Documents — FOIA Public Records Archive
Every claim traces back to these records. Browse the primary sources yourself.
About these documents
These are excerpts and key documents from more than 1,200 public records obtained by Arkansans for Pension Integrity through three rounds of Freedom of Information Act requests to Arkansas state agencies: the State Treasurer’s Office, Arkansas Teacher Retirement System (ATRS), Arkansas Public Employees Retirement System (APERS), the Arkansas Auditor of State, and the Arkansas State Highway Employees’ Retirement System (ASHERS).
All documents were provided by the agencies in response to lawful FOIA requests. Where noted, page ranges have been extracted from larger compiled document sets. No content has been altered.
1,227 documents obtained across three FOIA rounds from Arkansas state agencies. 12 requests filed across four rounds (AJRS Round 4 response pending). Every claim on this site traces back to these records.
Primary sources
Key evidence documents
- Auditor's communications director calls the bond issuer's representatives "friends" in internal email Internal email from Auditor's Director of Communications to a colleague, expressing personal support for the bond issuer's representatives Larry Berman and Brad Young AUDIT-JUN25-0568
- Bond issuer marketing materials sent to Auditor's .gov email Marketing and promotional materials from the bond issuer directed to the State Auditor's government email address AUDIT-JUN25-0085
- Bond issuer's "Private & Exclusive" briefing invitation for Milligan and staff Invitation to a private economic briefing hosted by the bond issuer for the State Auditor and his staff AUDIT-JUN25-0001
- Berman calls Milligan "truly one of a kind, forever grateful" on Oct 7 anniversary The bond issuer's national managing director Lawrence Berman's correspondence with State Auditor Milligan on the anniversary of October 7, praising his support AUDIT-JUN25-0516
- ADG article: $10M purchase announced, Governor Sanders quote Arkansas Democrat-Gazette coverage of the $10 million Treasury purchase, including Governor Sanders stating Arkansas "stands with Israel" TREAS-SEP25-0008
- Official purchase confirmation — November 2023 State Treasury purchase confirmation for a $10 million non-tradable sovereign bond (3-year Jubilee at 5.40%), dated November 1, 2023. For context on the political statements surrounding this purchase, see our evidence page TREAS-SEP25-0066
Extracted records
Excerpts from compiled records
These are page-range extracts from larger compiled FOIA response documents.
- Bond salesmen congratulate Treasurer on re-election The bond issuer's representatives congratulate Dennis Milligan on his 2018 re-election as State Treasurer. Pages 19–21 of original. TREAS-SEP25-0015
- Berman cites deceased Treasurer Lowery's verbal promise The bond issuer's national managing director Lawrence Berman invokes a verbal commitment from the late Treasurer to push purchases. Pages 50–51 of original. TREAS-SEP25-0015
- Berman thanks APERS staff for "kind hospitality" Thank-you correspondence from the bond issuer to APERS staff after a meeting, with follow-up sales pitch. Page 26 of original. APERS-JUL25-0002
- Berman uses $20M Treasury purchase as sales leverage The bond issuer's executive cites the State Treasury's $20 million purchase as leverage while pitching APERS Executive Director Amy Fecher. Pages 589–590 of original. APERS-JUL25-0002
- Milligan nominated as SFOF National Chair State Financial Officers Foundation nominates Dennis Milligan as National Chair. Pages 307–308 of original. TREAS-FEB26-0108
Reference materials
Reference documents
- Treasury investment policy — the standards that should apply The State Treasurer's most recent investment policy document, establishing the pecuniary and prudent-investor standards for state investments TREAS-SEP25-0049
- Purchase confirmation — May 2025 State Treasury purchase confirmation for a $10 million non-tradable sovereign bond (3-year Jubilee at approximately 4.86%), dated May 2025. For context on how this purchase followed internal recommendations against new purchases, see our evidence page TREAS-SEP25-0063
Second FOIA round
Round 2 FOIA responses (February 2026)
A second round of FOIA requests produced 265 additional documents:
Treasury
- Documents: 118
- Pages: 2,526
- Contents: Daily trading dashboards, ROI reports, sovereign bond cash flow projections, 412-page redacted communications compilation, custodial statements, SFOF conference materials, portfolio snapshots, marketing materials, management signoff records
APERS
- Documents: 16
- Pages: 9,241 total
- Contents: Four quarterly board packets (March–December 2025), four Investment Finance Committee subcommittee packets, 8,648-page comprehensive FOIA production, six sets of meeting minutes
ATRS
- Documents: 7 (partial response)
- Pages: 51
- Contents: Investment guidelines for "Israeli Jubilee bond account" (document title) managed by Reams Asset Management, contract documents, sign-in sheets, email files
- Status: Full scope confirmed in writing by ATRS General Counsel; full response not yet delivered
Auditor of State
- Documents: 124
- Pages: Delivered via flash drive
- Contents: Email correspondence from three custodians (Dennis Milligan, Jason Brady, Wendy Spadoni) covering bond purchase coordination, SFOF conference materials, media response chains, and board meeting correspondence
- Status: Received March 3, 2026; fully processed
Third FOIA round
Round 3 FOIA responses (March 2026)
A third round of FOIA requests expanded the investigation to previously uninvestigated retirement systems:
ASHERS (Arkansas State Highway Employees' Retirement System)
- Documents: 5
- Contents: Email correspondence revealing that the bond issuer's national sales leadership was introduced to ASHERS staff through the same April 2025 pitch tour, but ASHERS declined to invest
ASPRS (Arkansas State Police Retirement System)
- Documents: 0 (null result)
- Contents: Confirmed no responsive documents — assets commingled with APERS under Act 1242 of 2009
LOPFI (Local Police and Fire Retirement System)
- Documents: 0 (null result)
- Contents: Confirmed no responsive records and no current holdings of the bonds under investigation (April 9, 2026); LOPFI manages investments independently with approximately $3.15 billion under management
Fourth FOIA round
Round 4 FOIA request (May 2026)
A fourth round of FOIA requests was filed in May 2026 after AJRS was identified as the sixth Arkansas pension system covered by Act 498:
AJRS (Arkansas Judicial Retirement System)
- Status: Response pending. FOIA filed May 8, 2026; acknowledged same-day by Richmond Giles, APERS Staff Attorney; production deadline extended to May 15, 2026 by mutual agreement.
- Contents: AJRS is administered by APERS staff and shares investment infrastructure, but operates as a separate benefit plan with its own Board of Trustees and trust fund (~$309 million AUM, ~89% funded). FOIA request filed to determine whether AJRS trust assets were included in sovereign bond purchases made through the APERS investment pool. The same-day acknowledgment by APERS legal counsel — the single attorney handling correspondence for both pension systems — operationally confirms the shared-staff structure.
Additional source documents are available upon request. Contact info@arpensions.org.