Evidence — Key Findings from 1,222 Arkansas Public Records

Key findings from more than 1,200 public records obtained through two rounds of FOIA requests to four Arkansas state agencies

Our research

Arkansans for Retirement Transparency has analyzed more than 1,200 public records from two rounds of Freedom of Information Act (FOIA) requests to four Arkansas state agencies: the State Treasury, ATRS, APERS, and the Auditor of State. The first round (August 2025) covered all four agencies; the second round (February–March 2026) produced responses from all four: Treasury (118 documents), APERS (16 documents including an 8,648-page production), ATRS (7 documents, partial response), and the Auditor of State (124 documents from three custodians, delivered March 3, 2026 via flash drive).

Every claim on this site is backed by documents in the public record. Below are the key findings.

Read the source documents. We’ve published key FOIA documents for you to review yourself. Browse the document archive →

Key findings

1. No independent credit analysis

Of more than 1,200 documents reviewed, zero contained an independent credit analysis of Israel Bonds prepared by pension fund staff or outside consultants. Standard investment practice requires pension fund managers to conduct or commission their own due diligence — not rely on sales materials from the bond issuer.

Arkansas’s pecuniary-only standard (Act 411 of 2023) and the prudent-investor rule (Ark. Code §§ 24-2-610–619) both require documented financial analysis before committing member funds to new investment positions. This finding holds across all documents received in Round 2 — including APERS’s 8,648-page FOIA production and Treasury’s 118-document response. The absence of any independent credit analysis in the entire public record is a significant gap.

On October 8, 2024, Steve Pulley, a Senior Investment Officer in the State Treasurer’s office, wrote an internal memo raising concerns about Israel Bonds. The memo noted that major credit-rating agencies — specifically Fitch, Moody’s, and S&P — had downgraded Israel’s credit rating, citing “heightened security risks and weakened economic prospects.” The memo recommended that Arkansas “hold our positions and allow for the $17M to roll off in the first half of 2025 and the $20M maturing in the calendar year 2026.” (For the investment standards that should have governed this decision, see the Treasury investment policy.)

Instead, even as bonds matured in accordance with the memo’s recommendation, the state purchased $20 million in new Israel Bonds. By May 2025, Senior Investment Officer Steve Pulley confirmed the Treasury held $55 million in Israel Bonds — roughly the same level the memo had recommended letting decline. What changed was not the credit outlook, but the political calculus.

3. Sales representatives met with agencies before authorizations

In April 2025, Israel Bonds national and regional sales representatives met with the directors of both ATRS and APERS, along with the State Treasurer and State Auditor. State Auditor Dennis Milligan arranged the meetings. A thank-you email from Israel Bonds executive Lawrence Berman later used the Treasury’s $20 million purchase as sales leverage on the APERS director. A separate thank-you email to APERS staff praised their “kind hospitality” and pitched follow-up meetings.

Within weeks:

  • The State Treasury purchased $20 million in new Israel Bonds
  • APERS authorized $25–50 million (May 15, 2025)
  • ATRS authorized up to $50 million (June 2, 2025)

In reply, an Israel Bonds executive called Milligan “truly one of a kind” and said he was “forever grateful” for his support. (Read the correspondence)

— Lawrence Berman, Israel Bonds National Managing Director, replying to the Auditor’s office on the October 7 anniversary (source document)

This language describes a political relationship, not a standard financial transaction.

3a. How Israel Bonds reached the APERS board

New records obtained in February 2026 confirm the specific pathway by which Israel Bonds were introduced at APERS. Jason Brady — the Auditor of State’s appointee to the APERS board — told fellow board members that “it had come to his attention” that Israel Bonds were available as an investment, and cited the State Treasury’s existing holdings: “The State Treasury currently holds approximately $55 million in Israel Bonds as part of its $11 billion portfolio.” The board subsequently approved an investment of $25–50 million.

Brady’s introduction framed Israel Bonds as already vetted by another state entity, implicitly reducing the perceived need for independent analysis. The chain is direct: Dennis Milligan, the former Treasurer who initiated Israel Bonds purchases at Treasury and then became Auditor of State, appointed Brady to the APERS board. Brady then introduced the same investment to that board.

The Auditor’s office also served as APERS’s de facto media response coordinator. When Arkansas Times journalist Jennifer Lenow sent APERS a request for comment about the Israel Bonds investments, Executive Director Amy Fecher’s first action was not to consult APERS’s own communications staff — it was to forward the inquiry to Jason Brady at the Auditor’s office with “FYI,” CC’ing Spadoni. Separately, when ATRS Executive Director Mark White sent the ATRS board a heads-up about the Arkansas Times investigation, Brady forwarded that email the same evening to Milligan’s personal AOL email address — routing state business communications outside the official state email system. The next morning — a Saturday — Brady forwarded the same chain to Stacy Peterson, the Auditor’s communications staff.

The conduit chain: Milligan initiates Israel Bonds at Treasury → becomes Auditor of State → appoints Brady to APERS board → Brady introduces Israel Bonds to APERS citing Treasury holdings → board authorizes $25–50 million without independent analysis.

3b. Board voted before staff had a contact

Despite the board’s May–June 2025 authorization of $25–50 million, APERS purchased zero Israel Bonds for at least two months. On July 30, 2025, Executive Director Amy Fecher confirmed: “Still zero for APERS.” The following day, CIO Carlos Borromeo emailed Seth Middleton at Stephens Inc. — APERS’s investment consultant — asking him to forward contact information to Bradley Young, Southeast Regional Executive Director at Israel Bonds.

By November 2025, a bond statement was received by APERS staff, indicating a purchase had eventually occurred. The two-month gap between authorization and purchase — and the fact that staff were still establishing basic contact with Israel Bonds representatives well after the board vote — suggests the board authorized the investment before operational groundwork was in place.

3c. Two pension funds, two approaches — neither with independent analysis

Round 2 records reveal that APERS and ATRS took markedly different paths to the same investment:

APERS chose to purchase Israel Bonds directly, with no external investment manager. CIO Carlos Borromeo stated: “APERS intent is to purchase the bonds directly. Staff opinion is that there is not a need to incur management fees.” This means APERS has no independent fiduciary oversight of its Israel Bonds position.

ATRS, by contrast, hired Reams Asset Management (a division of Columbus Investments Inc.) and established formal “Investment guidelines for the Arkansas State Teacher Retirement Israeli Jubilee bond account” dated September 25, 2025 — roughly four months after the board authorized the investment. ATRS’s approach included a professional manager and written guidelines, but the guidelines were created after the authorization, not before.

The divergent structures raise a common question: in neither case has any independent credit analysis of Israel Bonds been produced. Whether purchased directly (APERS) or through a manager (ATRS), the investment arrived at both pension funds through the same political channel — not through the professional investment process each system ordinarily follows.

3d. Agencies were watching each other

APERS’s FOIA production contains news articles about ATRS’s Israel Bonds investment and its arrangement with Reams Asset Management — articles that APERS staff apparently circulated or received internally. Combined with Brady citing Treasury’s $55 million holdings at the APERS board meeting, a pattern emerges: each agency’s decision was influenced by awareness of what other state agencies were doing, rather than by independent financial analysis.

3e. The Auditor arranged a two-day pitch tour in his own office

Records obtained in March 2026 reveal the Auditor of State’s office personally orchestrated a coordinated pitch tour for Israel Bonds sales representatives. On Friday, April 11, 2025, Auditor Dennis Milligan and his executive assistant Wendy Spadoni sent four meeting arrangement emails within 18 minutes — scheduling back-to-back meetings for Israel Bonds executives Lawrence Berman and Bradley Young with the heads of all three investing agencies:

  • 2:01 PM — Spadoni to APERS Executive Director Amy Fecher: Monday, April 14 at 9:00 AM
  • 2:02 PM — Milligan to APERS Investment Subcommittee Chair Daryl Bassett: Monday, April 14 at 1:15 PM
  • 2:18 PM — Milligan to ATRS Executive Director Mark White: Tuesday, April 15 at 10:00 AM
  • 2:18 PM — Milligan to State Treasurer John Thurston: Tuesday, April 15 at 11:30 AM
Every meeting was scheduled in the Auditor’s own office — Room 230 of the State Capitol. Every email was CC’d to Jason Brady, the Auditor’s deputy. Every email attached biographical documents for Berman and Young. A planner note from Spadoni’s calendar, dated March 31, 2025, corroborates pre-planning: “★ Larry Berman trip 13th 14th or 15th.”

The Auditor of State has no investment authority over any of these funds. The Auditor does not manage pension assets, does not sit on pension investment committees, and plays no formal role in the Treasury’s bond purchases. Yet this office — through Milligan personally — convened every decision-maker in the state who would need to approve Israel Bonds purchases, arranged the meetings in his own Capitol office, and staffed them through Brady.

Within weeks of these meetings, all three agencies authorized or purchased Israel Bonds: the Treasury bought $20 million (May 1), APERS authorized $25–50 million (May 15), and ATRS authorized up to $50 million (June 2).

3f. ATRS deployed the full $50 million by December 2025

On December 29, 2025, ATRS Deputy Director Rod Graves sent a routine “Board Update-Liquidity” email to the ATRS board. Buried in the liquidity accounting was the first post-purchase confirmation in the public record: “December payments since the last Board update consisted of several ATRS obligations including capital calls for various investments of approximately $185 million. This includes the Scout (Reams) mandate of $50 million for Israel Bonds.”

The full $50 million authorized by Resolution 2025-22 was deployed in a single transaction through ATRS’s investment manager, Reams Asset Management (operating as Scout). This confirms that the authorization moved from board vote (June 2, 2025) to investment guidelines (September 25, 2025) to full deployment (December 2025) — a six-month process in which the financial analysis that should have preceded authorization was never produced.

ATRS’s $23.7 billion portfolio now holds $50 million in non-tradable sovereign debt that cannot be sold before maturity, purchased without an independent credit analysis at any stage of the process.

3g. 37 pages of analysis for other investments, zero pages for Israel Bonds

The publicly-posted APERS board packets for the May 15 Investment Subcommittee and June 11 Full Board meetings reveal a stark contrast in how the board handled different investment decisions at the same meetings.

For secondary infrastructure investments (up to $100 million each in three funds), the board received:

  • 8 slides of CIO analysis from Carlos Borromeo on portfolio positioning and risk/return characteristics
  • 32 pages of Callan analysis evaluating six finalists (Ares, Blackstone, HarbourVest, Macquarie, Pantheon, Partners Group) with quantitative screening, performance comparisons, and fee analysis
  • Presentations from three institutional firms (HarbourVest, Neuberger Berman, Stephens Inc.)
  • Board member questions about due diligence methodology (Jim Hudson) and recommended direction (Larry Walther to CIO)

For private credit (discussed at the same May 15 meeting):

  • Written briefings from Stephens (quantitative performance data: 8.8% average return for direct lending vs. 4.4% for high-yield bonds), HarbourVest, and Neuberger Berman
  • Board discussion of allocation percentages and portfolio fit

For the $25–50 million Israel Bonds authorization (also at the May 15 meeting):

  • Zero pages of written analysis
  • Zero involvement from CIO Carlos Borromeo
  • Zero Callan review (Callan analyzed every other investment in the packet)
  • No credit analysis, yield comparison, liquidity assessment, or consultant recommendation
  • One board member’s verbal pitch — Jason Brady, the Auditor’s proxy
  • No recorded questions from any board member
  • Motion, second, carried without dissent

The June 11 full board packet — the 88-page document every board member received before ratifying the subcommittee’s actions — contains 15 slides of CIO market analysis, 37 pages of Callan quarterly performance reporting with peer rankings and investment manager returns, and 5 pages of Stephens private equity reporting. The Israel Bonds authorization appears only in the embedded subcommittee minutes (4 pages) and a two-paragraph summary in the subcommittee chair report. No Israel Bonds analysis of any kind accompanies it.

At the same meeting, the CIO’s own MSCI EAFE country performance chart showed Israel returning -1.97% for Q1 2025 — one of only three negative-return countries in the 21-country index. This data was presented to the same board that was ratifying the Israel Bonds authorization. No one connected the data points.

Also at the same May 15 meeting, Secretary Jim Hudson requested that APERS develop a competitive RFP for investment advisor services — insisting on competitive bidding for who advises the fund, while accepting no competitive analysis for what the fund invests in.

Source: APERS Board Packet for June 11, 2025, publicly posted at apers.org. Also exists in the FOIA registry as APERS-FEB26-0002.

3h. ATRS leadership present at APERS authorization

The May 15, 2025 APERS Investment Subcommittee meeting — where Brady pitched Israel Bonds and the board authorized $25–50 million — was attended by three ATRS officials listed as visitors: Executive Director Mark White, Rod Graves, and Tammy Porter.

White is the same ATRS Executive Director whose office initially denied a FOIA request seeking Israel Bonds records as “insufficiently specific” in December 2024 (read the response). Both ATRS and APERS authorized first-ever direct Israel Bonds purchases in the same period. The presence of ATRS leadership at the APERS authorization meeting suggests coordination or at minimum awareness of the cross-system initiative.

The two pension systems also have an established pattern of coordination: in the Five Below securities litigation case (E.D. Pa.), ATRS and APERS hold joint lead plaintiff status, and both pursued the Trade Desk case jointly with MissPERS.

Source: APERS Board Packet for June 11, 2025, page 8 (May 15 subcommittee attendee list) and page 75 (securities litigation case status).

3i. Former Treasurer chaired the subcommittee that authorized Israel Bonds

Larry Walther — who served as Arkansas’s 40th Treasurer of State from August 2023 to January 2025 and maintained the Treasury’s Israel Bonds position throughout his tenure — chaired the Investment Finance Subcommittee that authorized APERS’s first-ever Israel Bonds purchase. The May 15, 2025 subcommittee minutes record “Mr. Larry Walther presided” as Chair of the Investment Finance Sub-Committee.

The former Treasurer who oversaw $55 million in Treasury Israel Bonds holdings now chairs the pension subcommittee that authorized $25–50 million more in the same instrument — and the subcommittee received zero pages of independent analysis before voting.

Additionally, APERS Board Secretary Daryl Bassett had previously appointed Jason Brady to preside over the March 5, 2025 subcommittee meeting, meaning Brady was sometimes the presiding officer of the very committee he later pitched Israel Bonds to.

Source: APERS Board Packet for June 11, 2025, pages 8 and 4.

4. Board Chair raised process concerns

ATRS Board Chair Danny Knight cast the sole “no” vote on Resolution 2025-22 (June 2, 2025), warning that selecting a specific bond at a trustee’s request was “going outside of the scope of the way we usually do things.” ATRS typically relies on professional investment managers — not board members or their proxies — to recommend specific securities.

“Even though this request started with a trustee, we still followed our usual process. Nothing prohibits a trustee from suggesting an investment.”

— ATRS Executive Director Mark White, after the June 2, 2025 vote

The question remains whether a proposal initiated through political channels and championed by an official with stated non-financial motivations can satisfy the pecuniary-only standard.

5. Public statements confirmed political motivations

Multiple state officials made public statements that framed the investments in political — not financial — terms:

“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.” (Source)

— Governor Sarah Sanders, press release (Oct. 2023)

“Those who bless Israel will be blessed, and those who curse Israel will be cursed. Arkansas unequivocally stands with Israel, as demonstrated by the recent actions of Governor Sarah Sanders and the Arkansas Legislature.”

— State Treasurer Larry Walther, press release (Oct. 2023)

Referred to the U.S. Ambassador to Israel as “my and Amy’s former boss” and called Israel “the United States’ most trusted and dependable ally in a volatile region.”

— Deputy Auditor Jason Brady, APERS Investment Subcommittee (May 15, 2025)

The purchase confirmation from November 2023 — one month after the October 7 attacks — documents the timing of one of these politically framed purchases.

Under Arkansas’s pecuniary-only standard, none of these are lawful bases for an investment decision. They are political statements. The law requires that the evaluation be based “only on pecuniary factors” — those with a material financial effect on risk or return.

6. First-ever direct foreign sovereign debt

Arkansas’s pension funds had never directly invested in foreign government bonds before 2025. Neither ATRS nor APERS previously held any direct foreign sovereign debt; their bond portfolios were limited to U.S. domestic and indirect international exposure.

Authorizing up to $100 million combined in a novel asset class — without documented independent analysis — represents a departure from established practice.

Authorized or committed exposure by agency

Treasury figure reflects current holdings (~0.5% of the Treasury's $11 billion portfolio), including $20M purchased since May 2025. ATRS authorization (~0.2% of ATRS's $23.7 billion portfolio) per Resolution 2025-22, June 2, 2025; full $50M deployed December 2025. APERS authorization (~0.2–0.4% of APERS's $11.58 billion portfolio) per Investment Subcommittee (May 15, 2025) and full board (June 11, 2025); at least one purchase confirmed by November 2025, exact amount unknown.

While these percentages are small, the investigation concerns whether standard fiduciary process was followed — not portfolio materiality. Hover over each bar for detail.

## The decision window

Three independent state agencies authorized up to $155 million within 49 days of the same April 2025 sales tour. The solid bars show how fast each agency moved from sales contact to board vote. The lighter bars show the gap between authorization and first investment action — in every case, months longer than the decision itself.

Solid bars: sales tour to board authorization. Light bars: authorization to first confirmed investment action. Dashed lines mark the internal memo recommending a hold (Dec 2024) and the April sales tour. Hover over bars for exact dates and durations. All dates from FOIA source documents.

The timeline

2017

  1. Israel Bonds outreach begins

    State Treasurer Dennis Milligan, after being approached by Israel Bonds representatives, reached out to then-Senator Jason Rapert to sponsor legislation enabling the state to purchase Israel Bonds. This led to the state's first Israel Bonds purchases through the Treasury. Rapert now chairs Christian outreach for Israel Bonds (DCI filings, ProPublica Nonprofit Explorer) — the legislator who created the legal authority now works for the bond seller.

2018

  1. Israel Bonds representatives congratulate Milligan on re-election

    Israel Bonds executives Lawrence Berman and Bradley Young sent congratulations to Dennis Milligan on his re-election as State Treasurer. Milligan replied that he looked "forward to our future together." (Read the correspondence)

2020

  1. Milligan nominated as SFOF National Chair

    Indiana Treasurer Kelly Mitchell nominated Dennis Milligan as National Chair of the State Financial Officers Foundation, praising his service and noting he managed an approximately $4.5 billion portfolio. (Read the nomination)

2023

  1. $10M purchase after October 7 attacks

    State Board of Finance approves $10 million additional Israel Bonds purchase, bringing total holdings to $57 million. Officials frame the purchase as Arkansas "standing with Israel."

2024

  1. Internal memo recommends against new purchases

    Senior Investment Officer Steve Pulley writes internal memo recommending against new Israel Bonds purchases, citing credit downgrades from major rating agencies.

  2. Auditor arranges meetings

    Auditor Milligan arranges meeting between Israel Bonds representatives and state officials.

2025

  1. Auditor schedules two-day pitch tour

    Auditor Milligan and his executive assistant send four meeting arrangement emails in 18 minutes, scheduling Israel Bonds executives Lawrence Berman and Bradley Young with the heads of APERS, ATRS, and the Treasury — all in the Auditor's own Capitol office, Room 230. Every email is CC'd to deputy Jason Brady and includes biographical documents for the sales representatives.

  2. Sales representatives meet with agency directors

    Israel Bonds sales representatives meet with directors of ATRS, APERS, the State Treasurer, and the State Auditor in back-to-back meetings at Room 230.

  3. $20M Treasury purchase; APERS authorizes $25–50M

    Treasury purchases $20 million in new Israel Bonds; APERS Investment Subcommittee authorizes $25–50 million.

  4. ATRS Board authorizes up to $50M

    ATRS Board adopts Resolution 2025-22 authorizing up to $50 million; Board Chair Danny Knight casts lone "no" vote.

  5. APERS full board approves Israel Bonds

    Following Jason Brady's introduction citing Treasury's $55 million holdings, the APERS full board approves the $25–50 million Israel Bonds authorization first advanced by the Investment Subcommittee in May.

  6. "Still zero for APERS"

    Two months after authorization, APERS Executive Director Amy Fecher confirms no Israel Bonds have been purchased. The following day, CIO Carlos Borromeo emails Stephens Inc. asking for Israel Bonds contact information.

  7. Arkansas Times investigation published

    Arkansas Times publishes in-depth investigation documenting the timeline, political connections, and fiduciary concerns.

  8. Governor's Israel trade mission

    Governor Sanders participates in Israel trade mission, boasts of state's Israel Bonds investments.

  9. ATRS establishes investment guidelines

    ATRS formalizes its Israel Bonds approach through Reams Asset Management with written "Investment guidelines for the Arkansas State Teacher Retirement Israeli Jubilee bond account" — nearly four months after the board authorized the investment.

  10. APERS purchase confirmed

    APERS staff receive a bond statement, confirming that an Israel Bonds purchase eventually occurred after the months-long delay following the May–June authorization.

  11. ATRS deploys full $50M

    ATRS Deputy Director Rod Graves confirms in a routine board liquidity update that the full $50 million Israel Bonds mandate was funded through the Scout (Reams) account — six months after board authorization and without an independent credit analysis at any stage.

2026

  1. Second FOIA round responses received

    Treasury delivers 118 documents (2,526 pages), APERS delivers 16 documents including an 8,648-page comprehensive production, and ATRS delivers 7 documents (partial response). Investigation corpus reaches 1,098 documents; Auditor of State Round 2 response pending.

  2. Auditor of State delivers Round 2 response

    124 documents from three custodians (Dennis Milligan, Jason Brady, Wendy Spadoni) received via flash drive from General Counsel TJ Fowler. Total investigation corpus: 1,222 documents.

  3. Board packet analysis reveals dual fiduciary standard; FOIA Round 3 filed

    Analysis of the publicly-posted APERS board packets reveals that 37 pages of Callan analysis were prepared for infrastructure investments while zero pages of analysis accompanied the Israel Bonds authorization — at the same meetings. FOIA Round 3 filed with ASHERS and LOPFI, expanding the investigation to two previously uninvestigated pension systems. Interstate outreach sent to parallel investigations in five states.

What the law requires

Arkansas law establishes clear standards for pension investments:

  • Sole interest rule — Trustees must invest assets “solely in the interest of the members and benefit recipients” (Ark. Code § 24-2-614)
  • Pecuniary factors only — Evaluations must be “based only on pecuniary factors” with material financial effects on risk or return (Act 411 of 2023)
  • Prudent investor standard — Trustees must exercise the care, skill, and diligence of an experienced, prudent investor (Ark. Code §§ 24-2-610–619)

The central question is whether these investments were driven by pecuniary benefit — as required by law — or by political motivations. The contrast between official financial justifications and celebratory political statements is the core of this issue.

What you can do

This evidence belongs to every Arkansan. Here’s how to use it:

Browse our source document archive to read the primary evidence yourself.

For additional source documents and detailed findings, contact us at info@arpensions.org.

Last updated: March 2026.