# Development Corporation for Israel (DCI) Development Corporation for Israel is the U.S. broker-dealer and exclusive issuer of State of Israel sovereign debt instruments sold under U.S. private placement and registered offering frameworks. DCI is the counterparty to all documented Arkansas state-government Israel Bonds purchases across the four Arkansas Treasurers (Milligan 2018-2021; Lowery 2023; Walther 2023; Thurston 2025-2026) and on the planned APERS authorization. DCI is a FINRA-registered broker-dealer with CRD #11148 (per the seed-list documentation of three FINRA events on DCI's regulatory record). ## Organizational profile **Headquarters**: 641 Lexington Avenue, New York, NY 10022. **Operational fiscal agent and recordkeeping**: Computershare Trust Company N.A., 150 Royall Street, Canton, MA 02021. Computershare maintains the IsraelBondsDirect platform for book-entry bond recordkeeping. Computershare also services Bondholder Statements, Interest Statements, redemption requests, and certificate handling for certificate-form positions. **Wire receipt account**: Bank of America, ABA 026009593, 100 West 33rd Street, New York, NY 10001. Beneficiary account name "Computershare Inc.aaf SOI Wire Purchase account." Reference field convention "Purchaser Name and Bond Type." (R3 Wire Confirm 2-17-26 documents the Charlotte NC branch BANK OF AMERICA, NA, 100 N TRYON ST, STE 170 as the routing receiving location.) **Standard FINRA disclosure footer on promotional materials**: "Israel bonds are not rated." ## Senior leadership and US personnel **[[dani-naveh]]** — President and CEO. Subject of the 6/19/2025 marketing email about the Iranian missile strike on his family home. Per the wiki's R1 documentation, Naveh succeeded Israel Maimon as DCI President & CEO sometime between 1/1/2021 and 5/1/2023. **[[lawrence-berman]]** — National Managing Director, Corporate & Institutional Sales. "Larry." Long-standing personal relationship with [[dennis-milligan]] dating from Milligan's Treasurer years. Berman is the documented primary DCI principal on Arkansas Israel Bonds counterparty engagement for all four Treasurer eras. Berman's 1/12/2018 12:58 PM email to Jason Brady (cc Bradley Young) is the first documented DCI correspondence with the Arkansas Treasurer's office. **[[brad-young]]** — Executive Director, Southeast Regional Office, Atlanta. Personal handwritten card on DCI letterhead documented at R2; participated in the November 2024 and April 2025 Arkansas trips; sent the 2/12/2026 wire-timing confirmation on the Feb 2026 transaction. **[[stuart-garawitz]]** — Vice President, National Sales. One of three institutional-sales reviewers; broadcast distributor of the 2/11/2025 Economic Summary; personal correspondent of Milligan on 2/18/2025. **[[luis-jimenez]]** — Associate Director, National Sales. One of three institutional-sales reviewers. Per Berman's 4/16/2025 framing on the May 2025 ladder transaction: "Luis ... is the real operations expert in our office as you know!" Operational principal on the Feb 17 2026 Thurston transaction's order-confirmation handoff; sent the 2/2/2026 order-confirmation email with CUSIP/rate/maturity details and the operational compliance attachments. **[[bill-mulvey]]** — Vice President, Operations. Coordinated the 6/30/2025 BNY/APERS Teams call on Israel Bonds back-office mechanics; provided the State Treasurer's-office sample statement to BNY/APERS that established the wiki's first detailed CUSIP-level breakdown of the Treasury position. Documented at R1 as the DCI Operations principal on the November 2023 Walther wire troubleshooting and the April 2025 Treasury Book Entry custodial migration. **[[mark-ng]]** — Associate Director, Central Processing; Registered Principal. Ran the Computershare wire reconciliation on the November 2023 Walther $10M Israel Bonds wire troubleshooting. **[[steven-hill]]** — Operations Approver who signed the 5/5/2025 Payment Validation document (Order ORD-2087155) confirming the Thurston $20M Israel Bonds purchase under the May 2025 ladder transaction. **[[raymond-su]]** — Operations staff handling Salesforce purchaser details and Computershare registration coordination; back-office contact for institutional clients' IsraelBondsDirect portal access. **[[ethan-behling]]** — Institutional outreach contact; sender of the Dec 2024 to Jan 2025 promotional cadence. **[[ana-torres]]** — Project Administrator, National Sales; thin entity documented at R2 Sub-batch 3 cc-distribution level. **[[marjorie-vaughn]] and [[geoffrey-gross]]** — Atlanta SE Region maturity-coordination staff. **[[starlaszia-watson]]** — Corporate & Institutional Sales + Synagogue and Rabbinic Activities role. Other thin-entity DCI staff documented at the R2 Sub-batch 3 cc-distribution level include Marcus Brodzki (Registered Representative, Atlanta) and Jacqueline Miron (Registered Representative, Atlanta). ## Documented Arkansas state-government Israel Bonds counterparty role DCI is the counterparty on all 14 documented Arkansas State Treasurer's-office Israel Bonds purchases (Milligan 6 events 2018-2021 totaling $105M; Walther 1 event 11/1/2023 of $10M; Thurston purchase #1 ladder 5/1/2025 of $20M; Thurston purchase #2 single-tenor 2/15/2026 of $10M). Cumulative purchases through 2/15/2026: $145M across 4 Treasurer eras. DCI is also the counterparty on the planned APERS Israel Bonds authorization ($25M-$50M, IFSC-authorized 5/15/2025). The wiki [[state-treasurer-israel-bonds-operations]] concept page documents the end-to-end operational pathway by which DCI sells Israel Bonds to the Arkansas Treasury. The wiki [[state-treasurer-israel-bonds-holdings]] concept page documents the resulting CUSIP-level holdings. ## Documented institutional financial sponsor of the State Financial Officers Foundation The Treasury R3 (2-19-26) production includes the 12/17/2020 End of Year Letter from Dennis Milligan as incoming 2021 SFOF National Chair to "SFOF Family." The letter's second paragraph names "every sponsor" by name: > 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) **DCI is institutionally a financial sponsor of SFOF as of 2020.** The wiki has no documentation of whether DCI's SFOF sponsorship continued after 2020 (the 2021-2025 SFOF sponsor lists are not in the productions); the 2020 sponsorship is the documented baseline. The structural significance: SFOF's Israel Bonds investment-promotion track (per [[sfof-state-financial-officer-network]]) — including the 11/4/2024 Garrity case study distribution to Milligan; the Peterson 6/4/2025 Arkansas post-vote case study forward to Adam Schwend at SFOF; the Brady SFOF Spring 2025 speech with DCI-derived content; the SFOF Policy Zoom on Israel Bonds and Operation Rising Lion content — operates inside a documented sponsor-funded relationship with DCI itself. 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. The wiki has documented several Milligan/Brady connections to DCI at the personal-relationship level (Berman's 1/12/2018 first email to Brady; the Berman-Brady "stand with and invest in Israel" rhetorical-template propagation; Milligan's long-standing personal relationship with Berman; the September 2021 NYC visit by Brady-Romanik-Gladden + Milligan; the November 2024 Berman/Young Little Rock visit with Huffman/Burleson; the April 2025 multi-official Capitol tour). The Treasury R3 finding extends this documented relationship to the **institutional-sponsorship level**: DCI funds SFOF, the organization Milligan chaired for 2021, where Milligan's "Israel Bonds adoption to state pension funds" advocacy network operates. ## DCI regulatory profile (Securities production-verified) DCI is registered as a broker-dealer with the U.S. Securities and Exchange Commission (SEC #8-4218 effective April 25, 1955), with FINRA (CRD #11148 effective December 9, 1983), and in all 50 US states plus DC, PR, and VI. The Arkansas Securities Department FOIA production at [[securities-foia-r1-4-20-26]] verified DCI's registration profile in detail. **Arkansas registration is structurally restricted.** Per ASD-152, DCI's AR registration is "Limited - BONDS FOR THE STATE OF ISRAEL" effective June 25, 1984. North Dakota holds a parallel restriction ("Limited - STATE OF ISRAEL BONDS ONLY" effective March 17, 1970). Arizona is "Limited" effective January 24, 1980 with terms not specified in the Web CRD display. All 47 other US jurisdictions show DCI as "Approved" general broker-dealer. The AR Limited registration is documented in detail at [[dci-arkansas-limited-registration]]. **Types of Business: 12Q only.** Per ASD-155, DCI's single Types-of-Business code is 12Q ("Broker or dealer selling securities of only one issuer or associate issuers (other than mutual funds)"). DCI has no Investment Adviser registration ("No IA Record"). The 12Q single-issuer-dealer status operates as the FINRA-level analog of the AR and ND state-Limited restrictions. **1986 Arkansas suspension.** The Arkansas Securities Commissioner suspended DCI's broker-dealer registration on April 7, 1986 (Order 86-27-S, signed by Commissioner Beverly Bassett) for failure to designate a principal under AR Securities Act Section 3(e). The suspension was vacated July 22, 1986 (Order 86-27a-S) after DCI provided proper documentation on May 23, 1986. The episode is documented in detail at [[dci-1986-arkansas-suspension]]. The 1986 AR action is NOT on DCI's FINRA Current Disclosure Summary record. **FINRA Current Disclosure Summary occurrences: 4 total.** Per ASD-008 through ASD-012, DCI's FINRA regulatory record contains four Current Disclosure Summary occurrences: 1. **Occurrence 118865** (Publicly Disclosable: Yes) — SEC 1983 currency-reporting and recordkeeping violations (Administrative Proceeding 3-6308); Censure; no monetary fine 2. **Occurrence 118866** (Publicly Disclosable: Yes) — North Carolina 1984 registration-lapse consent order (File ECC84-006); Cease and Desist; rescission offers to NC residents 3. **Occurrence 279351** (Publicly Disclosable: Yes) — NASD 1997-1998 unregistered-principal-functioning action (Case C06980016); Censure plus $9,500 fine plus independent-consultant supervisory-system review 4. **Occurrence 1711997** (Publicly Disclosable: No) — 07/10/2014 BD Amendment control-affiliate filing identifying Stuart Garawitz (CRD #861993); regulator/sanction/details not entered in the production The four-occurrence formal count resolves the wiki's prior seed-list "3 FINRA events" claim, which was conservative in that it counted only the publicly-disclosable events. The four-occurrence inventory is documented in detail at [[dci-finra-disclosure-events]]. **Arkansas-registered DCI broker-dealer agents (6 total per ASD-151):** | Name | CRD # | AR Reg Effective | Notes | |---|---|---|---| | [[jacqueline-miron]] | 1041260 | 08/01/2019 | Atlanta Registered Representative | | [[lawrence-berman]] | 2919738 | 01/03/2007 | Terminated 12/31/2010; reregistered 01/09/2015 | | [[nir-fisher]] | 5160790 | 03/20/2008 | | | [[brad-young]] | 5276306 | 03/11/2009 | Atlanta Executive Director, SE Regional Office | | [[samuel-libchaber]] | 7782721 | 01/02/2025 | Most recent AR registration | | [[stuart-garawitz]] | 861993 | 01/19/2011 | Control/Influence Y; subject of 2014 control-affiliate disclosure | The three wiki-documented Arkansas-facing DCI principals (Berman, Young, Garawitz) are all AR-registered broker-dealer agents and conduct Arkansas state-government transactions under DCI's AR Limited registration scope. **Direct Owners / Executive Officers structure (22 entries per ASD-023):** Per the Direct Owners filing, DCI's documented direct ownership and executive structure consists of one corporate entity (the parent organization) and 21 named individuals: - **[[association-for-development-of-israel]]** — Sole Shareholder (75% or more ownership), nonprofit membership corporation; renamed 03/2014 from "American Society of Resettlement & Rehabilitation in Israel, Inc." The 21 named individuals (alphabetical by surname, with CRD # and effective date in role; Control/Influence Y flag noted): - Cornick, Kenneth Lawrence — Director 09/2024 — CRD #2528105 - Diener, Robert Benjamin — Director 02/1998 — CRD #3043768 - Fox, William Zev — Director 05/2014 — CRD #212366 - **[[stuart-garawitz]]** — Vice President - Sales 01/2012 — CRD #861993 — **Control/Influence Y** - **[[howard-goldstein]]** — Director / Chairman Emeritus 05/2018 — CRD #2235827 - Grant, Adrian Mervyn — Director 05/2014 — CRD #6364527 - Herbstman, Burton Lee — Director 05/2014 — CRD #6364536 - Herbstman, Helene Ellen — Director 05/2014 — CRD #6364551 - **[[jordan-horvath]]** — Chief Legal Officer / Chief Compliance Officer / FINRA Executive Rep / Asst Secretary / VP-Legal 08/2009 — CRD #4928984 — **Control/Influence Y** - **[[andrew-hutter]]** — Director / Chairman of the Board 05/2014 — CRD #6364574 - **[[erik-kruger]]** — Financial Operations Principal / CFO / Principal Financial Officer 11/2014 — CRD #5739446 — **Control/Influence Y** - Lewis, Shira Joy — Director / Treasurer 05/2014 — CRD #2672845 - **[[bill-mulvey]]** — Principal Operations Officer 05/2019 — CRD #2760487 - **[[dani-naveh]]** — President, CEO and Director 12/2021 — CRD #7413657 — **Control/Influence Y** - Pines, Alan Jay — Director 05/2014 — CRD #6417612 - Rothenberg, Larry Lee — Director 02/2025 — CRD #1079161 - Rubens, Josh M — Director 01/2023 — CRD #7681292 - Rubin, Andrew David — Director 01/1997 — CRD #2876452 - Segal, Glenn — Director / Secretary 05/2014 — CRD #6364874 - Stein, Laura — Director 01/2023 — CRD #7681994 - Swig, Kent Mason — Director 02/2004 — CRD #4768476 - Zeidman, Fred Schwartz — Director 02/2004 — CRD #4774789 Four officers carry the Control/Influence Y flag: Garawitz (Sales VP), Horvath (CLO/CCO), Kruger (CFO), and Naveh (President/CEO). The four constitute DCI's documented operational control core. A substantial board-reconstitution cluster occurred in May 2014: nine board members carry the 05/2014 effective date (Hutter, Lewis, both Herbstmans, Grant, Segal, Pines, Fox, plus Kruger 11/2014). The 05/2014 cluster is contemporaneous with the parent organization's March 2014 name change and with the 07/10/2014 Occurrence 1711997 control-affiliate DRP filing on Garawitz. **Custody and clearing arrangements (ASD-013 through ASD-022):** DCI's books-and-records custodians per Item 8A include Computershare Inc. (cross-confirmed as the documented Arkansas fiscal agent per [[state-treasurer-israel-bonds-operations]]), Global Relay Communications Inc. (electronic-communications archiving), Salesforce Inc. (CRM), and Own Company Inc. **No Arkansas physical presence.** Per ASD-006 and ASD-153, DCI has no Arkansas branch office. All AR-registered DCI agents operate from out-of-state locations under the Section 3(e) principal-designation requirement documented at [[dci-1986-arkansas-suspension]]. **No introducing arrangements** (ASD-114). DCI operates as a principal broker-dealer. **No succession events** (ASD-154). **No DBAs or name changes** (ASD-146). DCI has operated under a single legal entity name "DEVELOPMENT CORPORATION FOR ISRAEL" since the 12/09/1983 FINRA registration date. ## DCI sales-channel substantive role DCI is the exclusive sales agent for State of Israel sovereign debt instruments sold under SEC private placement (Regulation D, qualifying institutional purchasers and accredited investors only) and SEC-registered offerings. The Institutional Bonds Treasury purchases ("Jubilee Fixed Rate Institutional Bonds") are sold to "(i) a state or political subdivision thereof, an agency or instrumentality of a state or any political subdivision thereof, or any municipal corporate instrumentality of one or more states; or (ii) an institution that is an 'accredited investor' as that term is defined in Regulation D under the Securities Act" per the standard disclosure footer. Treasury's QIB Accredited Investor Letter for each annual Private Placement Memorandum cycle certifies Arkansas's eligibility under Section 2 ("State and Municipal Entities") with the dual qualification: (a) not an Accredited Investor under Rule 501(a) of Regulation D Promulgated under the Securities Act of 1933; (b) a state or political subdivision thereof with total assets of at least $50 million. The 2025 PPM cycle (Private Placement Memorandum dated August 1, 2025) is the cycle under which the Feb 17, 2026 Thurston transaction was executed. ## Israel Ministry of Finance directive relationship The R2 Sub-batch 3 production documents five instances 2019-2025 of Berman explicitly disclosing Israel Ministry of Finance directives to DCI on what to sell and at what spreads (1/8/2019 $100M institutional allocation cap; 5/8/2020 "asked us to sell additional paper this quarter"; 1/15/2021 "follow their mandate"; 12/23/2024 "reviewing raising the spread"; 2/18/2025 "extra spread for this period only... additional 15bps"). DCI's pricing and issuance are operationally subordinate to Israel Ministry of Finance directives. The "spreads" and "amounts" Berman pitches to state customers are Ministry-directed, not market-derived. The 1/15/2025 DCI briefing with Israel's Accountant General Yali Rothenberg (Berman's 1/7/2025 invitation to Pulley + Burleson + Huffman at decision-relevant timing on the post-1/1/2025-maturity reinvestment window) documents direct DCI-Israel-government engagement with state Treasury staff. The substantive analytical material flowing to state purchasers via DCI includes Israel-government-direct briefings, reinforcing the [[independent-credit-analysis-gap]] concept's finding that the substitute-for-independent-credit-analysis material is structurally seller-side. ## Documented operational variants at DCI The wiki documents three operational-pathway variants by which DCI engages Arkansas state government staff: (1) **Berman-led senior-level relationship engagement** (2018-2025 documented). Berman as National Managing Director operates the senior-level Treasurer/Auditor relationship. Milligan-era cumulative purchases 2018-2021 were initiated by Berman-Brady email correspondence; the November 2023 Walther-era purchase was Berman-Pulley-Huffman; the April 2025 Capitol tour was Berman/Young-orchestrated through the Auditor's office; the May 2025 Thurston ladder was Berman-Pulley with Huffman pre-conversation target-setting; the Feb 2026 Thurston single-tenor was Berman cold solicitation with same-day Pulley acceptance. (2) **Jimenez-led operational-detail execution** (May 2025+, accelerating). On the May 2025 ladder, Berman's 4/16/2025 email referenced "Luis ... will get out of the way and leave our side of the transaction to our experts." On the Feb 2026 single-tenor, Jimenez sent the 2/2/2026 order-confirmation email with bond-detail attachments (the 8-1-2025 PPM-cycle Accredited Investor Letter and the Arkansas State Treasurer Investment Form 2-2026 [Book]) — Berman remained as cc, not the primary operational contact. The Berman-to-Jimenez operational transition is consistent with DCI's documented institutional pattern of Berman maintaining the senior-relationship role while Jimenez/Mulvey/Hill execute operational-detail steps. (3) **Multi-channel cross-office political engagement** (October 2024+ documented). The Auditor's-office channel that produced the April 2025 multi-official Capitol tour (Berman + Young meeting Speaker Evans, Pro Tem Hester, Speaker designee Voss, Cabinet Secretaries Hudson and Bassett, both pension Executive Directors, and Treasurer Thurston) is a parallel-engagement channel distinct from the standard Berman-Pulley Treasury operational pathway. The Auditor's-office channel routes through Brady (Chief Deputy Auditor) and Spadoni (Executive Assistant), not through the Treasury investment-officer chain. ## Cross-references [[lawrence-berman]] [[brad-young]] [[stuart-garawitz]] [[luis-jimenez]] [[bill-mulvey]] [[mark-ng]] [[steven-hill]] [[raymond-su]] [[ethan-behling]] [[ana-torres]] [[marjorie-vaughn]] [[geoffrey-gross]] [[starlaszia-watson]] DCI US personnel [[dani-naveh]] DCI President & CEO [[yali-rothenberg]] Israel Ministry of Finance Accountant General; January 2025 briefing speaker to Treasury staff via DCI [[sfof]] [[sfof-state-financial-officer-network]] [[sfof-policy-letter-operation]] State Financial Officers Foundation; documented at the R3 level as an institutional financial sponsor relationship with DCI [[dennis-milligan]] Auditor of State (post-2023), former 2021 SFOF National Chair; named DCI as institutional SFOF sponsor in the 12/17/2020 End of Year Letter [[auditor-as-dci-channel]] concept page on the Auditor's office as scheduling, access, and political-cover intermediary for DCI institutional sales [[dci-promotional-pipeline]] concept page on the direct DCI marketing pipeline reaching Arkansas state-government officials [[state-treasurer-israel-bonds-operations]] [[state-treasurer-israel-bonds-holdings]] [[apers-israel-bonds-authorization]] companion concept pages on the resulting Arkansas state-government Israel Bonds purchases [[treasury-foia-r3-2-19-26]] [[treasury-foia-r2-9-23-25]] [[treasury-foia-r1-7-7-25]] [[apers-foia-r1-7-7-25]] [[auditor-foia-r1-milligan]] [[auditor-foia-r2-milligan]] source pages