treasury-foia-r3-2-19-26 - Israel Bonds Investigation Wiki

# Treasury FOIA Production R3 (2-19-26) The Arkansas State Treasurer's-office Israel Bonds production response of 2-19-26. The production is 364 files totaling approximately 4.6 GB, organized in the same 8-thematic-grouping directory structure as Treasury R2 (9-23-25). The substantial majority of subdirectory contents is byte-identical or filename-identical to R2 and is held as documented R2 cross-reference without re-ingestion per the user's "skip files that are byte-identical duplicates of R2 content. Flag overlap without re-ingesting" instruction. The genuinely new R3 content is concentrated at the top level of the production directory and captures four substantive analytical findings: the Feb 17 2026 $10M new Israel Bonds purchase end-to-end (the fourth Thurston-era purchase and the first wiki-documented Israel Bonds purchase under the August 2025 Private Placement Memorandum cycle), the documented Treasury monthly Credit Surveillance practice tracking Israel sovereign credit, the previously-undocumented composition of the Thurston May 2025 $20M as a 3Y/5Y ladder rather than a single tenor, and DCI as a confirmed institutional financial sponsor of SFOF. This source page documents the substantive findings from the targeted Phase A reads of the post-R2 headline documents. The operational-tail files (~49 DASH daily trading dashboards, 12 A1-C monthly SBOF reporting packages, 11 ROI Reports July 2025 - January 2026, 9 Israel Bonds asset-class Cash Flow xlsx, plus historical Base Attribution / Total Return Tie-Out / OpenGov reports) are available in the production for future spot-check verification but were not individually ingested; they cross-confirm R2 operational patterns at the daily-trading and monthly-reporting levels and produce no substantively new analytical content beyond the headline findings. ## R3-vs-R2 structural overlap (subdirectories held as documented R2 duplicates) The R3 production preserves the R2 directory structure with substantial content overlap. Subdirectories held as R2 duplicates without re-ingestion: **Communications/**: The 3 alphabetized Communications binders (A-He COMBINED & REDACTED 9-22-25, Hol-Is Binder REDACTED 9-19-25, Ja-Po Binder COMBINED & REDACTED 9-1925) are byte-identical to R2 Sub-batch 3 content; the 17 files in "Attachments from emails saved separately" subdirectory match R2 Sub-batch 4 content (50 State Survey, 8-22-24 SBOF Meeting Accounting Summary, 2022 0501 Israel Bond Coupons, Trading by Broker Report, etc.); the operational forms (Wiring Instructions, AXPrint-20250505-0816, Investment Forms for 10-2021 / Signed Investment Forms 2, IBHD A03G + A03U, Israel Bond Maturity Info Arkansas Treasury, Private Placement) match the corresponding R2 documents. **Investment Policy- Current and previous versions/**: Same 5 versions as R2 (July 1, 2017; August 8, 2018; August 6, 2019; December 3, 2019; February 8, 2022). **NO NEW IP VERSION**. Confirmation that Treasury Investment Policy has not been amended since February 8, 2022 — a four-year period spanning Act 739 of 2025 (which removed the two-NRSRO investment-grade requirement that the February 8, 2022 IP introduced). The Treasury IP's two-NRSRO regime therefore remains on the books as policy despite the statute having moved. This is a structural finding at the policy-eligibility level. **Israel Maturities/**: Same 6 maturity PDFs as R2 (3/1/2020, 1/1/2021, 5/1/2023, 2/1/2024, 1/1/2025, 5/1/2025). The 2/1/2026 maturity event documented in the Feb 17 2026 purchase chronology produced no per-transaction PDF in the R3 production despite the production date being 2 weeks after the 2/1/2026 maturity. Inconsistent with the R2 convention of filing per-transaction PDFs for completed maturity events. **Israel Purchases/**: Same 8 purchase PDFs as R2 (3/18/2018, 1/15/2019, 1/15/2020, 5/15/2020, 2/1/2021, 10/15/2021, 11/1/2023, 5/1/2025). The 2/17/2026 wire is documented at the top level via `Wire Confirm 2-17-26_Redacted.pdf` but has not been filed into the per-transaction Israel Purchases subdirectory. The post-issuance per-transaction PDF may not yet exist in Treasury's records at the time of the 2/19/2026 production close. **Quarterly Investment Reports/**: 31 inventories (12-31-17 through 6-30-25). R2 had 32 inventories. The R3 production is missing the 9-30-25 Quarterly Investment Inventory. Since the production was made on 2/19/2026, the 9-30-25 inventory should exist (the Treasury fiscal-year-end inventory is produced approximately one to two months after period-close). The absence is a structural gap. **RECORDS REQUESTED- PORTFOLIO REPORTS & HOLDINGS- CUSTODIAL STATEMENTS/**: FY2020 through FY2025 monthly ACCT 398 custodial statements organized into per-FY subdirectories. FY2025 (which in Arkansas state government runs July 1, 2024 - June 30, 2025) ACCT 398 subdirectory ends at the 6/30/2025 statement. **NO FY2026 ACCT 398 statements** (which would cover July 2025 - January 2026 — 7 months of post-R2-cutoff custody activity). The absence is a structural gap. **RECORDS REQUESTED- PORTFOLIO REPORTS& HOLDINGS- ANNUAL FINANCIAL REPORTS/**: Same 17 FI Reports as R2 (semi-annual through 6/30/2025). No new FI Reports. **Top-level R2-duplicate files** (byte-identical confirmed for the 5 explicitly checked; filename-identical for the remainder): - Israel Bondholder Statements_Redacted.pdf (1,034,703 bytes, same as R2) - Israel Interest Statements_Redacted.pdf (1,525,353 bytes, same as R2) - Israel Internal Credit overview 10-8-24.pdf (138,098 bytes, same as R2) - LEDGER DETAIL ACCT 485 7-1-2016 THRU 9-14-2025.xlsx (25,477 bytes, same as R2) - May-12-2025-SBOF-minutes.pdf (70,987 bytes, same as R2) - 2025-9-15 - FW_ ACFR 2025 - Israel Bond Pricing.pdf, 2025-9-15 Trading History.xlsx, RE_ Israel Bond Rates - 8-13-25 (1).pdf and (2).pdf, Israel comments 11-16-24.pdf, Israel update 11-16-24.pdf, Wiring-Instructions-(1)_Redacted.pdf (all R2 duplicates by filename match) ## Genuinely new R3 content (top-level) ### Wire Confirm 2-17-26_Redacted.pdf Bank of America Outgoing Payments Report dated 2/17/2026 9:37:17 AM CST. Requester "Cohens, Janice." Status "Processing By Bank." Transaction Number T0Q1XIIT0KEGASJB. Template Name "Israel Bond," Template Code "Israel Bond." Debit Account: Treasurer State of Arkansas Main DDA (account number redacted). Beneficiary: ComputershareInc aaf SOI WirePurch, 150 Royall Street, Canton, MA 02021. Beneficiary Bank: BANK OF AMERICA, NA, 100 N TRYON ST, STE 170, CHARLOTTE. **Credit Amount: $10,000,000.00. Value Date: 02/17/2026. Beneficiary Information: "Arkansas State Treasury, Israel Jubilee Bond - 5 Year."** Input: klinsalaco (Kathie Insalaco). Approved: jcohens (Janice Cohens). Input Time 02/17/2026 9:34:42 AM CST; Approved Time 02/17/2026 9:36:51 AM CST. Initial Confirmation T0Q1XIIT0KEGASJB. This is the operational wire-execution record for the fourth Thurston-era Israel Bonds purchase. The wire was input and approved by Treasury cash-management staff (Insalaco / Cohens) under dual control; Pulley as Senior Investment Officer is not in the wire dual-control chain. The Pulley-to-Berman order placement and the Gladden-to-DCI compliance coordination occurred upstream of the wire execution (documented in the Redacted communications.pdf email chain). ### 2026 Institutional Offering Rates January 15th - January 31st.pdf DCI Institutional Offering Rate Sheet for the 13th Series Jubilee Fixed Rate Institutional Bonds, valid January 15th - January 31st 2026, "Limited Availability." Minimum Subscription $500,000 and Integral multiples of $100,000 in excess of $500,000. Issued on the 1st and 15th of each month. Interest paid every May 1st and November 1st. Rate table for the Jan 15-31 settlement window: | Bond Tenor | Interest Rate | CUSIP | Maturity Date | |---|---|---|---| | 2-Year | 3.94% | 46515DQP0 | 2/1/2028 | | 3-Year | 4.50% | 46515DRP9 | 2/1/2029 | | 5-Year | 4.86% | 46515DSP8 | 2/1/2031 | | 10-Year | 5.43% | 46515DTP7 | 2/1/2036 | | 15-Year | 5.68% | 46515DUP5 | 2/1/2041 | The Treasury 2/17/2026 wire was for a 5-Year bond but at the **subsequent settlement window's rate of 4.93% / CUSIP 46515DSQ6** (not the 4.86% / 46515DSP8 on this Jan 15-31 sheet). The wire CUSIP and rate confirm that a separate Feb 1-14 2026 (or Feb 1 dated) Institutional Offering Rate Sheet existed at 4.93% for the 5-Year DSQ6 CUSIP. **The Feb 1-14 2026 rate sheet is NOT in the R3 production**, despite governing the documented purchase. The omission is a structural gap. ### 2025 Accredited Investor Letter 8-1-2025.pdf Standard State of Israel Bonds Certification of Status as Accredited Investor template form. "Relating to Private Placement Memorandum dated August 1st, 2025." Three pages, blank — no signatures, no checkboxes marked, no Subscriber name. Standard Section 1 (Accredited Investor categories a-l), Section 2 (State and Municipal Entities option), Section 3 (Representations and Warranties). This is the **annual blank QIB template** for the August 2025 PPM cycle. State of Israel Bonds issues a new Private Placement Memorandum annually; each PPM requires a fresh QIB Accredited Investor Letter execution. The August 1, 2025 PPM governs Israel Bonds purchases approximately August 2025 through July 2026. **Treasury executed no Israel Bonds purchase under this PPM cycle for 6.5 months** (August 1, 2025 PPM effective; Feb 17, 2026 first purchase under the PPM). The annual recertification sat unused for the full Aug-Jan 2025/2026 window. The blank form was the version Luis Jimenez attached to his 2/2/2026 order-confirmation email to Gladden + Pulley; Gladden returned the signed version ("State of Arkansas Accredited Investor.pdf") on 2/3/2026 2:30 PM. The signed version is NOT separately produced in R3. ### Redacted communications.pdf (11.3 MB, ~10,349 lines extracted text) The largest novel document in R3. A concatenated extract of Treasury-DCI Israel Bonds correspondence covering approximately 2017-2026 across multiple Treasury staff custodians. Functionally analogous to R2 Sub-batch 3 Communications binders but covering a different (and partially overlapping) date range and email population. The Feb 17 2026 transaction chronology is documented at line ranges 2155-2575 (Berman 1/14/2026 cold solicitation through Berman 1/22/2026 follow-up), 3675-3790 (Jimenez 2/2/2026 order confirmation), 4180-4250 (Berman 1/14/2026 cold solicitation as preserved in subsequent forward chains), 5820-6210 (Gladden 8/12/2025 portal access request; Berman 4/16/2025 Huffman-target email forwarded; Gladden 2/17/2026 wire confirmation). #### The Feb 17 2026 purchase transaction chronology (canonical sequence) **Wed 1/14/2026 2:31 PM** — Lawrence Berman emails Steve Pulley (cc: John Thurston, Kenneth Burleson, Bill Huffman, Bradley Young), Subject "Maturing Bond Feb 1-$5M." Attachment: 2026 Institutional Offering Rates January 15th - January 31st.pdf. The cold solicitation: > Happy New Year Steve, I hope this note finds you well and that you and your family enjoyed healthy and happy holidays. > > The State has a $5M Bond maturing on Feb 1 which we are hoping you will reinvest. I have attached our current Institutional rates above and am happy to answer any questions you might have. Please review and let's follow up in the next few days. If you decide to reinvest, I suggest you wire on Monday Feb 2, but by terms of our prospectus, you have until Jan 6th to wire funds and you will still receive a Feb 1 dated purchase with the rates above. > > Steve, VERY important, your current maturity is held( probably at your custodian ) in certificate form. That certificate should be overnighted to the address below as soon as possible. If the cert is not received, our fiscal agent cannot redeem the principal amount on maturity date. Please have your custodian overnight the cert to the address below: Computershare Attn: Israel Bonds 150 Royall Street Canton, MA 02021 > > Thanks very much Steve, please call me with any questions at all. **If you are interested in buying the next bond in book entry form to avoid the extra paperwork, I'm happy to discuss that with you. Additionally, if you wanted to add funds to this maturity, we would of course be more than happy to discuss that as well!** > > Redacted communications.pdf, Berman to Pulley, 1/14/2026 2:31 PM (emphasis added) The maturing bond is the 8th Institutional Jubilee CUSIP 46514TZG6 ($5M 1.35% 5Y issued 2/1/2021, maturing 2/1/2026). Berman's pitch follows the documented pattern: (a) cold-solicit reinvestment of the maturity proceeds; (b) upsell — explicit invitation to "add funds to this maturity." **Wed 1/14/2026 3:50 PM** — Luis Jimenez (DCI Associate Director, National Sales) forwards to Celeste Gladden with operational mechanism offer: > Hi Celeste, Just wanted to make sure you know there was an option for the State to reinvest without exchanging funds. If you'd like to reinvest the upcoming maturing bond then we can use the bond as the funding for the new bond. Let me know and I can complete the paperwork to reinvest it with this method. > Redacted communications.pdf, Jimenez to Gladden, 1/14/2026 3:50:41 PM The "reinvest without exchanging funds" option would allow Treasury to use the maturing bond's principal proceeds as direct funding for the new bond (without an outgoing wire and inbound redemption). Treasury did not select this option; the 2/17/2026 wire executed separately from the 2/1/2026 maturity redemption. **Wed 1/14/2026 4:43 PM** — Berman replies (cc Pulley + the full chain), apparently following Pulley's acceptance (Pulley's original response email is preserved only in reply-tail fragments in this extract): > Yes, should make things much easier Steve. I hope your custodian will agree! > > Thanks Celeste as always for all your help. If you have any questions on the redemption process or the book entry process for purchases, please reach out to me, or better, Luis Jimenez copied above, as he's the real operations expert in our office as you know!! > > Thanks again all. > Redacted communications.pdf, Berman to Pulley, 1/14/2026 4:43 PM Pulley's accepted course documented in the reply-tail fragment retained in the chain: "[Book] entry settlement. Book entry settlement should make life easier for all of us. Thanks again!" The Pulley response was sent approximately 2 hours and 12 minutes after Berman's 2:31 PM cold solicitation. **The full text of Pulley's original 1/14/2026 ~4:30-ish PM response email is not preserved in the present extract; only the reply-tail fragment retained inside Berman's 4:43 PM reply.** Recovery of the full text would require a follow-up FOIA. **Thu 1/22/2026 8:08 AM** — Gladden email to Jimenez/Berman/Young (cc Pulley). Content not visible in the present extract. **Thu 1/22/2026 11:20 AM** — Berman follow-up after the certificate had been forwarded for the 2/1/2026 maturity redemption: > Hi Steve, Now that the cert has been forwarded, I wanted to follow up on the Feb 1 reinvestment. Can we answer any questions or assist you with paperwork in any way? We deeply appreciated your review and continued investment in our paper. Looking forward to building our partnership. > Redacted communications.pdf, Berman to Pulley, 1/22/2026 11:20:26 AM **Mon 2/2/2026 3:36:33 PM** — Luis Jimenez emails Gladden + Pulley (cc Young, Berman) with the order-confirmation details and required compliance attachments: > Hi Celeste/ Steve, Please find the investment form for the upcoming investment as well as the accredited investor letter. The accredited investor letter will need to be completed and signed. Let me know if any changes need to be made on the investment form. > > Below are the details for the new bond: > > 13th Series Institutional Jubilee Fixed Rate Bond 5-Year > Cusip: 46515DSQ6 > Issue Date: 2/15/2026 Maturity Date: 2/1/2031 > Interest Rate: 4.93% > Interest Payment Dates: May 1 & November 1 > First Coupon Date: May 1, 2026 > Interest Calc Method: Actual/365 > > The wire should be sent on February 17th, 2026. > Redacted communications.pdf, Jimenez to Gladden + Pulley, 2/2/2026 3:36:33 PM. Attachments: 2025 Accredited Investor Letter 8-1-2025.pdf, Arkansas State Treasurer Investment Form 2-2026 (Book).pdf Note the issue date 2/15/2026 (Sunday) and wire date 2/17/2026 (Tuesday) reflect the Sunday issue date + Monday Feb 16 2026 Presidents Day federal holiday → next business day wire execution. **Tue 2/3/2026 2:30:04 PM** — Gladden replies with the signed accredited investor letter: > Please see accredited investor letter, attached. We will wire funds on Feb 17. > Redacted communications.pdf, Gladden to Jimenez + Pulley, 2/3/2026 2:30:04 PM. Attachment: State of Arkansas Accredited Investor.pdf The signed version is the executed QIB letter for the August 2025 PPM cycle. The signatory is not directly visible in the present extract; comparison to the May 2025 transaction (where Huffman signed) suggests Huffman or another Chief Deputy Treasurer signed the Feb 2026 letter. **The signed PDF is NOT separately produced in R3** despite being a discrete attachment named in the email; recovery would require a follow-up FOIA. **Tue 2/3/2026 1:59:21 PM** — Steven Kilgore to Robert Romanik (cc Holly Beaver), Subject "2026 January - Total Return Tie-Out to Book Return_Treasury Gen AGG (214160).xlsx": > FYI, ROI for January is in at coming to 3.364%, which is lower than January. I don't yet have the breakdowns by category of bond. > Redacted communications.pdf, Kilgore to Romanik, 2/3/2026 1:59:21 PM Routine month-end ROI reporting parallel to the Israel Bonds order coordination occurring on the same day. **Thu 2/12/2026 12:51 PM** — Bradley Young (DCI Executive Director, Atlanta Office – SE Region) emails Gladden + Jimenez + Pulley (cc Berman) with wire-timing confirmation: > Celeste, Thanks so much for your help. Just confirming your below email that you are wiring the funds on Tuesday, the 17th. If you need anything from me, please let me know. Brad > Redacted communications.pdf, Young to Gladden, 2/12/2026 12:51 PM **Tue 2/17/2026 9:34:42 AM** — klinsalaco (Kathie Insalaco) inputs the wire in the Bank of America Outgoing Payments system. **Tue 2/17/2026 9:36:51 AM** — jcohens (Janice Cohens) approves the wire under dual-control. **Tue 2/17/2026 9:46:00 AM** — Gladden emails Bradley Young (cc Jimenez, Pulley, Berman) with wire confirmation: > Bradley, The wire confirmation for today's purchase is attached. Celeste > Redacted communications.pdf, Gladden to Young, 2/17/2026 9:46:00 AM. Attachment: Wire Confirm 2-17-26.pdf The wire confirmation document is the top-level `Wire Confirm 2-17-26_Redacted.pdf` file in R3. #### Order acceptance turnaround: 2 hours 12 minutes The order-acceptance turnaround from Berman's 1/14/2026 2:31 PM cold solicitation to Pulley's ~4:43 PM acceptance is **2 hours and 12 minutes**. The visible reply-tail fragment of Pulley's response confirms only book-entry settlement preference; no internal analytical product (credit re-evaluation, yield-comparison shopping, alternatives analysis) is preserved in the documentary record. The acceptance was within a sub-half-day window; the substantive merits analysis was not produced. This is structurally consistent with R2's 4/16/2025 same-day mechanics documented at [[treasury-internal-credit-analysis]] and [[state-treasurer-israel-bonds-operations]]: Berman pitch → Pulley order placement within hours, no documented intervening internal investment-merits review. The Feb 2026 turnaround is faster (2h 12m) than the May 2025 turnaround (4 hours from Berman's 12:06 PM pitch to Pulley's 2:20 PM order), continuing the pattern. #### The Feb 17 2026 purchase reverses the position trajectory The 10/8/2024 Treasury Israel Internal Credit overview document recommended HOLDING positions and allowing maturities to roll off. The Conclusion's specific prediction: "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 $20M maturing in 2026 referred to the four 2026 maturities documented on the 6/30/2025 Bondholder Statement: 2/1/2026 8th Institutional ($5M), 10/1/2026 12th Jubilee ($5M), 10/1/2026 10th Institutional ($5M), and 11/1/2026 11th Institutional ($10M) — total $25M maturing 2026 (the document said $20M, an arithmetic slip). The Feb 17 2026 purchase is **the second documented substantive override** of the 10/8/2024 HOLD recommendation (after the May 2025 Thurston $20M): - 5/1/2025: $7M maturity rolled off (as predicted) + $20M new purchase (override). Net +$13M. - 2/1/2026: $5M maturity rolled off (as predicted) + $10M new purchase (override). Net +$5M. Position trajectory: - 10/8/2024 memo baseline: $52M (after 2/1/2024 maturity) - 1/1/2025: $42M (after 1/1/2025 $10M maturity) - 5/1/2025 pre-purchase: $35M (after 5/1/2025 $7M maturity) - 5/1/2025 post-purchase: $55M (after Thurston $20M) - 12/31/2025: $55M (stable through year-end) - 2/1/2026: $50M (after 8th Institutional $5M maturity) - 2/15/2026: $60M (after Thurston $10M Feb 17 2026 wire settles) **If the 10/8/2024 HOLD recommendation had been followed, the position at 2/15/2026 would have been $30M. The actual position is $60M. The $30M difference is the cumulative substantive override** ($20M May 2025 + $10M Feb 2026 = $30M new purchases on top of the maturity-roll-off baseline). #### The continued override pattern documents Dortch's 12/6/2024 framing as institutionally durable Damon Dortch's 12/6/2024 2:23 PM articulation — "We buy them to make a political statement and usually at the direction of the elected Treasurer" — predicted the institutional pattern observed across both Thurston-era purchases (May 2025 and Feb 2026). The Feb 2026 transaction documents that the institutional pattern is durable: the elected-Treasurer-directed political-statement purchase mechanism continued through a second purchase cycle without any documented internal re-evaluation of the 10/8/2024 standing HOLD recommendation. The wiki [[treasury-internal-credit-analysis]] concept page is extended to capture this finding. ### End of Year Letter from Treasurer Milligan.pdf Dec 17, 2020 letter on State Financial Officers Foundation letterhead from Dennis Milligan as "2021 SFOF National Chair" to "SFOF Family." The letter's primary purpose is Milligan's pre-chair-installation thank-you to "every sponsor" listed by name on the second-paragraph sponsor list. The SFOF National Leadership Team and Board of Directors are listed in the left navigation. **The sponsor list names "Development Corporation for Israel" among 21 enumerated sponsors:** > Specifically, thank you to: Public Trust Advisors, Federated Hermes, iTEDIUM, Mastercard, American Council of Life Insurers, Academy Securities, Ascensus, Clearwater Analytics, EVERFI, Fidelity, OpenGov, Pomerantz, LLP, Singularis Group, Visa, EnTrust Global, **Development Corporation for Israel**, Claimfound, Arabesque, KKR, J.P. Morgan, and Robbins Geller Rudman & Dowd, LLP. > End of Year Letter from Treasurer Milligan.pdf, 12/17/2020 (emphasis added) This is the **first wiki documentation that DCI is institutionally a financial sponsor of the State Financial Officers Foundation**, not merely engaged through Milligan/Brady individual relationships. The implication: SFOF's promotional infrastructure on Israel Bonds (covered at [[sfof-state-financial-officer-network]] including the Stacy Garrity Pennsylvania case study, the multi-state sign-on letter machinery, and the Israel Bonds product-promotion track) is funded in part by the issuer of the bonds being promoted. SFOF and DCI are in a structural conflict relationship: SFOF promotes Israel Bonds adoption to state financial officers while receiving DCI sponsor funding. The 2020 SFOF National Leadership Team documented in the letter masthead: - President: Derek Kreifels (SFOF) - National Chair: Dennis Milligan (AR, Treasurer) - National Vice Chair: John Murante (NE Treasurer) - Past National Chair: Kelly Mitchell (IN Treasurer) - Auditor At-Large: John "JB" McCuskey (West Virginia State Auditor) - Staff Representative: Lorran Ferguson (Kentucky Deputy Chief of Staff) The 2020 SFOF Board of Directors documented in the letter masthead: - President: John Hart - Vice President: Bridgett Wagner - Secretary/Treasurer: Seth Metcalf - Members at Large: Jimmy Kemp, Lisa B. Nelson, Ron Crane, Derek Kreifels The 2020-2021 era SFOF org chart is now in the wiki documentary record. Subsequent SFOF leadership changes (Kreifels departing for Public Fiduciary Network 2024 / Prospr Aligned 2025; OJ Oleka assuming CEO; Noah Wall as EVP Policy & Government Affairs) document the post-2020 evolution captured at the SFOF entity and concept pages. ### 2023.05.09_Letter_to_Asset_Managers.pdf and 2023.05.09_Letter_to_proxy_advisory_firms.pdf Two parallel DRAFT letters dated May 15, 2023 (the file-naming date 2023.05.09 is the draft-distribution date one week earlier). Both letters are addressed to "[Name of CEO]" of the recipient organization with "[Signatures]" placeholder at the bottom and "INSERT STATE SEALS" placeholder at the top, confirming pre-signing draft status. Both letters identify the Utah Office of State Treasurer as the coordinating office: "If you have any questions about the contents of this letter, please contact the Utah Office of State Treasurer by phone (801-538-1042) or email ([email protected])." The letters are multi-state SFOF-template anti-ESG fiduciary-duty pressure letters. The Asset Managers letter (11 pages) covers shareholder proposals on climate reporting, GHG emissions actions, diversity and racial equity, and specific ESG proponents (National Legal and Policy Center, National Center for Public Policy Research, Steven Milloy). The Proxy Advisory Firms letter (8 pages) covers parallel proxy-voting recommendation practices on the same topics, with additional sections on ISS and Glass Lewis voting guidelines and the 99.5% institutional-investor compliance rate Paul Rose's Manhattan Institute paper documents. Both letters invoke the Vanguard CEO Tim Buckley February 26 2023 Wall Street Journal interview ("ESG investing does not have any advantage over broad-based investing") as authority for the anti-ESG framing, and both letters cite T. Rowe Price's February 2023 proxy-voting guidelines as authority for the "competitive harm" voting standard. **The substantive significance for the wiki**: these are Lowery-era Treasury retentions (May 2023 falls between Milligan's January 2023 term-limited departure and Lowery's August 2023 death). Milligan was Auditor of State by May 2023, not Treasurer. The drafts therefore document **simultaneous parallel SFOF-coordinated anti-ESG letter operation retention at Treasurer's office (under Lowery) and at Auditor's office (under Milligan)**, extending the SFOF Policy Letter Operation concept (currently documented at [[sfof-policy-letter-operation]] as Brady-orchestrated through the Auditor's office) to the Treasurer's office. The wiki has no R3 evidence that Lowery or any subsequent Treasurer signed either letter; the drafts may have been retained for review and not joined. The substantive operational implication: the SFOF policy-letter operation routes drafts to both Treasury and Auditor offices simultaneously. ### 001CS0003_17665_11-soiadv_00005286_20250820054_Redacted.pdf Computershare Bondholder Statement for "ARKANSAS STATE TREASURER, ATTN CELESTE GLADDEN, 1401 W CAPITOL STE 275, LITTLE ROCK AR 72201." Document title "State of Israel - Bondholder Statement 30 Jun 2025." Print date encoded in filename ("20250820") is 8/20/2025. Holder Account Number redacted. Cumulative Treasury Israel Bonds position as of 6/30/2025: **$55,000,000 across 7 CUSIPs.** | Bond Description | Interest Rate | Issue Date | Currency | Total Certificated | Total Book Based | Total Current Value | Maturity Date | CUSIP | |---|---|---|---|---|---|---|---|---| | 11TH JUBILEE FIX 10Y 2.83 2030/01/01 | 2.83% | 15 Jan 2020 | USD | $10,000,000.00 | $0.00 | $10,000,000.00 | 01 Jan 2030 | 46513JHA2 | | 12TH INSTITUTIONAL JUBILEE FIX 3Y 4.66 2028/05/01 | 4.66% | 01 May 2025 | USD | $0.00 | $10,000,000.00 | $10,000,000.00 | 01 May 2028 | 46514X2P3 | | 12TH INSTITUTIONAL JUBILEE FIX 5Y 5.17 2030/05/01 | 5.17% | 01 May 2025 | USD | $0.00 | $10,000,000.00 | $10,000,000.00 | 01 May 2030 | 46514X3P2 | | 11TH INSTITUTIONAL JUBILEE FIX 3Y 5.40 2026/11/01 | 5.40% | 01 Nov 2023 | USD | $10,000,000.00 | $0.00 | $10,000,000.00 | 01 Nov 2026 | 46514AM22 | | 8TH INSTITUTIONAL JUBILEE FIX 5Y 1.35 2026/02/01 | 1.35% | 01 Feb 2021 | USD | $5,000,000.00 | $0.00 | $5,000,000.00 | 01 Feb 2026 | 46514TZG6 | | 12TH JUBILEE FIX 5Y 1.92 2026/10/01 | 1.92% | 15 Oct 2021 | USD | $5,000,000.00 | $0.00 | $5,000,000.00 | 01 Oct 2026 | 46514TQN1 | | 10TH INSTITUTIONAL JUBILEE FIX 5Y 2.07 2026/10/01 | 2.07% | 15 Oct 2021 | USD | $5,000,000.00 | $0.00 | $5,000,000.00 | 01 Oct 2026 | 46514TZZ4 | The "Total Certificated" vs "Total Book Based" columns document the certificate-form-versus-book-entry-form custodial split: the four Milligan-era positions (46513JHA2, 46514TZG6, 46514TQN1, 46514TZZ4) and the Walther-era position (46514AM22) are in certificate form ($35M total certificated); the two Thurston May 2025 positions (46514X2P3, 46514X3P2) are in book-entry form ($20M total book-based). The certificate-vs-book-entry split confirms the April 2025 Book Entry custodial migration covered new purchases (Thurston 5/1/2025) but did not migrate pre-existing certificate positions. **The previously-undocumented substantive finding is the CUSIP-level composition of the Thurston May 1, 2025 $20M purchase**: - **$10M at 12th Institutional Jubilee Fixed Rate 3-Year 4.66%, CUSIP 46514X2P3, Maturity 5/1/2028** - **$10M at 12th Institutional Jubilee Fixed Rate 5-Year 5.17%, CUSIP 46514X3P2, Maturity 5/1/2030** The wiki [[state-treasurer-israel-bonds-holdings]] and [[state-treasurer-israel-bonds-operations]] concept pages framed the Thurston May 2025 transaction as "$20M" without breaking the laddered composition out explicitly. The 3Y/5Y ladder structure is now in the wiki documentary record from the canonical custodial Bondholder Statement. The 5/5/2025 DCI Payment Validation document (Order ORD-2087155, Operations Approver Steven Hill, documented at the [[treasury-foia-r1-7-7-25]] source page) cross-confirms the 3Y/5Y split at the DCI Operations Approval level: Report Number 2025-667-12IIB05FX-2193057-1 ($10M 5-year, Pay Date 5/1/2030) and Report Number 2025-667-12IIB03FX-2193057-2 ($10M 3-year, Pay Date 5/1/2028). The R3 Bondholder Statement is the custodial-side cross-confirmation. ### A1 - November 2025 Investment Recap.pdf and A1 - December 2025 Investment Recap.pdf Two of the 12 monthly SBOF reporting package documents (A1 Investment Recap series) in the production. Format is a 2-page formatted summary documenting (a) MMTF and CD balances, (b) Receipts Variance (warrants vs principal paydowns), (c) Net Income & Investment Projections vs SBOF Q-target, (d) FY2026 Historical ROI by month, (e) Long Term and Short Term portfolio composition by asset category, (f) Market Comments and In Summary, (g) Long Term Portfolio Purchases (per-CUSIP table for the month), (h) **Credit Surveillance** section, (i) Earmarks (CSLFRF balance), (j) FY 2026 Long Term Portfolio Purchases by Month rollup. The Investment Team roster documented in both recap headers (consistent with R2 Sub-batch 3 Treasury staff structure): - MMTF: Celeste Gladden - Liquidity: Damon Dortch - Long Term: Robert Romanik - Long Term: Steve Pulley - Investment Accounting: Holly Beaver (Hester-Beaver), Steven Kilgore **The headline analytical finding from the A1 series is the Credit Surveillance section.** Both the 11/30/2025 and 12/31/2025 recaps include a Credit Surveillance table listing only TWO credits in the entire $11.4B Treasury portfolio: **Honeywell International** (Moody's A2 / S&P A* — "Remains on Negative credit watch") and **Israel** (Moody's Baa1 / S&P A- — "Remains on Negative outlook by both services"). > Credit Surveillance > Honeywell International | A2 | A* | Remains on Negative credit watch > **Israel | Baa1 | A- | Remains on Negative outlook by both services** > A1 - November 2025 Investment Recap.pdf p.2 and A1 - December 2025 Investment Recap.pdf p.2 (emphasis added) **This is the first wiki documentation that Treasury investment staff treat Israel sovereign credit as a routine distressed-watch monitoring item in the monthly Investment Recap.** The two-credit population (Israel + Honeywell) means Israel sovereign credit is one of only two credits in the entire $11.4B Treasury portfolio singled out for active monthly Credit Surveillance distress tracking. **Treasury continues to make new Israel Bonds purchases despite the active Credit Surveillance distress designation.** The Feb 17 2026 $10M new purchase was placed by Pulley with full institutional awareness of the active Credit Surveillance flag on Israel sovereign credit — the credit was on the November and December 2025 Credit Surveillance lists, and the January and February 2026 lists (in the post-purchase A1 recaps not yet in production) presumably continued the listing. The Credit Surveillance practice is itself a substantive Treasury internal credit-monitoring function. The 10/8/2024 internal credit overview's Conclusion explicitly framed the HOLD recommendation as enabling "the team to maintain ongoing credit surveillance for this very fluid situation" — the operational practice documented in the November and December 2025 A1 recaps is the documented continuation of that ongoing credit surveillance. The new finding is that the Credit Surveillance practice was operationally maintained AND new purchases were made under the active surveillance flag. Portfolio composition snapshots (Long Term): **11/30/2025**: Non-US Govt category — 3.98% book return, $55,170,751 book value + accrued, 0.5% weight. Total LT $9,770,332,485 (83.7% of $11,466,041,196 total book port value). **12/31/2025**: Non-US Govt category — 3.83% book return, $55,347,194 book value + accrued, 0.5% weight. Total LT $9,771,089,480 (83.6% of $11,455,134,383 total book port value). The $55,170,751 → $55,347,194 month-over-month change is +$176,443, consistent with accrued-interest accumulation on the existing $55M position (no principal change). Position is stable at $55M throughout November and December 2025. The Long Term Portfolio Purchases by Month table (per the 12/31/2025 recap): | Month | Purchases | |---|---| | July 2025 | $37,212,000 | | August 2025 | $10,000,000 | | September 2025 | $122,632,768 | | October 2025 | $103,165,081 | | November 2025 | $45,000,000 | | December 2025 | $47,256,000 | | **1H FY2026** | **$315,265,849 (Down -37% vs FY 2025)** | The August 2025 $10M long-term purchase was NOT Israel Bonds (the Non-US Govt line is stable at $55M through November and December). The August 2025 Accredited Investor Letter 8-1-2025 PPM cycle therefore sat unused for the full 6.5-month window August 2025 - February 2026 before being executed against on Feb 17 2026. The Market Comments and In Summary sections in both recaps document Federal Reserve rate-cut activity: November ("eyeing another 25bps rate cut for December"; the Government reopened November 12th to end the longest government shutdown in history); December ("The Federal reserve cut rates for a 3rd consecutive time in the month of December bringing the discount rate down to (3.50% - 3.75%)"; "Early indications point to a pause in rates for the time being"). ### June 15-30.pdf DCI Institutional Offering Rate Sheet for the **12th Series** Jubilee Fixed Rate Institutional Bonds, valid June 15th - June 30th 2025. The filename "June 15-30.pdf" indicates 2025 from the 12th Series designation (the 13th Series began at or about the January 2026 sheet documented above). Rate table for the Jun 15-30 2025 settlement window: | Bond Tenor | Interest Rate | CUSIP | |---|---|---| | 2-Year | 4.35% | 46514XZ36 | | 3-Year | 4.77% | 46514X2T5 | | 5-Year | 5.12% | 46514X3T4 | | 10-Year | 5.67% | 46514X4T3 | | 15-Year | 5.92% | 46514X5T2 | Treasury did NOT execute against this rate sheet; no Israel Bonds purchase occurred in the Jun 15-30 2025 window per the 6/30/2025 Bondholder Statement. The rate sheet documents DCI's ongoing promotional pipeline to Treasury (rate sheets are sent to Treasury per the established Berman-Pulley channel) but Treasury's purchase cadence is not driven by rate-sheet receipt. Rate trajectory comparison across the documented R3 rate sheets: | Window | Series | 5-Year Rate | 5-Year CUSIP | |---|---|---|---| | Jun 15-30 2025 | 12th | 5.12% | 46514X3T4 | | Jan 15-31 2026 | 13th | 4.86% | 46515DSP8 | | Feb 1-14 2026 (not in production, inferred from email) | 13th | **4.93%** | **46515DSQ6** | The Treasury 2/17/2026 purchase locked in 4.93% — higher than the immediately-preceding window's 4.86% but lower than the prior 5.12% by 19 bps. The rate trajectory broadly reflects the Federal Reserve's 75 bps of cuts during the late-2025 / early-2026 cycle. ## Operational tail available for future spot-check verification The following R3 files are available in the production but were not individually ingested per the user direction to "skip Phase B" cross-confirmation reads. The following operational-tail content is documented as available for future spot-check verification: **DASH daily trading dashboards (~49 PDFs)**: Daily Purchases & Sales Dashboard PDFs from `DASH_20251120` through `DASH_20260213`. Document daily Treasury portfolio trading activity at the daily-transaction level. The DASH files for 2/12/2026 and 2/13/2026 (immediately preceding the 2/17/2026 wire) are the highest-priority spot-check targets if Israel-Bonds-specific daily-transaction-level documentation is needed. **A1 / A2 / A3 / B1 / B2 / C monthly SBOF reporting package (12 documents for November and December 2025)**: - A1 Investment Recap (the November and December files ingested above) - A2 Market Outlook (November + December) - A3 Accounting Notes (November + December) - B1 CP Trading Worksheets (November + December) - B2 Daily Purchases & Sales Dashboards (November + December) - C Treasury Mgmt Signoff (November + December) **ROI Reports (11 documents covering July 2025 - January 2026)**: - 2025 0731 ROI - MMTF - Preliminary.xlsx - 2025 0731 ROI - Treasury General - Preliminary.xlsx - 2025 0731 ROI - Treasury General.xlsx - 2025-8-31 ROI Report - Treasury General.xlsx - 2025 0930 ROI Report_Treasury Gen AGG (214160).xlsx - 2025 1031 ROI Report - Treasury General - PDF.pdf and .xlsx - 2025 1130 ROI Report - Treasury General - PDF.pdf and .xlsx - 2025 1131 - Preliminary ROI.xlsx (Note: "1131" is a Treasury internal naming for the 11-month FY position; not a calendar date) - 2025 1231 ROI Report_Treasury Gen AGG (214160).xlsx - 12. ROI Report_Treasury Gen FY2026.pdf - ROI Report_Money Mgmt AGG (214159) - Preliminary.xlsx - ROI Report_Treasury Gen AGG (214160) - Preliminary.xlsx - ROI Report _Treasury Gen AGG (214160) - PDF.pdf **Israel Bonds asset-class Cash Flow xlsx files (2 dated specifically for Israel Bonds)**: - 2025 1103 IA- Non- MBS Cash Flow_Treasury Gen AGG- ISRAEL BONDS- PAR.xlsx (November 3 2025 cash-flow report; documents per-CUSIP coupon payments expected November 1 2025) - 2026 0202 IA- Non- MBS Cash Flow_Treasury Gen AGG- ISRAEL BONDS- PAR & MATURITY.xlsx (February 2 2026 cash-flow report; documents the 8th Institutional CUSIP 46514TZG6 $5M maturity event and concurrent coupon payments expected February 1 2026) The 2/2/2026 cash-flow report is the operational documentation of the Feb 1 2026 maturity event that Berman's 1/14/2026 cold solicitation pitched as reinvestment opportunity. Holly Hester-Beaver's 2/2/2026 7:49:32 AM cover email in the Redacted communications.pdf extract (line 197+) accompanies this file: "The Israel bond does also have a maturity, so I noted that on the spreadsheet. The Israel bond coupons should come through as a wire from Computershare at some point today." The cover note documents Treasury Investment Accounting's awareness of the 2/1/2026 maturity event and the parallel coupon-payment event on the same day. **Historical operational reports (cross-confirmation only)**: - 2021 0831 Total Return Tie-Out to Book Return_Treasury Gen AGG (214160).xlsx - 2022 0630 Total Return Table_Treasury Gen AGG (214160).xlsx - 2026 January - Total Return Tie-Out to Book Return_Treasury Gen AGG (214160).xlsx - Base Attribution_Treasury Gen AGG (214160).xlsx - Base Exposure - Duration_Art-Treasury General SK (213341).xlsx - Base Returns_Treasury Gen AGG (214160).pdf - Copy of 2020 12 OpenGov.xlsx - Copy of OpenGov Reports Draft 2020 0930 Revised 1027.xlsx (and "Copy of Copy of" variant) - Copy of Open Gov Report February 2021.xlsx - 9-30-2025 Treasury General Data.xlsx - JUNE 2025 CUSTODY BALANCES CROSSMATCH.xlsx - Investment Income Receipted by Month by Type TAS0000.xlsx - Arkansas State Treasurer Investment Form 2-202_Redacted.pdf (blank generic Investment Form template) - State of AR LT Port 6-30-2023.xlsx - All_data_export_-_usage_details.xlsx - Dashboard definition page.docx **SFOF event/logistics documents (historical context only)**: - 2020 Virtual Conference Detailed Schedule.pdf - SFOF Airport Meet and Greet Info and Instructions.pdf - SFOF National Meeting July 2021 - 1.pdf - SFOF Online Meeting Graphic.pdf32 (003).pdf - SFOF Travel Reimbursement Policy.pdf These SFOF documents are likely R2-residual (the R2 Sub-batches 4-8 ingest documented the comprehensive Communications attachments folder content) and may have been re-included in R3 from prior retention, not new captures. ## Structural findings and FOIA follow-up targets ### Structural findings already in the R3 directory survey (a) **No Treasury Investment Policy version added since February 8, 2022.** Confirmed by the Investment Policy subdirectory's preservation of the same 5 versions as R2. The Treasury IP has not been amended to reflect Act 739 of 2025 (which removed the two-NRSRO investment-grade requirement that the February 8, 2022 IP introduced). Documented at [[independent-credit-analysis-gap]] under "The 2022 IP two-NRSRO requirement and Act 739 of 2025." (b) **No FY2026 custodial statements** despite the production being made 2/19/2026 — 7 months post-FY2026 start (July 1, 2025) and 7 months of Treasury custody activity at BNY for the period July 2025 - January 2026. The FY2026 ACCT 398 monthly custodial statements are a FOIA follow-up target. (c) **9/30/2025 Quarterly Investment Inventory missing** despite the production date being 4.5 months post-period-close (allowing ample time for the inventory to be produced under Treasury's documented quarterly cycle). The 9/30/2025 inventory is a FOIA follow-up target. (d) **R3 file-modified timestamps are all 2/19/2026 23:23**. Files were re-stamped at production export time; cross-confirmation with R2 cannot rely on modification timestamps alone — byte-size and filename matching are the working duplicate-detection methods. ### New FOIA follow-up targets surfaced by Phase A reads 1. **The Feb 1-14 2026 DCI Institutional Offering Rate Sheet** (showing CUSIP 46515DSQ6 at 4.93% 5-Year). The Treasury 2/17/2026 purchase locked in this rate. The rate sheet is not in R3 despite the Jan 15-31 2026 sheet being included. Treasury investment staff received the Feb 1-14 sheet but it is not in the production. 2. **Pulley's full Jan 14 2026 4:43 PM order email** to Berman. The Redacted communications.pdf extract preserves only the reply-tail fragment retained inside Berman's 4:43 PM reply. The original order email (containing Pulley's full content) is a FOIA follow-up target. 3. **The Arkansas State Treasurer Investment Form 2-2026 (Book).pdf** that Jimenez attached to the 2/2/2026 order-confirmation email. The form documents the specific terms Treasury agreed to. Not separately produced in R3 (only the blank 2-202 generic Investment Form template is present at top level). 4. **The signed "State of Arkansas Accredited Investor.pdf"** Gladden returned to Jimenez on 2/3/2026 2:30 PM with Treasury's checkboxes marked and signed for the August 2025 PPM cycle. The signed PDF is a FOIA follow-up target; the signatory identity (Huffman? Munson? Treasurer?) would document the Feb 2026 transaction's Chief-Deputy-Treasurer-level authorization step parallel to the May 2025 Huffman signature. 5. **FY2026 monthly custodial statements** for July 2025 - January 2026 (7 statements). 6. **9/30/2025 Quarterly Investment Inventory** completing the quarterly-inventory record through end-of-Q1-FY2026. 7. **Treasury IP amendment activity post-February 2022** — confirmation that no further IP versions exist OR scope query for newer versions (especially any Act 739 of 2025 implementing amendment). 8. **Three-quotation-bid / broker-selection-competitiveness documentation for the 2/15/2026 Israel Bonds settlement** (extending R2 follow-up target A from prior purchases to the new Feb 2026 purchase). Under the December 3, 2019 IP amendment's escape clause for sole-sourced asset classes, 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)." The R3 production contains no such broker-selection-competitiveness documentation for the Feb 2026 purchase. 9. **The Olan Reeves successor at General Counsel role** post-2024 (Reeves was Interim General Counsel late 2024 per R1). Any FOIA correspondence or Treasury legal-counsel review of the Feb 2026 purchase is not in R3. 10. **The 2/3/2026 - 2/12/2026 internal Treasury thread** (between Gladden's 2/3/2026 signed-accredited-investor return and Bradley Young's 2/12/2026 wire-confirmation). The Redacted communications.pdf extract shows no Treasury-internal email traffic in this 9-day window; whether any internal Treasury review or notification occurred during this window is undocumented. 11. **Treasury internal documentation of awareness of the Israel Credit Surveillance flag at the time of the 2/17/2026 purchase decision.** The A1 November 2025 and December 2025 Investment Recaps document the active Credit Surveillance flag. Whether Pulley or Huffman documented the awareness of the flag in connection with the 2/17/2026 purchase decision is not in R3. 12. **SBOF presentation of the 2/17/2026 purchase**. Thurston's 5/12/2025 SBOF remarks on the May 2025 purchase used the "consistent with our historical levels" framing. Whether the 2/17/2026 purchase is similarly reported to SBOF, and what framing is used, is a future ingest target. The next SBOF meeting after the 2/17/2026 wire would likely be a Q3 FY2026 meeting (the Q1 FY2026 meeting that R3 references as the Steven Kilgore "Q1 2026 SBOF" 11/3/2025 prep email referred to a meeting that occurred in November 2025). ## Cross-references [[treasury-foia-r1-7-7-25]] [[treasury-foia-r2-9-23-25]] prior Treasury source pages; R3 extends the chronology through February 2026 [[state-treasurer-israel-bonds-holdings]] holdings concept page; updated for the Feb 2026 purchase and the 3Y/5Y ladder correction on the Thurston May 2025 transaction [[state-treasurer-israel-bonds-operations]] operational pathway concept page; extended to document the Feb 2026 transaction chronology [[treasury-internal-credit-analysis]] internal credit analysis concept page; extended to document the monthly Credit Surveillance practice and the Feb 2026 second-instance override [[independent-credit-analysis-gap]] cross-system gap concept page; extended to document the Feb 2026 chronology continuation [[sfof-state-financial-officer-network]] SFOF concept page; extended to document DCI as institutional SFOF financial sponsor [[sfof-policy-letter-operation]] SFOF policy letter operation concept page; extended to document Lowery-era Treasury retention of the May 2023 SFOF anti-ESG drafts [[lawrence-berman]] [[steve-pulley]] [[celeste-gladden]] [[bill-huffman]] [[john-thurston]] Treasury-DCI principals on the Feb 2026 transaction [[luis-jimenez]] DCI Associate Director, National Sales; operational principal on the Feb 2026 transaction's order-confirmation and compliance coordination [[brad-young]] DCI Executive Director, Atlanta Office, SE Region; wire-timing-confirmation participant on the Feb 2026 transaction [[dennis-milligan]] Auditor of State (post-January 2023); author of the Dec 17, 2020 SFOF End of Year Letter as incoming 2021 SFOF National Chair that names DCI as institutional sponsor [[damon-dortch]] [[robert-romanik]] [[steven-kilgore]] [[holly-hester-beaver]] Treasury investment team and accounting principals documented on the Investment Recap headers and the Israel Bonds Cash Flow coordination [[janice-cohens]] Treasury cash-management staff; wire-approver on the 2/17/2026 transaction (newly promoted from R2 Sub-batch 3 distribution-list-level documentation to entity page) [[kathie-insalaco]] Treasury cash-management staff; wire-inputter on the 2/17/2026 transaction (newly promoted from R2 Sub-batch 3 distribution-list-level documentation to entity page)