milligan participates in [[derek-kreifels]] [[prospr-aligned]] SFOF alumni infrastructure reaching Milligan as press-release recipient [[rob-phillips]] [[abacus-global-management]] second investment-product pitch through SFOF networking circuit [[kurt-underwood]] Auditor's-office video producer and [[melissa-corrigan]] Chief of Staff documented in Milligan's calendar (SFOF video recording on 4/16; SFOF Spring meeting attendance) [[stacy-peterson]] Auditor's-office Director of Communications (APR) who drafted his 10/7/2024 Capitol Rotunda speech and is the third operational principal in Auditor's-office Israel Bonds and SFOF coordination [[jason-rapert]] former state senator and National Association of Christian Lawmakers founder whom Milligan publicly credited at the 10/7/2024 Capitol Rotunda speech with sponsoring Act 644 of 2017 [[national-association-of-christian-lawmakers]] institutional venue of the 10/7/2024 Capitol Rotunda press conference at which Milligan delivered the Christian-Zionist solidarity-and-Act-644 remarks [[michael-herzog]] Israeli Ambassador recipient of the Auditor's-office 10/3/2024 mailed Israel Solidarity Letter [[october-2024-israel-solidarity-operation]] concept page on the public-facing campaign Peterson designed and Milligan delivered in early October 2024 [[kenneth-burleson]] [[bill-huffman]] Treasury Deputies Brady coordinated with for the November 5, 2024 Election Day Berman trip into Milligan's office [[terry-hansen]] citizen author of the 6/4/2025 Anti-Palestinianism letter that reached Milligan's office through the auditor@ shared mailbox ## Milligan's ATRS Board attendance via Brady designee (7/3/25 production) The 7/3/25 supplemental ATRS FOIA production introduces a previously-undocumented detail. At the April 7, 2025 ATRS Board meeting, Milligan attended not personally but via designee Jason Brady. The 4/7 attendance roster lists "Jason Brady, designeed for Hon. Dennis Milligan, State Auditor." Brady's substantive procedural participation at the meeting (moving and seconding motions) is documented at [[jason-brady]] and [[atrs-board-governance-structure]]. The Milligan-Brady designee pattern at ATRS Board meetings reinforces [[board-colleague-conflict]] by extending the conflict from a single-person (Milligan) framing to a two-person (Milligan personally when present; Brady-as-designee when absent) framing. Whether Milligan attended the 6/2 meeting personally or via Brady designee is not knowable from the packet (which is pre-meeting); the 6/2 minutes when produced would document this. [[atrs-foia-r1-staff-emails]] [[atrs-board-rules-r1]] [[auditor-foia-r1-milligan]] [[auditor-foia-r1-spadoni]] [[auditor-foia-r2-jbrady]] [[auditor-foia-r2-milligan]] [[auditor-foia-r2-stacy-peterson]] [[auditor-foia-r2-residual]] [[atrs-bot-packets-7-3-25]] [[treasury-foia-r3-2-19-26]] source pages ## Treasury R3 2-19-26 production: Milligan's 12/17/2020 SFOF End of Year Letter naming DCI as institutional sponsor The Treasury R3 (2-19-26) production includes Milligan's 12/17/2020 End of Year Letter on State Financial Officers Foundation letterhead, signed by Milligan as "Treasurer Dennis Milligan (AR), 2021 SFOF National Chair." The letter is Milligan's pre-chair-installation gratitude letter to "SFOF Family." Its second paragraph names "every sponsor" by enumerated list, including **Development Corporation for Israel** alongside 20 other named institutional sponsors: > 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. > End of Year Letter from Treasurer Milligan.pdf, 12/17/2020 (emphasis added) This is the first wiki documentation that Milligan, as 2021 SFOF National Chair, personally thanked DCI by name as an institutional financial sponsor of SFOF. The structural significance — that DCI is funding the state-financial-officer organization Milligan chaired for 2021, and that the same SFOF subsequently distributes Israel Bonds investment-promotion content to its state-financial-officer constituency (the 11/4/2024 Garrity case study to Milligan, the 6/4/2025 Auditor's-office Arkansas adoption forward to SFOF from Peterson) — is developed at [[sfof-state-financial-officer-network]] and [[development-corporation-for-israel]]. The 12/17/2020 letter's masthead documents the 2020-2021 era SFOF National Leadership Team: 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). Milligan's standing as 2021 SFOF National Chair (the year-long term following his post-Treasurer-tenure transition; Milligan was Treasurer through January 2023, so his 2021 SFOF Chair term overlapped his Treasurer years) is documented at the SFOF org-chart level. The wiki therefore extends Milligan's documented SFOF involvement from "past chair" (a 2021-era role per the Brady-drafted Milligan SFOF Spring 2025 speech) to **documented incoming-Chair gratitude letter author naming DCI as institutional sponsor**. Milligan's long-standing personal relationship with [[lawrence-berman]] (per the seed-list framing) is now contextualized inside Milligan's organizational SFOF role, where DCI itself was a documented financial sponsor of SFOF. ## Auditor R3 3-3-26 production: personal AOL routing and the April 2025 Facebook post The Auditor R3 production at [[auditor-foia-r3-3-3-26]] documents two substantive Milligan-side findings. **The personal AOL routing pattern.** Brady forwarded Mark White's 7/11/2025 3:55 PM ATRS Board notification of the Arkansas Times article publication to Milligan at his personal AOL address `[email protected]` at 7/11/2025 7:28 PM CDT from his iPhone. The same Milligan personal AOL address documented at [[stacy-peterson]] for the 10/4/2024 Israel solidarity speech approval. Second documented instance of Brady-Milligan personal-account routing on Israel Bonds business. The Auditor's-office correspondence about Israel Bonds flows through both the official auditor.ar.gov channel and Milligan's personal AOL. The Milligan AOL account is not subject to FOIA at the Auditor's-office level; the personal-account routing has the operational consequence of moving correspondence outside the Auditor's-office FOIA-search perimeter. **Milligan's April 2025 Facebook post on the Berman/Young Capitol tour.** The Lenow Arkansas Times article (published 7/11/2025, captured as PDF attachment in the R3 production) quotes a Milligan Facebook post from April 2025: > *"I'm always happy to have my friends Larry Berman and Brad Young from Israel Bonds Development Corp. in Little Rock. I'm proud to be a supporter of the State of Israel and happy to help these fine gentlemen in any way that I can."* > Milligan Facebook post, April 2025, quoted in Lenow, Arkansas Times, 7/11/2025 The post is a public-facing, personal-voice acknowledgment of the April 2025 Capitol tour meeting with Berman and Young. The "my friends" framing matches the Brad Young handwritten December 2024 thank-you card to Milligan documented at [[auditor-foia-r2-residual]] ("friends like you... critical to our success and to Israel's future"). The "happy to help these fine gentlemen in any way that I can" framing is operationally consistent with the wiki's documented Auditor's-office channel role of arranging meetings, providing legislative access, and serving as scheduling intermediary on DCI's behalf — but in personal-voice rather than official-state-business register. **Lenow's non-response finding.** Lenow's Arkansas Times article notes: *"The office of the state auditor did not respond to a request for comment about whether Milligan considered non-financial factors when advocating for state entities to invest in Israeli bonds."* The Auditor's-office documented silence to Lenow's central pecuniary-vs-political question is substantively distinct from the ATRS, APERS, and Treasury spokesperson responses (all of which provided defensive statements per [[auditor-foia-r3-3-3-26]]). No Auditor's-office Sent-Items reply to Lenow exists in the R3 production across the Brady, Milligan, or Spadoni custodians.