# Arkansas Securities Department FOIA Response 4-20-26 (DCI broker-dealer FOIA) The Arkansas Securities Department produced 155 PDFs totaling approximately 310 megabytes on April 20, 2026 in response to Joshua Dunlap's FOIA request on Development Corporation for Israel (CRD #11148). The production was transmitted via OneDrive by Amber E. Crouch, Attorney III at the Arkansas Securities Department. The on-disk archive at `raw/securities/FOIA Response 4-20-26/` totals 312 files (155 PDFs plus 155 corresponding extracted-text files at `_extracted_text/`, plus the production INDEX.md and the original OneDrive_2026-04-27.zip archive). The production is essentially a Web CRD records dump — DCI's registration status, filings history, ownership structure, disclosure events, custody arrangements, and registered agents — pulled from the FINRA Central Registration Depository system by the AR Securities Department in response to the Dunlap FOIA. The production is the wiki's tenth source-page ingest and the first source page covering the Arkansas Securities Department as the producing agency. The producing-agency profile is structurally distinct from the prior nine productions: the Securities Department is not a pension system, not a state financial officer, and not in the Israel Bonds purchaser chain; it is the state-level securities regulator with broker-dealer registration authority over the DCI counterparty entity. ## Production characteristics The 155 PDFs are organized by the AR Securities Department under the renaming convention `ASD-NNN_<Original-Name>.pdf` where NNN is a sequential file number (001-155) and the original filename is preserved with hyphenation. The INDEX.md at the top level of the production maps each renamed file to its original filename. Each PDF has a corresponding `.txt` mirror in the `_extracted_text/` subdirectory, produced by the ingest preparation process for fast text reads. The 155 files cluster by Web CRD report type: - **ASD-001 through ASD-007**: registration acknowledgement (1987), pre-FOIA financials (2009, 2010), 2023 CRS Form mailing, Applicant Information, Form BR Branch Offices, Form CRS - **ASD-008 through ASD-012**: Current Disclosure Summary CRD reports — 4 occurrence-specific reports (118865, 118866, 1711997, 279351) plus the overall summary - **ASD-013 through ASD-022**: Custody and Clearing Arrangements (10 files, multiple subsections) - **ASD-023**: Direct Owners / Executive Officers (Redacted) - **ASD-024 through ASD-108**: Filing CRD 1 through Filing CRD 85 (85 sequential BD/BDW/BD-Amendment filings, most Redacted) - **ASD-109 through ASD-111**: Financial and Control Arrangements (3 files, subsections 9A, 9B, overall) - **ASD-112**: Form CRS - **ASD-113**: Indirect Owners - **ASD-114 through ASD-119**: Introducing Arrangements, Legacy Branch, Legal Status, Main CRD Contact Info (Redacted), Maintain Trustee Info, Mass Transfer History - **ASD-120**: Orders 86-27-S, 86-27a-S (1986) — the only file in the production from an Arkansas-state-level regulatory proceeding - **ASD-121 through ASD-128**: Organization Affiliates (7 files, subsections 10A-1 through 10A-4, 10A, 10B, overall) and Organization Form Filing History - **ASD-129 through ASD-138**: Organization Legacy (DE) Disclosure History (10 files) - **ASD-139 through ASD-145**: Organization Legacy (DI) Disclosure History (6 files) plus Organization Legacy Filing History - **ASD-146 through ASD-148**: Organization Names List, Other Business Descriptions, Other Business Names - **ASD-149 through ASD-150**: Reg Arc and Z Rec records - **ASD-151**: Registered Broker-Dealer Agents (the list of individuals registered as DCI agents in Arkansas) - **ASD-152**: Registration Status - **ASD-153**: Schedule E Branch Offices - **ASD-154**: Succession - **ASD-155**: Types of Business The production is not correspondence. There are no emails between the AR Securities Department and DCI, between the AR Securities Department and the Arkansas pension systems, between the AR Securities Department and the Auditor's office, or between the AR Securities Department and the Treasurer's office. The production is the regulator's view of DCI as a registered broker-dealer — what FINRA's Web CRD system shows when a state regulator queries CRD #11148. ## The Dunlap FOIA trigger The production responds to a Joshua Dunlap FOIA submission to the Arkansas Securities Department. The wiki has documented Dunlap as the FOIA-trigger requester for three prior productions (Auditor R3 at [[auditor-foia-r3-3-3-26]] from his 6/22/2025 submission; APERS R2 at [[apers-foia-r2-2-27-26]] from his 2/13/2026 submission; and the 7/7/2025 APERS chunked production at [[apers-foia-r1-7-7-25]] from his 7/1/2025 submission). The AR Securities Department production becomes the fourth Dunlap-triggered production captured in the wiki. The specific Dunlap-to-AR-Securities FOIA submission date and category list is not in the production itself; the Dunlap-Crouch initial correspondence is not preserved among the 155 ASD files. The wiki's [[joshua-dunlap]] entity page documents the Dunlap-as-production-trigger pattern. The 4/20/2026 production date is consistent with a 2026-Q1 FOIA submission timeline. ## The 1986 Arkansas suspension orders (ASD-120) The most analytically significant file in the production is ASD-120, the only Arkansas-state-level regulatory document. The file contains two orders from the Arkansas Securities Department against DCI dated 1986: - **Order 86-27-S** (April 7, 1986): The Arkansas Securities Commissioner Beverly Bassett ordered DCI's broker-dealer registration suspended for failure to designate a principal under AR Securities Act Section 3(e). The order's verbatim Conclusions of Law: "Failure to designate a principal as required by Section 3(e) of the Act results in an application for registration being incomplete in a material respect under Section 6(a)(2)(A). The Commissioner is empowered under Section 6(a) and Section 6(c) of the Act to summarily suspend the registration of Development Corporation For Israel due to said Broker-Dealer's failure to properly designate a principal. Suspension of the registration of Development Corporation For Israel is in the public interest." - **Order 86-27a-S** (July 22, 1986): The Commissioner vacated the suspension after DCI provided proper documentation on May 23, 1986. Reinstatement was retroactive to "the last approval date before April 7, 1986." The 1986 suspension is the wiki's first documented Arkansas-state-level regulatory action against DCI. It is procedural-compliance in nature (administrative deficiency in principal designation), not sanctions for substantive misconduct. The orders are documented in the dedicated concept page [[dci-1986-arkansas-suspension]]. The 1986 orders are NOT on DCI's FINRA Current Disclosure Summary record. The 4 disclosure occurrences documented in ASD-008 through ASD-011 (SEC 1983, NC 1984, NASD 1997-1998, control affiliate 2014) do not include the 1986 AR suspension. The procedural-compliance brief-suspension event apparently was not migrated into the Web CRD disclosure system when DCI completed BD Conversion to modern Web CRD on July 5, 1999 (per ASD-128 Organization Form Filing History). The 1986 AR action is documented only in the AR Securities Department's own files. ## The Arkansas single-issuer registration restriction (ASD-152) DCI's Arkansas broker-dealer registration is structurally limited. Per ASD-152, the Web CRD Organization Registration Status displays: > "AR Limited -BONDS FOR THE STATE OF ISRAEL 06/25/1984" > ASD-152_Registration-Status-CRD.pdf, page 1 Arkansas is one of only two US jurisdictions where DCI's broker-dealer registration is explicitly limited to State of Israel bonds. North Dakota has a parallel restriction: > "ND Limited -STATE OF ISRAEL BONDS ONLY 03/17/1970" > ASD-152_Registration-Status-CRD.pdf, page 1 Arizona is "Limited" but the restriction terms are not specified in the Web CRD status display ("AZ Limited - 01/24/1980"). All 47 other US jurisdictions show DCI as "Approved" general broker-dealer. The Arkansas restriction is documented in the dedicated concept page [[dci-arkansas-limited-registration]] alongside the related FINRA Types-of-Business code 12Q ("Broker or dealer selling securities of only one issuer or associate issuers") per ASD-155. ## The 4 FINRA Current Disclosure Summary occurrences DCI's FINRA regulatory record contains four Current Disclosure Summary occurrences, not three as the wiki's seed-list had indicated pending this production. Three are publicly disclosable substantive regulatory events: 1. **Occurrence 118865** (ASD-008): SEC 1983 currency-reporting and recordkeeping violations. Administrative Proceeding File No. 3-6308. Sanction: Censure plus undertaking to adopt procedures. No monetary fine. 2. **Occurrence 118866** (ASD-009): North Carolina 1984 registration-lapse consent order. File No. ECC84-006. Sanction: Cease and desist; rescission offers required to NC residents. 3. **Occurrence 279351** (ASD-011): NASD 1997-1998 unregistered-principal-functioning action. Case C06980016. Sanction: Censure plus $9,500 fine plus required independent supervisory-system consultant. The fourth occurrence is non-publicly-disclosable: 4. **Occurrence 1711997** (ASD-010): Filed 07/10/2014 as a BD Amendment Regulatory Action DRP. The filing identifies Stuart Neal Garawitz (CRD #861993) as the control affiliate subject. All other DRP fields (regulator, sanction, allegations, resolution, dollar amount) are blank. Publicly Disclosable: No. Reportable: Yes. The four occurrences are documented in the dedicated concept page [[dci-finra-disclosure-events]] with verbatim quotes of allegations and resolutions. The seed-list "3 FINRA events" claim is technically a public-disclosability count and is conservative in that respect; the formal occurrence count is 4. ## Direct Owners and Executive Officers (ASD-023) DCI's Direct Owners filing names 21 individuals and one corporate entity: - **Association for Development of Israel, Inc.** — Sole Shareholder (75% or more ownership), corporate entity, status acquired 03/1955. The Association is a not-for-profit membership corporation. The filing notes: "ASSOCIATION FOR DEVELOPMENT OF ISRAEL, INC., IS A NOT-FOR PROFIT MEMBERSHIP CORP. (NEW ENTITY NAME 3/2014)." The prior name was "AMERICAN SOCIETY OF RESETTLEMENT & REHABILITATION IN ISRAEL, INC." The new entity page [[association-for-development-of-israel]] documents the parent organization. The 21 named individuals (alphabetical by surname with role, effective date, and CRD#): | Name | Role | Effective | CRD # | Control/Influence | |---|---|---|---|---| | Cornick, Kenneth Lawrence | Director | 09/2024 | 2528105 | N | | Diener, Robert Benjamin | Director | 02/1998 | 3043768 | N | | Fox, William Zev | Director | 05/2014 | 212366 | N | | Garawitz, Stuart Neal | Vice President - Sales | 01/2012 | 861993 | **Y** | | Goldstein, Howard Lewis | Director / Chairman Emeritus | 05/2018 | 2235827 | N | | Grant, Adrian Mervyn | Director | 05/2014 | 6364527 | N | | Herbstman, Burton Lee | Director | 05/2014 | 6364536 | N | | Herbstman, Helene Ellen | Director | 05/2014 | 6364551 | N | | Horvath, Jordan A | CLO / CCO / FINRA Executive Rep / Asst Sec / VP-Legal | 08/2009 | 4928984 | **Y** | | Hutter, Andrew Mark | Director / Chairman of the Board | 05/2014 | 6364574 | N | | Kruger, Erik S | Financial Operations Principal / CFO | 11/2014 | 5739446 | **Y** | | Lewis, Shira Joy | Director / Treasurer | 05/2014 | 2672845 | N | | Mulvey, William James Jr | Principal Operations Officer | 05/2019 | 2760487 | N | | Naveh, Dani | President, CEO and Director | 12/2021 | 7413657 | **Y** | | Pines, Alan Jay | Director | 05/2014 | 6417612 | N | | Rothenberg, Larry Lee | Director | 02/2025 | 1079161 | N | | Rubens, Josh M | Director | 01/2023 | 7681292 | N | | Rubin, Andrew David | Director | 01/1997 | 2876452 | N | | Segal, Glenn | Director / Secretary | 05/2014 | 6364874 | N | | Stein, Laura | Director | 01/2023 | 7681994 | N | | Swig, Kent Mason | Director | 02/2004 | 4768476 | N | | Zeidman, Fred Schwartz | Director | 02/2004 | 4774789 | N | Four officers carry the Control/Influence = Y flag: Garawitz (Sales VP), Horvath (Chief Legal/Compliance Officer), Kruger (CFO), and Naveh (President/CEO). The four constitute DCI's documented operational control core. The 05/2014 cluster (Hutter, Lewis, both Herbstmans, Grant, Segal, Pines, Fox, plus Kruger 11/2014 and Mulvey 05/2019) indicates a substantial board reconstitution in May 2014, contemporaneous with the 03/2014 parent-organization name change and with the 07/10/2014 Occurrence 1711997 control-affiliate DRP filing on Garawitz. Whether the 2014 events are causally connected is not knowable from the production alone but the temporal clustering is documented. ## Arkansas-registered DCI broker-dealer agents (ASD-151) The production documents six individuals currently registered as DCI broker-dealer agents in Arkansas: | Name | CRD # | AR Reg Effective | AR Term Effective | Notes | |---|---|---|---|---| | Miron, Jacqueline Rady | 1041260 | 08/01/2019 | — | | | Berman, Lawrence Ethan | 2919738 | 01/03/2007 | 12/31/2010 | Reregistered 01/09/2015 | | Fisher, Nir Chaim | 5160790 | 03/20/2008 | — | | | Young, Bradley R | 5276306 | 03/11/2009 | — | | | Libchaber, Samuel | 7782721 | 01/02/2025 | — | | | Garawitz, Stuart Neal | 861993 | 01/19/2011 | — | | The wiki's three documented Arkansas-facing DCI principals (Berman, Young, Garawitz) are all licensed broker-dealer agents in Arkansas. Berman's registration shows a four-year termination gap (12/31/2010 to 01/09/2015); during that gap, no Berman email correspondence with Arkansas state officials is documented in the wiki's productions, which is consistent with him being unregistered to act as a broker-dealer agent in Arkansas during that period. Berman's re-registration on 01/09/2015 predates the wiki's 1/12/2018 first-documented Brady-Berman email correspondence at the Treasury Israel Bonds purchase pathway by approximately three years. Garawitz's 01/19/2011 AR registration predates his 01/2012 Direct Owners effective date as VP-Sales by approximately one year, suggesting his AR registration accompanied an earlier registered-representative role before he transitioned to a control-affiliate executive role. The three other AR-registered agents (Miron, Fisher, Libchaber) are new wiki entities documented in this production. Miron was previously referenced as "Jacqueline Miron (Registered Representative, Atlanta)" at [[development-corporation-for-israel]] from R2 Sub-batch 3 cc-distribution-level documentation; the AR-registered-agent finding adds her Arkansas registration effective date of 08/01/2019 to the wiki record. ## Custody, clearing, and operational arrangements DCI's Custody and Clearing Arrangements (ASD-013 through ASD-022) identify four organizations maintaining DCI's books and records under Item 8A: - **Computershare Inc.** (the documented fiscal agent for Arkansas Israel Bonds positions at [[development-corporation-for-israel]] and [[state-treasurer-israel-bonds-operations]]) - **Global Relay Communications Inc.** (electronic-communications archiving) - **Salesforce, Inc.** (customer relationship management) - **Own Company Inc.** (specific function not documented in the extracted text) The Computershare role is cross-confirmed by the production at the regulatory-disclosure level, corroborating the wiki's prior Treasury-side documentation of Computershare as the fiscal agent. The Global Relay finding documents that DCI uses a regulated electronic-communications archiving vendor for compliance; this is structurally consistent with the documented Berman email correspondence patterns and the registered-agent disclosure obligations under FINRA rules. DCI has no Introducing Arrangements (ASD-114 shows "no introducing arrangements found"). DCI operates as a principal broker-dealer, not as an introducing broker. DCI has no documented organizational succession (ASD-154 reports "no succession found"). DCI has no documented DBAs (ASD-146 shows a single legal entity name "DEVELOPMENT CORPORATION FOR ISRAEL" effective 12/09/1983, the FINRA registration date). ## Affiliate structure (ASD-121 through ASD-128) DCI's affiliate structure consists of: - **Association for Development of Israel, Inc.** (parent; nonprofit; sole shareholder) - **Capital for Israel, Inc.** (sister entity; NASD member; common parent ownership through the Association) - **Development Company for Israel (Holdings) Ltd.** (English/Welsh holding company) - **Development Company for Israel (International) Ltd.** (international affiliate) - **Canada-Israel Securities Ltd.** (Canadian affiliate) - **Development Company for Israel (Europe) GmbH** (European affiliate) The Indirect Owners filing (ASD-113) reports "No indirect owners were found." There is no parent bank holding company, public-company beneficial owner, or other layered ownership structure beyond the nonprofit Association. DCI is structurally a wholly-owned subsidiary of a New York nonprofit at 730 Broadway. ## Documents referenced in this batch but not present The production is a CRD records dump and is missing several categories of records a wiki investigation would want: - **The 1986 Memorandum on Independent Contractors** (Exhibit A to Order 86-27-S; referenced but not produced; the 1987 acknowledgement form at ASD-001 acknowledges receipt of a December 1, 1986 memorandum on Independent Contractors that is a separate document from the March 7, 1986 memorandum cited in the suspension order) - **The 1986 Memorandum on Section 3(e) principal designation** (March 7, 1986; cited in Order 86-27-S as the predicate notice; not produced) - **Pre-1984 Arkansas registration records** (the Web CRD shows AR effective 06/25/1984, but DCI was SEC-registered as 8-4218 from 04/25/1955 and the prior registration history with Arkansas, if any, is not produced) - **Any AR Securities Department internal communications about DCI** (memoranda, examination reports, complaint inquiries, examination notes — none are in the production) - **Any AR Securities Department correspondence with the pension systems on Israel Bonds eligibility, custody, or registration questions** (none are in the production) - **Any AR Securities Department correspondence with the State Treasurer's office on Israel Bonds purchases** (none are in the production) - **The non-public Occurrence 1711997 details** (the 2014 control-affiliate DRP for Garawitz; all substantive fields are blank in the public-CRD pull; the underlying event is not knowable from this production) - **The 85 Filing CRD documents in unredacted form** (ASD-024 through ASD-108 are mostly Redacted; the redactions are typical for Web CRD pulls but limit access to internal-detail data) - **The pre-FOIA Dunlap-Crouch correspondence** (the FOIA submission itself, the AR Securities Department FOIA-processing memorandum, the Crouch determination letter; none are in the production) - **Any AR Securities Department complaint or examination file on DCI Israel Bonds sales to Arkansas pension systems** (none surface in the production; whether the AR Securities Department has investigated the Arkansas pension systems' Israel Bonds purchases is not knowable from this production) The structural finding from the production's omissions: the AR Securities Department's documented engagement with DCI is concentrated in the 1986 procedural-compliance episode (Section 3(e) principal designation) and in routine subsequent registration maintenance (the 47-year registration anniversary in June 2026 is not specifically documented but is implied by the active "Limited" status). There is no documented Securities-Department-side engagement with the Arkansas pension systems' Israel Bonds purchases, no documented examination of DCI institutional sales to Arkansas accredited investors under Reg D, and no documented coordination with the Arkansas State Board of Finance, the State Treasurer's office, or the State Auditor's office on Israel Bonds matters. ## Cross-references [[dci-1986-arkansas-suspension]] new concept page documenting the 1986 procedural-compliance suspension orders [[dci-arkansas-limited-registration]] new concept page documenting the structural single-issuer restriction on DCI's AR registration [[dci-finra-disclosure-events]] new concept page consolidating the 4 FINRA Current Disclosure Summary occurrences [[development-corporation-for-israel]] DCI entity page with verified registration profile and ownership structure updated from this production [[association-for-development-of-israel]] new entity page on DCI's nonprofit parent organization [[jordan-horvath]] [[erik-kruger]] [[andrew-hutter]] [[howard-goldstein]] new DCI senior-leadership entity pages [[jacqueline-miron]] [[nir-fisher]] [[samuel-libchaber]] new AR-registered DCI agent entity pages [[beverly-bassett]] Arkansas Securities Commissioner who signed Order 86-27-S [[amber-crouch]] AR Securities Department Attorney III who produced the FOIA response [[lawrence-berman]] [[brad-young]] [[stuart-garawitz]] [[dani-naveh]] [[bill-mulvey]] DCI entity pages updated with CRD numbers and AR registration effective dates [[joshua-dunlap]] FOIA-trigger requester (fourth Dunlap-triggered production captured in the wiki) [[independent-credit-analysis-gap]] structurally reinforced by the AR-limited-registration finding (a single-issuer dealer cannot structurally provide independent credit analysis on its single product) [[dci-promotional-pipeline]] enriched by the AR-registered-agent finding (the documented DCI promotional pipeline operates through state-licensed registered persons)