# Steve Pulley Senior Investment Officer at the Arkansas Office of the Treasurer of State. Email signature throughout the Dunlap FOIA production: > Steve Pulley > Senior Investment Officer > Office of the Treasurer of State > Phone: 501.682.1415 (o) > 501.764.8931 (m) > [email protected] > > Victory Building > 1401 W. Capitol, Ste 275 > Little Rock, AR 72201 > > www.artreasury.gov The Israel Bonds account lead at the Treasurer's office across both the Walther (August 2023 - January 2025) and Thurston (January 2025 onward) tenures. Pulley placed the Thurston $20M April 2025 Israel Bonds order; reviewed October 2024 Israel Prayer Ceremony speaking notes; handled FOIA-response document gathering on the October 2024 internal credit overview; coordinated the Book Entry custodial migration in April 2025; and reported the Treasurer's-office investment activity to the State Board of Finance via Thurston's prepared remarks. ## The dissenting-memo question — RESOLVED The seed-list characterization of Pulley as "Treasury, authored dissenting memo" is **not supported by the documentary record across Treasury R1 (7-7-25), R2 Sub-batch 1 (top-level Israel-specific documents), R2 Sub-batch 2 (per-transaction Israel Purchases and Maturities), and R2 Sub-batch 3 (alphabetized Communications binders A-He, Hol-Is, and Ja-Po covering 2018-2025 Treasury Israel Bonds correspondence)**. The Sub-batch 3 binders comprise approximately 14,335 lines of extracted email text covering Berman, Brady, Pulley, Romanik, Dortch, Munson, Huffman, Gladden, Kilgore, Walther, Thurston, Milligan, Lowery, and DCI counterparties across 2018-2025. No Pulley-authored dissenting memo, procedural objection, or formal cautionary memorandum on Israel Bonds appears anywhere in the Treasury R2 production. Of the three scenarios held open at R1, the documentary record resolves to scenario (c): **the seed-list characterization is incorrect**. The closely-adjacent scenarios (b) — that the seed-list confused Pulley with Romanik or Dortch — also resolves negatively: neither Romanik nor Dortch authored a procedural-objection document in the production. Romanik's substantive Israel Bonds documentary footprint is thin (loop-in cc on the 4/16/2025 Pulley forward; 5/12/2025 SBOF Federal Reserve presentation; routine cc on rate-sheet correspondence). Dortch's substantive footprint is documented at the [[damon-dortch]] entity page and is structurally distinct from a procedural objection. The wiki schema rule "absence is information, not evidence" produces the resolved finding: across the entire Treasury R2 production (the largest single Treasury production in the wiki to date), no procedural-dissent document on Israel Bonds exists by any Treasury investment-team principal. The 10/8/2024 Israel Internal Credit overview is structurally distinct (an analytical product with portfolio recommendation, not a procedural objection). The closest documented analytical staff product on the political-character of the Israel Bonds program is Dortch's 12/6/2024 2:23 PM internal email to Kilgore stating "We buy them to make a political statement and usually at the direction of the elected Treasurer" — but this is candid institutional acknowledgment from one staff peer to another, not a procedural objection registered for the record. The documentary record across R1 and R2 places Pulley as the consistent operationally-cooperative Israel Bonds account lead under Walther and Thurston, with no procedural reservation, no caution language, and no formal opposition in any documented Pulley email. Pulley's 2/3/2025 12:23 PM "we are watching the situation with rates, tariffs and Fed policy to determine when to take advantage of our next buying opportunities" framing is the closest Pulley language to caution in the production, and Berman's 2/3/2025 2:17 PM escalation to Burleson and Huffman ("Not sure exactly what's going on") followed by Huffman's 2/4/2025 11:12 AM "Our office continues to be supportive of your program" framing closed the moment of caution within 24 hours. Pulley placed the 4/16/2025 $20M Thurston order ten weeks later. The wiki maintains the resolved finding: the seed-list "authored dissenting memo" claim is not supported by the production. The substantive question the seed-list pointed at — what role does internal-staff opposition play in the Israel Bonds purchase pathway — is answered by the documented record: internal Treasury staff produced an analytical recommendation (10/8/2024 HOLD) that was overridden by elected-Treasurer-directed external sales pressure (Berman pitch + Huffman target-setting + Pulley order placement), and at least one internal-staff peer (Dortch) candidly characterized the institutional pattern as "political statement... at the direction of the elected Treasurer" two months before the override was placed. ## The Walther-era 2023 $10M purchase The 11/1/2023 - 11/2/2023 wire-pending email thread documents Pulley as the Senior Investment Officer Berman pressured directly when the $10M wire failed to clear at Computershare on the contracted deadline. Berman's 11/1/2023 1:58 PM message addressed Pulley personally: > Hi Steve, > Just a reminder you wire is due today for your $10M purchase. If not received today, have to cancel the transaction > Can you give me an update on the pending payment. > Many thanks. > Larry Pulley forwarded the message to Gladden at 2:02 PM. The wire cleared at 3:04 AM on 11/2 after Berman, Mulvey, Mark Ng, and the Treasury-Computershare-BofA chain reconciled the BofA hold. Berman's 11/2 11:41 AM post-event message thanked "Celeste, thank you Steve, for all your efforts and for this important investment." The 2023 transaction establishes the Berman-Pulley working relationship as the operational entry point for the wiki's prior framing of the Walther-era $10M position. Pulley was therefore Israel Bonds account lead under Walther. ## The 10/4/2024 Israel Prayer Ceremony review Pulley reviewed the speaking notes Heather McKim drafted for the Walther Israel Prayer Ceremony. Eric Munson sent Pulley the draft 10/4/2024 4:53 PM: > Please read over and proof attached press release. Call me if any suggestions 501-951-8837 Pulley responded 10/7/2024 7:53 AM: > I'm confused this is a press release from 10/27/23. I think you sent me last year's release. The exchange documents Pulley as the substantive reviewer for Treasurer's-office Israel Bonds public communications, parallel to Brady's role at the Auditor's office. Pulley's confusion-about-the-date response identified that McKim's draft had carried over 2023's $52M total figure rather than the contemporaneous October 2024 figure, suggesting Pulley was familiar with the actual position size at the time. ## The 10/7-10/8/2024 Treasurer briefing initiation Eric Munson (Chief Deputy Treasurer) emailed Pulley and Robert Romanik on 10/7/2024 4:18 PM: > Rob & Steve, > The Treasurer requested a briefing or summary on Israel bonds sometime this week. He wanted to hear from you on your opinion about purchasing more Israel bonds in the future. Give me a call or I can come down and meet with you tomorrow - on Tuesday. The Treasurer at the time was Larry Walther. The briefing was scheduled for Tuesday 10/8/2024 per Pulley's 10/8 1:24 PM "Sounds good" reply. The 10/8/2024 date matches the date in the filename of the "Israel Internal Credit overview 10-8-24.docx" document Pulley subsequently sent to McKim on 12/11/2024 as a FOIA-response attachment. The internal credit overview was therefore prepared in connection with the 10/8/2024 Walther briefing. Pulley's substantive opinion delivered to Walther at the 10/8 briefing is not documented in this batch. Whether Pulley recommended additional Israel Bonds purchases, recommended against them, or offered a procedurally neutral analysis is not knowable from the production. ## The 12/11/2024 FOIA-response document gathering Pulley sent Heather McKim five attachments at 2:41 PM: > Heather attached you will find any documents relevant to the most recent FOIA request. If you have any questions please let me know. The attachments: - Israel holdings 10-7-24 (1).xlsx (Clearwater Analytics holdings report) - Israel holdings 10-7-24 (1).xlsx (duplicate) - Israel rating report.pdf - Moody Rating Action Report - Israel - September 2024.pdf.docx - Israel Internal Credit overview 10-8-24.docx This is the first wiki documentation of an internal credit-analysis document at any Arkansas state agency on Israel sovereigns. The document text is not in the production; only the filename. Pulley therefore prepared internal credit material on Israel sovereigns in October 2024 but the substantive analysis is not yet in the wiki documentary record. ## The 12/31/2024 Walther-to-Thurston transition correspondence Pulley emailed Berman 12/31/2024 12:14 PM in response to Berman's January-15-reinvestment-rates message: > Thanks Larry, give us a little time because we are swearing in a new Treasurer tomorrow and it will take a bit to get everyone up to speed on where we are with the various sub-assets. The transition correspondence establishes that Pulley remained Israel Bonds account lead across the Walther-Thurston transition without interruption. Pulley sent Berman a 12/31/2024 New Year greeting on a separate thread: "I hope you and your family have a Happy New Year and a prosperous 2025!" Berman's reciprocal greeting on 12/31/2024 12:22 PM and 12:25 PM closed with "on behalf of all our staff at Israel Bonds, we wish you and your family, and all your colleagues at the Treasury department, a safe, a happy, and especially a healthy new year!!" ## The 4/16/2025 Thurston $20M order Pulley's 2:20 PM email to Berman placed the order: > Hey Larry, thanks for all of the information on the current issue. Pencil us in for $10MM of the 3yr 4.66% along with $10MM of the 5yr 5.17%. Did you need us to update the QIB? Celeste Gladden with our team will be contacting Bill Mulvey to coordinate the redemption along with getting all of our positions in B/E format. This new format will be a big help on the operations and settlement of your bonds. Please don't hesitate to contact me if you have any questions > > Thanks again, The order matches Bill Huffman's pre-conversation target with Berman exactly ($20M in 3 and 5 year paper bringing the portfolio to $55M). Pulley's email was sent four hours after Berman's 12:06 PM rate-sheet pitch. Pulley's tone is operationally cooperative; no procedural review questions, no reservations, no fiduciary-duty framing. Pulley also forwarded the rate-sheet email to Gladden 4/16/2025 2:01 PM with cover note: "Hey Celeste it looks like State of Israel is moving to a B/E format..if that is the case we need to migrate our holdings and redemptions to reduce the lift on settlements and marturities." [sic] The Book Entry migration recommendation is Pulley's own initiative on the operational efficiency rationale, not on procedural-control grounds. ## The 4/16/2025 Romanik loop-in Pulley forwarded the same email chain to Robert Romanik at 2:54 PM with cover note: > Just to loop you in....I noticed that you weren't on the chain The cover note indicates Romanik is normally on Israel Bonds correspondence and was inadvertently excluded from the 4/16/2025 12:06 PM Berman pitch. Romanik's substantive role is not directly documented in the Dunlap FOIA, but the loop-in confirms Romanik is in Pulley's investment-team distribution. ## The 4/21/2025 Accredited Investor letter Pulley emailed Bill Huffman 4/21/2025 9:04 AM (cc Michael Harry, Celeste Gladden): > Bill attached you will find the Accredited Investor Letter that'll need to be signed in order for State of Israel to update their internal files attesting that we are an accredited investor. I'll bring a hard copy to our meeting tomorrow morning for your signature. The QIB Rule 506 compliance documentation step. Huffman's 9:14 AM reply via Outlook for iOS acknowledged receipt. Gladden transmitted the signed certificate to Berman 4/22/2025 10:47 AM. ## The 5/12/2025 SBOF reporting Thurston's prepared State Board of Finance opening remarks (presumably drafted by Pulley or his team) included: > Regarding foreign investments, we have purchased Israeli bonds in amounts consistent with our historical levels. And the closing line on Act 739 of 2025 explicitly defers to Pulley: > (Steve Pulley can answer additional questions) Same day Pulley emailed Amanda O'Neal at 2:18 PM: > We had new purchases of $20 million bringing our total position to $55 million. The framing ("amounts consistent with our historical levels" + "$20 million bringing our total position to $55 million") presents the Thurston purchase as a routine portfolio operation rather than a discretionary acquisition driven by the 4/15/2025 Berman Capitol meeting. The wiki's contemporaneous documentary record (Berman's 4/17 thank-you to Fecher; Brady's 5/15 IFSC remarks attributing the Treasury purchase to the Capitol-tour outcome) contradicts the "consistent with historical levels" framing: prior Treasury Israel Bonds purchase cadence was approximately $5M per year average across Milligan-Walther tenure; the Thurston $20M single-month purchase is 4x the historical average. ## The 9/4/2024 Israel Bonds pricing discrepancy Pulley emailed Steven Kilgore 9/4/2024 11:22 AM concerning a BNY-vs-Clearwater Analytics pricing discrepancy on Israel bonds: > Concerning the discrepancy on the Israel bonds it appears that BONY has a more accurate pricing. Clearwater is severely off market for this particular security. Pulley's role on operational pricing reconciliation is documented; the substantive content of why Clearwater was "severely off market" on Israel bonds and not on other Treasury bond positions is not analyzed in the email thread. ## Cross-references [[treasury-foia-r1-7-7-25]] source page [[celeste-gladden]] [[robert-romanik]] [[damon-dortch]] Treasury investment-team peers [[eric-munson]] Chief Deputy Treasurer who initiated the 10/7/2024 Walther Israel Bonds briefing request [[steven-kilgore]] Investment Accounting Director / Internal Audit who handled the BNY-Clearwater pricing discrepancy and the SBOF custodian policy review [[heather-mckim]] Treasury staff who handled FOIA-support work for Pulley [[bill-huffman]] Chief Deputy Treasurer (Thurston era) who set the $55M target with Berman before Pulley placed the order [[lawrence-berman]] DCI sales lead Pulley corresponded with on order placement, maturity reinvestment, holiday greetings, and rate-sheet communication [[john-thurston]] [[larry-walther]] the two Treasurers Pulley served across [[state-treasurer-israel-bonds-holdings]] the $55M Treasury position Pulley operationally administered [[state-treasurer-israel-bonds-operations]] the operational pathway Pulley led [[october-2024-treasurer-israel-prayer-ceremony]] the Walther-era event Pulley reviewed speaking notes for [[independent-credit-analysis-gap]] the gap concept that the Pulley 10/8/2024 Israel Internal Credit overview document qualifies pending text production ## Treasury R2 9-23-25 production: the 10/8/2024 internal credit overview text resolved The Treasury R2 production produces the substantive text of the "Israel Internal Credit overview 10-8-24" document Pulley transmitted to McKim on 12/11/2024. The R1 wiki held the document's existence as open question 2; the substantive resolution at R2 is documented at the dedicated concept page [[treasury-internal-credit-analysis]]. The document is a 2-page rating-agency-derivative internal credit analysis with a Conclusion recommendation to HOLD positions and not add bonds. The recommendation was overridden by the Thurston May 2025 $20M Israel Bonds purchase Pulley himself placed. **Pulley's relationship to the 10/8/2024 document.** The document was prepared in connection with the 10/8/2024 Walther briefing that Munson initiated. The document does not bear an authorship attribution within its text. Pulley as Senior Investment Officer is the most plausible primary author, but the document may also have been a Pulley-Romanik joint product or a broader Treasury investment-team product. The wiki holds Pulley as the most plausible primary author pending further evidence. **Pulley's relationship to the override.** Pulley placed the 4/16/2025 2:20 PM Thurston $20M order against the standing 10/8/2024 internal credit-team recommendation to HOLD. The order was placed without documented internal re-evaluation of the 10/8/2024 recommendation, and was based on the Berman pitch + Huffman pre-conversation target-setting. The substantive significance is that Pulley as the most plausible primary author of the 10/8/2024 recommendation subsequently placed the order against that recommendation. The wiki does not document the internal Treasury process by which the override was authorized or how Pulley as Senior Investment Officer reconciled the order placement with the standing internal credit-team recommendation. **The dissenting-memo question is resolved by Sub-batch 3.** The 10/8/2024 internal credit overview is structurally distinct from a "dissenting memo" in the procedural sense. It is an analytical product with a portfolio recommendation. The Communications binders (Sub-batch 3) contain no separate Pulley procedural-dissent document. See the resolved-question section above for the full documentary record across R1, R2 Sub-batch 1, Sub-batch 2, and Sub-batch 3. ## Treasury R2 Sub-batch 3 (Communications binders): operational continuity and the absence of dissent The R2 Sub-batch 3 alphabetized Communications binders (A-He, Hol-Is, Ja-Po) place Pulley as the consistent operationally-cooperative Israel Bonds account lead from his first documented Berman contact (10/17/2023 10:00 PM) through the August 2025 portal-access workflow. The binders contain no Pulley procedural-objection document. The dissenting-memo question is closed; see the resolved-question section. **Pulley's first documented Berman contact (10/17/2023 10:00 PM).** Pulley emailed Berman 10/17/2023 10:00 PM: > Larry if you give me a call tomorrow at you convenience, I had a couple of questions on State of Israel Bonds. Berman replied 5:38 PM from Ireland: "I'm in Ireland as I type, but I fly back tomorrow and have a layover at Newark. If the connection isn't too tight, I'll call you when I land. Otherwise, I'll call you Thursday morning." Berman called Pulley from Newark 10/18/2023 10:37 AM. The substance of Pulley's "couple of questions" is not in the email; whatever Berman conveyed verbally was sufficient to produce Pulley's 10/24/2023 12:12 PM inaugural Walther-era $10M order seven days later. The 10:00 PM Tuesday timestamp is after-hours. Whether the after-hours framing reflects Pulley's preference for off-record initial outreach or a procedural-uncertainty reaction to Munson's 6/2/2023 forward of the Berman pitch (Berman 5/31/2023: "I did have a conversation with Treasurer Lowery at the SFOF conference before he became ill") is not documented. **Pulley reviewed the 10/27/2023 Walther press release before publication.** Heather McKim's 10/27/2023 2:12 PM "Please read and respond - Priority" email circulated the draft press release to Pulley, Munson, and Stephen Bright. Pulley's 2:36 PM reply: "I think the original statement is satisfactory and doesn't require additional explanation." Munson suggested omitting one sentence ("The Arkansas Treasury has also put our money where our mouth is by purchasing the additional $10 million in Israel bonds"). McKim's 2:55 PM follow-up captured the editorial pre-clearance pattern: "By the way, Larry was good with it too, just wanted me to send it to you all. I will run any changes by him as well." Berman pre-reviewed and approved the press release before McKim circulated to the internal Treasury team. Pulley's role was internal review under Berman's pre-approval pattern. **The 2/3/2025 escalation pattern.** Berman's 2/3/2025 12:01 PM rate-sheet email to Pulley + Burleson + Huffman pitched reinvestment of the 1/1/2025 $10M maturity. Pulley's 12:23 PM reply was the closest Pulley language to caution in the documented record: > Thanks Larry for the update, we are watching the situation with rates, tariffs and Fed policy to determine when to take advantage of our next buying opportunities. Berman 2 hours and 14 minutes later (2/3/2025 2:17 PM) escalated to Burleson and Huffman without Pulley: > Hi Ken, Hi Bill, I wanted you to see Steve's response. Not sure exactly what's going on, but we had the best rates last period we've had in several months, and they continue to be solid today. Huffman's response 2/4/2025 11:12 AM closed the moment of caution: > I hope all is well. Thank you for the update. Our office continues to be supportive of your program. Steve and I have visited regarding buying opportunities. We look forward to continuing our relationship. Thank you. Bill. The escalation pattern documents that when Pulley's response was non-committal, Berman immediately routed over Pulley's head to Huffman. Huffman's "Our office continues to be supportive of your program" framing on behalf of Treasury operationally re-set the relationship without Pulley needing to revise his framing. Pulley placed the 4/16/2025 $20M Thurston order ten weeks later. **The Berman/Young November 2024 Little Rock visit (previously undocumented).** Berman's 12/23/2024 11:09 AM email to Pulley + Huffman + Burleson + Gladden references "As we discussed when Brad and I were in town last month" — placing a Berman/Bradley Young visit to Little Rock in November 2024. Berman's 4/17/2025 2:40 PM thank-you to Thurston confirms: "After meeting Bill and Ken on our earlier trip to Little Rock, we knew that our partnership with the Arkansas Treasurers office was in capable hands." The November 2024 visit met Huffman ("Bill") and Burleson ("Ken") — Thurston-era Chief Deputy Treasurer and Deputy Treasurer respectively. Whether Pulley attended is not documented in the binder. **The 1/7/2025 Yali Rothenberg exclusive briefing invitation.** Berman 1/7/2025 2:41 PM invited Pulley + Burleson + Huffman to a 1/15/2025 "exclusive briefing" with "Israel's long time Accountant General, Yali Rothenberg": > The timing is good with your bond up for reinvestment. I think you will find his presentation interesting, informative, and compelling. The "your bond up for reinvestment" reference is to the 1/1/2025 $10M maturity. Berman's "exclusive briefing" with Israel's Accountant General was substantively a sales context for the post-maturity reinvestment pitch. **Pulley placed the inaugural Walther-era $10M order on 10/24/2023.** Pulley's 10/24/2023 12:12 PM order email to Berman placed the November 2023 $10M institutional purchase: > Thank you Larry for the details. We plan to purchase $10MM of the 3yr bond at 5.40%. I'll work on making sure the appropriate forms are completed and back to you prior to settlement on November 1st. The 12:12 PM Tuesday placement was followed within 90 minutes by Munson's 1:32 PM "10-25 SBOF Treasurer Walther remarks.docx" drafting for Walther's 10/25/2023 SBOF appearance (the appearance that produced the Wickline article's "considering some additional purchase of bonds" framing). The 10/27/2023 press release followed the SBOF appearance. The press machinery activation lagged the order placement by hours, not days. **Pulley's other Sub-batch 3 documented correspondence is operationally cooperative.** December 2024 maturity coordination: 12/23/2024 1:15 PM "Thank you for the update," 12/31/2024 12:14 PM "give us a little time because we are swearing in a new Treasurer tomorrow and it will take a bit to get everyone up to speed," 12/31/2024 12:15 PM "I hope you and your family have a Happy New Year and a prosperous 2025!" February 2025 rate-sheet acknowledgments. April-May 2025 order placement (already documented at R1). May 2025 Book Entry migration administrative correspondence. August 2025 portal-access workflow with Computershare. No Pulley correspondence reaches procedural-objection language across any sub-batch. ## Treasury R3 2-19-26 production: Pulley as same-day-acceptance order-placer on the Feb 17 2026 Thurston purchase The Treasury R3 (2-19-26) production documents Pulley's role on the second Thurston-era Israel Bonds purchase. The transaction follows Pulley's established pattern (Berman cold solicitation → Pulley same-day acceptance → Gladden compliance coordination → Treasury wire) but with a faster turnaround than the May 2025 ladder transaction. ### The 2-hour-12-minute acceptance window Berman's 1/14/2026 2:31 PM cold solicitation pitched reinvestment of the 2/1/2026 $5M maturity with explicit upsell ("if you wanted to add funds to this maturity, we would of course be more than happy to discuss that as well!"). Pulley's acceptance reply was sent approximately **2 hours and 12 minutes later** (the precise time is preserved only in reply-tail fragment within Berman's 4:43 PM acknowledgment). The visible Pulley reply-tail fragment: "[Book] entry settlement. Book entry settlement should make life easier for all of us. Thanks again!" Pulley's response confirmed book-entry settlement preference. The decision to **accept the $10M new purchase (doubling the maturing $5M position) — rather than reinvest only $5M, or decline reinvestment** — was made within the 2h 12m window. The substantive merits analysis (alternative-yield shopping, credit re-evaluation in light of the active Israel Credit Surveillance flag on the November/December 2025 A1 Investment Recap documents, comparative analysis of corporate or municipal alternatives) is not preserved in the documentary record. Whether Pulley placed phone calls or consulted with Huffman or Romanik during the 2:31 PM - 4:43 PM window is undocumented. The Feb 2026 turnaround is faster than the May 2025 turnaround (~4 hours from Berman's 12:06 PM pitch to Pulley's 2:20 PM order). The institutional pattern of Pulley's rapid acceptance of Berman cold solicitations is documented as hardening into routine across the two Thurston-era purchases. ### The Pulley-as-Credit-Surveillance-monitor / Pulley-as-Israel-Bonds-purchaser institutional split Pulley is listed as the Long Term portfolio principal on both the November 30 2025 A1 Investment Recap and the December 31 2025 A1 Investment Recap headers (alongside Robert Romanik). The Credit Surveillance section of both monthly recaps lists Israel sovereign credit at "Baa1 / A- / Remains on Negative outlook by both services." Pulley therefore signs off (in the institutional sense) on the monthly Credit Surveillance flag for Israel sovereign credit during the precise period in which he accepts Berman's 1/14/2026 cold solicitation and places the 2/17/2026 $10M new purchase order. The institutional pattern Pulley personally executes: - **Pulley as Long Term portfolio principal**: Monthly Credit Surveillance review flags Israel on Negative outlook (Nov 2025, Dec 2025; presumed Jan 2026 and Feb 2026 in subsequent A1 recaps not yet in production). - **Pulley as Senior Investment Officer Israel Bonds account lead**: Accepts Berman's 1/14/2026 cold solicitation 2 hours after receipt; places the $10M new purchase order under the active Credit Surveillance flag. The two outputs (monthly Credit Surveillance documentation; new-purchase order) are produced by the same Pulley but flow through institutionally distinct documentary streams (the A1 Investment Recap monthly report; the Berman-Jimenez email order chain). No cross-referencing between the two outputs is preserved in the documentary record. The institutional pattern is consistent with Damon Dortch's 12/6/2024 articulation that "We buy them to make a political statement and usually at the direction of the elected Treasurer" — analytical product and political-direction-execution operate in parallel within Treasury's documentary architecture. ### Book entry settlement preference as the operational simplification Pulley's 1/14/2026 4:43 PM reply confirmed book-entry settlement preference. The Feb 2026 purchase is therefore the second book-entry-form Israel Bonds purchase Treasury has executed (the May 2025 ladder being the first). The April 2025 Book Entry migration Pulley coordinated with Mulvey and Kilgore at R1 produced the operational ability for book-entry settlement; the May 2025 and Feb 2026 transactions are the first two purchases under that capability. Treasury's custodial architecture for Israel Bonds is progressively migrating from BNY-held certificate-form positions to Computershare-held book-entry-form positions as the older Milligan-era and Walther-era certificate positions mature off. [[treasury-foia-r3-2-19-26]] source page