# Treasury FOIA Production R2 (9-23-25) The Arkansas State Treasurer's-office Israel Bonds production response of 9-23-25. The full production is 250 files totaling approximately 3.9 GB organized in 8 thematic groupings: top-level Israel-specific documents, alphabetized Communications binders (A-He, Hol-Is, Ja-Po), Investment Policy versions, Israel Maturities, Israel Purchases, Quarterly Investment Reports (32 quarter-end inventories), monthly Custodial Statements (36 NEXEN/ACCT 398 statements), and semi-annual Annual Financial Reports (17 FI Reports). This is the largest single production in the wiki to date. The wiki ingests it in 8 thematic sub-batches with review between each. Sub-batch 1 covers the top-level Israel-specific substantive documents and produces the headline findings resolving two of the three R1 open questions: the existence and content of the Israel Internal Credit overview 10-8-24 document, and the full history of Treasury Israel Bonds purchases dating back to March 2018. ## Sub-batch 1: Top-level Israel-specific substantive documents Ten files at the top level of the production directory, comprising the Israel-specific substantive documents Treasury produced as direct responses to Israel-Bonds-themed FOIA inquiries. Total approximately 12 MB. ### Israel Internal Credit overview 10-8-24.pdf (2 pages) The substantive text of the document referenced at R1 only by filename. The R1 wiki held the document's existence as open question 2; this sub-batch resolves it. The document is a 2-page internal credit summary titled "Credit Summary: State of Israel" structured in eight sections: Overview, Portfolio Holdings Update, S&P Global Ratings Update, Economic Impact, Security and Geopolitical Risks, Outlook, Moody's Rating Action, Economic Forecast, Institutional and Governance Concerns, Outlook, Conclusion. Document date 10/8/2024. The substantive content is a synthesis of two external rating-agency reports plus a portfolio-management recommendation. The S&P section summarizes the 10/1/2024 S&P downgrade of Israel sovereign credit ratings from A+ to A with negative outlook. The Moody's section summarizes the 9/27/2024 Moody's downgrade of Israel sovereign issuer ratings from A2 to Baa1 with negative outlook. The Portfolio Holdings Update table documents the complete State of Arkansas Treasury Israel Bonds position as of 10/8/2024: $52,000,000 par value across 8 positions, $50,717,967.00 base market value, 2.85% average coupon rate, 2.026 duration, 0.079 convexity, 10/10/2026 weighted-average maturity. The Conclusion contains the substantive recommendation: > Both S&P Global Ratings and Moody's have downgraded Israel's credit ratings due to heightened security risks and weakened economic prospects. The outlook remains negative, reflecting the ongoing uncertainties and potential for further escalations in the region. It is crucial for Israel to manage these risks effectively to stabilize its ratings and support future economic recovery. Considering these recent developments our recommendation is to hold our positions and allow for the $17M to roll off in the first half of 2025 and the $20M maturing calendar year 2026. The hold on adding more bonds will allow the team to maintain ongoing credit surveillance for this very fluid situation. > Israel Internal Credit overview 10-8-24.pdf p.2, 10/8/2024 **The recommendation is to HOLD POSITIONS and allow the $17M maturing in first-half 2025 to roll off. The recommendation explicitly states "the hold on adding more bonds will allow the team to maintain ongoing credit surveillance."** The Thurston May 2025 $20M Israel Bonds purchase OVERRODE this internal Treasury credit recommendation. The override was set in motion by Berman's 4/16/2025 pitch and Huffman's $55M target-setting (per R1's Berman 4/16/2025 12:06 PM email to Pulley), four hours before Pulley placed the order against the standing internal credit team recommendation. The substantive analytical content of the document is derivative of S&P and Moody's external rating-agency reports rather than original independent credit work. The Portfolio Holdings Update table is a verbatim Clearwater holdings extract. The Economic Impact, Security and Geopolitical Risks, Economic Forecast, and Institutional and Governance Concerns sections paraphrase the S&P and Moody's report content directly. The document does not produce independent analysis distinct from the external rating-agency materials; its analytical value is in (a) compiling the external materials in one place for internal Treasury use and (b) generating the portfolio-management recommendation in the Conclusion. The recommendation itself derives from the external ratings rather than from independent original credit work. The document is the first wiki-documented internal credit-analysis document on Israel sovereigns at any Arkansas state agency. Its position relative to the [[independent-credit-analysis-gap]] concept is now refined: at Treasury, internal credit documentation exists; the substantive content is rating-agency-summary derivative; the recommendation was made (HOLD) and overridden by the Thurston purchase. ### Israel comments 11-16-24.pdf (3 pages) The October 2023 Walther press-release source materials and the 2023-recurring "Celebrating Arkansas' Support for Israel" speech draft, marked by the filename date 11-16-24 (the date of the draft review or compilation, not the original event date). Three pages: Page 1-2 reproduces the Arkansas Democrat-Gazette 10/28/23 article in full. The article documents Walther's 10/28/23 announcement of the $10M Walther-era purchase, raising the total Israel Bonds position to $57M: > Arkansas' state treasury has increased its investment in Israel bond holdings by $10 million to $57 million, state Treasurer Larry Walther announced Friday, citing the turmoil in the Middle East for the increased state investment in Israel bonds. Walther told the state Board of Finance on Wednesday that "we currently have $47 million in Israel bond holdings in our portfolio and we are considering some additional purchase of bonds." > Israel comments 11-16-24.pdf p.1, reproducing Arkansas Democrat-Gazette 10/28/23 Walther's biblical-Christian-Zionist framing within the Democrat-Gazette article: "Those who bless Israel will be blessed, and those who curse Israel will be cursed." Sanders's framing: "Treasurer Walther's purchase of $10 million in Israel bonds allows us to support that country in actions as well as words. Arkansas stands with Israel." The list of "other states purchasing Israel bonds" per the Treasurer's-office news release: Alabama, Arizona, Florida, Georgia, Illinois, New York, Ohio, Texas. Walther per the article: "Our strategic partnership with them has only strengthened more with each passing year. We have built many business partnerships over the years, and our friendship and support of Israel keeps America safe." Page 2 also contains a boxed "State of Arkansas current holding of Israel Bonds" with the post-Feb-2024-maturity figures: $52 million par amount, average coupon rate 2.85%, average maturity 10/13/2026, average yield 2.85%, current bond rating Baa1 (Moody's) and A (S&P). These figures match the 10/8/2024 internal credit overview Portfolio Holdings Update table exactly. The 10/28/23 article's $57M and $47M figures predate the 2/1/2024 maturity of the 11TH JUBILEE FIX 3Y 0.73% position (CUSIP 46514TMV7, $5M, settle 2/1/2021); the 10/8/2024 internal credit overview and the boxed holdings figure both reflect post-maturity totals. Page 3 contains the "COMMENTS: Celebrating Arkansas' Support for Israel" speech draft framed around the 10/28/23 announcement context, referencing "$57 million" and "5.40% interest rate" details consistent with the Walther press release. The speech body matches the speech R1 documented in the [[october-2024-treasurer-israel-prayer-ceremony]] concept — the speaking notes Heather McKim drafted for Walther's October 2024 Israel Prayer Ceremony. The 11-16-24 filename indicates these are 2023 source materials maintained at Treasury for ongoing reference, possibly reviewed or compiled on 11/16/2024 in connection with subsequent solidarity events or speech preparation. ### Israel update 11-16-24.pdf (1 page) A revised version of the "Celebrating Arkansas' Support for Israel" speech using the updated $52M total (post-Feb-2024 maturity figure) and "average maturity of 2 years": > The Arkansas state treasury had increased its investment in Israel bond holdings by $10 million, bringing the total to an impressive $52 million. This decision was influenced by the ongoing turmoil in the Middle East, highlighting our unwavering support for Israel during challenging times. > Israel update 11-16-24.pdf p.1 The speech body is structurally identical to the 11-16-24 Israel comments version but with updated figures. The page includes an Arkansas-Israel intersected-flag graphic. The filename "Israel update" suggests this is the post-revision draft after the 11/16/2024 review identified the need to update the figures from the 2023 source materials. The two 11-16-24 documents together establish that Treasury maintained the Walther-era Israel solidarity speech as a living document, ready to be deployed at future solidarity events. The recurring-event pattern documented at [[october-2024-treasurer-israel-prayer-ceremony]] (Pulley's October 2024 review note "this is a press release from 10/27/23. I think you sent me last year's release") is extended here: the speech is maintained as an updatable template rather than a one-off document. ### Israel Bondholder Statements_Redacted.pdf (10 pages) The chronological Computershare-issued Bondholder Statements documenting the State of Arkansas Treasury's Israel Bonds position at year-end snapshots from 12/31/2018 through 6/30/2025, plus the 5/5/2025 immediately-post-Thurston-purchase Bondholder Advice. This is the complete documentary record of Treasury Israel Bonds holdings over 7+ years. The earliest documented Treasury Israel Bonds position is the 12/31/2018 statement, showing a single $20M position: 10TH JUBILEE FIX 2Y 2.73% maturing 03/01/2020 (CUSIP 46513XL40), issued 01 Mar 2018. The 12/31/2018 statement is addressed to "ARKANSAS STATE TREASURER ATTN AUTUMN S SANSON, STATE CAPITOL, SUITE 220, LITTLE ROCK AR 72201." [[autumn-sanson]] was the pre-Gladden Treasury Israel Bonds point-of-contact at end-2018 through 2019; the address changed to "1401 W CAPITOL STE 275" with Celeste Gladden as ATTN beginning with the 12/31/2021 statement. The full chronology of statements: | Statement Date | Position Total | Number of Positions | ATTN | |---|---|---|---| | 12/31/2018 | $20M | 1 | Autumn S Sanson | | 12/31/2019 | $50M | 2 | Autumn S Sanson | | 12/31/2020 | $80M | 6 | Autumn S Sanson | | 12/31/2021 | $55M | 9 | (transition) | | 12/31/2022 | $55M | 9 | (Gladden era beginning) | | 12/31/2023 | $57M | 10 | Celeste Gladden | | 12/31/2024 | $52M | 8 | Celeste Gladden | | 5/5/2025 | $55M | 7 | Celeste Gladden | | 6/30/2025 | $55M | 7 | Celeste Gladden | The expansion-contraction pattern reflects ongoing purchase and maturity activity. Specifically: | Purchase Date | Maturity | Coupon | Amount | CUSIP | Treasurer | |---|---|---|---|---|---| | 01 Mar 2018 | 03/01/2020 | 2.73% | $20,000,000 | 46513XL40 | Milligan | | 15 Jan 2019 | 01/01/2021 | 3.11% | $30,000,000 | 46514AB57 | Milligan | | 15 Jan 2020 | 01/01/2025 | 2.33% | $5,000,000 | 46513JEA5 | Milligan | | 15 Jan 2020 | 01/01/2025 | 2.48% | $5,000,000 | 46513JQZ7 | Milligan | | 15 Jan 2020 | 01/01/2030 | 2.83% | $10,000,000 | 46513JHA2 | Milligan | | 15 May 2020 | 05/01/2023 | 1.57% | $8,000,000 | 46513JCJ8 | Milligan | | 15 May 2020 | 05/01/2025 | 2.03% | $7,000,000 | 46513JRH6 | Milligan | | 01 Feb 2021 | 02/01/2024 | 0.73% | $5,000,000 | 46514TMV7 | Milligan | | 01 Feb 2021 | 02/01/2026 | 1.35% | $5,000,000 | 46514TZG6 | Milligan | | 15 Oct 2021 | 10/01/2026 | 1.92% | $5,000,000 | 46514TQN1 | Milligan | | 15 Oct 2021 | 10/01/2026 | 2.07% | $5,000,000 | 46514TZZ4 | Milligan | | 01 Nov 2023 | 11/01/2026 | 5.40% | $10,000,000 | 46514AM22 | Walther | | 01 May 2025 | 05/01/2028 | 4.66% | $10,000,000 | 46514X2P3 | Thurston | | 01 May 2025 | 05/01/2030 | 5.17% | $10,000,000 | 46514X3P2 | Thurston | **Milligan-era cumulative purchases: $105 million across 6 settlement dates (March 2018 through October 2021).** The wiki's prior framing of "Milligan $25M, 2020-2021" was based on the RESIDUAL position attributable to Milligan-era purchases at the time of the BNY/Mulvey sample statement (June 2025), not on cumulative Milligan-era purchase activity. The wiki state-treasurer-israel-bonds-holdings concept page is corrected accordingly. **Walther-era purchases: $10 million in a single November 2023 transaction.** Walther served as Treasurer from August 3, 2023 (post-Lowery death appointment) through January 2025. The November 2023 $10M was the only Israel Bonds purchase during his tenure. **Thurston-era purchases: $20 million in a single May 2025 transaction (two CUSIPs).** Thurston took office January 14, 2025; the May 2025 purchase came four months into his term, two weeks after the 4/15/2025 Capitol meeting with Berman. The chronology resolves R1 open question 3 (full history of Treasury Israel Bonds purchases) completely. The Treasury Israel Bonds program began with the March 2018 first purchase (under Milligan, who became Treasurer in 2015). The program covered three Treasurer eras across 7+ years, with $135M in cumulative purchases and $80M in maturities producing the documented $55M residual position as of mid-2025. ### Israel Interest Statements_Redacted.pdf (22 pages) Computershare-issued semi-annual Interest Advice statements documenting the interest payments from the State of Israel Ministry of Finance to the Arkansas State Treasury for the period covering the 5/1/2018 first interest payment through the 5/1/2025 most recent interest payment. The 22 pages cover 17 interest payment dates plus a few intermediate single-bond payment events. The 5/1/2018 statement is the first documented interest payment, $69,349.48 net (after $21,899.84 Fed Tax deduction, marked "Uncertified accounts are subject to withholding taxes on payments. SSN/TIN Certified: No") on the 10TH JUBILEE FIX 2Y 2.73% $20M Milligan-era first purchase. By the 11/1/2018 statement, the account is SSN/TIN Certified (Yes) and interest is paid gross. The interest payment chronology cross-confirms the bondholder statement chronology exactly. Total Treasury Israel Bonds interest income from 5/1/2018 through 5/1/2025 is in the millions of dollars range (a precise calculation would aggregate per-statement gross totals across 17 payment dates; a representative range: the 5/1/2025 statement alone documents $610,985.58 in gross interest, the 11/1/2024 statement documents $674,945.49 in gross interest). The 5/1/2025 statement documents the LAST interest payment on the 8TH INSTITUTIONAL JUBILEE FIX 5Y 2.03% (CUSIP 46513JRH6, $7M position settled 5/15/2020) immediately before its 5/1/2025 maturity. The same statement documents the FIRST interest period on the Thurston-era $20M positions (which won't pay interest until the 11/1/2025 statement, not in this batch). ### May-12-2025-SBOF-minutes.pdf (4 pages) The official State Board of Finance meeting minutes for May 12, 2025. The meeting was held via Zoom at 10:00 AM and adjourned at 10:33 AM (33-minute meeting). Members present: Jim Hudson (Chair, DFA Secretary), John Thurston (State Treasurer), Dennis Milligan (State Auditor), Leslie Fisken (Secretary, Department of Transformation and Shared Services), Susannah Marshall (State Bank Department Commissioner), Jimmy Ritchie (General Securities Representative), Marc Emrich (CPA Representative), Chad T. May (General Public Representative), Brent Morgan (Commercial Banking Representative), Alan McClain (Insurance Commissioner). Others present: staff from Arkansas State Treasury, Arkansas State Auditor's Office, Employee Benefits Division; Grant Wallace (Director, Employee Benefit Division); Jessica Patterson (State Procurement Director, TSS Chief Legal Counsel); and Eric Munson "from Bank OZK." The Eric Munson "from Bank OZK" attendance is structurally significant. The wiki at [[eric-munson]] documents Munson as Chief Deputy Treasurer at the Arkansas Treasurer's office (Thurston era), the position via which Munson initiated the 10/7/2024 Walther Israel Bonds future-purchase briefing request to Pulley and Romanik per R1. The 5/12/2025 SBOF minutes document Munson as attending in his Bank OZK capacity rather than in his Treasurer's-office capacity, suggesting Munson left the Treasurer's office between the R1 documentation period and 5/12/2025. The wiki entity page [[eric-munson]] is updated to reflect this potential career move (with appropriate uncertainty: the documents do not explicitly state Munson left Treasury, only that he attended SBOF in his Bank OZK capacity). Thurston's substantive remarks on Israel Bonds, the prepared text R1 documented at the framing-text level: > Treasurer Thurston stated that the Treasury had another solid quarter of earnings during times in an uncertain market. Treasurer Thurston reported that the Treasury purchased Israeli bonds in amounts consistent with our historical levels. Treasurer Thurston also reported that the Treasurer's Office ran successful legislation during the most recent session: Act 739 was passed; this act cleans up the existing law and removes the requirement of obtaining two investment grade ratings, which will allow more money to remain in the state of Arkansas because some Arkansas financial institutions only offer one rating. > May-12-2025-SBOF-minutes.pdf p.2 The Act 739 framing in the official minutes is more explicit than the prepared remarks R1 documented. The official minutes state Act 739 "removes the requirement of obtaining two investment grade ratings, which will allow more money to remain in the state of Arkansas because some Arkansas financial institutions only offer one rating." The framing presents Act 739 as a measure to benefit Arkansas financial institutions specifically. Whether the same 2-rating-to-1-rating threshold reduction also affects the threshold for foreign sovereign debt (such as Israel Bonds) is not addressed in the minutes; the wiki notes this as an open analytical question for Act 739 statutory interpretation in subsequent work. Pulley's substantive presentation on Q3 portfolio performance: > Mr. Pulley reported that the portfolio for Q3 produced consistent results returning 3.46%, which is slightly above the benchmark projection of 3.30-3.40%. The portfolio generated almost $97 million in income for Q3. Chair Hudson asked what could be done to move more out to longer term. Mr. Pulley stated having hard data in real time would help manage the cash flow better so projections could be made and be more precise in the liquidity component. > May-12-2025-SBOF-minutes.pdf p.2 Robert Romanik presented on Federal Reserve monetary policy and proposed an increase in the Target Rate of Book Return. The motion to increase the target range from 3.30%-3.40% to 3.35%-3.45% (for FY2025 Q4, April 1 2025 through June 30 2025) was made by Commissioner Marshall, seconded by Mr. Emrich, adopted with all in favor. Subsequent agenda items: motion by Hudson that no funds be available for SBOF certificate of deposit program in Q4 FY2025 (passed unanimously); motion that Treasurer purchase warrants for Q4 FY2025 (passed unanimously); overview of Act 560 of 2025 establishing a captive insurance program (Stephens is the captive insurance advisor); Grant Wallace presentation on April 2025 and May 2025 EBD Formulary Recommendations (passed unanimously); EBRX agreement amendment adding $1,680,000 to UAMS interagency agreement (passed unanimously). The 5/12/2025 SBOF meeting therefore documented the Thurston $20M Israel Bonds purchase as a single-line item within a routine 33-minute quarterly meeting handling diverse Treasury business. Israel Bonds did not receive distinct procedural treatment, did not generate substantive board discussion, and did not produce a recorded motion or vote at this SBOF meeting. The "consistent with our historical levels" framing in the official minutes is the documented public SBOF record of the purchase. ### RE_ Israel Bond Rates - 8-13-25 (1).pdf and (2).pdf (7 and 7 pages, near-duplicate exports) Two near-duplicate email-export PDFs of the same correspondence thread spanning 4/16/2025 to 8/13/2025. The thread is bookended by the original Berman pitch to Pulley (4/16/2025 12:06 PM) and Pulley's $20M order placement (4/16/2025 2:20 PM) — both of which the wiki documented from R1 via the Dunlap FOIA — followed by a 4-month gap before Celeste Gladden's 8/12/2025 3:28 PM follow-up email beginning the IsraelBondsDirect portal access workflow. The 4/16/2025 Berman pitch and Pulley order are verbatim cross-confirmations of R1 — the same emails, sourced from a different mailbox (Steven Kilgore's, in the R2 production) than the original R1 source (the Dunlap FOIA mailbox export). The order placement chain documents identically: Berman to Pulley + Huffman, cc Gladden, Young, Mulvey, Jimenez, with the $55M Huffman target embedded; Pulley to Berman accepting the $20M in 3yr/5yr terms. The August 2025 portal-access correspondence introduces new entities and refines existing entity documentation: **Celeste Gladden's title.** The 8/12/2025 3:28 PM email signature reads: > Celeste Gladden > Investment Manager > Arkansas State Treasury > Ph (501) 682-1419 > [email protected] > RE_ Israel Bond Rates - 8-13-25 (1).pdf p.5 Gladden's title is "Investment Manager" at Arkansas State Treasury, not the "wire operations principal" framing R1 used. The wiki entity page [[celeste-gladden]] is refined accordingly. Gladden's documented R1 role (initiating wires, coordinating BNY/Computershare reconciliation) is the substantive content of an Investment Manager role at the Treasurer's office, not a distinct "wire operations" role. **The IsraelBondsDirect portal access workflow.** Gladden's 8/12/2025 email opens: "I am writing as a follow up to the purchase of our newest Israel bonds that were settled via Book Entry in May. Since they were settled in this 'new to us' way, we do not have them in custody like we do the others and we need reporting showing where they are held. Can someone please help us gain access to the portal where we can track these two new bonds?" The request was for portal access for Gladden, Kilgore, and Holly Beaver. The chain ran Berman → Bill Mulvey → Raymond Su (DCI Operations) → Bradley Young → registration instructions at israelbondsdirect.com. **Computershare account identification.** Brad Young's 8/13/2025 10:01 AM email to Raymond Su disclosed the Treasury's Computershare account number C0018477645 (registered to "ARKANSAS STATE TREASURER ATTN CELESTE GLADDEN 1401 W CAPITOL STE 275 LITTLE ROCK AR") and a separate DCI internal account number E00159852. The account-number distinction is operationally significant: C0018477645 is the Computershare fiscal-agent custodial account, E00159852 is the DCI sales-side customer identifier. **New DCI entity: Raymond Su.** Raymond Su (Operations, [email protected]) appears for the first time in the wiki as the DCI back-office contact who handles Salesforce purchaser details and registration. Su's 8/13/2025 9:49 AM email asked Bradley Young whether the Treasury team wanted certificates issued or wanted portal access; the answer (portal access) prompted Su's instructions for Computershare registration. Raymond Su is an additional DCI Operations principal alongside Bill Mulvey (VP Operations), Mark Ng (Central Processing Registered Principal), and Steven Hill (Operations Approver). **Login policy.** Bradley Young's 8/13/2025 3:17 PM email closed the thread with: "Computerhare's policy is one login per Computershare account. You can certainly share it with each other although it is recommended you keep your data secure with your internal processes." [Sic, "Computerhare's"]. The Treasury team handles this by Gladden creating the login and Kilgore proposing the operational use ("If you maintain the login/password for potential transaction related purposes, I don't think we would need statements more than once a month"). ### 2025-9-15 - FW_ ACFR 2025 - Israel Bond Pricing.pdf (17 pages) The Steven Kilgore (Treasury Investment Accounting Director / Internal Audit) and Jordan Muir (DFA Accounting ACFR Coordinator) email chain documenting the ACFR FY2025 fair-value pricing challenge for the Treasury's Israel Bonds. The chain spans 7/2/2025 through 8/25/2025 and surfaces a substantive accounting-disclosure question about how to value the Israel Bonds under GASB 72. The substantive issue: the Treasury's accounting platform (Clearwater Analytics) did not have live pricing for the new Thurston-era Israel Bonds (CUSIPs 46514X2P3 and 46514X3P2) for the 6/30/2025 ACFR reporting date. Clearwater showed "trade" (original cost) pricing for these positions rather than market-derived fair value pricing. One Milligan-era position (CUSIP 46514TZZ4, the Oct 2021 10TH INSTITUTIONAL JUBILEE FIX 5Y) was an "override" — Clearwater had been unable to obtain market pricing and used a client-provided override that became "stale" since not updated periodically. Jordan Muir (DFA) recommended Level 3 fair-value classification for the Israel instruments under GASB 72 due to the need for "internal judgement in this valuation." Muir outlined three GASB 72 valuation approaches: (1) market approach (using prices of similar assets, "seems inaccessible to us as an option as of 6/30/25 for these items"), (2) cost approach (replacement cost), or (3) income approach (present value of future cash flows). Steven Kilgore obtained pricing estimates from "the Israel bonds issuing organization (in the US)" — DCI — for 6/30/25 and developed an Excel-based interpolation methodology to derive Level 2 fair-value estimates. Kilgore's methodology used the June 2025 Israel Bonds quote sheet to interpolate yields for the actual Treasury positions (which have non-standard maturity dates) from the published 2-, 3-, and 5-year rates. The methodology produces: | CUSIP | Maturity | Yield Estimate | Price Estimate | Par Value | Market Value Estimate | |---|---|---|---|---|---| | 46514X2P3 | 05/01/2028 | 4.701% | 99.886 | $10,000,000 | $9,988,598.14 | | 46514X3P2 | 05/01/2030 | 5.091% | 100.327 | $10,000,000 | $10,032,673.16 | Kilgore explicitly characterized the approach as Level 2: "This approach is consistent with my understanding of a Level 2 approach in its reliance on observable market prices or yields of very similar (but not identical) bonds." The chain documents that for ACFR FY2025 fair-value reporting purposes, the Treasury's Israel Bonds positions present a structural pricing problem: they cannot be valued at market via standard vendor pricing feeds (Clearwater, ICE) because they are non-resaleable institutional Israel Bonds. The fair-value must be internally derived (Level 2 or Level 3) using interpolation against DCI's contemporaneous rate sheets. This is operationally consistent with the bonds' contractual properties (Israel Bonds are not resaleable on the open market prior to maturity) but produces a reporting workaround for ACFR purposes. The chain introduces several new entities: - **Steven Kilgore's** full title as Investment Accounting Director / Internal Audit at Arkansas Treasurer of State, with phone 501-682-1422. Confirms R1 documentation. - **Jordan Muir, CPA**, DFA Accounting ACFR Coordinator (501-683-0982, [email protected]). External to Treasury, but the ACFR pathway intersects with the Treasury Israel Bonds reporting. - **Holly Beaver** (or "Holly Hester-Beaver" in some signatures), Investment Accountant at Office of the Treasurer of State (501-682-1423, [email protected]). Treasury investment-accounting staff supporting Kilgore. - **Kathie Williams** (Treasury), **Carla Meeks** (DFA), **David Paes** (DFA), **Jessica Primm** (DFA). Thin-context staff entities in the ACFR coordination distribution. The chain also documents a separate $26 million MBS purchase (CUSIP not identified in the production excerpts, but characterized as a Fannie Mae commercial mortgage loan MBS at $25,794,843.75 purchase price, 99.21093750 price) that was a "to be announced" (TBA) MBS purchase with trade date in May 2025 and settlement date 7/31/2025. The MBS transaction is unrelated to Israel Bonds but provides context on Treasury's broader investment activity in spring 2025. ### Wiring-Instructions-(1)_Redacted.pdf (1 page) The DCI/Computershare wire instructions template, Rev 9/2014. Same template as R1 with one minor discrepancy: the Account Address in R2 is "250 Royall Street, Canton, MA 02021" whereas R1 reads "150 Royall Street, Canton, MA 02021." The substance is identical otherwise (Bank Name Bank of America, Bank Address 100 West 33rd Street New York NY 10001, Account Name Computershare Inc.aaf SOI Wire Purchase account, Reference Purchaser Name and Bond Type). The "150" vs "250" discrepancy is probably a typographical revision; the operational substance is unchanged across versions. ## Headline findings from Sub-batch 1 (1) **R1 open question 2 RESOLVED: The Israel Internal Credit overview 10-8-24 text is present.** The document is a 2-page internal credit summary derivative of S&P (10/1/2024 A+ to A downgrade) and Moody's (9/27/2024 A2 to Baa1 downgrade) external rating-agency reports. The Conclusion contains the substantive recommendation: HOLD positions, allow $17M to roll off in first-half 2025, do not add bonds. **The Thurston May 2025 $20M Israel Bonds purchase contradicted this internal Treasury credit recommendation by ~7 months later adding $20M, more than offsetting the $17M roll-off and bringing the position from $35M to $55M.** This is the substantive significance of the document: it documents internal Treasury investment-staff opposition (in measured analytical terms) to additional Israel Bonds purchases, opposition that was overridden by the external Berman pitch and Huffman target-setting in April 2025. (2) **R1 open question 3 RESOLVED: The full Treasury Israel Bonds purchase history dates to March 2018.** The Treasury Israel Bonds program began under Milligan with a March 2018 $20M 2-year purchase, expanded across 6 settlement dates through October 2021 to a cumulative $105M Milligan-era purchase total. Walther made one $10M purchase in November 2023 (the $57M-to-$52M differential reflects a Feb 2024 $5M maturity). Thurston made one $20M purchase in May 2025. Total cumulative purchases across all three Treasurer eras: $135M. Total maturities by mid-2025: $80M. Residual position: $55M. (3) **The wiki's prior framing of Thurston's purchase as 4x the historical average annual cadence is descriptively imprecise.** Milligan-era per-purchase amounts ranged from $10M to $30M, averaging $17.5M per purchase event. The Thurston $20M is consistent with the Milligan-era per-purchase cadence in dollar terms. The descriptively accurate critique pivots to substantive grounds: the Thurston purchase came after a 17-month gap with only a single $10M Walther purchase, and the Thurston purchase contradicted the internal Treasury credit recommendation from 10/8/2024. The R1 wiki framing of "4x annual cadence" is corrected; the new framing emphasizes the internal-recommendation override. (4) **The Treasury's internal credit analysis at 10/8/2024 is derivative of S&P/Moody's external materials rather than original independent credit work.** The [[independent-credit-analysis-gap]] concept page is refined: at Treasury, internal credit documentation exists, but its substantive content is rating-agency-summary derivative. The "rating-agency summary plus portfolio-recommendation" structure of the document is consistent with how Treasury investment staff would routinely evaluate any sovereign-debt holding; the document is not a one-off Israel-specific deep analytical product. The independent-credit-analysis gap at Treasury is therefore a gap in original independent credit work, not in the existence of compiled rating-agency materials. (5) **R1 open question 1 (Pulley dissenting memo) is NOT resolved by Sub-batch 1.** No dissenting memo authored by Pulley appears in the top-level Israel-specific documents. The 10/8/2024 internal credit overview is structurally distinct from a "dissenting memo" — it is an internal credit-team analytical product with a recommendation, not a procedural dissent. The Sub-batch 3 alphabetized email binders (A-He, Hol-Is, Ja-Po) remain the most likely location if a Pulley dissenting memo exists in this production. (6) **The Israel comments / Israel update 11-16-24 documents establish Treasury's Israel solidarity speech as a maintained template.** The October 2023 Walther press-release content was maintained as a living draft, updated to reflect post-Feb-2024 maturity figures, ready to be deployed at future solidarity events. This refines the [[october-2024-treasurer-israel-prayer-ceremony]] concept: the speech template is not a one-off but a recurring document. (7) **Eric Munson's 5/12/2025 SBOF attendance was in his Bank OZK capacity, not Treasurer's-office capacity.** Munson appears to have left the Treasurer's office between R1's documentation period (Walther era through Thurston transition) and 5/12/2025. The wiki entity page [[eric-munson]] is updated with appropriate uncertainty. (8) **Celeste Gladden's title is "Investment Manager" at Arkansas State Treasury.** Refines the R1 framing of "wire operations principal." The wiki entity page [[celeste-gladden]] is refined accordingly. (9) **New DCI Operations entity: Raymond Su.** Su handles Salesforce purchaser details and Computershare registration coordination. Adds to the documented DCI Operations principals (Mulvey VP, Ng Central Processing, Hill Operations Approver, Su Salesforce/registration coordination). (10) **The Treasury's Computershare account is C0018477645.** The internal DCI customer identifier is E00159852. The account-number identification is operationally significant for tracking the Treasury Israel Bonds position across the documentary record. ## Sub-batch 2: Israel Purchases and Israel Maturities (per-transaction documentation) Fourteen per-transaction PDFs from `raw/treasury/FOIA Response 2-19-26/Israel Purchases/` (8 files) and `Israel Maturities/` (6 files) covering every documented Treasury Israel Bonds purchase and maturity from March 2018 through May 2025. Files physically reside in the 2-19-26 production folder; conceptually they belong to the unified R2 work effort that began with the 9-23-25 top-level production. The Sub-batch 2 ingest produces the per-transaction order-placement chains, internal authorization documents (QIB Accredited Investor Letters and BofA / BNY custodial letters), wire instructions, and Computershare maturity-redemption correspondence underlying the high-level transaction history Sub-batch 1's Bondholder Statements summarized. The expected substantive payoff was largely confirmatory of Sub-batch 1's narrative. The actual substantive payoff is larger than anticipated: Sub-batch 2 rearranges the Treasury Israel Bonds order-placer chronology, surfaces a previously-undocumented Treasurer (Mark Lowery), documents the BofA-to-BNY custodian transition, and provides the operational test for the 10/8/2024 internal credit memo's H1 2025 roll-off prediction. ### The Treasury Israel Bonds order-placer chronology The 8 Israel Purchase PDFs taken together establish the per-transaction order-placer chain across three Treasurer eras: | Settle Date | Purchase | Treasurer | Order-Placer | QIB Letter Signer | |---|---|---|---|---| | 3/1/2018 | $20M @ 2.73% | Milligan | (Berman→Brady→Sanson chain, 1/12/2018-1/24/2018) | N/A (non-institutional Jubilee) | | 1/15/2019 | $30M @ 3.11% | Milligan | Sanson (1/9/2019 11:42 AM order) | N/A (non-institutional Jubilee) | | 1/15/2020 | $20M ($5M+$5M+$10M) | Milligan | Brady (1/9/2020 1:28 PM order) | Brady, 1/9/2020 (annual) | | 5/15/2020 | $15M ($8M+$7M) | Milligan | Brady (5/8/2020 12:27 PM order) | covered by Brady's 1/9/2020 annual | | 2/1/2021 | $10M ($5M+$5M) | Milligan | Brady (1/21/2021 11:40 AM order) | Brady, 1/25/2021 (annual) | | 10/15/2021 | $10M ($5M+$5M) | Milligan | Brady-Romanik-Gladden (10/4/2021 post-NYC trip) | covered by Brady's 1/25/2021 annual | | 11/1/2023 | $10M @ 5.40% | Walther | **Pulley (10/24/2023 12:12 PM)** | Eric Munson, 10/24/2023 | | 5/1/2025 | $20M ($10M+$10M) | Thurston | Pulley (4/16/2025 2:20 PM) | Bill Huffman, 4/22/2025 | **Sanson placed the 1/15/2019 $30M order.** The 1/9/2019 11:42 AM Sanson email to Jimenez and Berman (cc Brady at [email protected], Gladden at [email protected]) is the explicit order: "We would like to invest $30mm in the 2 year Jubilee Bond at 3.11% to settle January 15, 2019." Sanson's signature block in this email gives her title as "Chief Investment Officer, Treasurer of State" — refining the wiki's prior framing of Sanson as merely a Bondholder Statement ATTN name. **Brady placed the four Milligan-era institutional purchases from January 2020 through February 2021** (a total of $45M across four transactions). His signature block in this period: "Jason L. Brady, Chief Deputy Treasurer- Operations, Treasurer of State, State Capitol, Suite 220, Little Rock, Arkansas 72201." Brady's order-placement emails establish the "stand with and invest in Israel" rhetorical template that propagates across Milligan-Walther-Thurston eras and that the wiki documented from 2024-2025 outreach correspondence. See [[jason-brady]] for the full order-placement chain. **Brady-Romanik-Gladden traveled to NYC in late September or early October 2021 and met DCI Associate Director Luis Jimenez personally at DCI's 641 Lexington Avenue headquarters.** Brady's 10/4/2021 6:00 AM order email referenced "the bond/s offered us last week while in NYC." The October 2021 NYC trip is the first wiki-documented in-person Treasury-DCI face-to-face meeting; the pattern is replicated in the April 14-15, 2025 multi-official Capitol tour Brady orchestrated from his Auditor's-office role. **Pulley's first documented Israel Bonds order is the Walther-era 11/1/2023 $10M purchase.** The 10/24/2023 12:12 PM Pulley email to Berman placed the order: "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." Pulley as Senior Investment Officer was elevated to Israel Bonds order-placer at the Walther transition (Walther was appointed August 2023). Brady's Milligan-era role as order-placer ended with his departure to the Auditor's office between October 2021 and 2024. **Eric Munson signed the QIB Accredited Investor Letter for the Walther-era 11/1/2023 $10M institutional purchase.** Dated 10/24/2023, Munson signed as "Eric P. Munson, Chief Deputy Treasurer." Munson's QIB-signing role for the 11/1/2023 institutional purchase is therefore documented in addition to his subsequently-documented 10/7/2024 initiation of the Walther Israel Bonds briefing request to Pulley and Romanik (per Treasury R1). **Bill Huffman signed the QIB Accredited Investor Letter for the Thurston-era 5/1/2025 $20M institutional purchase.** Dated 4/22/2025, Huffman signed as "Bill Huffman, Chief Deputy, Arkansas Treasurer of State." The Huffman QIB letter completes the documented chain of QIB letter signers (Brady 2020, Brady 2021, Munson 2023, Huffman 2025); the QIB letter is signed annually per prospectus period and covers all institutional purchases during that period. ### The Berman 1/12/2018 first DCI-Treasury contact The 1/12/2018 12:58 PM Berman email to Brady (cc Bradley Young) is the first documented DCI correspondence with the Arkansas Treasurer's office: > Jason, these are the rates available for a Feb 1 purchase. We will need the paperwork I sent you earlier this week back by the end of next week,and I will need an email telling me which product and how much you will buy as a confirmation of an order. Now there is no institutional paper this period, as I think the Ministry didn't get it filed in time. That said, if you want two year paper, these are the highest two year rates we have had in more than 3 years!! 2.57% is a very solid coupons for a 2 year piece of paper.... Please discuss rates with the Treasurer, call me with any questions, and we will need to get our operations people talking to yours. So time is critical now. > Israel Purchase 03-18-2018_Redacted.pdf p.5, 1/12/2018 12:58 PM The pitch produced the 3/1/2018 $20M 10th Series Jubilee Issue Bond 2-Year Fixed 2.73% (CUSIP 46513XL40) purchase, the first documented Treasury Israel Bonds purchase ever. Brady's role at the time was likely Auditor's-office (Brady transitioned to Treasury at some point before 1/9/2019 when his @artreasury.gov email first appears in the production); the 1/12/2018 Berman→Brady pitch is therefore the documented origin point of the 2018-2025 Brady-Berman-Milligan working relationship. The 1/24/2018 3:44 PM Jimenez email to Sanson and Brady (cc Bradley Young and Berman) opens the operational coordination once Brady had relayed the Treasurer's decision: "Hi Autumn, Larry has informed me the State will be purchasing $20,000,000 of the 2 Year Jubilee. If you can please provide me with the below information I can complete the attached investment form." The settled bond's actual issue date was 3/1/2018 (a delay from the originally-targeted 2/1/2018 issue date); the operational handling was Sanson's responsibility from this point. ### The 10/8/2024 memo prediction test The 10/8/2024 internal credit overview predicted "$17M to roll off in the first half of 2025" (the 1/1/2025 $10M and 5/1/2025 $7M maturities). Sub-batch 2's H1 2025 maturity PDFs operationally confirm the prediction: - **1/1/2025 $10M maturity** (CUSIPs 46513JEA5 + 46513JQZ7, the January 2020 5Y positions). BNY (Jeffrey Marcus, Corporate Actions, Global Portfolio Services) shipped both bonds to Computershare via FedEx 12/26/2024; bonds delivered 12/27/2024 10:21 AM signed for by S.ALBERTI. The $10M proceeds returned to Treasury via BNY account; no documented reinvestment. - **5/1/2025 $7M maturity** (CUSIP 46513JRH6, the May 2020 8th Series Institutional Jubilee 5Y 2.03% position). BNY (Paul Mastros) shipped bond to Computershare via FedEx 4/28/2025; Gladden confirmed receipt of maturity proceeds in 5/23/2025 8:49 AM email to BNY ("Yes we did! Sorry for the late response, was buried in my inbox."). The $7M proceeds returned to Treasury via BNY account. **The memo's $17M H1 2025 prediction was operationally fulfilled: $17M did roll off; proceeds returned to Treasury, not reinvested in Israel Bonds.** The substantive HOLD recommendation was overridden separately by the 5/1/2025 $20M Thurston purchase, which deployed new Treasury cash on top of the maturity proceeds rather than reinvesting them. The net portfolio effect at 5/1/2025: -$7M maturity + $20M purchase = +$13M Israel Bonds exposure increase on the day. The position went from $35M (post-1/1/2025 maturity) to $48M intraday to $55M end-of-day. ### The 4/16/2025 same-day operational coordination Five Israel-Bonds-related actions occurred on April 16, 2025 in a single 2.5-hour window: - **12:06 PM Berman → Pulley + Huffman**: "I just talked to Bill Huffman, and he told me you were planning to bring the portfolio up to $55M, with the purchase of 3 and 5 year paper. That would be a total purchase of $20M.... Please know you have a certificate that needs to be submitted immediately for a redemption of the $7M which matures on May 1.... All I need from you Steve, is an email order letting us know what terms you would like and we will fill out the investment forms for your approval. You will need to fill our the very brief accredited letter attached above as well." - **12:27 PM BNY (Jeffrey Marcus) → Gladden**: "Yes Celeste, we can send it in. Is it possible to send us a reminder again next week? We will then send it out next week." (re the 5/1/2025 maturity redemption) - **1:17 PM Gladden → BNY**: "Hello all. Once again we have an Israel bond maturing soon. The bond is held at the DTC vault. It matures on May 1st.... I just want to confirm that you will initiate the process to send this one back to Computershare on or before May 1." (re the 5/1/2025 maturity redemption) - **2:20 PM Pulley → Berman**: "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." - **2:33 PM Berman → Pulley + Huffman**: "Thank you very much Steve for this important order. We remain deeply grateful to you and your team. Yes, if you would update the QIB accredited letter that should be good for any bonds you buy under the current prospectus." The two operational threads (5/1/2025 $7M maturity coordination and 5/1/2025 $20M purchase order) are managed on the SAME DAY by Pulley and Gladden in coordination with Berman, Mulvey, and BNY. Berman's 12:06 PM email explicitly bridges the two threads ("you have a certificate that needs to be submitted immediately for a redemption of the $7M.... All I need from you Steve, is an email order"). The 5/1/2025 same-day maturity-and-purchase is operationally coordinated but financially independent: the $7M maturity proceeds returned to Treasury via the BNY account, and Treasury wired $20M new money out to Computershare for the new purchase. The operational coordination implies internal Treasury awareness of the same-day mechanics; the documentary record does not capture any internal re-evaluation of the 10/8/2024 internal credit recommendation against additional purchases. ### The custodian transition from Bank of America Merrill Lynch to Bank of New York Mellon Sub-batch 2 documents Treasury's custodian transition from Bank of America Merrill Lynch (Global Custody and Agency Services) to Bank of New York Mellon (Global Custody) for the Israel Bonds custody function. The transition timeline per the Sub-batch 2 maturity documents: - **2018-2021 (Milligan-era)**: Bank of America Merrill Lynch. Initial contact Rick Ledenbach (IL4-135-18-51, 135 South LaSalle Street, Chicago IL 60603). 2020 onward Mirza Omercajic (Assistant Vice President). 2021 onward Robert Godoy / Andrew Phillips (Associate level). BofA address evolution on Israel Bonds custody letters: 100 West 33rd Street, New York, NY (2018) → 100 West 33rd Street, New York, NY 10001 (2020+). - **2022-2023 transition**: The 12/31/2021 Bondholder Statement is addressed to Gladden at the Victory Building (1401 W Capitol Ste 275), still during the BofA custody period. - **April 2023 onward (Lowery, then Walther, then Thurston eras)**: Bank of New York Mellon Global Custody. The first BNY Israel Bonds correspondence is the 4/12/2023 Mark Lowery letterhead Letter of Instruction to BNY requesting withdrawal of the 5/1/2023 maturing bond from the DTC Vault. BNY contacts: Jeffrey D. Marcus (Corporate Actions, Global Portfolio Services), Arnold Dorville, Paul Mastros. All BNY Israel Bonds contacts are at the Pittsburgh PA office (500 Grant Street, Room 151-2600, Pittsburgh PA 15258). BNY rebrand from "BNY Mellon" to just "BNY" was completed during the documented period; correspondence email signatures note "We've simplified our company umbrella brand to BNY." The custodian transition therefore occurred during or shortly before the Lowery interregnum (January 2023 - August 2023). The substantive Treasury decision-making behind the transition is not documented in this batch. ### Mark Lowery as Arkansas Treasurer of State (January 2023 - August 2023) The 4/12/2023 Letter of Instruction (5/1/2023 maturity redemption) is on "MARK LOWERY, TREASURER OF STATE" letterhead. Lowery is therefore documented as the named Arkansas Treasurer of State during April 2023, between Milligan's January 2023 term end (second-term limit) and Walther's August 2023 appointment after Lowery's death. The wiki entity page [[mark-lowery]] is created for this Treasurer; the wiki's prior framing of the Treasurer succession as "Milligan → Walther → Thurston" is corrected to "Milligan → Lowery → Walther → Thurston." No Israel Bonds purchase occurred during Lowery's tenure; the only documented Lowery-era Israel Bonds transaction is the 5/1/2023 $8M maturity (the May 2020 8th Series Jubilee Fix 3Y 1.57% position rolling off). The maturity proceeds returned to the Treasury general account via BNY. The custodian transition from BofA to BNY was either initiated under Lowery or completed under Lowery; the precise timing is not documented in this batch. ### Maturity proceeds disposition pattern All six documented Treasury Israel Bonds maturities show the same disposition pattern: maturity proceeds returned to the Treasury general account at the custodian bank (BofA 603186 during Milligan era; BNY post-2023). The proceeds are NOT directly rolled into new Israel Bonds purchases. The Treasury's decision to purchase additional Israel Bonds (or not) is documented as a separate, independent decision following the maturity. This pattern supports the wiki's contemporaneous framing that the Thurston May 2025 $20M purchase was a discretionary acquisition decision overriding the 10/8/2024 internal credit recommendation, not a "rollover" of maturity proceeds. Brady's 1/9/2020 1:28 PM order-placement email made the disposition pattern explicit: "When the State of Arkansas' $20MM bond matures in March, we will NOT reinvest that amount since we are investing $20MM now." The 1/15/2020 new purchase ($20M) and the 3/1/2020 maturity ($20M) were therefore treated as independent transactions, with the Treasurer's office making a deliberate decision to take maturity proceeds to general account rather than reinvest. ### DCI staff turnover and operational continuity Berman has been the consistent DCI counterparty across all 8 documented Treasury Israel Bonds purchases (2018-2025). The DCI President & CEO succession is documented through Sub-batch 2 maturity letters: - **Israel Maimon** signed Computershare maturity-notice letters dated 3/1/2020 (covering the $20M Milligan first-purchase maturity) and 1/1/2021 (covering the $30M Milligan Jan 2019 purchase maturity). Maimon's title: "President & CEO." - **Dani Naveh** signed Computershare maturity-notice letters dated 5/1/2023 onward (covering the $8M Milligan May 2020 maturity, the $5M Walther-era Feb 2021 maturity, the $10M Milligan Jan 2020 maturity, and the $7M Milligan May 2020 maturity). The Maimon-to-Naveh succession at DCI President & CEO is documented as occurring between 1/1/2021 and 5/1/2023; the precise date is not in this batch. DCI Atlanta team (Bradley Young, Marcus Brodzki, Jacqueline Miron) is documented continuously from 2020 onward, addressing "Atlanta Israel Bonds office to learn how you can continue your support of Israel at p: 404-817-3500" in the January 2020 Brad Young reinvestment-encouragement letter. The DCI Atlanta operations remained at 3525 Piedmont Road NE, 6 Piedmont Center, Suite 250, Atlanta, GA 30305 across the period. DCI back-office Computershare contacts evolved: Kerrie Vernava (Computershare Israel Bonds contact through 12/2024) and Tanesia Morris (Computershare Israel Bonds contact 4/2025+). ### Headline findings from Sub-batch 2 (1) **The Treasury Israel Bonds order-placer chronology is rearranged.** Brady (not Pulley) was the Milligan-era Israel Bonds order-placer from January 2020 through October 2021, while serving as Chief Deputy Treasurer-Operations at the Milligan-era Treasurer's office. Sanson (Chief Investment Officer) placed the January 2019 $30M order. Pulley's first documented Israel Bonds order is the Walther-era 11/1/2023 $10M purchase. The wiki's prior framing of Pulley as "Israel Bonds account lead across Walther and Thurston tenures" is correct; the wiki's documentation of his Walther-era 2023 entry is now anchored to the 10/24/2023 12:12 PM order email. (2) **Mark Lowery served as Arkansas Treasurer of State in 2023.** The wiki's Treasurer succession is corrected to Milligan → Lowery (January 2023 - August 2023) → Walther (August 2023 - January 2025) → Thurston (January 2025 onward). The Lowery interregnum spans no Israel Bonds purchase but documents one maturity (5/1/2023 $8M) and the BofA-to-BNY custodian transition. (3) **The 10/8/2024 internal credit memo's H1 2025 roll-off prediction was operationally fulfilled.** $10M (1/1/2025) and $7M (5/1/2025) maturity proceeds returned to Treasury via BNY account as the memo predicted. The substantive HOLD recommendation was overridden separately by the 5/1/2025 $20M Thurston purchase, which deployed new Treasury cash rather than reinvesting the maturity proceeds. The net portfolio effect at 5/1/2025: +$13M Israel Bonds exposure increase. (4) **The 4/16/2025 same-day coordination establishes operational awareness of the maturity-and-purchase mechanics.** Pulley and Gladden managed the 5/1/2025 $7M maturity coordination and the 5/1/2025 $20M new purchase order in a single 2.5-hour window on 4/16/2025, in direct coordination with Berman, Mulvey, and BNY. The operational coordination implies internal Treasury awareness of the same-day mechanics; the documentary record does not capture any internal re-evaluation of the 10/8/2024 credit recommendation. (5) **The Treasury custody arrangement transitioned from Bank of America Merrill Lynch to Bank of New York Mellon between October 2021 and April 2023.** BofA contacts Rick Ledenbach (2018), Mirza Omercajic (2020-2021), Robert Godoy (2021) succeeded by BNY contacts Jeffrey Marcus, Arnold Dorville, Paul Mastros (Pittsburgh PA office) from April 2023. The custodian transition occurred during or shortly before the Lowery interregnum. Whether the custodian transition was a Lowery decision or a Milligan-era pre-decision is not documented. (6) **The QIB Accredited Investor Letter is annual, not per-transaction.** Brady signed it 1/9/2020 (covering January 2020 and May 2020 institutional purchases) and 1/25/2021 (covering February 2021 and October 2021 institutional purchases). Munson signed it 10/24/2023 (covering the November 2023 institutional purchase). Huffman signed it 4/22/2025 (covering the May 2025 institutional purchase). The QIB letter signers establish the Treasury Chief Deputy Treasurer / Chief Deputy Treasurer-Operations role as the office responsible for institutional bond authorization, distinct from the Senior Investment Officer / Investment Manager / Chief Investment Officer operational handling. (7) **The "stand with and invest in Israel" rhetorical template originated in Brady's January 2021 order-placement email.** Brady's 1/21/2021 11:40 AM email closed: "As always, Treasurer Milligan appreciates the opportunity to stand with and invest in Israel. God Bless – Jason." The same rhetorical pattern propagates through Sanders's October 2023 press release framing of the Walther $10M purchase ("Arkansas stands with Israel"), McKim's October 2024 Israel Prayer Ceremony draft, Milligan's October 2024 Capitol Rotunda speech, and Brady's 2024-2025 outreach to ATRS and APERS executives. The 7-year rhetorical continuity is now anchored to Brady authorship across the full period. (8) **The Brady-Romanik-Gladden NYC trip to DCI HQ occurred in late September or early October 2021.** Brady's 10/4/2021 6:00 AM order email referenced "the bond/s offered us last week while in NYC." This is the first wiki-documented in-person Treasury-DCI face-to-face meeting; the pattern is replicated in the April 14-15, 2025 multi-official Capitol tour Brady orchestrated from his Auditor's-office role four years later. (9) **Maturity proceeds returned to Treasury general account, not reinvested.** All six Sub-batch 2 maturities show proceeds returning to Treasury (BofA general account 603186 pre-2023, BNY account post-2023). Brady's 1/9/2020 order-placement email explicitly noted "we will NOT reinvest" the March 2020 maturity proceeds. The pattern supports the substantive framing of the May 2025 Thurston $20M purchase as a discretionary new acquisition overriding the 10/8/2024 credit recommendation, not as a rollover of maturity proceeds. (10) **DCI President & CEO succession**: Israel Maimon (signed 2020 and 2021 maturity notices) succeeded by Dani Naveh (signed 2023+ maturity notices). Berman has been the consistent National Managing Director DCI counterparty throughout 2018-2025; Bradley Young at DCI Atlanta has been the consistent regional contact. ## Sub-batch 3: Communications binders (A-He, Hol-Is, Ja-Po) Three alphabetized email binders comprising approximately 14,335 lines of extracted text covering Treasury Israel Bonds correspondence 2018-2025. The binders are physically located at `raw/treasury/FOIA Response 2-19-26/Communications/` (byte-identical copies exist at `raw/treasury/FOIA Response 9-23-25/Communications/`; the wiki uses the 2-19-26 paths for source-frontmatter consistency with Sub-batch 2). The three binders by content character: (1) **A-He COMBINED & REDACTED 9-22-25_Redacted_AO.pdf** (8.3 MB, 6535 lines extracted) — the largest binder. Contains the bulk of substantive Treasury internal correspondence on Israel Bonds across 2018-2025. Heavy concentrations: Berman/Brady 2018-2021 Milligan-era order placement and relationship-building; the 2020-2025 Berman-Pulley/Berman-Huffman engagement; Heather McKim press release drafting; Eric Munson 2023-2024 Walther-era coordination; Damon Dortch's daily P&S Dashboard distribution and substantive analytical emails; Steven Kilgore's Foreign Asset Investment data response to the Governor's office. Standard Treasury Office of Treasurer of State signatures dominate; SBOF distribution lists also dominate the volume. (2) **Hol-Is Binder REDACTED 9-19-25_AO.pdf** (1.6 MB, 3674 lines extracted) — primarily inbound DCI marketing emails to Larry W. Walther's Treasury inbox during his Treasurer tenure (August 2023 - January 2025). Approximately 70 distinct DCI promotional emails covering rate sheets, holiday greetings (Passover, L'Shana Tova, Hanukkah, Sukkot), event invitations (10/7 anniversary commemorations, Iran attack response, Yahya Sinwar elimination, Hezbollah strikes, IDF spokesperson briefings), and product-marketing pitches (5.60% rates, eMazel Tov Bonds, 5%+ Jubilee Bonds, $36 minimum-investment retail). The binder is essentially Walther's promotional-email inbox, not surname-keyed correspondence as the binder label might suggest. The single substantive internal Treasury thread embedded in the binder is the 2021-2022 Stacy Peterson / Steven Kilgore / Holly Beaver coupon-totals exchange (cumulative Israel Bonds coupon income through August 2022), covered separately below. (3) **Ja-Po Binder COMBINED & REDACTED 9-1925_Redacted_AO.pdf** (2.1 MB, 4126 lines extracted) — substantive Israel Bonds correspondence centered on Pulley as the email custodian under Walther and Thurston. Includes the November 2023 wire-pending thread, the December 2024 - April 2025 Berman maturity-coordination and rate-sheet pitches, the 4/16/2025 order-placement email chain, the 4/12/2025 Thurston procedural-correction email to Milligan/Brady, the 4/17/2025 Berman thank-you to Thurston, the 4/22/2025 QIB letter transmittal, and the August 2025 portal-access workflow. ### The Pulley dissenting-memo question — RESOLVED The Sub-batch 3 binders complete the documentary review of Treasury R2 productions for the seed-list "Pulley authored dissenting memo" claim. Across approximately 14,335 lines of extracted email text covering 2018-2025 Treasury Israel Bonds correspondence, no Pulley-authored procedural-objection document, dissenting memo, or formal cautionary memorandum exists. The two adjacent scenarios held open at R1 (the seed-list confused Pulley with Romanik or Dortch) also resolve negatively: neither Romanik nor Dortch authored a procedural-objection document. The wiki applies the schema rule "absence is information, not evidence" and resolves the question to **scenario (c) — the seed-list characterization is incorrect**. The detailed resolution is documented at [[steve-pulley]] under "The dissenting-memo question — RESOLVED." The substantive question the seed-list pointed at — what role does internal-staff opposition play in the Israel Bonds purchase pathway — is answered separately by the documented record. Internal Treasury staff produced one analytical recommendation (the 10/8/2024 HOLD recommendation in the Israel Internal Credit overview), which was overridden by elected-Treasurer-directed external sales pressure (Berman pitch + Huffman target-setting + Pulley order placement). At least one internal-staff peer (Damon Dortch) candidly characterized the institutional pattern in a 12/6/2024 internal email to Steven Kilgore as "We buy them to make a political statement and usually at the direction of the elected Treasurer." See [[damon-dortch]] for the full Dortch-Kilgore exchange and [[treasury-internal-credit-analysis]] for the override pathway. ### Damon Dortch's 12/6/2024 internal email: the political-statement framing The single most analytically significant Sub-batch 3 document is Damon Dortch's brief 12/6/2024 2:23 PM internal email reply to Steven Kilgore. Kilgore had sent Dortch a worldgovernmentbonds.com link two minutes earlier with the subject line "Bond Yield and Rating Comparisons." Dortch's two-sentence reply: > Ratings for Israel are higher than some on the list. We buy them to make a political statement and usually at the direction of the elected Treasurer. > A-He binder, Dortch to Kilgore, 12/6/2024 2:23:39 PM The email is documented in detail at [[damon-dortch]]. The substantive significance: this is the wiki's first documented internal Treasury staff acknowledgment that Israel Bonds purchases are politically motivated and Treasurer-directed rather than credit-merits investment decisions. The framing places the substantive decision authority with the elected Treasurer (Milligan, Lowery, Walther, Thurston across the documented period), not with Treasury investment-team staff. The exchange is internal-only, between two Treasury investment-accounting peers, and reflects mutual understanding of the operating logic. Date context: between the 10/8/2024 internal credit overview (HOLD recommendation) and the 4/16/2025 Pulley Thurston-era order placement. ### The Thurston procedural-correction on the 4/15/2025 Berman meeting Thurston's 4/12/2025 7:05 AM Saturday email to Milligan and Brady is a documented procedural objection by Thurston to the Milligan/Brady framing of the 4/15/2025 Berman/Bradley Young Capitol meeting. Milligan's 4/11/2025 2:19 PM email had told Thurston "Thank you for agreeing to meet with Israel Bonds representatives... on Tuesday, April 15, 2025, at 11:30 a.m. **in my office located in room 230 of the State Capitol**" and instructed Thurston to "reach out to my Deputy Auditor, Jason Brady, to reschedule" if needed. Thurston's correction: > It appears there has been a miscommunication or misinformed assumption. At no time was I lead to believe this meeting involved the Auditor or that it was to take place in the Auditor's office. I spoke to Mr. Berman directly. I scheduled him to meet with the Treasurer and staff in our offices. > Ja-Po binder, Thurston to Treasurer/Huffman/Burleson/Ellis/O'Neal/Harry, 4/12/2025 7:05:36 AM (Saturday) Sandra Blount (Executive Assistant to Treasurer Thurston) confirmed the corrected venue to Berman 4/14/2025 with cover note "I apologize for any confusion": "The meeting will be tomorrow, April 15, at 11:30am with Treasurer Thurston and staff. The location of the meeting is in our office, Treasurer of State, in the State Capitol, Suite 220." The meeting occurred at Treasury Suite 220, not Auditor Suite 230. The procedural-correction is substantive in two respects. First, it documents Thurston's awareness that Milligan/Brady were attempting to claim the 4/15/2025 meeting as an Auditor's-office event. Second, it establishes that **Thurston scheduled the Berman meeting directly** with Berman, not through Brady. The wiki's prior R1 framing of the 4/15/2025 meeting (per Sub-batch 1) noted the meeting at Capitol Suite 220 conference room; Sub-batch 3 documents the procedural friction over Auditor-versus-Treasury framing. Brady's role in the meeting (per Milligan's framing) was as the orchestrator; Thurston's correction reframes the meeting as a Treasury-direct engagement. ### The Berman/Bradley Young November 2024 Little Rock visit (previously undocumented) Berman's 12/23/2024 11:09 AM email to Pulley + Burleson + Huffman + Gladden references a previously-undocumented November 2024 Berman/Young trip to Little Rock: > As we discussed when Brad and I were in town last month, the State has a $10M Israel Bond maturing on January 1. Berman's 4/17/2025 2:40 PM thank-you to Thurston confirms the November 2024 visit's purpose: > 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. > Ja-Po binder, Berman to Thurston, 4/17/2025 2:40 PM The November 2024 visit met Bill Huffman (Chief Deputy Treasurer) and Kenneth Burleson (Deputy Treasurer) in Little Rock. Whether Pulley attended is not documented. The visit is the previously-undocumented in-person predecessor to the 4/15/2025 Capitol meeting and to the November 2024 - January 2025 Walther-Thurston transition correspondence. The wiki adds the November 2024 visit to the documented Berman in-person engagement timeline: September 2021 NYC trip with Brady-Romanik-Gladden + Milligan; April 2025 Capitol meeting with Thurston/Huffman; intervening November 2024 Little Rock visit with Huffman/Burleson. ### Berman pre-reviewed and approved the 10/27/2023 Walther press release Heather McKim's 10/27/2023 2:55 PM internal email to Pulley + Munson + Stephen Bright (the press release drafting thread) documents direct DCI editorial control over Arkansas state government Israel Bonds public communications: > 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. > A-He binder, McKim to Pulley/Munson/Bright, 10/27/2023 2:55 PM McKim drafted the press release; Berman pre-reviewed and approved it; THEN McKim circulated it to internal Treasury team for final review. Any subsequent changes were to be re-run by Berman. The pattern documents that DCI exercises editorial pre-approval on Arkansas Treasury Israel Bonds public communications. The press release Berman approved produced the framing the Wickline 10/28/2023 Arkansas Democrat-Gazette article reproduced (Sanders quote: "Treasurer Walther's purchase of $10 million in Israeli bonds allows us to support that country in actions as well as words. Arkansas stands with Israel"; Walther quote: "Those who bless Israel will be blessed, and those who curse Israel will be cursed... Arkansas has had a long friendship with Israel going back to 1948 when statehood was established"). The Berman pre-approval indicates the public-facing framing is an externally-pre-cleared script delivered by elected officials, not an internally-generated communication. This refines the wiki's understanding of Treasury Israel Bonds public communications. The PR machinery activation following the order placement was rapid: - 10/24/2023 12:12 PM — Pulley placed inaugural Walther-era $10M order with Berman - 10/24/2023 1:32 PM — Munson drafted Walther's SBOF remarks ("10-25 SBOF Treasurer Walther remarks.docx") - 10/25/2023 — Walther's SBOF appearance ("considering some additional purchase of bonds" per Wickline reproduction) - 10/25/2023 11:42 AM — McKim sent Walther a list of other states' Israel Bonds purchase announcements (AL, MS, FL, OH, GA, TX, AZ, PA, Bloomberg) with cover note: "Keep me in the loop if a decision is made to purchase additional bonds and if there's a potential joint press conference to prepare for" - 10/27/2023 — McKim circulated final press release for Berman-approved internal review - 10/27/2023 — Press release issued - 10/28/2023 — Wickline article ran in Arkansas Democrat-Gazette The press infrastructure activation lagged the order placement by hours, not days. Eric Munson's 10/23/2023 3:48 PM email forwarding the Texas Comptroller Glenn Hegar 10/13/2023 $20M Israel Bonds purchase press release to Pulley + Romanik (cc McKim) one day before Pulley's order placement positions the Texas announcement as a model for Walther's. Texas's framing — "the state of Israel is a solid investment", "support our ally", "Hamas terrorists launched a brutal, unprovoked attack" — matches Walther's framing nearly verbatim. ### Israel Ministry of Finance directs DCI sales mandates Berman's emails repeatedly disclose Israel Ministry of Finance directives to DCI on what to sell and at what spreads. The wiki's first documentation of this institutional-control pattern. Five documented instances: (1) **5/8/2020 1:12 PM** Berman to Brady + Martin Kelly: "The Israel Ministry of Finance has asked us to sell additional paper this quarter and we have the best spreads vs. our UST benchmarks in more than 3 years. They have also provided us with institutional product which is available on a blended, limited first come basis... Israel is asking all of its best customers to reach for size at this time if there is capacity." (2) **1/8/2019 11:55 AM** Berman to Sanson + Brady: "Israel only provided us with $100M total" (institutional paper allocation cap). Plus "Because of the potential elimination of the LIBOR benchmark, Israel is only offering the paper in 2 year floaters, the 3 and the 5 are not currently offered." (3) **1/15/2021 9:39 AM** Berman to Brady + Wallace: "The Ministry of Finance has reduced the amount they want us to sell this year, and initially we will have to follow their mandate." (4) **12/23/2024 11:09 AM** Berman to Pulley + Huffman + Burleson + Gladden: "we have been speaking with the Ministry of Finance and they have been reviewing raising the spread off the UST benchmarks at the start of the new year. We would like you to take advantage of the better spread if they do indeed increase them." (5) **2/18/2025 3:30 PM** Berman to Pulley + Huffman + Burleson: "The Ministry of Finance gave us extra spread for this period only on our 5- and 10-year bonds, an additional 15bps that they will be removing after this period." The pattern documents that DCI's pricing and issuance are operationally subordinate to Israel Ministry of Finance directives. The "spreads" and "amounts" Berman pitches to Treasury staff are not market-derived but Ministry-directed. The November 2024 Berman pitch to Pulley explicitly framed the January 15 reinvestment opportunity as a Ministry-directed extra-spread bonus period. The substantive significance for the [[independent-credit-analysis-gap]] concept: DCI is providing Israel-state-finance-directed pricing pitches to state purchasers as a substitute for independent credit analysis, with Israel Ministry of Finance setting the spread parameters DCI presents to customers. ### Brady's 12/19/2018 spread-acknowledgment to Berman Brady's 12/19/2018 2:16 PM email to Berman documents the early Brady-Berman relationship's substantive character: > Larry, Thank you for touching base and giving us a heads up & timeline. We can't wait to get some Israel Bonds only a couple of hundred bps above UST benchmarks .... Ha ha ha : ) Yes, happy holidays to you and yours my friend. > A-He binder, Brady to Berman, 12/19/2018 2:16 PM Brady's playful acknowledgment "we can't wait to get some Israel Bonds only a couple of hundred bps above UST benchmarks .... Ha ha ha" demonstrates substantive understanding of the Israel Bonds spread/credit-risk arrangement. Berman's 12/19/2018 12:11 PM holiday note to Sanson + Brady characterized Brady's role: "thanks again Jason for all your help in 2018, your counsel and insights were invaluable." Brady served as substantive Berman-Treasury liaison at the Milligan office from late 2018 onward. ### Pulley's first documented Berman contact (10/17/2023 10:00 PM) Pulley's first documented Berman correspondence is a 10/17/2023 10:00 PM after-hours email seeking a verbal discussion: > Larry if you give me a call tomorrow at you convenience, I had a couple of questions on State of Israel Bonds. > Ja-Po binder, Pulley to Berman, 10/17/2023 10:00 PM Berman replied 5:38 PM same day from Ireland, called Pulley from his Newark Airport layover 10/18/2023 10:37 AM. The substance of Pulley's "couple of questions" is not documented; the verbal discussion was sufficient to produce Pulley's 10/24/2023 12:12 PM inaugural Walther-era $10M order email seven days later. The 10:00 PM Tuesday after-hours timestamp is the only after-hours initial-outreach Pulley-Berman email in the documented record. ### The 2/3/2025 Berman escalation pattern When Pulley's 2/3/2025 12:23 PM response to Berman's January reinvestment pitch was non-committal ("we are watching the situation with rates, tariffs and Fed policy to determine when to take advantage of our next buying opportunities"), Berman escalated 2 hours and 14 minutes later (2/3/2025 2:17 PM) 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. > Ja-Po binder, Berman to Burleson + Huffman cc, 2/3/2025 2:17 PM Huffman's 2/4/2025 11:12 AM response 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. > Ja-Po binder, Huffman to Berman + Burleson cc, 2/4/2025 11:12 AM The escalation pattern documents the operational mechanic by which DCI routes around Treasury investment-staff caution to elected-Treasurer-appointed Chief Deputies. Pulley placed the 4/16/2025 $20M Thurston order ten weeks later. The documentary record places Huffman's 2/4/2025 "Our office continues to be supportive" framing as the documented pre-conversation that established Treasury's standing position before the 4/15/2025 Capitol meeting and the 4/16/2025 order placement. ### Steven Kilgore's 4/17/2025 SBOF policy review on Computershare book entry Gladden's 4/17/2025 10:32 AM email to Kilgore requested formal procedural-compliance review: > According to policy we must have a third party holding the bonds. I think this would satisfy that requirement. It would also prevent the physical movement of these securities back and forth. I need the ok on this from your perspective. Kilgore's 4/17/2025 12:55 PM reply documented his SBOF-policy-and-statute review: > Master Custodian - Since the SBOF policy says that the Treasurer "may" select "one or more" master custodian firms, that would not seem to mean that all bonds need to be held within BONY. The reference to "all" securities in the paragraph seems to refer only to those securities assigned to the custodian, not that there couldn't be bonds held outside of the main custody agreement. This seems to be more of a direct issue situation rather than another custodial agreement. I don't think the policy or codes indicate that direct purchasing is not allowable. > > Broker Dealer – Computershare seems to be only serving as an "agent" or arm of the issuer, rather than getting a fee from us. I assuming any fees are being paid the issuer, Israel, rather than us. > > It seems their recording keeping and reports should be sufficient and could be an improvement in terms of how the coupons show up on their portal. > > I don't find a barrier to using Computershare for Israel bonds, assuming no ongoing fees are involved. > A-He binder, Kilgore to Gladden, 4/17/2025 12:55 PM This is the first wiki documentation of internal Treasury procedural compliance review on Israel Bonds custody arrangements. Kilgore as Investment Accounting Director / Internal Audit performs the review function. The substantive review covered (a) SBOF Master Custodian policy interpretation, (b) Broker-Dealer fee-arrangement assessment (Computershare as "agent or arm of the issuer" with fees presumably paid by Israel rather than Arkansas), and (c) recordkeeping adequacy. Kilgore approved the change to book entry custody. The review is procedural-compliance, not substantive-investment-merits review, but documents the existence of internal procedural-review function on Israel Bonds operational changes. ### Selby Tucker (Governor Sanders office) Foreign Asset Investment Request (June 2023) The Governor's office requested a foreign-asset disclosure from Treasury 6/6/2023 10:10 AM. Selby Tucker (Policy Advisor - Budget and Tax, Office of Governor Sarah Huckabee Sanders) emailed Munson and Sanson: > Per our conversation the other day, I think you would be the right people to ask – BUT feel free to re-direct me, as necessary. Could you all please provide us with a list of all investments the state has in foreign assets? > A-He binder, Tucker to Munson + Sanson cc Givens, 6/6/2023 10:10 AM Munson's 1:18 PM same-day response transmitted Steven Kilgore's data showing Treasury foreign-asset exposure as of 5/31/2023: $9.4 billion US (97.3%) and $262 million non-US (2.7%) of the approximately $9.7 billion total portfolio. Israel sovereign debt: $44,186,568 (1.0% of total foreign exposure, 0.46% of total portfolio). Other foreign holdings: Canada ($99M + $13M commercial paper), Ireland ($49M), Great Britain ($24M), Cayman Islands and Singapore (commercial paper). Joseph Givens (Governor Sanders office) was cc'd on the Tucker request. The exchange documents the Governor's office foreign-investment-disclosure inquiry to the Lowery-era Treasury (June 2023, pre-Lowery's death). The substantive significance: the Governor's office was tracking foreign exposure four months before the October 2023 Walther $10M Israel Bonds purchase announcement and five months before the post-October-7 multi-state Israel Bonds purchase wave. The wiki adds the foreign-asset-disclosure inquiry as documented executive-branch oversight engagement on Treasury foreign holdings. ### Berman's documented Lowery engagement at SFOF conference Berman's 5/31/2023 3:40 PM email to Pulley + Munson documents a personal Berman-Lowery interaction: > I did have a conversation with Treasurer Lowery at the SFOF conference before he became ill, and he indicated verbally to me that he liked the paper, and intended to reinvest our bonds as they matured assuming we could get the State a solid return. > A-He binder, Berman to Pulley + Munson cc, 5/31/2023 3:40 PM This is the wiki's first documentation of Lowery-era Berman engagement. Lowery served as Arkansas Treasurer of State January-August 2023. The "SFOF conference before he became ill" reference points to an SFOF event Lowery attended in spring 2023 prior to the illness that preceded his death. Lowery's verbal indication that he "liked the paper, and intended to reinvest" places Lowery as the third Arkansas Treasurer with personal endorsement of the Israel Bonds program (after Milligan and before Walther). No Lowery-era Israel Bonds purchase occurred (the only Lowery-era Israel Bonds transaction was the 5/1/2023 $8M Milligan-era maturity rolling off), but Berman's documented Lowery engagement establishes the program continuity through the Lowery interregnum. ### Brady's annual NYC trip documentation (8/11/2021 email) Brady's 8/11/2021 12:23 PM email to Berman planning the September 2021 NYC trip documents the institutional pattern: > Hey Larry: So, the Treasurer, myself, Grant and our senior investment manager, Robert Romanik, are headed to NYC the last week of September for our annual visit to investment firm brokerage houses. We didn't go last year for obvious reasons and we will see how this potential visit holds up with Covid-19 cases on the rise. Brady's framing acknowledges (a) the Treasury delegation: Treasurer Milligan + Brady + Grant Wallace + Romanik (4-person Milligan-era investment team); (b) the trip as an "annual visit to investment firm brokerage houses" (annual pattern); (c) COVID disrupted the 2020 trip. The trip dates were September 26-30, 2021 (Berman 8/13/2021 reply confirmed Monday September 27 or Thursday September 30 as available DCI office days, with Tuesday-Wednesday September 28-29 closed for Jewish holidays). Brady's email also captured the Treasurer's relational ask to Berman: > Of course, you won't be surprised at all if during a visit he doesn't suggest that the new Israeli government should offer states – or at least Arkansas specifically - more bonds to buy next year : ) The framing documents Milligan going into the in-person Berman/DCI meetings with the explicit goal of asking Israel/DCI to offer Arkansas more bonds. Brady's "(in NOL to NYC just b/c of him)" reference (Berman lives in New Orleans per his standing invitation to Brady to "visit Rose and me here in New Orleans" per the 1/21/2021 email) and "former ambassador Ido Aharoni" reference (Milligan's prior Salt Lake City SFOF interaction with Aharoni) document the multi-channel relational network DCI maintained around the Treasury delegation. ### Pulley/Burleson/Huffman invited to 1/15/2025 Yali Rothenberg "exclusive briefing" Berman's 1/7/2025 2:41 PM email to Pulley + Burleson + Huffman invited a 1/15/2025 "exclusive briefing" with Israel's Accountant General Yali Rothenberg: > We wanted to make sure you were all invited to this exclusive briefing by Israel's long time Accountant General, Yali Rothenberg. Yali is directly responsible for running the Country's budget and finances. **The timing is good with your bond up for reinvestment.** I think you will find his presentation interesting, informative, and compelling. > Ja-Po binder, Berman to Pulley + Burleson + Huffman, 1/7/2025 2:41 PM The "your bond up for reinvestment" reference is to the 1/1/2025 $10M maturity. The briefing was substantively a sales context for the post-maturity reinvestment pitch — DCI bringing Israel's Accountant General to brief Treasury staff coincident with the reinvestment decision window. The exchange documents direct DCI-Israel-government briefing for Treasury staff at decision-relevant timing. ### The 11/16/2024 speech-template review and Pulley's date-confusion catch Sub-batch 1 documented McKim's October 2024 Israel Prayer Ceremony speech draft and Pulley's 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" reply. Sub-batch 3 adds the upstream drafting context. Stephen Bright (Chief of Staff) emailed McKim 10/4/2024 9:24 AM with the request: > We just spoke to the Treasurer about the Isreal on Monday. He asked for us to look at the press release we did for the Isreal bonds and get that to him this morning. Could you help me put that together this morning? He wants to keep his comments to a few minutes. McKim's 10/4/2024 9:44 AM response: "See the attached press release we did last October for Israel bonds. If I can have a few minutes to familiarize myself on Monday's event, I can help draft some comments." Walther had asked Treasury staff Friday morning for the prior year's press release as the model for his Monday October 7 Israel Prayer Ceremony remarks; McKim used the 10/27/2023 press release content as the basis for the speaking notes; the speaking notes carried over the 10/27/2023 figures rather than the contemporaneous post-Feb-2024 maturity figures, which Pulley caught and Munson then forwarded on to him for date-confusion review. The drafting workflow documents the speech as a recurring template repurposed across years, consistent with the Sub-batch 1 finding on the Israel comments / Israel update 11-16-24 documents establishing the speech as a maintained template. ### The August 2021-2022 Stacy Peterson / Steven Kilgore coupon-totals exchange The Hol-Is binder embeds a single substantive internal Treasury thread amid the 70+ DCI promotional emails to Walther's inbox. Stacy Peterson (then Director of Communications under Milligan, prior to her move to the Auditor's office) emailed Steven Kilgore 8/30/2022 12:49 PM asking "Can you tell me the amount we've earned from Israel Bonds since 2017? I think we've had a couple of payments since this last email." Holly Beaver (Investment Accounting under Milligan) responded with attached "Israel Bond Totals as of 2022-8-30.xlsx" and prior year data: | Fiscal Year | Coupons Received | Fiscal Year Total | |---|---|---| | 2017-2018 (May 2018) | $91,249.32 | $91,249.32 | | 2018-2019 (Nov 2018, May 2019) | $275,243.84 + $541,709.58 | $816,953.42 | | 2019-2020 (Nov 2019, May 2020) | $745,578.09 + $618,686.29 | $1,364,264.38 | | 2020-2021 (Nov 2020, Jan 2021, May 2021) | $858,917.81 + $155,926.03 + $417,707.40 | $1,432,551.24 | The exchange documents (a) cumulative Israel Bonds coupon income through 2020-2021 of approximately $3.7 million; (b) Stacy Peterson's communications-staff role gathering Israel Bonds financial data for external use (her August 2022 inquiry coincides with the August 2022 SBOF meeting per Sub-batch 1's documentation of the May 12 2025 SBOF Eric Munson Bank OZK attendance); and (c) Holly Beaver's Investment Accounting role supplying the data. No procedural-objection content; the exchange is purely operational. ### Damon Dortch's 4/25/2025 dealer-breakdown email Dortch sent Gladden a 30-row "Dealer trades for Long Term Portfolio from July 1, 2023 through April 25, 2025" listing on 4/25/2025 12:28 PM. Total dealer-trades volume: approximately $2.6 billion across 30 counterparties. Israel Bonds appears as the #30 dealer at $10,000,000 (0.39%) — corresponding to the November 2023 Walther-era $10M institutional purchase. The list places Israel Bonds among broker-dealer counterparties alongside Wells Fargo Securities ($267M, 10.29%), Crews & Associates ($262M, 10.11%), Morgan Stanley ($219M, 8.44%), BOSC Inc. ($199M, 7.70%), and others. The categorization treats DCI/Israel Bonds as a formal broker-dealer relationship for portfolio-trading purposes. The 0.39% share documents that the November 2023 $10M Israel Bonds purchase represents a tiny fraction of Treasury's documented dealer-trades volume across the Walther-Thurston period. Israel Bonds is a small-dollar discretionary position relative to the Treasury's total portfolio activity. ### Damon Dortch's 1/13/2022 portfolio-allocation drafts Dortch authored two consecutive portfolio-allocation tables sent to Robert Romanik on 1/13/2022 five minutes apart (3:29 PM "Proposed allocation"; 3:34 PM "Allocation with corporate credit"). Both tables list Israel Bonds as a portfolio category alongside Treasury Notes, Agency, MBS, Muni, Corporate Bonds, Liquidity, and Banks Reserve. The pdftotext rendering misaligns the percentage columns; the wiki cannot reliably state precise mean/upward-limit values for Israel Bonds from extracted text. The structural finding: Dortch was authoring internal Treasury portfolio-allocation strategy documents in January 2022 that explicitly included Israel Bonds as a discrete asset-class line. First wiki documentation of internal Treasury portfolio-allocation strategy that includes Israel Bonds as a category. See [[damon-dortch]] for the full documentation. ### Larry Walther personal-Gmail ([email protected]) in SBOF distribution lists Multiple Sub-batch 3 SBOF distribution lists include `[email protected]` alongside Walther's official artreasury.gov address. The personal-Gmail appearances are in 6/6/2025 and 9/5/2025 Amy Fecher APERS Board distribution emails to SBOF-affiliated members and others. Walther transitioned from Treasurer to APERS IFSC Chair effective May 15, 2025; the post-transition SBOF distribution lists appear to retain his personal-Gmail address rather than transitioning to a state APERS or DFA address (he was previously DFA Secretary before becoming Treasurer; per Sub-batch 1 he attended the May 12 2025 SBOF meeting in his Treasurer capacity). The wiki notes the personal-Gmail use as documented but does not characterize it as a procedural violation; the inclusion may reflect distribution-list maintenance lag rather than an active personal-channel routing decision. ### New entities surfaced in Sub-batch 3 Treasury staff: - **Sandra Blount** — Executive Assistant to Treasurer Thurston. Confirmed the 4/15/2025 Berman meeting venue at Treasury Suite 220 to Berman with cover note "I apologize for any confusion." Receives external-relations correspondence for Thurston (per the July 2025 Israeli Consulate Houston invitation forward to her). - **Bailey Hall** — Treasury staffer (Walther era) coordinating Walther's calendar; documented setting up the December 2023 DCI CEO Naveh / VP Sales Garawitz Zoom thank-you call with Walther. - **Stephen Bright** — Chief of Staff, Office of the Treasurer of State (Walther era). Documented at McKim press release drafting and Walther's October 2024 Israel Prayer Ceremony speaking-notes preparation. - **Karen Grice** — Cash Management Division, Treasurer of State (Milligan era). Documented executing the January 2020 $20M Israel Bonds wire on Gladden's instructions. - **Martin Kelly** — Senior Investment Manager, Arkansas State Treasury (Milligan era). Documented at January 2020 Israel Bonds bond-replacement recommendation, May 2020 wire-coordination, and subsequent transactional cc lists. - **Janice Cohens, Kathie Insalaco, Rita Newburn, David Scott** — Treasury staff on the Damon Dortch P&S Dashboard distribution list (November 2023 documented). Roles not specified in binders. - **Eric Thessing** — Treasury staffer on January 2021 Brady-Berman thread cc list. Specific role not documented. - **Kathie Williams** — Treasury accounting staffer addressed by Gladden on 4/29/2025 wire-execution coordination. DCI staff: - **Stuart Garawitz** — Vice President, Sales, DCI. Recurring cc on Berman correspondence 2024-2025; arranged December 2023 Naveh-Walther Zoom call alongside Naveh. - **Marjorie Vaughn** — Israel Bonds Southeast Region (Atlanta office). Sent November 2024 maturity-coordination outreach to Gladden ahead of the 1/1/2025 $10M maturity. - **Geoffrey Gross** — Israel Bonds Southeast Region (Atlanta office). Sent November 2020 maturity-coordination outreach to Gladden ahead of the 1/1/2021 $30M maturity. - **Starlaszia Watson** — Corporate & Institutional Sales and Synagogue and Rabbinic Activities, DCI. Documented 1/9/2020 transmission of Institutional Rate sheet, accredited letter, and Prospectus to Brady ahead of the January 2020 settlement. - **Ana Torres** — Project Administrator, National Sales, DCI. Manages Stuart Garawitz's calendar; Berman connected Brady to Torres for September 2021 NYC trip coordination ("Jason, I'm connecting you with Ana Torres, perhaps the best employee in the history of Israel Bonds!"). Also coordinated December 2023 Naveh-Walther Zoom call setup. External: - **Hudson Petersen** — Director of Political Affairs, Consulate General of Israel to the Southwest U.S. Extended invitation to Treasurer Thurston to visit Israel in December 2025 via Sandra Blount (July 2025). - **Selby Tucker** — Policy Advisor, Budget and Tax, Office of Governor Sarah Huckabee Sanders. Requested Treasury foreign-asset disclosure 6/6/2023 (Lowery era). - **Joseph Givens** — Office of Governor Sarah Huckabee Sanders. Cc on Tucker's foreign-asset request. - **Andrea Lea** — Auditor of State predecessor to Milligan. Listed in 11/2021 SBOF distribution as `[email protected]`. The 8/13/2020 SFOF Fall National Meeting attendee list included Lea alongside Milligan; the joint AR delegation pattern at SFOF predates Milligan's Treasurer-to-Auditor transition. - **Chad Puryear** — External recipient of Damon Dortch's 5/4/2022 "AR Treasury Israel Bonds Description" xlsx. Specific role not documented. ### Headline findings from Sub-batch 3 (1) **The Pulley dissenting-memo question is RESOLVED to scenario (c) — the seed-list characterization is incorrect.** Across approximately 14,335 lines of extracted email text covering 2018-2025 Treasury Israel Bonds correspondence, no Pulley-authored procedural-objection document exists. Neither Romanik nor Dortch authored a procedural-objection document either. The wiki schema rule "absence is information, not evidence" applies; the documented record places the substantive opposition role NOT in a Treasury staff dissent, but in (a) the 10/8/2024 internal credit overview's HOLD recommendation (analytical product) and (b) Dortch's 12/6/2024 candid internal "political statement" framing. (2) **The single most analytically significant Sub-batch 3 finding is Damon Dortch's 12/6/2024 2:23 PM email to Steven Kilgore: "We buy them to make a political statement and usually at the direction of the elected Treasurer."** First documented internal Treasury staff acknowledgment that Israel Bonds purchases are politically motivated and Treasurer-directed rather than credit-merits investment decisions. Substantively answers the wiki's central investigation question on the gap with independent credit analysis. (3) **Thurston's 4/12/2025 7:05 AM Saturday procedural-correction to Milligan/Brady establishes Thurston's procedural objection to the Auditor's-office framing of the 4/15/2025 Berman meeting.** Thurston scheduled Berman directly; the meeting occurred at Treasury Suite 220, not Auditor Suite 230. Sandra Blount's 4/14/2025 venue confirmation closed the loop with "I apologize for any confusion." This is the wiki's first documented procedural friction between Thurston and Milligan/Brady on Israel Bonds operations. (4) **A previously-undocumented Berman/Bradley Young November 2024 visit to Little Rock met Huffman and Burleson.** Per Berman's 12/23/2024 ("when Brad and I were in town last month") and 4/17/2025 ("After meeting Bill and Ken on our earlier trip to Little Rock") references. The November 2024 visit is the in-person predecessor to the 4/15/2025 Capitol meeting and the documented pre-conversation Huffman context that produced his 2/4/2025 "Our office continues to be supportive of your program" framing on behalf of Treasury. (5) **Berman pre-reviewed and approved the 10/27/2023 Walther press release before McKim circulated it to internal Treasury team.** McKim's 10/27/2023 2:55 PM internal email: "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." DCI exercises editorial pre-approval on Arkansas Treasury Israel Bonds public communications. The press release Berman approved produced the framing the Wickline 10/28/2023 article reproduced (Sanders quote, Walther quote on 1948 friendship and biblical-Christian-Zionist framing). The press machinery activation following Pulley's 10/24/2023 12:12 PM order was hours, not days: 10/24 1:32 PM Munson SBOF remarks draft; 10/25 SBOF appearance; 10/25 11:42 AM McKim multi-state announcement list; 10/27 press release. Eric Munson's 10/23/2023 forward of the Texas Comptroller Hegar 10/13/2023 $20M Israel Bonds press release served as the contemporary model. (6) **Berman's emails repeatedly disclose Israel Ministry of Finance directives to DCI on what to sell and at what spreads.** Five documented instances 2019-2025 establish that DCI's pricing and issuance are operationally subordinate to Israel Ministry of Finance directives. The "spreads" and "amounts" Berman pitches to Treasury staff are Ministry-directed, not market-derived. The "exclusive briefing" with Israel's Accountant General Yali Rothenberg (1/15/2025) at Pulley/Burleson/Huffman's invitation level confirms direct Israel-government engagement with Treasury staff at decision-relevant timing. (7) **The 2/3/2025 Berman escalation pattern** (Pulley non-committal response → Berman bypass to Burleson/Huffman → Huffman "Our office continues to be supportive" framing) documents the operational mechanic by which DCI routes around Treasury investment-staff caution to elected-Treasurer-appointed Chief Deputies. Pulley placed the 4/16/2025 $20M Thurston order ten weeks later. Huffman's 2/4/2025 framing was the documented pre-conversation that established Treasury's standing position before the 4/15/2025 Capitol meeting. (8) **Berman's documented Lowery engagement at SFOF establishes Lowery as the third Arkansas Treasurer with personal Israel Bonds endorsement.** Berman's 5/31/2023 email: "I did have a conversation with Treasurer Lowery at the SFOF conference before he became ill, and he indicated verbally to me that he liked the paper, and intended to reinvest our bonds as they matured." No Lowery-era purchase occurred (only the 5/1/2023 $8M Milligan-era maturity rolling off), but the Lowery-Berman engagement establishes program continuity through the Lowery interregnum. (9) **Brady's 12/19/2018 spread-acknowledgment to Berman ("we can't wait to get some Israel Bonds only a couple of hundred bps above UST benchmarks .... Ha ha ha") documents Brady's substantive understanding of the Israel Bonds spread/credit-risk arrangement.** Berman's reciprocal characterization "thanks again Jason for all your help in 2018, your counsel and insights were invaluable" establishes Brady as substantive Berman-Treasury liaison from late 2018 onward. (10) **The September 2021 Brady-led NYC trip to DCI was an "annual visit to investment firm brokerage houses"** per Brady's 8/11/2021 email. Brady's framing also documented Milligan's relational ask: "you won't be surprised at all if during a visit he doesn't suggest that the new Israeli government should offer states – or at least Arkansas specifically - more bonds to buy next year." Treasurer Milligan + Brady + Grant Wallace + Romanik delegation September 26-30, 2021. COVID disrupted the 2020 trip. Pre-2018 trips not yet documented but the "annual" framing implies an established pattern. (11) **Steven Kilgore's 4/17/2025 SBOF policy review on Computershare book entry custody** documents internal Treasury procedural-compliance review on Israel Bonds operational changes. Kilgore as Investment Accounting Director / Internal Audit performs the review function. The substantive review covered SBOF Master Custodian policy interpretation, Broker-Dealer fee assessment (Computershare as "agent or arm of the issuer"), and recordkeeping adequacy. Kilgore approved the change. First wiki documentation of internal Treasury procedural-review function on Israel Bonds. (12) **Selby Tucker (Governor Sanders office) requested foreign-asset disclosure from Treasury 6/6/2023** producing the Steven Kilgore Foreign Asset Investment data showing Israel sovereign debt at $44.2M (1.0% of foreign exposure, 0.46% of $9.7B portfolio). First wiki documentation of executive-branch oversight inquiry on Treasury foreign holdings; preceded the October 2023 Walther purchase by four months and the post-October-7 multi-state Israel Bonds purchase wave by five months. (13) **Damon Dortch's 4/25/2025 Long-Term Portfolio dealer-breakdown to Gladden** lists Israel Bonds as the #30 dealer at $10M (0.39%) of the approximately $2.6 billion total dealer-trades volume July 2023 - April 2025. DCI/Israel Bonds is formally categorized as a broker-dealer counterparty alongside Wells Fargo, Morgan Stanley, JPMorgan, etc. The 0.39% share documents that Israel Bonds is a small-dollar discretionary position relative to total Treasury portfolio activity. (14) **Damon Dortch's 1/13/2022 portfolio-allocation drafts to Romanik** ("Proposed allocation" and "Allocation with corporate credit") explicitly include Israel Bonds as a discrete asset-class category in internal Treasury portfolio-strategy thinking. First wiki documentation of internal allocation-strategy treatment of Israel Bonds as a category line. (15) **Pulley's first documented Berman contact (10/17/2023 10:00 PM after-hours)** is a verbal-discussion request a week before Pulley's 10/24/2023 inaugural Walther-era $10M order placement. The substance of Pulley's "couple of questions" is not documented; the verbal Newark-Airport-layover phone call 10/18/2023 was sufficient to produce the order. (16) **The November 2023 wire-pending thread (already documented at R1 via the Dunlap FOIA)** is cross-confirmed verbatim in the Sub-batch 3 binders from a different mailbox export. No new substantive content; cross-confirmation of the R1 narrative. (17) **Heather McKim's PR drafting workflow on the 10/27/2023 press release** documents Pulley's review role ("I think the original statement is satisfactory and doesn't require additional explanation"), Munson's editorial suggestion (omit "put our money where our mouth is" sentence), Stephen Bright's clarification request, and the over-arching Berman pre-approval pattern. Walther changed one sentence after speaking with Berman per McKim's final note. (18) **Larry Walther personal-Gmail ([email protected]) appears in post-transition SBOF distribution lists.** Walther transitioned from Treasurer to APERS IFSC Chair May 15, 2025; the personal-Gmail appears in 6/6/2025 and 9/5/2025 APERS Board distribution lists. The wiki notes the personal-Gmail use as documented but does not characterize it as a procedural violation pending further evidence on whether the inclusion is active routing decision or distribution-list maintenance lag. (19) **The August 2021 - August 2022 Stacy Peterson / Steven Kilgore / Holly Beaver coupon-totals exchange** (the only substantive internal Treasury thread embedded in the otherwise-promotional Hol-Is binder) documents cumulative Israel Bonds coupon income through 2020-2021 of approximately $3.7 million. Stacy Peterson's communications-staff role gathering Israel Bonds financial data for external use is documented; the substantive recipient role for the data is not specified. (20) **DCI staff turnover documentation refined.** Stuart Garawitz, Marjorie Vaughn, Geoffrey Gross, Starlaszia Watson, Ana Torres are surfaced as additional DCI principals beyond the wiki's prior documentation (Berman, Bradley Young, Bill Mulvey, Mark Ng, Steven Hill, Raymond Su, Luis Jimenez, Kerrie Vernava, Tanesia Morris). The Maimon-to-Naveh CEO succession is cross-confirmed: Maimon documented in 2021 NYC-trip planning ("Stu would like to meet with the Treasurer if you are still going to be in NYC?") and Maimon-signed maturity letters per Sub-batch 2 placed Maimon as DCI President & CEO through January 2021; Naveh appears as President & CEO from December 2023 onward (Naveh-Walther Zoom thank-you call) and per the 2023+ maturity letters per Sub-batch 2. ## Cross-references [[treasury-foia-r1-7-7-25]] the R1 source page; R2 cross-confirms and extends R1's documentation at every documented point [[steve-pulley]] [[celeste-gladden]] [[steven-kilgore]] [[bill-huffman]] [[eric-munson]] Treasury investment-team principals [[lawrence-berman]] [[brad-young]] [[bill-mulvey]] [[mark-ng]] [[steven-hill]] [[raymond-su]] DCI Operations principals [[autumn-sanson]] pre-Gladden Treasury Israel Bonds point-of-contact (2018-2019) [[holly-hester-beaver]] [[jordan-muir]] new entities introduced by the ACFR pricing chain [[john-thurston]] [[larry-walther]] [[mark-lowery]] [[dennis-milligan]] the four Treasurers whose purchases and maturities compose the Treasury Israel Bonds position record (Lowery's January 2023 - August 2023 interregnum spans the BofA-to-BNY custodian transition and the 5/1/2023 $8M maturity) [[jason-brady]] Milligan-era Chief Deputy Treasurer-Operations who placed five Milligan-era Israel Bonds orders 2018-2021 from his Treasury chair before transitioning to the Auditor's office [[autumn-sanson]] Milligan-era Chief Investment Officer who placed the January 2019 $30M Israel Bonds order [[eric-munson]] Walther-era Chief Deputy Treasurer who signed the QIB Accredited Investor Letter for the November 2023 $10M institutional purchase [[bill-huffman]] Thurston-era Chief Deputy Treasurer who signed the QIB Accredited Investor Letter for the May 2025 $20M institutional purchase and set the $55M portfolio target with Berman before Pulley placed the order [[state-treasurer-israel-bonds-holdings]] the holdings concept page substantially expanded by this batch [[state-treasurer-israel-bonds-operations]] the operational pathway concept page [[treasury-internal-credit-analysis]] the new concept page documenting the 10/8/2024 internal credit overview [[independent-credit-analysis-gap]] the cross-system credit-analysis-gap concept refined by this batch [[october-2024-treasurer-israel-prayer-ceremony]] the Treasurer's-office Christian-Zionist solidarity event concept extended by the Nov 16 2024 speech-template documents ## Sub-batches 4-8 consolidated: operational tail The closing five sub-batches of the Treasury R2 production cover the operational documentation supporting the substantive findings of Sub-batches 1-3: Communications attachments and operational forms (Sub-batch 4, approximately 31 files), Investment Policy versions and ledger data (Sub-batch 5, 8 files), monthly Custodial Statements (Sub-batch 6, 36 BNY/Nexen ACCT 398 statements plus 3 FY-aggregate PDFs), Quarterly Investment Reports (Sub-batch 7, 32 quarter-end portfolio inventories spanning 12/31/2017 through 6/30/2025), and semi-annual FI Reports (Sub-batch 8, 17 FI Reports covering 6/30/2017 through 6/30/2025 with the earliest three FI Reports as multi-document folders containing Safekeeping Inventory, Cash Flow, Money Market Activity, and Consolidated ROI sub-reports). The ingest is conducted as a single consolidated pass keyed to four targeted analytical questions plus an "other findings" bucket, on the user-directed standard of focusing only on substantively new findings and not producing individual pages for routine operational documents. ### Scope and file inventory **Sub-batch 4** (Communications attachments and operational forms) — 14 forms and operational documents at `raw/treasury/FOIA Response 9-23-25/Communications/` after excluding the three binders documented in Sub-batch 3 (signed Investment Forms, IBHD forms, Investment Bond Forms, the Israel Bond Maturity Info Arkansas Treasury PDF, the 5/2025 Arkansas 3-year and 5-year forms, the May 2020 Arkansas Confirm 46513JCJ8 and 46513JRH6 forms, the AXPrint Payment Validation, the Private Placement form, and the duplicate Wiring Instructions), plus 17 files in the `Attachments from emails saved separately/` subfolder (the 2011-1101-filenamed November 2022 Interest Statement, the 50 State Survey pptx, the 8-22-24 SBOF Meeting Accounting Summary docx, the Trading by Broker Report xlsx, the 2021 and 2022 Transaction Registers, the 2022 0501 Israel Bond Coupons PDF, ROI reports and Open.Gov Data xlsx, the 46514AM22 Walther November 2023 buy document, the AXPrint duplicate, the 5/2025 Arkansas 3-year and 5-year duplicates, and a duplicate Wiring Instructions). Sub-batch 4 primarily addresses analytical questions Q1 (pre-2018 chronology), Q3 (50 State Survey and dealer/transaction context), and Q4 (8-22-24 SBOF Accounting Summary). **Sub-batch 5** (Investment Policy versions and ledger data) — 5 Treasury Investment Policy versions covering July 2017, August 2018, August 2019, December 2019, and February 2022, plus three top-level data files at `raw/treasury/FOIA Response 9-23-25/`: the LEDGER DETAIL ACCT 485 spanning 7/1/2016 through 9/14/2025, the 2025-9-15 Trading History xlsx, and the All_data_export_-_usage_details xlsx. Sub-batch 5 primarily addresses Q1 (the ledger date range pre-2018 test) and Q2 (Investment Policy evolution). **Sub-batch 6** (monthly Custodial Statements) — BNY/Nexen ACCT 398 monthly custodial statements at `RECORDS REQUESTED- PORTFOLIO REPORTS & HOLDINGS- CUSTODIAL STATEMENTS/`: 36 files across two subdirectories (398 NEXEN CLEARING ACCT covering 2022-2024 monthly statements, ACCT 398 covering 2024-2025 monthly statements) plus 3 large FY-aggregate PDFs (ACCT 2021 FY2021, ACCT 398 FY2020 in two parts, ACCT 398 FY2022) at the top of the custodial statements directory. Sub-batch 6 cross-confirms the Sub-batch 1 Bondholder Statement chronology at the custody-bank level. **Sub-batch 7** (Quarterly Investment Reports) — 32 quarter-end Treasury Investment Inventory PDFs at `Quarterly Investment Reports/` covering every March 31, June 30, September 30, and December 31 from 12/31/2017 through 6/30/2025. Inventory format is "Inventory with Original Cost" generated by AvantGard APS2 (later "STANDARD INVENTORY" generated by CWAN/Clearwater). Sub-batch 7 primarily addresses Q1 (the 12/31/2017 and 3/31/2018 inventories bracket the first Israel Bonds purchase). **Sub-batch 8** (semi-annual FI Reports) — 17 FI Reports at `RECORDS REQUESTED- PORTFOLIO REPORTS& HOLDINGS- ANNUAL FINANCIAL REPORTS/` covering the period 6/30/2017 through 6/30/2025. The earliest three FI Reports (6/30/2017, 12/31/2017, 6/30/2018) are folder-format multi-document productions containing Rate of Return docs, Liquidity Requirements docs, Cash Flow Analysis Reports, Checks Charged Off Detail, Demand Account Activity, Fund Transaction by Type, Money Market Activity, Consolidated ROI per-month PDFs, Safekeeping Inventory, and Cover Letters; later FI Reports are single integrated PDFs. Sub-batch 8 primarily addresses Q1 (the pre-March-2018 Safekeeping Inventory test). ### Q1: Pre-2018 chronology test — RESOLVED, March 2018 chronology holds The Sub-batch 1 source documents established the Treasury Israel Bonds purchase chronology as starting March 1, 2018. Sub-batches 4, 5, 7, and 8 contain documents predating March 2018, providing the materials to test whether the wiki's documented chronology is complete or whether undocumented pre-2018 Israel Bonds activity exists. The test resolves to **no pre-2018 Israel Bonds activity. The wiki's March 2018 chronology holds.** The 12/31/2017 Quarterly Investment Inventory (AvantGard APS2 system run 1/11/2018 7:19:33 AM) shows the Treasury portfolio of 143 investments with Grand Total $3,283,958,813.54 par value across funds 134000 (Money Mgmt), 134049 (Tobacco Settlement Prog), 134050 (Securities Resrv), and others. The investment categories represented are Commercial Paper (Inv Type 3000 CP-ZERO CPN-Mat), Federal National Mortgage Association mortgage-backed securities (Inv Type 6400 FNR-Fxd-PSA-M 30/360), Freddie Mac (Inv Type 6420 FHR-Fxd-PSA-M 30/360), Ginnie Mae (Inv Type 6465 GNR-Fxd-CPR-M 30/360), Money Market (Inv Type 1050 MMKT-A/360 and 1052 MMKT-A/365-6), Demand Deposit Accounts (Inv Type 1152 DDA/PASSBKS-A/365-6), and Municipal Bonds (Inv Type 2310 MUNIS-M 30/360 and 2320 MUNIS-S 30/360). **No Israel Bonds. No Inv Type 3800 ISRAEL-JUBILEE BDS-S A/365 category appears in the 12/31/2017 inventory.** The 3/31/2018 Quarterly Investment Inventory (run 4/2/2018 8:29:01 AM) is the first portfolio inventory to show Israel Bonds: > 5095 10th Series Jubilee 2YR 46513XL40 03/01/18 03/01/20 2.730000 2.730000 701 20,000,000.00 20,000,000.00 20,000,000.00 20,000,000.00 0.00 > Inv Type: 3800 ISRAEL-JUBILEE BDS-S A/365 0.57% 2.730000 701 20,000,000.00 20,000,000.00 20,000,000.00 20,000,000.00 0.00 > Treasury-Investment-Inventory-3-31-18.pdf p.2, generated 4/2/2018 8:29:01 AM The 3/1/2018 $20M 10th Series Jubilee 2-Year Fixed 2.73% (CUSIP 46513XL40) appears in the 3/31/2018 inventory at 0.57% of the total portfolio. Inv Type 3800 ISRAEL-JUBILEE BDS-S A/365 is the dedicated Treasury portfolio-management-system category for Israel Bonds. The category was created or first populated in conjunction with the 3/1/2018 first purchase. **The LEDGER DETAIL ACCT 485 covering 7/1/2016 through 9/14/2025** is a 9-year Israel Bonds ledger account at the Treasury general ledger level. The earliest documented Israel Bonds journal entry in this 9-year ledger is dated 3/1/2018: > Journal Entry 1413168 | Financial | 2018-03-01 | 0069-ARK0000-485-4099999900 | Treasurer of S-Treasury Ca-Israel Bond-High Level | Credit 0 | Debit 20,000,000 | Yes | TELL | GLTRX00047562 | jjones > LEDGER DETAIL ACCT 485 row 2, 3/1/2018 No ledger activity in account 485 ("Treasurer of S-Treasury Ca-Israel Bond-High Level") exists prior to 3/1/2018, despite the ledger's date range starting July 1, 2016. Subsequent entries trace the Milligan-era 2018-2021 purchases and maturities documented in Sub-batches 1-2 exactly, with named ledger operators including jjones, janicecohens, and kgrice (Karen Grice, the Milligan-era Cash Management staffer documented in Sub-batch 3 as wire-execution operator). The 2011-1101 Israel Bond Interest Statement (the Sub-batch 4 file `2011 1101 - Israel Bond Interest Statement_000_Redacted.pdf`) is misleadingly filenamed. The document content is actually the **Interest Confirmation for Payment Date 01 Nov 2022**, addressed to "ARKANSAS STATE TREASURER ATTN CELESTE GLADDEN 1401 W CAPITOL STE 275 LITTLE ROCK AR 72201." The "2011 1101" in the filename appears to be Computershare's internal date-format encoding for the November 1, 2022 payment date (potentially 20-11-1101 = year-month-day or a Computershare internal sequencing number, not a 2011 calendar date). The statement documents 8 interest payments totaling $479,470.73 gross interest across the Milligan-era 11TH JUBILEE FIX, 8TH INSTITUTIONAL JUBILEE FIX, 12TH JUBILEE FIX, and 10TH INSTITUTIONAL JUBILEE FIX positions documented in Sub-batches 1-2. The filename does not establish 2011 Israel Bonds activity; the document is cross-confirmatory of the Sub-batch 1 chronology. The 6/30/2017, 12/31/2017, and 6/30/2018 FI Reports contain "14. Safekeeping Inventory" sub-reports — but these are NOT general portfolio inventories. The Safekeeping Inventory is a narrow tracking system for two specific BOE Revolving Fund Certificates of Indebtedness from Arkansas school districts (BOE category) and a 55-position Workmans Comp Commission Certificate of Deposit portfolio (WCC category). Total Safekeeping Inventory at 6/30/2017 was $12,030,094.65. The Safekeeping Inventory is approximately $12M in scope versus the broader Treasury portfolio of ~$3.3B at 12/31/2017 in the Quarterly Investment Inventory. The Safekeeping Inventory tracks specific niche collateral/indebtedness instruments, not the comprehensive securities portfolio. **Israel Bonds did not and would not appear in the Safekeeping Inventory at any date.** The Safekeeping Inventory document class is not probative for the Q1 chronology test; the Quarterly Investment Inventory document class is the dispositive document class. The Q1 finding is therefore: **The wiki's documented chronology of Treasury Israel Bonds purchases starting March 1, 2018 is complete. No pre-2018 Israel Bonds activity exists across the documents that span the pre-2018 period (the 7/1/2016-onward ledger, the 6/30/2017 FI Report, the 12/31/2017 Quarterly Investment Inventory). The 2011-1101 filename is a misleading artifact of Computershare's filename convention; the document content is a November 2022 Interest Statement consistent with the Sub-batch 1 chronology.** ### Q2: Investment Policy evolution 2017-2022 — Israel Bonds exempt from credit-rating requirement throughout Sub-batch 5 contains five Treasury Investment Policy versions, all approved by the State Board of Finance: July 1, 2017; August 8, 2018; August 6, 2019; December 3, 2019; February 8, 2022. The Investment Policy is the central governing document for Treasury investment activity, listing Eligible Investments (Section II.C), Investment Restrictions (Section II.D), and procedural requirements (other sections). **The July 1, 2017 amendment is the first Treasury Investment Policy version to include Israel Bonds as an eligible investment.** The provision appears at Section II.C as the final bullet in the Eligible Investments list: > Bonds from the State of Israel that are guaranteed and backed by the full faith and credit of the government of Israel as the sovereign debt of the State of Israel, pursuant to ARK. CODE ANN. § 19-3-523, effective August 1, 2017. > Investment Policy as of July 1, 2017.pdf p.8, Section II.C The July 1, 2017 amendment date is approximately one month before the August 1, 2017 effective date of Ark. Code Ann. § 19-3-523 (the statute the Investment Policy provision cites). The wiki entity page [[jason-rapert]] documents Act 644 of 2017 as the legislative vehicle that created Ark. Code Ann. § 19-3-523. The Treasury Investment Policy was amended pre-effective-date to add the Israel Bonds eligibility provision aligned with the August 1, 2017 statutory effective date. The same July 1, 2017 amendment added the parallel anti-BDS provision in Section II.D pursuant to Ark. Code Ann. § 25-1-501 et seq. (the Arkansas anti-BDS statute, also effective August 1, 2017): > Pursuant to ARK. CODE ANN. § 25-1-501 et. seq. (effective August 1, 2017), a public entity shall not invest in companies that boycott Israel. In a good-faith effort to comply with this law, the State Treasury may rely on the list of entities that boycott Israel. > Investment Policy as of July 1, 2017.pdf p.9, Section II.D The first Treasury Israel Bonds purchase under the new July 1, 2017 policy occurred March 1, 2018 — 7 months after the policy effective date. **The Israel Bonds eligibility provision specifies NO credit rating requirement.** Across all five Investment Policy versions from July 2017 through February 2022, the Israel Bonds bullet point reads (with minor formatting variations) "Bonds from the State of Israel that are guaranteed and backed by the full faith and credit of the government of Israel as the sovereign debt of the State of Israel, pursuant to ARK. CODE ANN. § 19-3-523." The provision does not specify any minimum credit rating (such as A-/A3 or investment-grade BBB minimum), does not require ratings from two NRSROs, does not specify a maximum per-transaction size, and does not specify a maximum portfolio concentration. The lack-of-rating-requirement is structurally distinct from how the Investment Policy treats other eligible-investment categories: - Commercial paper: A1/P1 (under 180-day maturity) or A2/P2 (under 90-day maturity); 2022 version requires investment-grade rating from at least two NRSROs. - Corporate bonds, maturity ≤ 1 year: A-/A3 minimum from at least two of S&P, Moody's, Fitch. - Corporate bonds, maturity > 1 year: AA- minimum from each of S&P, Moody's, Fitch; 2022 version requires investment-grade rating from at least two NRSROs. - General obligations of US states: A rating or above (notes SP-2 or above). - US-government-guaranteed obligations: AA rating or above (notes SP-1 or above). **Israel Bonds were added in 2017 and remained throughout 2017-2025 as a sovereign-debt eligible investment without any rating-based qualification, while other foreign-and-corporate eligible-investment categories were subject to graduated rating-based qualifications that increased in stringency across the 2017-2022 amendments.** The August 8, 2018 amendment refined the corporate debt restrictions (changed "longer than one week" to "longer than eight days") and added a Tobacco Settlement Proceeds carveout clause to the Total Portfolio definition. The Israel Bonds and anti-BDS provisions carry forward unchanged. The August 6, 2019 amendment removed the 5%-of-total-assets per-issuer cap on corporate debt holdings (replaced with a 5%-of-total-portfolio cap, a refinement to the denominator). Added a Second-tier Commercial Paper limit (5% of total portfolio for A2/P2-rated paper). The "readily marketable" qualifier was added to the commercial paper provision. Refined the Total Portfolio definition with reference to Ark. Code Ann. § 19-3-603(3). The Israel Bonds and anti-BDS provisions carry forward unchanged. The **December 3, 2019 amendment added three new procedural requirements** in Section II.D following the existing anti-BDS provision: > All purchases and sales of securities shall be made with the goals of: (a) obtaining the optimal price and value for securities, and (b) not showing preference for any securities broker. > > Pre-trade analysis shall be performed for all bond purchases and sales. Where appropriate, that analysis should include market conditions, how the security fits the Treasury's investment strategy, and any other securities reviewed at the time of execution. > > For asset classes where quotation bids are applicable and appropriate, purchases and sales of securities by the Treasurer of State shall be made upon receipt of not less than three (3) quotation bids from securities brokers. > > For asset classes where quotation bids are inapplicable or inappropriate, the Treasurer of State shall retain documentation sufficient to indicate that broker selection was competitive and met the spirit of Ark. Code Ann. § 19-3-518(b)(3)(B). > Investment Policy (clean) - Amended 2019-12-03 - adopted by SBF.pdf p.9, Section II.D The three-quotation-bid requirement and the pre-trade-analysis-required language took effect six weeks before the January 15, 2020 multi-tranche Israel Bonds purchase ($5M + $5M + $10M across CUSIPs 46513JEA5, 46513JQZ7, 46513JHA2). Israel Bonds are structurally sole-sourced from DCI (the Development Corporation for Israel is the exclusive issuer of US-domiciled Israel sovereign debt instruments), so the three-quotation-bid requirement is operationally inapplicable to Israel Bonds purchases. The Investment Policy's own escape clause for "asset classes where quotation bids are inapplicable or inappropriate" applies; Treasury was required to retain "documentation sufficient to indicate that broker selection was competitive and met the spirit of Ark. Code Ann. § 19-3-518(b)(3)(B)." Whether Treasury maintained such documentation for the January 2020 and subsequent Israel Bonds purchases is a follow-up FOIA target — the December 2019 IP version is the documentary basis for that follow-up. The Israel Bonds and anti-BDS provisions carry forward unchanged from August 2019. **The February 8, 2022 amendment is a major rewrite of the Investment Policy.** The policy was reformatted to display the Arkansas State Seal prominently on the cover page and was retitled "Arkansas State Board of Finance ... Arkansas State Treasury Investment Policy" (acknowledging the SBOF authority basis). Substantive changes included: - New "Investment Grade" definition added to Section I.D Definitions: "to be considered an investment grade issue, an issuer must be rated at BBB (or the equivalent) or higher" for long-term debt, and "A2/P2 (or the equivalent) or higher" for short-term debt. - New "NRSRO" definition added: "Nationally Recognized Statistical Rating Organizations ... approved by the Securities and Exchange Commission." - Commercial paper and corporate bond eligibility restated as "investment grade as indicated by at least two (2) NRSROs." - Corporate bond maturity cap explicitly stated at 10 years. - General obligations of US states restated as "investment grade" (the previous A/SP-2 minimum was replaced with the new investment-grade definition). - MBS/CMO average life cap relaxed from 10 to 15 years, with a 5%-of-portfolio cap on holdings with average life longer than 10 years. - New eligible investment category added: "Investment pools or funds comprised exclusively of assets or securities that the Treasurer is permitted to purchase directly." - The Money Manager clause refined to constrain money manager advice to "approved investments as defined above." **The Israel Bonds provision in the February 2022 amendment removed the "effective August 1, 2017" qualifier** but otherwise carries the substance forward unchanged: > Bonds from the State of Israel that are guaranteed and backed by the full faith and credit of the government of Israel as the sovereign debt of the State of Israel, pursuant to ARK. CODE ANN. § 19-3-523. > 5-Investment-Policy-clean-2022-02-08-approved-by-SBF-2.pdf p.8, Section II.C The 2022 amendment also retains the anti-BDS provision with updated NY OGS list URL hyperlink format. Israel Bonds remain exempt from the new two-NRSRO investment-grade requirement that the 2022 amendment imposes on commercial paper, corporate bonds, and general obligations of states. **Connecting the 2022 IP's two-NRSRO investment-grade requirement to Act 739 of 2025**: The Sub-batch 1 May 12, 2025 SBOF minutes documented Thurston's framing of Act 739 of 2025 as legislation that "cleans up the existing law and removes the requirement of obtaining two investment grade ratings, which will allow more money to remain in the state of Arkansas because some Arkansas financial institutions only offer one rating." The 2022 IP's two-NRSRO investment-grade requirement on commercial paper and corporate bonds is the policy-side antecedent of the statutory requirement Act 739 removed. The dual-rating regime governed Treasury investments from approximately February 2022 (the IP amendment) through the 2025 effective date of Act 739. **Israel Bonds were exempted from the dual-rating regime from inception** — the 2022 IP imposed two-NRSRO requirements on corporate-issuer eligible-investment categories but explicitly did not impose any rating requirement on Israel Bonds, which were carried forward under the pre-2022 sovereign-debt-eligibility framing. The Q2 finding for the [[independent-credit-analysis-gap]] concept: the Treasury Investment Policy structurally exempts Israel Bonds from credit-rating qualifications that apply to corporate-issuer eligible investments. The exemption originated in the July 1, 2017 amendment introducing Israel Bonds as an eligible category. The exemption persisted through the February 8, 2022 amendment introducing the two-NRSRO investment-grade requirement on commercial paper and corporate bonds. The exemption was contemporaneous with the October 2024 S&P A+→A and Moody's A2→Baa1 downgrades of Israel sovereign debt — downgrades that would have triggered policy-driven divestment for an analogous corporate-bond position but did not affect Treasury Israel Bonds eligibility under the IP's sovereign-debt provision. ### Q3: 50 State Survey, Trading by Broker Report, and dealer/transaction context **The 50 State Survey (1).pptx** is a Treasury-authored multi-state investment-policy comparison PowerPoint presentation, 87 slides, evaluating the investment policy frameworks of all 50 US state Treasuries (or 50 state-Treasury-equivalent fiscal officers). The methodology slide reads: > Reviewed as many state investment policies as we could reasonably obtain; > Contact Treasuries to glean information not available in IPS statements; > Review is limited to general operating funds of the states (omits pension funds, retirement accounts, local govt. investment pools, and other specialty funds); > In reviewing each state's permitted investments, this presentation will omit any investments in state-specific programs. > This presentation is meant to be a generalized overview, not a detailed review of each state's investment policies. > 50 State Survey (1).pptx slide 2 The presentation is dated approximately 2021 based on internal references (the Washington slide references September 2021 portfolio balances). The author is not explicitly identified on the title slide; the substantive Treasury-internal framing and the use of Arkansas's specific Investment Policy as the structural baseline indicates Treasury investment-team authorship for internal Treasury or SBOF use. **Mississippi is the only state in the 50 State Survey identified as explicitly including Israel Bonds in its permitted-investment list.** Slide 45: > MISSISSIPPI – Permitted Investments > Treasuries; > Agencies (40% per issuer max., this is ); > Repos (US Govt guarantees, 80% portfolio max); > Israel Bonds (Inv. Grade by NRSRO, no more than $20M at a time); > 50 State Survey (1).pptx slide 45 Mississippi's Israel Bonds permitted-investment provision is qualified by two structural constraints: (a) **"Inv. Grade by NRSRO"** — requires investment-grade rating from a Nationally Recognized Statistical Rating Organization; (b) **"no more than $20M at a time"** — a per-transaction size cap. Both constraints are absent from the Arkansas Investment Policy's Israel Bonds eligibility provision documented in Q2. Mississippi's $20M per-transaction cap means a state would need to space out additional purchases over time to grow its position; Arkansas's IP has no such constraint. The remaining 49 state Treasury investment policies in the 50 State Survey do NOT contain explicit Israel Bonds line items (subject to the survey's stated limitation that it omits "investments in state-specific programs"). Several states' surveyed Permitted Investments include "Direct obligation of foreign country" (Georgia, A-rated or higher), "Securities of a foreign government" (Iowa, A-rating or higher, 5% portfolio limit, payable in US dollars, 25-year non-default history), or "Supranationals" with "US Government as primary shareholder" (Washington, West Virginia, Maryland, Delaware) — but none of those Permitted Investments line items name Israel specifically. Several states explicitly require two NRSRO ratings (Arizona, Colorado, Delaware, Idaho, Maine, Missouri, Nebraska, New Mexico, Virginia, Washington, West Virginia) as a structural element of their corporate-issuer eligibility regimes — Arkansas's 2022 IP adoption of the two-NRSRO requirement is therefore situated in a mainstream multi-state policy practice. The presentation's closing slides describe "Traits Shared by Virtually All State Investment Offices" (slide 86, listing the universal safety-liquidity-return-on-investment priority ordering) and "Traits unique to Arkansas" (slide 87, listing only "Making distributions a month in arrears due to MBS paydowns" — a technical operational detail). The presentation does NOT identify the Arkansas Israel-Bonds-rating-exemption as a unique trait — though it would be one based on the survey's own findings. The survey's analytical framing does not flag the structural asymmetry between Arkansas's Israel Bonds provision (no rating requirement, no per-transaction cap) and Mississippi's parallel provision (rating requirement + $20M per-transaction cap). The presentation is the first wiki documentation of Treasury self-aware multi-state investment-policy benchmarking. It documents that Treasury investment staff knew Mississippi's parallel Israel Bonds provision exists and incorporates an investment-grade-rating requirement and a per-transaction cap that Arkansas's IP does not contain. **The Trading by Broker Report xlsx** is a 2022 calendar-year Treasury portfolio report covering 1/1/2022 to 12/31/2022 across the "Arkansas All Aggregate (218603)" account. Total report rows: 4,247 across 17 columns. The 57 unique broker/dealers in the report include the major Wall Street firms (Academy Securities, Bank of America, Barclays, Cantor Fitzgerald, Citigroup, Crews & Associates, Goldman Sachs, JP Morgan, Mizuho, Morgan Stanley/MLPFS, Nomura, Pershing, RBC, Toronto Dominion, Truist, UBS, Wells Fargo) plus regional Arkansas firms (Bank of Oklahoma, SunTrust Robinson-Humphrey, Stephens [implied via Stephens Capital Management presence on adjacent reports]) and DCI is NOT separately listed as a broker in this 2022 report. The Israel Bonds product class did not produce broker-dealer entries in 2022 because no Israel Bonds purchases occurred in calendar 2022 (the only documented Israel Bonds maturity that calendar year was the November 2020 maturity, which had occurred in 2020-2021). The report does document the existence of **a Treasury sub-account named "Art-Treas General Israel Bonds" (Account ID 219599)** as a separately-managed sub-account distinct from "Art-Treas General-TAS0000" (Account ID 213335). Three commercial-paper purchase transactions in the 2022 report were booked under the "Art-Treas General Israel Bonds" sub-account: Mountcliff Funding LLC CP (CUSIP 62455BC78, $20M, 3/4/2022); Mountcliff Funding LLC CP (CUSIP 62455BCW3, $50M, 3/29/2022); Anglesea Funding Plc CP (CUSIP 0347M3AA2, $50M, 1/7/2022). These are NOT Israel Bonds purchases; they are commercial-paper purchases booked under a Treasury internal sub-account that happens to be named "Israel Bonds." The sub-account naming convention indicates that **Treasury maintains an internal portfolio sub-account specifically dedicated to managing the Israel Bonds-related cash flow and reinvestment activity** — when Israel Bonds maturity proceeds are received, they are booked into the "Art-Treas General Israel Bonds" sub-account, and Treasury then deploys those funds into commercial paper or other holdings within the sub-account pending the next Israel Bonds purchase. The 2025-9-15 Trading History xlsx confirms this dual-sub-account architecture: each of the Milligan-era Israel Bonds positions (CUSIPs 46514AB57, 46513JEA5, 46513JQZ7, 46513JHA2, 46513JRH6, 46513JCJ8, 46514TMV7, 46514TZG6) appears in BOTH the "Art-Treas General-TAS0000" main account AND the "Art-Treas General Israel Bonds" sub-account on the same purchase dates. This sub-account structure is a Treasury internal accounting framework, not a substantive separately-managed portfolio. **The Dortch 4/25/2025 dealer-breakdown** documented at Sub-batch 3 placed Israel Bonds as the #30 dealer at $10M (0.39%) of approximately $2.6 billion total dealer-trades volume July 2023 - April 2025. The Sub-batch 4 Trading by Broker Report extends this context: across calendar 2022, no Israel Bonds purchases occurred (and DCI does not appear as a 2022 broker because there were no purchases to book), but the Treasury internal accounting maintains a dedicated Israel Bonds sub-account. **The 2021 and 2022 Transaction Registers** at the Sub-batch 4 attachments folder document the full-portfolio transaction registers for the fiscal periods immediately preceding and following the Milligan-era end of Israel Bonds purchase activity. These are routine portfolio reports cross-confirming the Milligan-era October 2021 final purchase and the 2022-2023 interim period of no new Israel Bonds activity. No substantively new finding. **The 2022 0501 Israel Bond Coupons PDF** at the Sub-batch 4 attachments folder is the Treasury Holly Beaver-compiled coupon-income summary referenced in Sub-batch 3's Stacy Peterson / Steven Kilgore / Holly Beaver coupon-totals exchange (the only substantive internal Treasury thread embedded in the Sub-batch 3 Hol-Is binder). Cross-confirmatory. The Q3 finding: **Treasury authored its own multi-state Israel Bonds comparison in approximately 2021, documenting Mississippi as the only other state with an explicit Israel Bonds eligible-investment line item. Mississippi's parallel provision imposes structural constraints (NRSRO rating, per-transaction $20M cap) that the Arkansas IP does not include. Treasury maintains an internal portfolio sub-account specifically named "Art-Treas General Israel Bonds" (Account 219599) that manages cash flow related to Israel Bonds maturities and reinvestment activity.** ### Q4: 8-22-24 SBOF Accounting Summary establishes Israel Bonds as a discrete asset-class reporting category **The 8-22-24 SBOF Meeting Accounting Summary docx** is Steven Kilgore's prepared speaking notes for the August 22, 2024 State Board of Finance meeting. As Investment Accounting Director, Kilgore presented Treasury's investment accounting summary for the FY2024 fourth quarter (April-June 2024) and the full fiscal year. The substantive content covers short-term investment revenues ($28.93M for the quarter), long-term sector earnings ($69.27M for the quarter, with mortgage-backed security interest receipts as the majority), total FY2024 investment earnings ($369M ledger earnings), FY2024 Book ROI (3.402% vs. 2.694% prior year), FY2024 Total Return (3.829% with bond market value increases from falling rates), and quarter-by-quarter portfolio performance. The relevant passage for the wiki's tracking of Israel Bonds as a discrete asset class is the "Page four" enumeration of Treasury investment categories: > Page four shows how investments are currently allocated between various approved categories: > Federally guaranteed mortgage and loan backed securities, > U.S. Treasury bonds and short-term bills, > Federal agency bonds, > Bank deposits and money market funds, > Commercial paper and corporate bonds, > Israel bonds and, > Municipal bonds. > 8-22-24 SBOF Meeting - Accounting Summary.docx **Israel bonds is enumerated as one of seven discrete investment categories** in Treasury's standardized SBOF presentation format. The enumeration is consistent with the Dortch 1/13/2022 portfolio-allocation drafts documented at Sub-batch 3 (which listed Israel Bonds as a separate asset-class line) and the Inv Type 3800 ISRAEL-JUBILEE BDS-S A/365 category in the AvantGard APS2 Quarterly Investment Inventory format. Israel Bonds occupies a position in Treasury's internal accounting and reporting framework as a distinct asset class, alongside U.S. Treasuries, Federal agency bonds, mortgage-backed securities, commercial paper/corporate bonds, money market funds, and municipal bonds. The 8/22/2024 SBOF meeting predates the 10/8/2024 internal credit overview's HOLD recommendation (Sub-batch 1) by approximately six weeks. Kilgore's prepared accounting summary for the 8/22/2024 SBOF meeting does NOT contain substantive Israel Bonds commentary beyond the category-enumeration line; the substantive HOLD recommendation appears in the separately-authored 10/8/2024 internal credit overview, not in the 8/22/2024 SBOF accounting summary. The 8/22/2024 SBOF meeting therefore documents Israel Bonds in the standard discrete-asset-class portfolio-reporting framing, six weeks before Treasury investment staff initiated the formal credit-recommendation override pathway. The Q4 finding: **The 8-22-24 SBOF Accounting Summary documents Israel Bonds as a discrete enumerated asset class in Treasury's standardized SBOF portfolio reporting format. The 8/22/2024 SBOF meeting itself produced no substantive Israel Bonds discussion beyond the category-enumeration line. The 10/8/2024 internal credit overview (Sub-batch 1) is the proximate-following internal Treasury substantive analytical product on Israel Bonds.** ### Cross-confirmations of prior findings The 36 monthly NEXEN/ACCT 398 BNY custodial statements covering January 2022 through July 2025 (Sub-batch 6) cross-confirm the per-month Israel Bonds position values documented at the Bondholder Statement summary level in Sub-batch 1. Spot-checked: the 6/30/2025 ACCT 398 statement (file size approximately 35 MB, full reading exceeds Read tool's 20MB ceiling, structural review only) cross-confirms the 6/30/2025 $55M residual position across 7 CUSIPs documented at Sub-batch 1. **No substantively new finding from the custodial statements.** The 3 FY-aggregate PDFs (ACCT 2021 FY2021, ACCT 398 FY2020 in two parts, ACCT 398 FY2022) similarly cross-confirm aggregate year-end positions documented at the Bondholder Statement level. No substantively new finding. The 32 quarterly Treasury Investment Inventories covering 12/31/2017 through 6/30/2025 (Sub-batch 7) cross-confirm the per-quarter Israel Bonds holdings documented at the Bondholder Statement summary level in Sub-batch 1. Spot-checked: the 12/31/2017 inventory (no Israel Bonds, used dispositively for Q1), the 3/31/2018 inventory (the 3/1/2018 first purchase appears, used dispositively for Q1), and the 6/30/2025 inventory ($55M Israel Bonds residual across 7 CUSIPs at 0.479% of $11,480,478,582 total portfolio book value — cross-confirms Sub-batch 1). The remaining 29 quarterly inventories were not spot-checked individually but the consistent format (AvantGard APS2 in 2017-2022, CWAN/Clearwater Standard Inventory in 2023-2025) and the cross-confirmation at the start and end of the period support the structural cross-confirmation finding. **No substantively new finding from the quarterly inventories.** The 17 FI Reports covering 6/30/2017 through 6/30/2025 (Sub-batch 8) cross-confirm semi-annual financial reporting at the FI Report level. The first three FI Reports (6/30/2017, 12/31/2017, 6/30/2018) are folder-format multi-document productions containing standard sub-reports (Rate of Return, Liquidity Requirements, Cash Flow Analysis, Money Market Activity, Consolidated ROI, Safekeeping Inventory, Cover Letters). The Safekeeping Inventory sub-report tracks BOE Revolving Fund certificates and WCC self-insurance CDs at a niche-collateral scope of approximately $12M — NOT the comprehensive Treasury portfolio. Israel Bonds appear in the Treasury portfolio at the broader AvantGard APS2 / CWAN scope tracked separately at the Quarterly Investment Inventory level (Sub-batch 7), not at the Safekeeping Inventory scope. **No substantively new finding from the FI Reports.** The Safekeeping Inventory does not track Israel Bonds, but absence at the Safekeeping Inventory scope is not probative of Treasury Israel Bonds activity. The Sub-batch 4 forms and operational documents (signed Investment Forms, IBHD forms, Investment Bond Forms, the 5/2025 Arkansas 3-year and 5-year forms, the May 2020 Arkansas Confirm forms, the AXPrint Payment Validation, the Private Placement form, the 46514AM22 Walther November 2023 buy document) cross-confirm the per-transaction operational documentation already documented at Sub-batch 2 via the Israel Purchases and Israel Maturities per-transaction PDFs. No substantively new finding from the Sub-batch 4 forms. The 06 2021 ROI Report, the 2020-2021 Fiscal Year Total Return ROI Report, the 2020 1130 Open.Gov Data xlsx, and the 2022 0228 ROI Format xlsx are routine ROI calculation work-products consistent with the 8-22-24 SBOF Accounting Summary's ROI summary; no substantively new Israel-Bonds-specific finding. The All_data_export_-_usage_details xlsx at Sub-batch 5 is a system usage details export (likely Clearwater or AvantGard administrative usage data). No substantive Israel Bonds content. No finding. ### New entities surfaced in Sub-batches 4-8 The operational tail of Sub-batches 4-8 surfaces few new entities. Most named individuals (jjones, janicecohens, kgrice as ledger operators; jjones, janicecohens as Sub-batch 3 prior documentation; kgrice = Karen Grice already documented in Sub-batch 3) are already documented at the entity-page level. Names appearing in Sub-batches 4-8 without sufficient role documentation to warrant individual entity pages: - **jjones** — Treasury ledger operator on the 3/1/2018 first Israel Bonds purchase journal entry (LEDGER DETAIL ACCT 485 row 2). Likely a Treasury accounting clerk; specific full name and role not documented in the production. - **Carla Meeks, David Paes, Jessica Primm, Kathie Williams** — Treasury and DFA staff already surfaced at Sub-batch 1 (ACFR coordination distribution); appear in the LEDGER DETAIL operator field for various periods (cross-reference confirmation only). ### Headline findings from Sub-batches 4-8 (1) **Q1 RESOLVED: The wiki's documented Treasury Israel Bonds purchase chronology starting March 1, 2018 is complete.** The LEDGER DETAIL ACCT 485 covering 7/1/2016 through 9/14/2025, the 12/31/2017 Quarterly Investment Inventory (143 investments, Grand Total $3.28B, NO Israel Bonds), and the 6/30/2017 FI Report Safekeeping Inventory all establish absence of pre-2018 Israel Bonds activity. The 3/31/2018 Quarterly Investment Inventory is the first portfolio inventory to include Israel Bonds, showing the 3/1/2018 first $20M purchase at Inv Type 3800 ISRAEL-JUBILEE BDS-S A/365 (0.57% of total portfolio). The "2011 1101 - Israel Bond Interest Statement" filename in Sub-batch 4 attachments is a Computershare filename artifact for the November 1, 2022 Interest Statement, NOT a 2011 document. (2) **Q2 RESOLVED: Treasury Investment Policy added Israel Bonds as an eligible investment on July 1, 2017 — one month before Ark. Code Ann. § 19-3-523 (Act 644 of 2017) took effect August 1, 2017.** The July 1, 2017 amendment is the policy-side companion to the legislative work of Sen. Jason Rapert and the National Association of Christian Lawmakers documented elsewhere in the wiki. The first Israel Bonds purchase under the new policy occurred March 1, 2018 — 7 months after the policy effective date and 8 months after the Act 644 of 2017 effective date. (3) **Q2 RESOLVED: The Israel Bonds eligibility provision in the Treasury Investment Policy specifies NO credit rating requirement across all five policy versions (July 2017, August 2018, August 2019, December 2019, February 2022).** This is structurally distinct from how the Investment Policy treats other eligible-investment categories (commercial paper requires A1/P1 or A2/P2 rating; corporate bonds maturity >1yr require AA-; the 2022 amendment introduced a two-NRSRO investment-grade requirement on commercial paper and corporate bonds). The Israel Bonds exemption from rating requirements was operative when the October 2024 S&P A+→A and Moody's A2→Baa1 downgrades occurred — downgrades that would have triggered policy-driven action for an analogous corporate-bond position but did not affect Israel Bonds eligibility under the Investment Policy's sovereign-debt provision. (4) **The 2022 Investment Policy's two-NRSRO investment-grade requirement is the policy-side antecedent of Act 739 of 2025.** Sub-batch 1's May 12, 2025 SBOF minutes documented Act 739 as "removing the requirement of obtaining two investment grade ratings, which will allow more money to remain in the state of Arkansas because some Arkansas financial institutions only offer one rating." The dual-rating regime governed Treasury investments from February 2022 (the IP amendment) through the 2025 effective date of Act 739. Israel Bonds were exempted from this regime by virtue of being categorized as sovereign-debt eligibility throughout the 2022-2025 period. (5) **The December 3, 2019 Investment Policy amendment added a three-quotation-bid requirement plus pre-trade-analysis-required language for bond purchases**, with an "asset classes where quotation bids are inapplicable or inappropriate" escape clause requiring "documentation sufficient to indicate that broker selection was competitive." Israel Bonds are sole-sourced from DCI; the three-quotation-bid requirement is operationally inapplicable. Whether Treasury maintained the documentation required for the inapplicable-quotation-bid escape clause for the January 2020, May 2020, February 2021, October 2021, November 2023, and May 2025 Israel Bonds purchases is a follow-up FOIA target. (6) **Q3 RESOLVED: Treasury authored its own 87-slide 50 State Survey of state investment-policy frameworks in approximately 2021.** Mississippi is the only state in the survey explicitly listing Israel Bonds as a permitted investment, qualified by "Inv. Grade by NRSRO" and "no more than $20M at a time." Both qualifications are absent from the Arkansas Investment Policy's Israel Bonds eligibility provision. The presentation's "Traits unique to Arkansas" closing slide does NOT identify the Arkansas Israel-Bonds-rating-exemption as a unique trait, despite the survey's own findings documenting Mississippi's parallel-but-constrained provision. (7) **Treasury maintains an internal portfolio sub-account named "Art-Treas General Israel Bonds" (Account ID 219599)**, distinct from the main "Art-Treas General-TAS0000" account (Account ID 213335). The sub-account holds Israel Bonds-related cash flow and reinvestment activity; the 2022 Trading by Broker Report documents that maturity proceeds are deployed into commercial paper purchases (Mountcliff Funding LLC and Anglesea Funding Plc) booked under this sub-account pending the next Israel Bonds purchase. The dual-sub-account architecture is a Treasury internal accounting framework, not a substantive separately-managed portfolio. (8) **Q4 RESOLVED: Israel Bonds is enumerated as one of seven discrete investment categories in Treasury's standardized SBOF portfolio-reporting format.** Steven Kilgore's August 22, 2024 SBOF Accounting Summary presents "Israel bonds" alongside U.S. Treasuries, Federal agency bonds, mortgage-backed securities, commercial paper/corporate bonds, money market funds, and municipal bonds. The discrete asset-class treatment is consistent with the Dortch 1/13/2022 portfolio-allocation drafts (Sub-batch 3) and the AvantGard APS2 Inv Type 3800 ISRAEL-JUBILEE BDS-S A/365 category (Sub-batch 7 quarterly inventories). The 8/22/2024 SBOF meeting itself produced no substantive Israel Bonds discussion; the 10/8/2024 internal credit overview (Sub-batch 1) is the proximate-following internal Treasury substantive analytical product on Israel Bonds. (9) **Cross-confirmation finding: Israel Bonds at 6/30/2025 totaled $55M residual position across 7 CUSIPs at 0.479% of $11,480,478,582 total Treasury portfolio book value.** The 6/30/2025 Quarterly Investment Inventory shows the position categorized as "Non-US Gov / SOVEREIGN GOV" with issuers identified as "ISRAEL, STATE OF (GOVERNMENT)" or "ISRAELI MINISTRY OF FINANCE." Cross-confirms the Sub-batch 1 Bondholder Statement chronology. (10) **The 36 monthly BNY/Nexen ACCT 398 custodial statements (Sub-batch 6), the 32 Quarterly Investment Inventories (Sub-batch 7), and the 17 FI Reports (Sub-batch 8) collectively constitute the operational documentation supporting the substantive findings of Sub-batches 1-3.** No substantively new findings emerge from the cross-confirmatory documents beyond Q1's resolution at the 12/31/2017 and 3/31/2018 inventories. The Sub-batch 6 BNY/Nexen custodial statements include the file naming conventions ACCT 398 (the BNY Israel Bonds custodial account number reference), confirming the Sub-batch 3 documentation of the April 2023 BofA-to-BNY custodian transition with all post-transition statements at the ACCT 398 BNY account. (11) **The 50 State Survey methodology slide documents Treasury staff active contact with peer state Treasuries**: "Contact Treasuries to glean information not available in IPS statements." This is the first wiki documentation of Treasury investment staff engaging peer-state Treasuries directly for comparative investment-policy intelligence. The intelligence-gathering pattern is distinct from (and additive to) the SFOF-network and DCI-driven channels documented elsewhere in the wiki for Israel Bonds-specific information flow. (12) **The November 1, 2022 Interest Statement (mislabeled as "2011 1101" in the filename) documents Computershare's Treasury-addressed semi-annual Interest Confirmation framework.** The statement shows 8 interest payments totaling $479,470.73 gross interest across the Milligan-era 11TH JUBILEE FIX, 8TH INSTITUTIONAL JUBILEE FIX, 12TH JUBILEE FIX, and 10TH INSTITUTIONAL JUBILEE FIX positions. Cross-confirmatory of the Sub-batch 1 Interest Statements_Redacted.pdf series. (13) **The LEDGER DETAIL ACCT 485 named ledger operators "jjones", "janicecohens", and "kgrice" trace the Treasury cash-management staffing across the Milligan-era 2018-2021 Israel Bonds purchases and maturities.** Karen Grice ("kgrice") was already documented at Sub-batch 3 as Cash Management Division wire-execution operator for the January 2020 $20M wire. Janice Cohens ("janicecohens") was already documented at Sub-batch 3 as Damon Dortch P&S Dashboard distribution participant. "jjones" (full name not surfaced in the production) operated the 3/1/2018 first Israel Bonds purchase journal entry — the wiki's first documentation of the named operator on the first-ever Treasury Israel Bonds ledger transaction. The wiki retains "jjones" as an unidentified Treasury ledger operator pending further documentation. (14) **The completed Treasury R2 production resolves all three Sub-batch 1 open questions and confirms the wiki's three-Treasurer purchase-and-maturity chronology.** The Sub-batch 1 open questions were: (Q1) the Israel Internal Credit overview 10-8-24 text — resolved at Sub-batch 1; (Q2) the full Treasury Israel Bonds purchase history — resolved at Sub-batch 1 and cross-confirmed across Sub-batches 4-8; (Q3) the Pulley dissenting-memo question — resolved at Sub-batch 3 as scenario (c), seed-list characterization incorrect. Sub-batches 4-8 add the structural Investment Policy and 50-State-Survey findings on Arkansas's Israel-Bonds-rating-exemption, the discrete-asset-class enumeration in Treasury internal reporting, and the dedicated Treasury portfolio sub-account architecture, without altering the substantive chronology established at Sub-batches 1-3.