Evidence — Key Findings from 1,098 Arkansas Public Records
Key findings from nearly 1,100 public records obtained through two rounds of FOIA requests to four Arkansas state agencies
Our research
Divest for AR Future has analyzed nearly 1,100 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 2026) has produced responses from Treasury (118 documents), APERS (16 documents including an 8,648-page production), and ATRS (7 documents, partial response). The Auditor of State’s second response remains pending.
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 nearly 1,100 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.
2. Internal memo recommended against new purchases
In late 2024, a senior investment manager in the State Treasurer’s office wrote an internal memo raising concerns about Israel Bonds. The memo noted that major credit-rating agencies — specifically 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, by the time that $17 million matured in May 2025, the state purchased two new $10 million bonds — bringing total Treasury holdings to $55 million. 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 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.
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
While these percentages are small, the investigation concerns whether standard fiduciary process was followed — not portfolio materiality.
The timeline
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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.
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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)
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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)
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$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."
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Internal memo recommends against new purchases
Senior Treasury investment manager writes internal memo recommending against new Israel Bonds purchases, citing credit downgrades from major rating agencies.
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Auditor arranges meetings
Auditor Milligan arranges meeting between Israel Bonds representatives and state officials.
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Sales representatives meet with agency directors
Israel Bonds sales representatives meet with directors of ATRS, APERS, the State Treasurer, and the State Auditor.
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$20M Treasury purchase; APERS authorizes $25–50M
Treasury purchases $20 million in new Israel Bonds; APERS Investment Subcommittee authorizes $25–50 million.
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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.
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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.
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"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.
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Arkansas Times investigation published
Arkansas Times publishes in-depth investigation documenting the timeline, political connections, and fiduciary concerns.
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Governor's Israel trade mission
Governor Sanders participates in Israel trade mission, boasts of state's Israel Bonds investments.
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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.
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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.
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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, with Requests 2 and 3 due March 3, 2026). Investigation corpus surpasses 1,098 documents.
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:
- Are you an educator? See what this means for your ATRS pension and use our letter template to contact trustees.
- Are you a state employee? See what this means for your APERS pension and use our letter template to contact trustees.
- Want to get involved? See all the ways you can take action — from writing trustees to attending board meetings.
- Are you a legislator or legislative staff? Read our policy brief with specific legislative recommendations for the 2027 session.
- Are you a journalist? Visit our press page for pull-ready statistics, timeline, and media contact.
Browse our source document archive to read the primary evidence yourself.
For additional source documents and detailed findings, contact us at divestforarfuture@proton.me.