# PJ Kelly Partner at Aon Investments USA Inc. Designated CFA and CAIA. Email [email protected], office 312.381.1276, mobile 312.968.0098, mailing address Aon Center, 200 E. Randolph St., Floor 6, Chicago. In this batch Kelly is ATRS's primary contact at Aon, the system's investment consultant. Kelly's role at ATRS is structured by Board Policy 4. Under Section S, the Executive Director and investment consultant are "jointly responsible for the initial selection of investment managers and any increase or decrease in an investment manager's funding." Kelly's 5/28/2025 forward of the Reams Asset Management offer to Rod Graves, and his contemporaneous disclosure that Reams was "light on experience with Israel bonds," is therefore the consultant-side input to a joint selection decision. Section A.5 of the same policy creates a written-recommendation requirement: "No investment shall be made without an investment consultant's written advice or written recommendation. The System shall not approve any material changes in any direct investment without first receiving written advice or a written recommendation from a third-party investment consultant." Whether Kelly produced a written advice or written recommendation document satisfying Section A.5 for the Israel Bonds action is not established in the materials Joshua has assembled to date. Rod Graves contacted Kelly and Aon colleague Katie Comstock on 5/9/2025 to schedule the June Board agenda Israel Bonds item. Three weeks later, on 5/28/2025, Kelly forwarded to Graves a manager pitch from Matt Waz at Raymond James Investment Management offering Reams Asset Management as a manager for the Israel bond mandate at a 3 basis point fee. Kelly's own framing in the forward is: "FYI - a compelling offer from Reams from a few perspective but they are light on experience with Israel bonds but have non-US bond experience and resources." This single sentence is the most consequential consultant-side characterization in the batch of the manager that ATRS subsequently selected. Kelly identifies Reams's lack of Israel bond experience explicitly while transmitting the offer. The materials in this batch do not show Kelly recommending alternatives or counseling against Reams. Graves's reply on 5/29/2025 was simply "Just give me a call when you want to discuss." Kelly is also the contact who interfaced with Waz to explore the secondary market for USD-denominated Israel sovereign debt that ATRS could "ultimately want to own in a laddered fashion." ## Kelly at the April 7 and June 2 Board meetings (7/3/25 production) The 7/3/25 supplemental ATRS FOIA production documents Kelly's procedural role across both Board meetings. At the April 7 meeting, Kelly presented the Preliminary Performance Report for the Month Ending February 28, 2025 jointly with Katie Comstock. The 4/7 minutes attribute: "PJ Kelly and Katie Comstock of Aon Hewitt Investment Consulting provided the Committee with a Preliminary Performance Report for Month ending February 28, 2025." At the June 2 meeting, Kelly is again named alongside Comstock for the Preliminary Performance Report for Q1 2025 and for the Private Debt Informational Presentation. Comstock is documented as Kelly's co-lead on the ATRS account; see [[katie-comstock]]. The 6/2 packet contains a Kelly + Comstock memo on the Israel Bonds Attachment 17 (pp.149-150). The complete text of the attachment, in its entirety, consists of: > Page 149: "Date: June 2, 2025 / To: Arkansas Teacher Retirement System (ATRS) / From: PJ Kelly, Katie Comstock" > > Page 150: "APPENDIX: Disclaimers" > 06-02-25_BOT_Packet.pdf pp.149-150 The memo header and the appendix heading appear on otherwise-blank pages. No substantive body text appears in the extracted text. Whether the rendered PDF contains image content beyond what text extraction captures is not knowable from this method. The structural position of the document is the Aon Hewitt advisory attachment to Resolution 2025-22; Resolution 2025-22's preamble cites "the advice of its general investment consultant, Aon Hewitt Investment Consulting, Inc" as the basis for the Board's authorization. See [[atrs-resolution-2025-22]] and [[independent-credit-analysis-gap]] for the analytical implications. ## Evidence > "FYI - a compelling offer from Reams from a few perspective but they are light on experience with Israel bonds but have non-US bond experience and resources. We can discuss tomorrow." > PJ Kelly to Rod Graves, Emails3.pdf p.31, 5/28/2025 > "https://www.israelbonds.com/ These are the bonds they ultimately want to own in a laddered fashion. Are these included in your analysis? Also what would the fee be?" > PJ Kelly to Matt Waz, Emails3.pdf p.32, 5/28/2025 > "PJ Kelly, CFA, CAIA, Partner, [email protected], O: 312.381.1276, M: 312.968.0098" > Kelly email signature, Emails3.pdf p.31, 5/28/2025 ## Cross-References [[matt-waz]] Raymond James / Reams contact who provided the manager pitch [[reams-asset-management]] manager Kelly forwarded the offer for [[rod-graves]] [[mark-white]] ATRS staff Kelly served [[independent-credit-analysis-gap]] [[written-recommendation-requirement]] concept pages that include Kelly's "light on experience" caveat and address the BP4 Section A.5 written-recommendation requirement [[atrs-investment-policy-bp4]] concept page on the policy framework binding Kelly's role [[katie-comstock]] Kelly's Aon Hewitt co-lead on the ATRS account [[atrs-foia-r1-staff-emails]] [[atrs-board-rules-r1]] [[atrs-bot-packets-7-3-25]] source pages ## 6/2 IC audio (R 2-28-26): the "investment grade private placement" framing of Israel Bonds The 6/2/2025 IC audio transcript at [[atrs-ic-audio-6-2-25]] captures Kelly producing the wiki's first verbatim characterization of Israel Bonds as an asset class. Kelly did not speak on the Israel Bonds item itself (the substantive deliberation on Resolution 2025-22 was carried by Brady's prepared speech, White's defense, Knight's procedural dissent, and Marshall's motion). Approximately 45 minutes after the Resolution 2025-22 IC vote, Kelly led the Private Debt informational presentation. During discussion of credit risk in private debt strategies, an IC member referenced Kelly's earlier comments on credit risk: > "I think I appreciate PJ the last comment about credit risk because that's obviously what and that's what I was wishing we would hear more of in my presentation" > 20250602B_IC.transcript.txt segments 2681-2685, [01:32:41 to 01:32:51] The IC member's framing acknowledges the substantive credit-analysis-product was thin on the earlier Israel Bonds item. Kelly responds: > "That's always a focus like when we bring you managers and strategies but there is a growing area where it's actually investment grade but it's private placements so similar to what like Israel bonds I mean that's investment grade but you know a lot of what you're talking about is sort of private it's not it's a liquid" > 20250602B_IC.transcript.txt segments 2686-2695, [01:32:51 to 01:33:11] Kelly classifies Israel Bonds as an "investment grade private placement." The "it's a liquid" rendering is a Whisper artifact for "illiquid." Kelly characterizes the private-placement asset class as a "growing area" that Aon brings managers and strategies on. Kelly recommends "taking advantage of" the asset class. The framing has direct structural consequences for [[independent-credit-analysis-gap]] and [[written-recommendation-requirement]]: Kelly's verbal characterization placed Israel Bonds inside an asset class Aon produces formal analytical work product on, undercutting the securities-licensure structural-rationale Mark White articulated at the same IC meeting (and later in the 7/2/2025 Lenow response documented at [[auditor-foia-r3-3-3-26]]). The 12/1/2025 IC documented at [[atrs-board-audio-12-1-25]] subsequently formalized the private credit asset class as a 5% target allocation across BP4 and BP6 policy amendments, with full Aon consultant analytical work product including benchmark selection (Morningstar LSTA Leveraged Loan Index + 200 basis points), structural guardrails (30-50% corporate direct lending, 30-50% asset-based lending, 10-30% opportunistic debt), and a fund-of-one vs fund-by-fund analysis. Kelly led the 12/1 private credit presentation alongside Eric Denany (Aon resident private credit expert) and Comstock. The structural disjunction is documented at [[independent-credit-analysis-gap]]: the same Kelly produced substantive analytical work product on the asset class to which his own 6/2 verbal framing assigned Israel Bonds, while the documentary record on Israel Bonds itself remains the empty Kelly + Comstock memo header on pages 149-150 of the 6/2 packet. ## 12/1/2025 IC private credit presentation (no Israel Bonds reference) The 12/1/2025 IC audio transcript at [[atrs-board-audio-12-1-25]] documents Kelly present and substantively active for approximately 30+ minutes on the private credit allocation policy adoption. Kelly led the consultant presentation with Comstock and Eric Denany. The Kelly-led discussion covered the sourcing of the 5% allocation (1% from real estate, 2% from public equity, 2% from fixed income), the benchmark recommendation, the structural guardrails within the allocation, and the fund-of-one vs fund-by-fund strategic decision. Kelly's substantive engagement included: > "5% target to private credit, so we'll talk about that a little bit more as we move on through the ..." > 20251201B_IC_Audio.transcript.txt segment 476, [00:31:50 to 00:31:56] The 12/1 IC and the BOT (combined approximately 2,966 segments and 188 minutes) contain zero references to Israel, Reams, Scout, Jubilee, Resolution 2025-22, or any term associated with the Israel Bonds mandate. Kelly's substantive engagement on private credit while remaining silent on Israel Bonds — the asset class he had verbally classified as a private placement six months earlier — documents the structural pattern at the consultant level. Kelly is the entity-level expression of the cross-Board-day analytical asymmetry documented at [[independent-credit-analysis-gap]]: same consultant, same asset class category, six months apart, substantive analytical work product on private credit, none on Israel Bonds. [[atrs-ic-audio-6-2-25]] [[atrs-board-audio-12-1-25]] source pages