# APERS Office FOIA Production R1, 7-7-25 The Arkansas Public Employees Retirement System's first FOIA production responsive to Israel Bonds requests, dated 7-7-25, comprises two PDFs combining email-thread captures with attachment inlining in Outlook PST-style export format. The two files together total 4,002 pages: `IB_FOIA_MAY_25_Reviewed.pdf` (636 pages, 38 emails; the substantive Israel-Bonds-specific subset reviewed in May 2025) and `IB_FOIA_JUL_25_Reviewed.pdf` (3,366 pages, 86 emails; the broader follow-up FOIA response superset). Each "Email N: Subject" page header marks an email start; attachments appear inlined between emails as they did in the original sent message. The production reaches the wiki as the first APERS-custodian source documenting the APERS Investment Finance Subcommittee's 5/15/2025 authorization of $25 to $50 million in Israel Bonds. The production was ingested in two chunks, completing the APERS R1 production. The original five-chunk plan was consolidated to two chunks at user direction after Chunk 1 review. ## Chunk 1: MAY 25 emails plus Investment Finance Subcommittee packet (pages 1-103, 587-636) Chunk 1 covers the substantive Israel-Bonds-specific record from the MAY 25 PDF: the 38 emails (E1-E38) plus a single read of the 69-page Investment Finance Subcommittee Meeting May 15 packet (E16, with E17-E23 as identical-content duplicate distributions to other recipients). The May 15 IFSC meeting is the central event in the APERS Israel Bonds adoption. ### The 5/15/2025 APERS Investment Finance Subcommittee meeting The IFSC met Thursday May 15, 2025 at 1:00 PM in the APERS Board Room (124 West Capitol Avenue, Suite 400, Little Rock 72201) as a hybrid in-person plus video conference meeting. The meeting authorized "a minimum of $25 million and up to a maximum of $50 million of system funds in Israel bonds" with no audible dissenters per the Mike Wickline article published the next day in the Arkansas Democrat-Gazette. Brady "told the Investments and Finance Subcommittee that in his efforts to further diversify the retirement system's investment portfolio with investments such as private equity and private credit and seek increased investment returns for the system, 'it has come to my attention that APERS does not own any Israel bonds, like those held by the state treasurer's office.'" Brady made the motion himself; Trustee Jim Hudson (Secretary of the Department of Finance and Administration) wanted "a maximum set of $50 million on the investment of system funds in Israel bonds, so Brady amended his motion to authorize the system's staff to invest a minimum of $25 million and a maximum of $50 million of system funds in Israel bonds." The meeting also authorized up to $100 million each in three infrastructure secondary funds: Partners Group Infrastructure Secondary, Ares Secondaries Infrastructure Solutions III, and Pantheon Global Infrastructure Fund V. The IFSC was chaired by Larry Walther; agenda item 1 was "Call to order and recognition of new subcommittee chair – Larry Walther," establishing this as Walther's first IFSC meeting as chair. Walther served as Arkansas State Treasurer from August 2023 until January 2025, the immediate predecessor to Thurston. Per the Wickline article, Walther personally purchased Israel Bonds during his Treasurer tenure. ### The IFSC packet — Israel Bonds attachment is empty The 69-page IFSC packet (Packet_05 15 25.pdf, distributed by Fecher to subcommittee members on 5/14/2025 9:12 AM) consists of the agenda, Borromeo's CIO Report (8 pages on Strategic Asset Allocation and Secondary Infrastructure overview), the Stephens Capital Management Private Credit Refresher presentation (7 pages by Larry Middleton, Bo Brister, and Seth Middleton), the HarbourVest Credit Secondaries presentation (11 pages by Melissa Cahill and Bill Cole), the Neuberger Berman Direct Lending presentation (8 pages by Gabe Feghali, Michael Schwartz, Will Proctor), and the Callan Infrastructure Secondaries Search Finalists report (32 pages dated May 12, 2025 covering six finalists: Ares, Blackstone, HarbourVest, Macquarie, Pantheon, Partners Group). The packet ends at page 103 with the Callan Client Disclosure for Infrastructure Secondaries. The agenda lists "Israel Bonds – Jason Brady" as item 4. The packet contains no Israel Bonds attachment. No Callan analysis. No Stephens analysis. No firm presentation. No written material of any kind on Israel Bonds. The Israel Bonds presentation at the IFSC meeting was Brady speaking. This is the APERS-custodian-confirmed structural asymmetry parallel to the ATRS BOT 6/2/2025 Kelly + Comstock empty-memo finding: in the same packet that authorized $25-50M in Israel Bonds, Callan provided 32 pages of analysis covering six infrastructure secondaries finalists, while the Israel Bonds item had zero pages of analytical attachment from any source. See [[callan-analysis-asymmetry]] and [[independent-credit-analysis-gap]]. ### Borromeo's framing — "the firms with the knowledge" Borromeo's 5/8/2025 7:08 AM agenda email to Fecher establishes Borromeo's intentional curation of the IFSC meeting structure: "Amy here is the agenda for the IFS meeting on the 15th, comments in the parenthesis is what I hope to achieve. / Secondary Infrastructure – Carlos will lead discussion. (I would like to add 3 new investment managers to the APERS lineup) / Private Credit discussion – Bo and team Stephens will lead the discussion (I didn't feel that we had the 'ok' to go ahead with P/C, so we are bringing in the firms with the knowledge) / HarbourVest – Ms. Melissa Cahill, Managing Director & Mr. Bill Cole, Principal / Neuberger Berman – Mr. Gabe Feghali, Client Advisor & Mr. Michael Schwartz, Managing Director & Mr. Will Proctor, Head of Sponsor Coverage / Israel Bonds – Mr. Jason Brady". The asymmetry is contemporaneous and known to Borromeo: Secondary Infrastructure had three competing managers under Callan's procured-search analytical framework; Private Credit had two manager firms with detailed presentations because "we are bringing in the firms with the knowledge"; Israel Bonds had Brady alone presenting. See [[westrock-procedural-asymmetry]] for the parallel one-person-two-procedural-standards framing established at ATRS. ### APERS held zero Israel Bonds prior to 5/15/2025 Borromeo's 12/10/2024 11:30 AM reply to APERS General Counsel Laura Gilson on the Badria Mryyan FOIA submission of the same date establishes the documentary baseline: "Because the Development for Israel bonds, which are issued by the Development Company for Israel, are not tradable and must be held until maturity, since August 01, 2017, APERS/ASPRS/AJRS has made zero investments with the Development Company for Israel. Regarding CUSIP 46513YJH2, since August 1, 2017, APERS/ASPRS/AJRS has zero transactions with that specific CUSIP." The decision the IFSC took on 5/15/2025 was a brand-new commitment, not the expansion of an existing position. The reply also documents that APERS administers ASPRS (Arkansas State Police Retirement System) and AJRS (Arkansas Judicial Retirement System) investments as a single unit ("APERS/ASPRS/AJRS"). This is the structural pathway by which the $25-50M Israel Bonds authorization extends to ASPRS and AJRS without separate authorizing action by either; cross-confirms the Act 1242 commingling pathway referenced in the seed-list. ### The Brady seed reaches APERS — Fecher's 19-minute reply Email 38 captures the same 10/23/2024 3:40 PM Brady seed message to Fecher and White already documented in the wiki via the Auditor's-office custodian batches (auditor@ shared mailbox capture in the R2 Residual production). The APERS-custodian copy now adds a finding the Auditor batches did not surface clearly: at 3:59 PM, nineteen minutes after Brady's outreach, Fecher replied accepting the meeting (Email 36-37): "Jason, I am happy to meet. November is particularly difficult for me. I am on leave from November 8-24. My only days available are November 4-7, or 28-29. I apologize for not being more flexible! I am happy to look at December dates if these dates do not work for others." At 3:59 PM Fecher also forwarded the Brady seed to Borromeo (Emails 34-35) with body "FYI" — the moment APERS-side internal involvement on Israel Bonds began. Fecher did not loop in Hollowoa, Gilson, Golleher, or any other APERS staff at that point; Borromeo alone received the FYI. ### November 5, 2024 (Election Day) APERS meeting cross-confirmation Email 33 (Ashley Golleher to Lawrence Berman, 11/6/2024 12:39 PM) is the APERS-custodian reciprocal of the previously-documented Berman 11/7 thank-you to Borromeo and Golleher. Golleher's text: "Mr. Berman, It was a pleasure to meet you this week. We appreciate you taking time to share information on Israel Bonds. I hope you all had a good evening and have a safe trip home. Sincerely, Ashley." The signature establishes Golleher's title as "Deputy Director of Operations" at APERS, refining the wiki's prior "APERS staff" framing. The 11/5/2024 Election Day APERS meeting between Berman/Young and Borromeo/Golleher is now cross-confirmed by both sides of the correspondence. ### April 14, 2025 9:00 AM Fecher–Berman meeting at Spadoni's office Emails 27-28 and 26 establish the April 14, 2025 meeting between Berman/Young and Fecher at Spadoni's State Capitol Room 230 office at 9:00 AM. This is the first stop of the multi-official Capitol tour documented at [[auditor-multi-official-capitol-tour]]. Berman's 4/17/2025 1:48 PM thank-you to Fecher attaches "APPROVED PPT 2.6.25 JH.pdf" — the State of Israel Economic Overview February 2025 PowerPoint with the "JH" suffix in filename (provenance unclear; could indicate Hudson involvement in the version approval but the document itself is the standard DCI institutional-sales deck). Berman's email contains a substantive new finding: "The State Treasurer made another significant investment ($20M) in our bonds after our meeting with his team this week, and we certainly hope that we can bring APERS on board as well." This documents the State Treasurer's 4/15/2025 $20M Israel Bonds purchase as a transaction directly resulting from the Capitol tour Berman meeting with Treasurer Thurston, and consistent with Brady's IFSC remarks per Wickline that "the state treasurer's office recently purchased of $20 million in Israel bonds, so the office now holds about $55 million in Israel bonds." ### The 5/15/2025 Berman rate sheet to Borromeo — same day as the IFSC vote Email 15 (Berman to Borromeo, 5/15/2025 3:13 PM) transmits the May 15-31 2025 Institutional Rates sheet ("May 15th – May 31st 2025 Institutional Rates.pdf" attached) with the cover note: "I wanted to share our new rates with you for your review. I believe the 3-year showing the best spread vs the benchmark UST coupons. These current rates are good until June 1, which would be the wire date to purchase any of these products." Borromeo replied at 3:19 PM same day (Email 14): "Thank you / Much appreciated / I will ask you to be patient with me, I have a full plate. I promise to touch base soon." Berman replied at 3:31 PM (Email 13): "Of course, Carlos, thank you again for the review." The IFSC meeting that authorized $25-50M in Israel Bonds began at 1:00 PM; the rate sheet thus arrived during or just after the meeting and Borromeo confirmed receipt 6 minutes after Berman's transmission. Stuart Garawitz and Bradley Young were cc'd on the entire chain. The exchange documents real-time DCI–APERS coordination on rate confirmation immediately around the authorization vote. ### Borromeo's Stephens "fixed income eyes" consultation — 1 day before the IFSC vote Emails 1-2 capture the entirety of the Borromeo–Stephens correspondence about Israel Bonds. On 5/14/2025 12:24 PM (the day before the 5/15 IFSC meeting), Borromeo emailed Stephens Capital Management's Bo Brister, Larry Middleton, and Seth Middleton with subject "Bonds" and a single-sentence body: "Bo I will need your fixed income eyes please / https://israelbonds.com/". Brister replied at 1:59 PM same day (Email 1-2 internal): "You bet. / Do we need to discuss?" The thread captured in the production ends there. Borromeo forwarded the thread to Fecher and APERS General Counsel Laura Gilson on 5/28/2025 at 2:52 PM with "Laura here is an email string that I sent to Stephes [sic] re: Israel bonds" — implying responsiveness to a FOIA request. The production contains no documented Stephens analysis, written response, or discussion summary of Israel Bonds. The "fixed income eyes" request was sent to Stephens, who attended the IFSC meeting THE NEXT DAY (per the agenda — Stephens led the Private Credit discussion alongside HarbourVest and Neuberger Berman) but Stephens's IFSC role was to discuss Private Credit, not Israel Bonds. The combined record establishes that APERS sought no independent fixed-income analysis on Israel Bonds before the IFSC vote authorized the investment. ### APERS post-vote FOIA handling — the Rollans inquiry Emails 3-11 capture APERS's same-day handling of the John Rollans 5/19/2025 12:54 PM FOI request. Rollans, identifying himself as "a retired member of the APERS," asked: "Does APERS own stock in Westrock coffee and if so how much? / Does APERS have sovereign bond investments with the state of Israel and if so how much?" — the same dual question he had sent ATRS the day before, where it had triggered the Westrock procedural asymmetry finding documented in [[westrock-procedural-asymmetry]]. The wiki's prior framing of Rollans as an ATRS retiree is now refined: he is a multi-system retiree, holding (or having held) membership in both ATRS and APERS, who sent the same dual question to both systems. The APERS response chain ran in 19 minutes: Fecher drafted the answer at 1:24 PM and sent it to Borromeo and Gilson asking "Are my answers accurate?"; Borromeo confirmed at 1:49 PM "You have answered correctly"; Fecher sent her reply to Rollans at 1:51 PM. Fecher's verbatim reply: "The APERS Board of Trustees Investment Finance Subcommittee authorized a $25-50 million investment in Israel Bonds at last week's meeting. We have not completed any bond purchases as of today but intend to do so." This is APERS's first known external public confirmation of the IFSC action. ### The IFSC subcommittee membership Fecher's 5/14/2025 9:12 AM packet distribution email establishes the IFSC roster: Gary Wallace ([email protected]), Jason Brady ([email protected]), Daryl Bassett ([email protected], Secretary of the Department of Labor and Licensing), [email protected] (Carnahan, full name not in the production), Jim Hudson (DFA Secretary), and Larry Walther ([email protected], IFSC Chair). Six members. CC: Sharon Mahoney ([email protected], presumably Hudson's staff at DFA), Anita Chance ([email protected], presumably Bassett's staff at ADLL), Wendy Spadoni (Auditor's office, Brady's staff). The CC pattern routes Auditor's-office and DFA staff into IFSC packet distribution; Wendy Spadoni's inclusion documents the Auditor's office systematic CC routing on APERS materials parallel to the [[auditor-as-dci-channel]] pattern. Three of the six IFSC members are Auditor's-office or cabinet-secretary connected: Brady (Auditor designee), Hudson (DFA Secretary), Bassett (DLL Secretary). At least Brady, Hudson, and Bassett met with Berman/Young during the April 14-15 Capitol tour. ### APERS internal staff distribution Fecher's 9:14 AM corrected version of the same email broadcast added APERS staff cc'd: Carlos Borromeo (CIO), Ashley Golleher (Deputy Director of Operations), Allison Woods, Laura Gilson (General Counsel), Richmond Giles, Patty Shipp, Jacobia Bates, Phillip Norton, and Brooke A. Hollowoa (Director of Communications). Nine staff. This is the wiki's first documentation of the APERS senior-staff structure surrounding the IFSC and Israel Bonds proposal. ### The 5/16/2025 Wickline article Email 12 (Brooke A. Hollowoa to Amy Fecher, 5/16/2025 2:11 PM) attaches the published Mike Wickline Arkansas Democrat-Gazette article "APERS panel authorizes investment of up to $50 million in Israel bonds" with cover note "How is this?" — the article was on the wire 19 hours after the IFSC meeting closed. Hollowoa is APERS Director of Communications. Wickline's article is the wiki's first verbatim published-press account of the IFSC meeting. The article quotes Borromeo as the source for system size ("The public employees retirement system's investments are valued at about $11.92 billion") and quotes Brady for the substantive remarks: the Mike Huckabee connection ("Brady said the U.S. ambassador to Israel is former Arkansas Gov. Mike Huckabee, who Brady once worked for as an aide. Huckabee is the father of Arkansas Gov. Sarah Huckabee Sanders"), the credit rating claim ("The state of Israel's current bond rating is A by S&P as well as by Fitch and that is a low risk for a bond, Brady said"), the regional-context framing ("Israel is considered the United States' most trusted and dependable ally in a region of the world that is volatile at best, considering Hamas, and the Gaza Strip, Iran, Iraq, Syria, and Hezbollah, and Libya and Lebanon"), the disclosure of his own prior service to Milligan in the Treasurer's office, and the disclosure of the State Treasurer's $55M Israel Bonds total ($35M legacy plus $20M post-4/15 purchase). The article also quotes Hudson saying "there is a greater emphasis on infrastructure in the United States" and quotes Brady saying "it seems the time is ripe now." ### The 12/10/2024 Mryyan FOIA Emails 31-32 capture the Badria Mryyan 12/10/2024 FOIA submission and APERS's response. Mryyan filed a request for "Any records since August 1, 2017 that reference the Arkansas Public Employees Retirement System's investments with the Development Corporation for Israel." Gilson initially declined the request 10:28 AM citing McBurney v. Young 133 S.Ct. 1709 (2013) Arkansas-citizenship requirement. Mryyan provided proof of voter registration at 612 Baywood Dr., Little Rock, AR 72211 at 10:36 AM. Gilson forwarded to Borromeo at 10:39 AM with the McBurney exemption note: "We have to respond to his request unless it fits an exemption in FOIA. Please let me know. I can usually ask and receive an extension from the requester to accommodate your extra burden of assembling the information." Borromeo responded substantively at 11:30 AM with the "zero investments since August 01, 2017" finding. Mryyan's 12/5/2024 ATRS FOIA (already in the wiki via the ATRS R1 batch, surfacing the SSgA CMX6 indirect exposure) and her 12/10/2024 APERS FOIA together establish her as the citizen FOIA requester whose work documented the structural baseline of zero direct Israel Bonds exposure across both pension systems before the 2025 authorization actions. ### DCI promotional pipeline confirmation Emails 29-30 capture the same 2/11/2025 Tyler Lee "On behalf of Stuart Garawitz: Israel Bonds' State of Israel Economic Summary" promotional email already documented in the [[dci-promotional-pipeline]] reaching the Auditor's office. Now confirmed in APERS-custodian distribution to Borromeo. Same content (the State of Israel Economic Overview February 2025 PowerPoint) attached to both. The "Dear Friends" salutation with mailmerge-style mass distribution reached APERS as well. Cross-confirms that the DCI promotional pipeline reached not just the Auditor's office but also the APERS CIO directly. ### Documents referenced in this chunk but not present (priority follow-up FOIA targets) - The May 15-31 2025 Institutional Rates sheet PDF (the May 15 attachment to Email 15) — extractable from the production but not separately analyzed in this chunk. - The "APPROVED PPT 2.6.25 JH.pdf" attached to Berman's 4/17 thank-you to Fecher (Email 26) — the standard DCI State of Israel Economic Overview PowerPoint with unexplained "JH" suffix in the filename. - Stephens Capital Management's substantive analysis on Israel Bonds, if any was produced after the 5/14/2025 12:24 PM Borromeo "fixed income eyes" request — the production ends with Brister's "Do we need to discuss?" reply. - The IFSC meeting minutes for 5/15/2025 — not in the production. - Any APERS Board ratification action on the IFSC's Israel Bonds authorization (the authorization was at the IFSC level; whether the full APERS Board took separate action is to be tested in Chunk 3 with the June 11 APERS Board Packet review). - Any APERS purchase records, settlement confirmations, or wire transfers establishing whether the $25-50M Israel Bonds authorization resulted in actual bond purchases (Fecher told Rollans on 5/19/2025 that "We have not completed any bond purchases as of today but intend to do so" — to be tested in subsequent chunks). - Any earlier (pre-5/8/2025) Borromeo correspondence with Brady or Milligan about Israel Bonds — the IFSC agenda framing suggests Brady's IFSC presentation was scheduled in advance but the operational coordination around scheduling Brady on the agenda is not in the production. - The MAY 25 PDF E16-E23 are eight identical-content distributions of the same IFSC packet to different recipients (likely the six IFSC members plus two staff cc copies); the recipient pattern is not separately documented in the production. ## Chunk 2: JUL 25 FOIA-process correspondence, post-vote reporter inquiries, board packets, Callan reports, and residual attachments (3,366 pages) Chunk 2 covers the entire JUL 25 PDF (3,366 pages, 86 emails). The chunk addresses: (a) the FOIA-process emails (E1-E11, E19-E26, E39-E50, E52-E58, E82-E83) that document how APERS handled Joshua Dunlap's 7/1/2025 FOIA request, Jennifer Lenow's 5/28 and 6/30 FOIA requests, and Mike Wickline's reporter inquiries; (b) the post-vote reporter inquiries from Wickline (E36, E38) and Gar Chung at FIN Daily (E27-E30); (c) the AJRS June 12, APERS June 11, and ASPRS June 11 Board Meeting Packets (E31-E35, ~430 pages); (d) the 4Q2024 Callan Reports and Executive Summaries for APERS and AJRS (E75, 478 pages); (e) the financial reporting trail (E84-E86) covering the FY2024 ACFR Note 3 Investments draft, the Update to Financial Section Note 3, and the APERS Financial Review; (f) substantial residual attachments (E51 1Q2025 APERS Materials 360 pages, E62 Acadian March 2025 360 pages, E71 legislative audit reports 76 pages, E74 other state RFP/RFQ 358 pages, E77 FR2022 98 pages, E80 APERS/AJRS Proxy Voting Q4 2024 122 pages, E81 APERS and ASPRS in PDF 184 pages, E63-E64 1Q 2025 Market Observations). JUL 25 E59-E61 (pages 1199-1405) are three additional duplicate distributions of the same May 15 IFSC packet already covered in Chunk 1 (the IFSC packet appeared 8 times in MAY 25 and 3 more times in JUL 25). The 5/15/2025 Berman rate sheet (E55) and the Borromeo-Stephens "fixed income eyes" thread (E48-E58) are also re-captures of the same content. The MAY 25 PDF is therefore the substantive subset; the JUL 25 PDF adds breadth (more attachment types) and adds the post-vote and FOIA-process record absent from MAY 25. ### The FOIA negotiation chain (E1-E11): Joshua Dunlap's 7/1/2025 request triggered the JUL 25 production On 7/1/2025 1:36 PM Joshua Dunlap ([email protected], 920 W 41st Street North Little Rock, Arkansas 72118) submitted a five-category FOIA request to Laura Gilson covering: (1) all internal/external correspondence among APERS Board Trustees, executive staff, and investment officers regarding Israel sovereign bonds; (2) Investment Committee & Board Records (agendas, minutes, presentation materials); (3) Analytical & Due Diligence Documents (reports, memoranda, due diligence analyses, risk assessments, financial projections); (4) External Communications with the Auditor's office (Milligan, Brady), DCI/Israel Bonds (Berman, Young), and Aon Hewitt Investment Consulting; (5) Governing Policies (current Investment Policy Statement plus all ESG/SRI policies). Timeframe: October 1, 2024 to date of processing. Gilson forwarded to Phillip Norton (APERS IT Director) the same day at 1:56 PM: "Phillip: Can you contact DIS for the fulfillment or can we pull this together in house? If you have questions, give me a call, thanks." Norton's 7/2/2025 4:24 PM staff coordination email proposed: rerun the previous DIS-side email search from May, with mailbox scope limited to Fecher, Borromeo, Golleher and search strings "Israel Bonds" and "Israel Bond" — the same parameters as the prior production for Wickline. Fecher concurred 4:29 PM: "If we are confident we can catch it all, I'm fine with using the previous DIS search and then scanning internally for communication after the date of the last search." Borromeo: "I defer to Amy" (4:26 PM) and "Phillip let's discuss pls / Call me on TEAMs or cell pls" (4:37 PM). Norton wrote 4:35 PM: "Carlos – I think you pulled some emails the other day in response to a different request – do you want to send me those so I can append them to the previous search results?" — referencing Borromeo's 5/28/2025 forward of the Stephens "fixed income eyes" thread to Gilson. The production was therefore assembled by combining the prior PST search with Borromeo's hand-pulled additions. The JUL 25 PDF is the resulting production. The wiki's documentary record of how the APERS R1 7-7-25 PDF was assembled is itself in the production — meta-documentation of the FOIA process that produced it. ### Norton's IT Director role and the May 2025 PST production for Wickline Email 39 captures Phillip Norton's 6/2/2025 7:37 AM message that established the prior production. Norton wrote: "The FOI response can be found at the following location. 'J:\Legal\FOIA\Israel Bonds\IB FOI May 2025.pst' It will need to be opened in an Outlook client. ... Let me know if you have any problems opening the file. It contains about 50 items, and only one person can open it at a time, so I recommend having a single person review it. ... Once we finish the review, I can generate a PDF that we can send to the requestor." The PST search parameters: mailboxes Fecher, Borromeo, Golleher; date October 1, 2024 to present; search strings "Israel Bonds"/"Israel Bond". Norton's signature: "Phillip Norton / IT Director / 124 W. Capitol Ave, Suite 400 Little Rock, AR 72201 / 501-683-0995". Gilson reviewed for redactions on 6/2/2025 12:36 PM and approved without changes: "Amy: I've reviewed and there are no redactions necessary. It is good to send. Laura". Borromeo, Golleher, and others struggled with the PST file ("file is in use"; only one reviewer could open it at a time). On 6/3/2025 1:56 PM Norton produced the PDF: "I have created a PDF with all the contents of this PST included. Please review and let me know if you want me to send it to Mr. Wickline. 'J:\Legal\FOIA\Israel Bonds\IB_FOIA_Reviewed.pdf'". The MAY 25 PDF is therefore identifiable as the artifact produced for Mike Wickline in early June 2025. Borromeo's 6/3 2:25 PM review note: "I reviewed also. He will have the CIO report memorized." — referring to Wickline as the recipient. ### APERS will purchase Israel Bonds DIRECTLY (no investment manager) Wickline emailed Fecher on 6/6/2025 9:37 AM with two questions: (1) "is APERS directly purchasing Israel bonds or using an investment manager to purchase the bonds and if it's the latter which investment manager is being used to purchase the bonds?" and (2) "when does APERS expect to purchase the bonds and when will it know how much it plans to purchase?" Wickline added a parenthetical: "during the debate at teachers, the first question came up and Jason Brady said he wasn't sure so." The note documents that during the 6/2/2025 ATRS Board debate on Resolution 2025-22, when asked about manager structure, Brady responded that he was not sure — yet Resolution 2025-22 explicitly named "Scout Investments / Reams Asset Management." Borromeo replied 6/6/2025 11:07 AM through Fecher: "#1, APERS intent is to purchase the bonds directly. Staff opinion is that there is not a need to incur management fees. #2, Staff anticipates the timing to be after the board meeting. The subcommittee authorized a range of $25 to $50. For duration and diversification purposes, as well as prudent risk management, I suspect the investments will be done over time, and not in a single transaction." Fecher's 6/9/2025 11:48 AM response to Wickline used the more polished version: "APERS intent is to purchase the bonds directly. With APERS Chief Investment Officer's experience in fixed income and credit markets, there is no need to incur management fees on this purchase. ... For duration and diversification purposes, as well as prudent risk management, I suspect the investments will be done over time, and not in a single transaction." The APERS approach therefore differs structurally from the ATRS approach: APERS will purchase directly through Borromeo as CIO; ATRS authorized through Reams Asset Management with a 3 bps fee (per the Matt Waz 5/28/2025 Reams analysis to PJ Kelly already in the wiki). Borromeo's "no need to incur management fees" justification substitutes his personal CIO experience for an external manager's analytical infrastructure. ### "The Board has left the decision to the Investment staff." On 6/30/2025 1:35 PM Borromeo wrote to Gilson on the Lenow follow-up FOIA: "Laura and Amy / I just had a video teams call regarding the Israel bond purchase. As of this email, no bonds have been purchased. The APERS investment team, custodian, and consultant met to discuss the back office details. Accounting, delivery, maturity, coupon payments, etc. Before any investment is made, the back office structure has to be planned out. Yes there have been back and forth emails regarding scheduling today's TEAMs call. Yes there have been verbal discussions. **I do not expect to see any contract negotiations. This is something the Board specifically has told the investment team to execute. The Board has left the decision to the Investment staff.** If you did a search, the only emails you would find would be regarding setting up a date/time for today's call." Borromeo's representation establishes that the IFSC's 5/15/2025 authorization functioned as an open-ended delegation to staff. The APERS Board did not subsequently deliberate on Israel Bonds at the 6/11/2025 Board meeting except to ratify the IFSC's minutes via the consent agenda. Execution discretion sits with Borromeo as CIO. As of 6/30/2025 no bonds had been purchased; as of 7/2/2025 the production captures sample-statement coordination with BNY (custodian) and DCI (Bill Mulvey, VP Operations) on operational mechanics. ### The State Treasurer's $55M Israel Bonds breakdown by Treasurer era (BNY sample statement) Email 11 attaches a BNY sample statement dated 5/5/2025 for "ARKANSAS STATE TREASURER" (Holder Account Number C0018477645) provided by Bill Mulvey (DCI VP Operations) showing the State Treasurer's office Israel Bonds positions. The statement breaks down the previously-reported $55M total position into seven CUSIP-level holdings: - **Milligan Treasurer-era purchases ($25M total)**: - $10M, 11TH JUBILEE FIX 10Y 2.83% maturity 2030/01/01, purchased 15 Jan 2020, CUSIP 46513JHA2 - $5M, 8TH INSTITUTIONAL JUBILEE FIX 5Y 1.35% maturity 2026/02/01, purchased 01 Feb 2021, CUSIP 46514TZG6 - $5M, 12TH JUBILEE FIX 5Y 1.92% maturity 2026/10/01, purchased 15 Oct 2021, CUSIP 46514TQN1 - $5M, 10TH INSTITUTIONAL JUBILEE FIX 5Y 2.07% maturity 2026/10/01, purchased 15 Oct 2021, CUSIP 46514TZZ4 - **Walther Treasurer-era purchase ($10M)**: - $10M, 11TH INSTITUTIONAL JUBILEE FIX 3Y 5.40% maturity 2026/11/01, purchased 01 Nov 2023, CUSIP 46514AM22 - **Thurston Treasurer-era purchases ($20M total, post-4/15/2025 Capitol meeting)**: - $10M, 12TH INSTITUTIONAL JUBILEE FIX 3Y 4.66% maturity 2028/05/01, purchased 01 May 2025, CUSIP 46514X2P3 - $10M, 12TH INSTITUTIONAL JUBILEE FIX 5Y 5.17% maturity 2030/05/01, purchased 01 May 2025, CUSIP 46514X3P2 Total: $55,000,000. The breakdown matches Brady's 5/15/2025 IFSC statement to the dollar. Coupon-rate progression (1.35% to 5.40% across the four years) reflects rising sovereign yields. Most positions are 3-5 year maturities; one is the 10-year Milligan-era purchase that matures January 2030. ### The 6/30/2025 Bill Mulvey/Brian Shea/Borromeo Teams call Emails 8-11 document the sample-statement coordination call. Bill Mulvey (DCI VP Operations) sent the BNY sample statement on 6/30/2025 1:31 PM to Christopher Igo (BNY) and Borromeo plus Usha Doolabh, with Lawrence Berman, Bradley Young, and Brian Shea cc'd. Brian Shea (BNY Asset Services Service Director, Boston, [email protected], 617-382-2505) followed up 7/2/2025 9:43 AM with operational follow-up questions: "Do you provide term sheets for the new issues? They advised the examples that you provided were market cusips that we currently have set-up. They want to be able to use the market cusips where possible. They also wanted to confirm that page 3 was the current holdings for the client and that shares would be the same as the cash value as the statement only shows cash." The exchange documents the operational integration between DCI institutional sales (Mulvey, Berman, Young), the BNY custodian relationship that holds Treasurer's-office Israel Bonds (Christopher Igo, Brian Shea), and the APERS investment team (Borromeo, Doolabh) preparing for APERS's first Israel Bonds purchase. BNY appears as the planned custodian for APERS Israel Bonds (consistent with BNY/Mellon being APERS's existing custodian per the Q4 2024 proxy reports email at E80). ### Lenow's 5/28/2025 APERS FOIA — initial Gilson response declared no other documents On 5/28/2025 10:59 AM Jennifer Lenow ([email protected], 126 Dennison St. Little Rock, AR, 72205) submitted an APERS FOIA: "Any correspondences, records, memos, agreements, presentations, or any other documents that reference any current or future investments of the Arkansas Public Employees Retirement System in the Development Corporation for Israel or Israel Bonds." Gilson forwarded to Borromeo at 11:04 AM same day asking "Let me know how to answer the question. As I understand it, the board authorized the purchase of Israel Bonds, but are there 'correspondences, records, memos, agreements, presentations, or any other documents that reference any current or future investments of the Arkansas Public Employees Retirement System in the Development Corporation for Israel or Israel Bonds' beyond the board agenda?" Borromeo replied 11:15 AM: "We can discuss, but, to answer your question, for myself, I do not have anything else." This representation by Borromeo is contradicted by the 5/14/2025 Borromeo-Stephens thread, the 5/15/2025 Berman rate sheet exchange, and Berman's 4/17/2025 Fecher thank-you with the $20M Thurston purchase reference — all materials the production now captures. Gilson responded to Lenow 5/28/2025 1:59 PM: "I've attached the board agenda for the topic you seek below. APERS does not have any other correspondences, records, memos, agreements, presentations, or any other documents that reference any current or future investments of the Arkansas Public Employees Retirement System in the Development Corporation for Israel or Israel Bonds that are responsive to your FOIA request." Gilson sent only the 5/15 IFSC agenda. Borromeo's same-day 2:52 PM forward of the "Stephes" thread to Gilson and Fecher labeled "Laura here is an email string that I sent to Stephes re: Israel bonds" is the moment Borromeo flagged additional responsive materials to counsel — three hours after Gilson had told Lenow no other documents existed. The wiki documentary record now includes evidence that APERS's initial FOIA response to Lenow did not surface materials that were known to exist. Whether the additional materials were subsequently produced to Lenow before her 6/30/2025 follow-up FOIA is not knowable from the production alone. ### Lenow's 6/30/2025 follow-up and 7/2/2025 substantive press inquiry On 6/30/2025 8:46 AM Lenow filed a follow-up FOIA: "I wanted to see if there have been any new records or communications related to the purchase of Israel Bonds, either directly or indirectly through an investment manager since my last FOIA request on May 28. I basically want to know whether there has been any discussion, contract negotiations, or decisions made about how APERS will actualize the decision of the board to purchase $25-50 million in Israel Bonds." Borromeo's 1:35 PM response is the "Board has left the decision to the Investment staff" passage already noted. On 7/2/2025 8:45 AM Lenow filed a substantive press inquiry to Gilson, identifying herself as "reporting on a story for the Arkansas Times about the state's recent investment decisions related to Israel bonds." The questions: "According to the APERS investment policy, 'As fiduciaries, trustees have a legal responsibility to act solely in the best interests of the members, retirees, and beneficiaries of the system. This responsibility requires trustees to act with care, skill, and prudence in managing the assets of the system.' The decision to purchase Israel bonds was made at the recommendation of Jason Brady, on behalf of Auditor Milligan. In Brady's rationale for the recommendation he mentioned his former boss, Mike Huckabee, who now serves as the U.S. Ambassador to Israel, as well as the geopolitical importance of Israel for U.S. foreign policy. Auditor Milligan has made public comments about Israel suggesting that his motivation for supporting Israel bonds goes well beyond pecuniary factors. Do these statements mean the board has considered non-pecuniary factors when making investments of APERS funds into Israel bonds? Furthermore, non-U.S. governmental bonds are not listed as a permissible investment in the Arkansas state statute pertaining to public employee retirement plans. Would an investment in Israel bonds violate state statute?" Lenow's questions are sharp: (1) the Act 498 pecuniary standard applied to the Auditor-channel non-pecuniary motivations Brady disclosed at the IFSC; and (2) the statutory permissibility of foreign sovereign bonds under Arkansas pension investment law. Fecher's 12:44 PM response was a 36-word non-response: "Jennifer, We are confident that the Irael [sic] Bonds investment follows all applicable state statutes and will result in a good outcome for the members and retirees of the Arkansas Public Employees' Retirement System. Thank you for your inquiry." Fecher cc'd Daryl Bassett (APERS Board Chair) and Jim Hudson (IFSC member who amended the motion to add the $50M ceiling). The cc pattern delivered the press response to the two cabinet-secretary IFSC members who voted for the action. ### Gilson's 5/29/2025 IPS Review memo (the legal blessing) Email 47 attaches "Investments and Finance Sub-Comm Policy considerations.lmg.5.29.2025.docx" — Gilson's legal review of the Israel Bonds investment under the APERS Investment Policy Statement. The memo (1 page) concludes: "The Investment Policy Statement (IPS) Section III., regarding statutory governing authority, restates Arkansas Code § 24-2-602 that the boards of trustees of the Arkansas Public Employees Retirement System 'shall have full power to invest and reinvest the moneys of the respective systems and to hold, purchase, sell, assign, transfer, or dispose of any investments so made as well as the proceeds of the investments and moneys.' Arkansas Code §§ 24-4-105(b)(2) and (7) gives the board administrative direction and control over executive director and staff and broadly authorizes the board to do 'any and all things necessary for the proper administration of the system.' In properly administering the system under its governing authority and under its fiduciary duty found in the prudent investor rule at §§24-2-601 through 24-2-619, the board properly created the Investment Finance Subcommittee (IFS) and delegated the authority to the subcommittee to review and recommend investments for APERS. ... Lastly, under the Asset Allocation Policy in Section VI, cash and fixed income are identified in the asset classes included in the asset allocation mix for APERS investments. **Israel Bonds are classified as fixed income, an allowable asset for investment under the IPS.**" The memo is the only documented legal review of the Israel Bonds purchase by APERS counsel. It conflates the statutory grant of broad investment authority with the propriety of the specific investment. It pre-emptively dismisses the kind of statutory permissibility question Lenow would raise on 7/2/2025. The memo does not address the prudent investor rule's substantive standard (whether the investment itself is prudent given the analytical record), nor does it address Act 498's pecuniary standard, nor the absence of independent credit analysis. ### The 6/11/2025 APERS Board ratified the IFSC's Israel Bonds action via the consent agenda The 6/11/2025 APERS Quarterly Board Meeting packet (E32, 90 pages) contains the agenda, the 3/12/2025 Board Meeting minutes, and the 5/15/2025 IFSC minutes. Item 4 of the 6/11 agenda is "Action Item: Approval of the Minutes for the March 12, 2025, Board Meeting (Page 3) and May 15, 2025, Investment Finance Subcommittee (Page 8)." The IFSC minutes (packet pages 8-11 = FOIA pages 430-433) document the 5/15 meeting in full including the Israel Bonds discussion and motion. The IFSC Chair Report (packet page 70 = FOIA page 491-492) summarizes for the Board: "Israel Bonds Investment / At the request of Board Member Jason Brady, the Board considered investment in Israel Bonds, citing low risk, solid returns, and current holdings by the State Treasurer's Office. The Board approved an investment of $25–50 million in Israel Bonds." Approval of the consent-agenda minutes by the full Board on 6/11/2025 constitutes the Board's ratification of the IFSC's authorization. There is no separate Board-level Israel Bonds resolution. This procedural pathway differs materially from ATRS where Resolution 2025-22 was a separate Board action requiring an explicit roll-call vote. ### IFSC May 15 minutes — additional roster, attendees, and parallel action items The 5/15 IFSC minutes (FOIA pp 430-433) document attendees beyond what the agenda surfaced: - **IFSC Members Present**: Walther (Chair), Jim Hudson (DFA), Jason Brady (State Auditor's Office, **proxy** for Milligan), Gary Wallace (Retired Law Enforcement), Gary Carnahan (Non-State Employee, Hot Springs AR). Bassett absent. Five of six members present. - **APERS Staff Present**: Fecher (Executive Director), Allison Woods (Deputy Director of Benefits), Carlos Borromeo (Deputy Director of Investments & Finance), Jacobia Bates (Director of Public Affairs), Laura Gilson (General Counsel), Ashley Golleher (Deputy Director of Operations), Patty Shipp (Assurance Officer), Richmond Giles (Legal Staff), Usha Doolabh (Investments Accounting Operations Manager, remote), Julianna Alamina (Investment Analyst, remote), Daryl Bussell (Information Systems Coordinator). - **Visitors Present**: **Mr. Mark White, Arkansas Teacher Retirement System** (the first documented cross-system Executive Director attendance at an APERS meeting). Plus Melissa Cahill and Bill Cole (HarbourVest), Gabe Feghali and Will Proctor (Neuberger Berman), and presumably Larry Middleton, Bo Brister, Seth Middleton (Stephens) per the agenda. The IFSC Chair Report records additional 5/15 IFSC actions beyond the Israel Bonds and three infrastructure-secondaries authorizations: **"Investment Advisor Services / Secretary Jim Hudson requested a plan for competitively bidding out investment advisor services. Director Fecher committed to presenting a timeline and methodology to the subcommittee."** The same Hudson who amended the Israel Bonds motion to add the $50M ceiling also pushed for a competitive RFP/RFQ process for investment advisor services (Callan's contract). The procedural intervention establishes Hudson as proceduralist on advisor procurement but votes-yes on Israel Bonds adoption that bypasses any competitive procurement process. ### APERS Board roster (March 12, 2025 meeting attendance) The 3/12/2025 APERS Board Meeting minutes (FOIA pp 425-onwards) document the Board roster: - **Secretary Daryl Bassett (State Employee, ADLL Secretary), CHAIR, Sherwood, AR** (the APERS Board Chair is Bassett; new finding) - The Honorable John Thurston (Treasurer of State), Little Rock, AR - Mr. Larry Walther (State Employee, Retiree), Little Rock, AR (Walther is also IFSC Chair) - Mr. Alan McVey (DFA proxy) - The Honorable Barry Moehring (Non-State Employee, County Judge), Bentonville, AR - Mr. Richard Wilson (Retired), Little Rock, AR (remote) - Mr. Gary Carnahan (Non-State Employee), Hot Springs, AR - The Honorable Joe Hurst (Non-State Employee, Mayor), Van Buren, AR (remote) - Mr. Gary Wallace (Retired Law Enforcement), Greenbrier, AR - Mr. Russell White (Retired Law Enforcement), Alma, AR - Mr. Jason Brady (State Auditor's Office) **proxy** for Milligan - Ms. Kaye Donham (Retired), Benton, AR (remote) 12 trustees documented. The 6/11/2025 Board distribution adds Dale Douthit and Phillip Milligan (likely the Arkansas State Police Director and Dennis Milligan's brother, on the ASPRS distribution but also evidently on the APERS Board via the cabinet-officer mechanism). The Board Chair is Bassett (DLL Secretary), who is also an IFSC member but was absent from the 5/15 IFSC meeting. ### Cross-system: the ASPRS June 11 and AJRS June 12 Board packets contain no Israel Bonds discussion The ASPRS June 11 Board Meeting Packet (E34, 71 pages) and AJRS June 12 Board Meeting Packet (E33/E31, 89 pages each) do not contain any Israel Bonds discussion item. Israel appears only as country-attribution data in the international equity portfolio analysis. ASPRS Board Members per 3/13/2025 minutes: Captain Kyle Drown (Chair, ASP Tier I), Captain Scott Joe (Vice Chair, ASP Tier II), Andy Babbitt (DFA), Denise Bugos (Citizen at Large), John Allison (ASP Commissioner, absent), Donnie Underwood (Citizen at Large, absent). AJRS Board Members per 3/13/2025 minutes: Hon. Herbert Wright (Circuit Judge, Chair, North Little Rock), Hon. Raymond Abramson (AR Court of Appeals, Holly Grove), Hon. Marcia Hearnsberger (Circuit Judge, Hot Springs), Hon. John Scott (Circuit Judge, Bentonville), Hon. Earnest Brown Jr. (Circuit Judge, Pine Bluff). The ASPRS 3/13 minutes confirm: "ASPERS portfolio fell 1.23% for the quarter but remains up 3.84% for Fiscal Year 2025 and 9.93% for calendar year 2024. APERS funds are co-invested with APERS." ASPRS trust fund $445.161M; AJRS trust fund $349.2M. Both systems are co-invested with APERS via the unified investment infrastructure under Borromeo. No separate Israel Bonds authorizing action by either system; the Israel Bonds purchase will flow proportionally via the commingled-funds mechanism per the 12/10/2024 Borromeo "APERS/ASPRS/AJRS" baseline reply. ### The Callan Reports (E75, 478 pages) confirm Callan-Israel-Bonds-analytical absence The 4Q2024 Callan Reports for APERS and AJRS (transmitted by Brianne Weymouth, Callan Senior VP, on 2/12/2025 via Email 75) totaling 478 pages contain ZERO Israel Bonds analysis. Israel appears only as country-attribution data in the international equity portfolio analysis (Mellon ACWI ex US Fund, Baillie Gifford Overseas, Lazard Asset Management, Acadian ACW ex US SmallCap, Franklin Templeton Intl SmallCap). Eleven Israel hits across 478 pages, all in MSCI ACWI ex-US country-allocation tables. No Israel sovereign credit analysis, no Israel Bonds investment recommendation, no Israel sovereign yield comparison. The chunk 1 finding that the IFSC packet contained zero Callan Israel Bonds analysis is therefore extended: across Callan's entire 4Q2024 quarterly reporting cycle for APERS, there is no Israel Bonds analysis. Sharpens [[callan-analysis-asymmetry]] from packet-level absence to full-Callan-work-product absence. The Callan team for APERS: Brianne R. Weymouth, CAIA (Senior VP, Fund Sponsor Consulting, [email protected], 312-346-3536, Chicago office at 120 North La Salle Street Suite 2400); John P. Jackson, CFA (Senior VP); Jack Malone, CFA (cc on transmissions). Weymouth and Jackson are the named Callan presenters at all APERS, AJRS, and ASPRS Board meetings in the documented period. Weymouth's 5/23/2025 transmission of 1Q2025 APERS materials (Email 51, 360 pages) shows the same scope — no Israel Bonds analytical material. Weymouth's email tone with Borromeo is casually friendly: "Let me know if you want to get together for lunch or dinner. Also, I think I'm finally back in shape enough to attend a workout class so let me know if you are accepting visitors on Tuesday night." ### Borromeo's RFP/RFQ research collection — procedural awareness without procedural use Email 74 (Borromeo to Jason Clark, Lead Portfolio Manager at PERS of Mississippi, 2/19/2025 9:36 AM) attaches Borromeo's collection of investment-consulting-services RFP/RFQ samples from other state pension systems (Mo LAGERS 2022, Ohio State Teachers Nov 2022, Oklahoma PERS 2022, plus an "ARTRS Sample DDQ.docx" from Arkansas Teacher Retirement). Cover note: "Jason here are the other state RFP/RFQ that I gathered when I was writing my RFQ." Borromeo had previously written an APERS investment-consulting-services RFQ. The procedural infrastructure for competitive procurement of investment-related services exists at APERS and Borromeo authored it. The same procedural infrastructure was not invoked for the Israel Bonds investment authorization itself. Hudson's 5/15/2025 IFSC request for "a plan for competitively bidding out investment advisor services" is consistent with APERS's existing RFP/RFQ infrastructure but is a request for the Callan contract specifically, not for the Israel Bonds purchase. ### The HarbourVest post-IFSC manager-introduction request — Borromeo's procedural caution Emails 27 and 30 capture Melissa Cahill (HarbourVest Managing Director, [email protected]) following up with Borromeo on 6/9/2025 after the FIN Daily Alert reported ATRS's Israel Bonds approval with the 5/15 IFSC meeting also covered. Cahill: "I see AR Teachers is considering PC now. You are a trailblazer. Mr. Brady seemed very positive on our credit secondaries presentation. I wonder if there is someone I know that would connect me with him..." Borromeo replied 12:26 PM: "Connect you with who? Mr. Brady or AR Teachers?" Cahill clarified she wanted Brady. Borromeo's 12:06 PM response: "I would not do that / Perhaps you should meet with Jerry over there." Borromeo declined to broker a HarbourVest-Brady introduction at ATRS. The procedural caution mirrors Borromeo's 2/12/2025 reply to Berman declining to provide letter-of-introduction to APERS fixed-income managers. Borromeo systematically refuses to broker manager introductions across pension systems — including for the post-IFSC HarbourVest follow-up. ### APERS pre-existing indirect Israel exposure — Israeli Shekel $7.79M The FY2024 ACFR Note 3 (Email 85 attachment, packet pages 20-34 = FOIA pages 3320-3334) documents APERS's foreign currency risk exposure as of June 30, 2024. The Foreign Currency Risk table shows International equity exposure includes Israeli Shekel $7,790,478 (0.62% of total $1,247,334,457 foreign currency exposure). This is APERS's pre-existing indirect Israel exposure via international equity managers, parallel to but smaller than ATRS's ~$1M Israel sovereign exposure via SSgA CMX6 documented at [[atrs-pre-existing-indirect-exposure]]. The Israeli Shekel exposure is via international equity (companies headquartered in Israel) rather than sovereign bonds. Both pension systems had documentary indirect Israel exposure before any direct Israel Bonds authorization. ### The 12/5/2024 Doolabh "China exposure" report — APERS can produce CUSIP-level holdings on demand Email 84 (12/5/2024 7:33 AM) is Usha Doolabh (APERS Investments Accounting Operations Manager) to Borromeo with "Asset and accrual apers 12 04 2024.xls" attached. Doolabh: "Carlos, I was only able to run the asset and accrual report for previous day, so 12/4/2024, it did not seem to give me anything for 11/29. Attached is what I was able to pull and sort to show China with base market value total, hoping it is accurate." The attached spreadsheet (3 pages of FOIA-extracted CUSIP-level holdings from a much larger underlying file) demonstrates APERS can produce CUSIP-level holdings reports with country attribution on demand for FOIA or internal review purposes. The infrastructure for granular Israel-Bonds-level analytical work exists; it was not deployed for the Israel Bonds investment decision. ### APERS senior staff structure documented (from board packets) The 5/15 IFSC minutes plus 3/12/2025 Board minutes plus 6/11/2025 Board distribution list together establish the APERS senior staff: - Amy Fecher — Executive Director (501-682-7854) - Carlos Borromeo — Deputy Director Investments & Finance / CIO (501-682-7864) - Ashley Golleher — Deputy Director of Operations (501-682-7831) - Allison Woods — Deputy Director of Benefits - Jason S. Willett — Chief Financial Officer (501-683-5888) - Laura Gilson — General Counsel (501-682-7853) - Phillip Norton — IT Director (501-683-0995) - Jacobia Bates — Director of Public Affairs - Brooke A. Hollowoa — Director of Communications (501-682-5435) - Patty Shipp — Assurance Officer - Richmond Giles — Staff Attorney / Legal Staff - Jon Aucoin — Digital Services Manager (501-683-6046) - Usha Doolabh — Investments Accounting Operations Manager / APERS Investments Manager (501-682-7812) - Julianna Alamina — Investment Analyst - Daryl Bussell — Information Systems Coordinator - Meredith Kittler — Digital Services / Financial Reporting - Cheryl Wilburn — Benefits Operations Manager - Kristi Brown — Member Services Supervisor / Retirement Coordinator - Shelly George — Retirement Section Manager Plus external-office staff with APERS distribution access: Sandra Blount ([email protected], Treasury staff), Andy Babbitt (DFA, [email protected]), Tricia Hogue (Benton County Judge office), John Copple ([email protected]). ### Documents referenced in this chunk but not present (priority follow-up FOIA targets) - The 6/11/2025 APERS Board Meeting minutes (the meeting itself happened the day after the packet; minutes would be ratified at the September 2025 Board meeting and not yet produced). - The 6/11/2025 ASPRS Board Meeting minutes and 6/12/2025 AJRS Board Meeting minutes (same status). - Any APERS direct purchase records, settlement confirmations, or wire transfers for the Israel Bonds positions — the latest documentation in the production is the 6/30/2025 BNY/Mulvey/Borromeo Teams call planning back-office structure; no documented purchases occurred before 7/2/2025. - Any Lenow follow-up after Fecher's 7/2/2025 12:44 PM 36-word press response — would be in the Arkansas Times article when published, not in the production. - The PGIM and International Farming agriculture / farmland funds Borromeo references on 5/19/2025 (Email 52) — APERS as the largest land holder for an Ag Farm Land group. - The 4Q2024 Callan reports for AJRS specifically (the AJRS 4Q24 Executive Summary, 4Q2024 AJRS Board Report, 4Q2024 AJRS Staff Report attached to Email 75 are partially captured in the production but not reviewed in depth for this ingest — they would mirror the APERS reports in not containing Israel Bonds analysis). - The "ARTRS Sample DDQ.docx" Borromeo attached to his 2/19/2025 RFP/RFQ collection email to Jason Clark at PERS of Mississippi — this is the ATRS due diligence questionnaire template, an artifact of cross-system staff collaboration. ## Cross-References [[carlos-borromeo]] [[amy-fecher]] [[laura-gilson]] [[ashley-golleher]] [[brooke-hollowoa]] [[larry-walther]] [[bo-brister]] APERS principals [[stephens-capital-management]] [[callan]] external service providers [[jason-brady]] [[jim-hudson]] [[daryl-bassett]] IFSC members from outside APERS staff [[lawrence-berman]] [[brad-young]] [[stuart-garawitz]] DCI representatives [[john-rollans]] [[badria-mryyan]] [[mike-wickline]] external requesters and reporters [[apers-israel-bonds-authorization]] the 5/15/2025 IFSC action [[callan-analysis-asymmetry]] the consultant-analytical-asymmetry concept [[independent-credit-analysis-gap]] [[westrock-procedural-asymmetry]] [[auditor-as-dci-channel]] [[dci-promotional-pipeline]] [[auditor-multi-official-capitol-tour]] cross-system concept threads