Evidence — Key Findings from 1,227 Arkansas Public Records

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

Our research

Arkansans for Pension Integrity has analyzed more than 1,200 public records from three rounds of Freedom of Information Act (FOIA) requests to Arkansas state agencies: the State Treasury, ATRS, APERS, the Auditor of State, and ASHERS. The first round (August 2025) covered 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). The third round (March 2026) expanded to ASHERS, ASPRS, and LOPFI — ASHERS delivered 5 documents, ASPRS confirmed no responsive records, and LOPFI confirmed no responsive records and no current holdings of the bonds under investigation (April 9, 2026). Five of six pension agencies have responded; a FOIA request to the sixth (AJRS, the Arkansas Judicial Retirement System) was filed May 8, 2026 — response pending. Total corpus: 1,227 documents across three FOIA rounds.

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 →

Up to $100 million committed

Two Arkansas pension boards authorized or committed up to $100 million in non-tradable foreign sovereign bonds — the first direct foreign sovereign debt purchases in Arkansas pension history.

Zero pages of independent analysis

Across more than 1,200 FOIA documents from Arkansas state agencies, we found zero pages of independent credit analysis. The bond issuer's own sales representatives served as both seller and analyst.

49 days from sales pitch to $120 million in new commitments

After a two-day pitch tour arranged by the Auditor of State in his own Capitol office, the Treasury made a $20 million new purchase and the two pension boards authorized up to $100 million more — all within 49 days. The Treasury's new purchase came even after its own senior investment staff had flagged credit-rating downgrades and recommended holding existing positions.

37 pages vs. zero pages

At the same board meetings, APERS received 37 pages of Callan analysis for infrastructure investments — and zero pages for the sovereign bond authorization. Every other investment had professional review. This one had a verbal pitch from the Auditor's proxy.

One voice of dissent

ATRS Board Chair Danny Knight cast the sole "no" vote, warning that selecting a specific bond at a trustee's request was "going outside of the scope of the way we usually do things." Read the full evidence below.

Key findings

1. No independent credit analysis

Of more than 1,200 documents reviewed, zero contained an independent credit analysis of these non-tradable sovereign 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-factors standard (Act 498 of 2023, the State Government Employee Retirement Protection Act, Ark. Code §§ 24-2-802(4)(A), 24-2-804(a)) requires pension board investment evaluations to be based “only on pecuniary factors” — those with material financial effect on risk or return. The prudent-investor rule (Ark. Code §§ 24-2-610–619) requires comparable diligence from pension trustees. Together, those standards already require the kind of analysis our FOIA investigation found missing. 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 the bonds under investigation. The memo noted that major credit-rating agencies — specifically Fitch, Moody’s, and S&P — had downgraded the issuing country’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 non-tradable sovereign bonds. By May 2025, Senior Investment Officer Steve Pulley confirmed the Treasury held $55 million in these 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, the bond issuer’s 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 the issuer’s national managing director, 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 non-tradable sovereign bonds
  • APERS authorized $25–50 million (May 15, 2025)
  • ATRS authorized up to $50 million (June 2, 2025)

From the public record:

In reply, the bond issuer’s national managing director called Milligan “truly one of a kind” and said he was “forever grateful” for his support. (Read the correspondence)

— Lawrence Berman, the bond issuer’s 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 these bonds reached the APERS board

New records obtained in February 2026 confirm the specific pathway by which non-tradable sovereign 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 these bonds were available as an investment, and cited the State Treasury’s existing holdings. From the public record: “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 the 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 sovereign bond 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 sovereign bond 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 sovereign bond purchases at Treasury → becomes Auditor of State → appoints Brady to APERS board → Brady introduces the same 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 non-tradable sovereign 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, the bond issuer’s Southeast Regional Executive Director.

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 the issuer’s 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 these 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 sovereign bond position.

ATRS, by contrast, hired Reams Asset Management (a division of Columbus Investments Inc.) and established formal investment guidelines for what the ATRS documents describe as the “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 these 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 sovereign bond 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 the bond issuer’s 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 the issuer’s executives Lawrence Berman and Bradley Young with the leadership of two pension boards (APERS and ATRS) and the State Treasurer:

  • 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 these bond 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 non-tradable sovereign 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. From 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 these 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 sovereign bond 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 sovereign bond authorization appears only in the embedded subcommittee minutes (4 pages) and a two-paragraph summary in the subcommittee chair report. No analysis of these bonds accompanies it.

At the same meeting, the CIO’s own MSCI EAFE country performance chart showed the issuing country 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 bond 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 the sovereign 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 records on these bonds as “insufficiently specific” in December 2024 (read the response). Both ATRS and APERS authorized first-ever direct sovereign bond 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 these bonds

Larry Walther — who served as Arkansas’s 40th Treasurer of State from August 2023 to January 2025 and maintained the Treasury’s sovereign bond position throughout his tenure — chaired the Investment Finance Subcommittee that authorized APERS’s first-ever purchase of these non-tradable sovereign bonds. 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 sovereign bond 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 these 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:

From the public record:

“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)

From the public record:

“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)

From the public record:

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 sovereign bond 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

In the 49-day window after the April 2025 sales tour, the Treasury made a $20 million new purchase and the two pension boards authorized up to $100 million more — up to $120 million in new commitments across 49 days. 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. Bond issuer outreach begins

    State Treasurer Dennis Milligan, after being approached by the bond issuer's representatives, reached out to then-Senator Jason Rapert to sponsor legislation enabling the state to purchase these bonds. This led to the state's first sovereign bond purchases through the Treasury. Rapert now chairs Christian outreach for the broker-dealer (FINRA BrokerCheck, CRD# 11148) — the legislator who created the legal authority now works for the bond seller.

2018

  1. Bond issuer representatives congratulate Milligan on re-election

    The bond issuer's 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 purchase of non-tradable sovereign bonds, bringing total holdings to $57 million. Officials frame the purchase in political rather than financial terms.

2024

  1. Internal memo recommends against new purchases

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

  2. Auditor arranges meetings

    Auditor Milligan arranges meeting between the bond issuer's 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 the bond issuer's 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

    The bond issuer's 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 non-tradable sovereign 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 sovereign bond authorization

    Following Jason Brady's introduction citing Treasury's $55 million holdings, the APERS full board approves the $25–50 million sovereign bond 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 sovereign bonds have been purchased. The following day, CIO Carlos Borromeo emails Stephens Inc. asking for the bond issuer's contact information.

  7. Arkansas Times investigation published

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

  8. Governor's trade mission to the issuing country

    Governor Sanders participates in a trade mission to the issuing country, publicly citing the state's sovereign bond investments.

  9. ATRS establishes investment guidelines

    ATRS formalizes its sovereign bond approach through Reams Asset Management with written investment guidelines for what the ATRS documents describe as the "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 a sovereign bond 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 sovereign bond 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. Round 2 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 sovereign bond authorization — at the same meetings. FOIA Round 3 filed with ASHERS and LOPFI, expanding the investigation to two previously uninvestigated pension systems.

  4. ASHERS delivers Round 3 response; ASPRS confirms null result

    ASHERS (Arkansas State Highway Employees' Retirement System) delivered 5 documents including 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) confirmed no responsive documents — assets commingled with APERS under Act 1242 of 2009. Investigation corpus reaches 1,227 total documents (1,044 active after deduplication).

  5. LOPFI confirms null result; five of six pension agencies responded

    LOPFI (Local Police and Fire Retirement System) confirmed no responsive records and no current holdings of the bonds under investigation. LOPFI manages its own investments independently with approximately $3.15 billion under management. With LOPFI's response, five of six Arkansas pension systems had responded to API's FOIA requests. Total corpus: 1,227 documents across three FOIA rounds.

  6. AJRS identified as sixth pension system; FOIA Round 4 filed and acknowledged

    AJRS (Arkansas Judicial Retirement System) identified as the sixth Arkansas pension system covered by Act 498. AJRS is administered by APERS staff and shares investment infrastructure, but has its own Board of Trustees (five members appointed by the Arkansas Judicial Council) and trust fund (~$309 million AUM, ~89% funded, ~139 active members). FOIA request filed May 8, 2026 to determine whether AJRS trust assets were included in sovereign bond purchases made through the APERS investment pool. Same-day acknowledgment received from Richmond Giles, APERS Staff Attorney — the single attorney handling FOIA correspondence for both APERS and AJRS, operationally confirming the shared-staff structure. Production deadline extended to May 15, 2026 by mutual agreement.

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 498 of 2023, the State Government Employee Retirement Protection Act, Ark. Code §§ 24-2-802(4)(A), 24-2-804(a))
  • 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.