The SFOF Pipeline

How the State Financial Officers Foundation connected the Arkansas adoption to a national network — and why interstate replication is a feature of the pipeline, not an accident.

Arkansas’s adoption of non-tradable sovereign debt at the state-government level is not a single-state story. The FOIA productions place the Arkansas Auditor of State’s office inside a national network of state financial officers that has actively promoted the same asset class across multiple states, and has used Arkansas’s adoption as a template for interstate replication.

SFOF as institutional infrastructure

The State Financial Officers Foundation is a 501(c)(3) network of conservative state financial officers (state treasurers, auditors, comptrollers). Its CEO is OJ Oleka; its Executive Vice President for Policy and Government Affairs is Noah Wall, who runs SFOF Action, the 501(c)(4) policy arm. Adam Slayton, SFOF Director of Operations, handled the logistics for Arkansas Auditor Dennis Milligan’s Spring 2025 SFOF National Meeting speech.

Milligan is a past chair of SFOF. The Arkansas Auditor’s office, the State Treasurer’s office, and predecessor offices have participated in SFOF activity for several years. The earliest documented SFOF Arkansas delegation captured in the FOIA productions appeared at the Fall 2020 National Meeting at the Omni Orlando Resort at ChampionsGate — a five-person Arkansas delegation comprising Milligan (then Treasurer), Brady, Grant Wallace, Stacy Peterson, and Andrea Lea.

The Auditor’s office’s relationship to SFOF is not just attendance. The Auditor R2 production includes records of Brady drafting Milligan’s April 24, 2025 SFOF Spring National Meeting speech, and a separate post-vote communication from Auditor Communications Director Stacy Peterson dated June 4, 2025, offering to share the Arkansas template with at least one other state’s financial officer staff: “Feel free to pass along to any member states.”

The promotional track

Alongside its policy-letter operation (see below), SFOF promotes the bond issuer’s instrument as a state-financial-officer investment. The most direct documentary evidence in the FOIA productions is the November 4, 2024 SFOF newsletter, which featured Pennsylvania Treasurer Stacy Garrity’s $20 million purchase as a model case study for other state treasurers. The Arkansas Auditor’s office received and circulated the newsletter internally.

The pattern visible across the FOIA productions:

  1. SFOF officers attend SFOF national meetings, where the issuer’s representatives maintain ongoing presence at “Corporate Partner Spotlight Meetings” and similar venues.
  2. The issuer’s institutional sales team coordinates state-by-state outreach to SFOF officers.
  3. When a state adopts the instrument, SFOF circulates the adoption as a case study to other states’ financial officers.
  4. Subsequent adoptions cite earlier adoptions as institutional precedent.

The Arkansas FOIA productions document the receiving end of step 3 (the Garrity case study reaching Arkansas) and the sending end of step 3 (the Peterson “feel free to pass along” message). At the introduction to the APERS board on May 15, 2025, Brady cited the State Treasury’s $55 million as the precedent supporting APERS’s authorization — exhibiting the same use-an-earlier-adoption-as-warrant pattern at the within-Arkansas level.

The SFOF policy-letter operation

SFOF’s institutional infrastructure also runs a multi-state sign-on letter operation independent of the bond pipeline. The Auditor R2 production documents Brady’s role as the Arkansas operational liaison on SFOF policy letters covering Tesla, anti-ESG positioning, anti-CCP positioning, debanking, USTR engagement, SEC and DOL submissions, China divestment, and national debt. The Treasury R3 production (February 19, 2026) confirms that several of these draft SFOF letters were retained at the Treasury as well — establishing that the SFOF coordination spans the two state-government offices most closely involved in the bond adoption.

Why interstate context matters for Arkansas fiduciary law

A.C.A. § 24-2-611(d) requires Arkansas pension trustees to “make a reasonable effort to verify facts relevant to the investment and management of trust assets.” When the principal precedent offered to a pension board is another state’s adoption — particularly when that adoption is promoted through a network with a documented role in coordinating both the sales and the post-sale promotion — the verification requirement attaches to that precedent itself.

The Pennsylvania Treasurer’s $20 million purchase of the same instrument was the subject of an independent journalist investigation by Spotlight PA published March 17, 2026, which raised ethics concerns parallel to those the Arkansas FOIA productions have documented. That report is the kind of public-record information a trustee exercising the “reasonable effort to verify facts” standard might be expected to be aware of — particularly when the same network is the source of the precedent and the trustee’s own staff has access to the network’s internal materials.

The Pension Investment Transparency Act produces the on-the-record analysis that would let an Arkansas pension board demonstrate it had verified, on pecuniary-factors grounds, the precedent it was relying upon. Without that documentation, a precedent-based decision is indistinguishable from a network-replication decision.