https://ultimateworldfinancialmap.blogspot.com/2025/12/mapping-union-blind-spots-join.html
Emails to go with PERAC investigation Page 1
Pi-001-2025-7-7-to-2025-7-9-Stebbins-McGinniss
Pi-002-2025-7-7-to-2025-7-8-RE_ PROSPER Application Access - BlackRock-2
Pi-003-2025-7-21-Stebbins-McGinniss
Pi-004-2025-7-28-Stebbins-William_Keefe_letter
Pi-005-2025-8-1-to-2025-8-8-Stebbins-McGinniss
Pi-006-2025-12-8-to-2025-10-20-Stebbins-Baruffi
Pi-007-2026-1-7-to-2025-12-14-Stebbins-Baruffi
Pi-008-2024-5-7-2024-5-9-Re_Hi John!!
Pi-009-2022-6-16-to-2021-5-27-Tech Valuations A Blind Spot in Private Markets
Pi-010-2021-5-6-to-2021-4-22-MA client 4Q20 reports
Pi-011-2021-2-24-to-2021-2-22-[EXTERNAL]RE The Town of Norwood - Q42020 -
Pi-012-2021-2-17-to-2021-1-Fee Report
Pi-013-2020-4-14-to-2020-4-13-New comment - [#5780] Re New PERAC
Pi-014-2020-2-11-to-2020-2-10-New comment - [#5413] FW RE 2019
Pi-015-2019-10-18-to-9-18-MYSS-Wainwright
Pi-016-2019-5-22-RE Assistance
Pi-017-2019-3-28-RE PERAC fund of funds guidelines
Pi-018-2019-3-15-to-2019-3-14-FW_ MA Consultant RFP's
Pi-019-2019-3-13-to-2018-10-16-RE Unigestion - Opportunity to Meet
Pi-020-2019-2-10-to-2019-1-28-Re Updated PERAC Contact Form_Boston Advisors, LLC
Pi-002-2025-7-7-to-2025-7-8-RE_ PROSPER Application Access - BlackRock-2
Pi-003-2025-7-21-Stebbins-McGinniss
Pi-004-2025-7-28-Stebbins-William_Keefe_letter
Pi-005-2025-8-1-to-2025-8-8-Stebbins-McGinniss
Pi-006-2025-12-8-to-2025-10-20-Stebbins-Baruffi
Pi-007-2026-1-7-to-2025-12-14-Stebbins-Baruffi
Pi-008-2024-5-7-2024-5-9-Re_Hi John!!
Pi-009-2022-6-16-to-2021-5-27-Tech Valuations A Blind Spot in Private Markets
Pi-010-2021-5-6-to-2021-4-22-MA client 4Q20 reports
Pi-011-2021-2-24-to-2021-2-22-[EXTERNAL]RE The Town of Norwood - Q42020 -
Pi-012-2021-2-17-to-2021-1-Fee Report
Pi-013-2020-4-14-to-2020-4-13-New comment - [#5780] Re New PERAC
Pi-014-2020-2-11-to-2020-2-10-New comment - [#5413] FW RE 2019
Pi-015-2019-10-18-to-9-18-MYSS-Wainwright
Pi-016-2019-5-22-RE Assistance
Pi-017-2019-3-28-RE PERAC fund of funds guidelines
Pi-018-2019-3-15-to-2019-3-14-FW_ MA Consultant RFP's
Pi-019-2019-3-13-to-2018-10-16-RE Unigestion - Opportunity to Meet
Pi-020-2019-2-10-to-2019-1-28-Re Updated PERAC Contact Form_Boston Advisors, LLC
=====================================================
Pi-001-2025-7-7-to-2025-7-9-Stebbins-McGinniss
Re: Public Records Request – PERAC Investment Records 2024–2025
From: Ricky Stebbins (thestebbman@yahoo.com)
To: felicia.m.mcginniss@mass.gov
Date: Wednesday, July 9, 2025 at 09:51 AM EDT
To: Felicia McGinniss, Esq.
Senior Associate General Counsel
Public Employee Retirement Administration Commission (PERAC)
Dear Ms. McGinniss,
Thank you for your response and for providing the two emails between PERAC and
BlackRock. I appreciate your time and transparency.
However, after carefully reviewing these emails and cross-referencing them with public
records and vendor access logs, I now have several follow-up questions and requests for
clarification. These are based on inconsistencies between your written statements and
the role PERAC appears to play in pension vendor coordination and disclosures.
Clarification Questions
1. Vendor Coordination and Investment Gatekeeping
1 of 8
• Why is PERAC advising vendors such as BlackRock on how to respond to
individual retirement board RFPs if PERAC does not conduct or influence
investments?
• What legal or regulatory authority allows PERAC to instruct vendors on
compliance for board-specific RFPs (e.g., MWRA)?
• How frequently does PERAC correspond directly with private investment
firms about open RFPs?
2.
3. PROSPER Portal Access
• What data fields or modules within the PROSPER portal were accessed by
BlackRock employees?
• Are outside vendors’ portal access logs retained? If so, I formally request
them for the BlackRock accounts added in the attached emails.
• Under what criteria does PERAC grant vendor access to PROSPER?
4.
5. Undisclosed Investment Influence
• How many vendors have contacted PERAC to clarify or satisfy PERAC
disclosures before responding to RFPs over the last 5 years?
• Is PERAC involved in the review, guidance, or approval of investment firms
participating in retirement board selections?
• Has PERAC ever provided verbal guidance or informal steering that is not
documented in email or written form?
6.
7. Disclosure Gaps and Transparency Compliance
• Do PERAC officers or contractors (e.g., John Galvin) attend investment
committee meetings or vendor pitches, even informally?
• Does PERAC maintain internal records of vendor-related communications
that are not cataloged under public procurement systems?
• Has PERAC coordinated with third-party platforms such as BlackRock,
Hamilton Lane, or PRIM to shape or influence RFP outcomes?
8.
2 of 8
Public Records Request Expansion
In accordance with Massachusetts public records law, I hereby formally request:
1. All communications (email, internal memos, meeting notes) between PERAC
employees and any vendor or investment firm from 2018 to 2025 that reference:
• PROSPER portal access
• RFP responses or disclosures
• BlackRock, PRIM, Hamilton Lane, or any vendor managing public
retirement funds
2.
3. All access logs to the PROSPER system from external IP addresses or users
affiliated with investment vendors, including but not limited to:
• BlackRock
• Hamilton Lane
• State Street
• Vanguard
• PRIM-affiliated firms
4.
5. All internal policies, memos, or training materials that:
• Define PERAC’s role in vendor guidance
• Explain what constitutes “investment influence” or “advisory capacity”
within PERAC’s compliance obligations
6.
3 of 8 12/8/2025, 9:58 PM
Notice of Legal and Public Oversight Interest
Due to the serious financial and ethical implications of possible undisclosed influence
over public retirement funds, this request is part of a larger transparency initiative
involving oversight bodies, investigative journalists, and legal analysts.
If PERAC has in any way misrepresented its level of involvement in pension
investment decisions or vendor guidance, that would constitute a breach of public trust
with implications under state ethics and procurement laws (e.g., M.G.L. c. 268A and c.
30B).
This is not a generic fishing expedition. It is a focused inquiry into patterns of selective
access, behind-the-scenes gatekeeping, and potential conflicts of interest affecting
millions in public retirement assets.
I respectfully ask that you treat this request with the seriousness it deserves.
Sincerely,
Ricky Stebbins
On Jul 8, 2025, at 9:36 AM, McGinniss, Felicia M. (PER) <Felicia.M.McGinniss@mass.gov> wrote:
Good Morning Mr. Stebbins,
PERAC has received your below Public Records Request; however, we are unable to comply with a majority of
said request as PERAC itself does not conduct any type of investments.
4 of 8
PERAC is the regulatory agency that oversees the 104 retirement systems in the Commonwealth. We assist the
retirement boards and ensure that our retirement law, Chapter 32, is applied uniformly throughout the systems.
PERAC itself does not enter into or handle any investments. Each of the 104 retirement boards conduct their own
investments and handle the management of the funds of that system. As such, we are unable to supply any
investment schedules or asset allocation reports.
I have attached copies of 2 emails between PERAC and Blackrock, but again, these are only advisory emails
about responding to RFPs sent out by retirement boards.
I would suggest that you send this request to each of the 104 retirement systems to see if any of them can
provide the information that you seek. I would also suggest sending this request to the Massachusetts Pension
Reserves Investment Management (IPRIM) Board as they are the ones that handle investing funds of certain
retirement boards.
Best,
Felicia
Felicia McGinniss, Esq.
Senior Associate General Counsel
Public Employee Retirement Administration Commission
10 Cabot Road, Suite 300
Medford, MA 02155
(617) 666-4446, ext. 909
www.mass.gov/perac
**Please note our new address (effective immediately).
From: Ricky Stebbins <thestebbman@yahoo.com>
Sent: Monday, July 7, 2025 1:11 AM
To: McGinniss, Felicia M. (PER) <Felicia.M.McGinniss@mass.gov>;
5 of 8 12/8/2025, 9:58 PM
CAUTION: This email originated from a sender outside of the Commonwealth of
Massachusetts mail system. Do not click on links or open attachments unless you
recognize the sender and know the content is safe.
recordsrequests@sec.state.ma.us; Dunker, Natacha A. (PER) <Natacha.A.Dunker@mass.gov>;
Bowman, Christopher (CSC) <christopher.bowman@mass.gov>; Stein, Paul (CSC)
<paul.m.stein@mass.gov>; Cynthia.Ittleman@state.ma.us; Camuso, Paul A. (CSC)
<paul.a.camuso@mass.gov>; zzTivnan, Kevin M (CSC) <kevin.m.tivnan@mass.gov>; Diaz, Medes
(CSC) <medes.diaz@mass.gov>; treasury.web@tre.state.ma.us; EOEEA (EEA) <EEA@mass.gov>
Subject: Public Records Request – PERAC Investment Records 2024–2025
Dear Records Access Officer,
Under the Massachusetts Public Records Law, M.G.L. c. 66, I am requesting access
to the following public records:
• All investment schedules and asset allocation reports from January 1, 2024, to
present related to the Massachusetts Public Employee Retirement
Administration Commission (PERAC), specifically including:
◦ BlackRock Exchange Traded Fund (ETF) holdings, including but not
limited to crypto ETFs.
◦ Investments in cryptocurrency mining companies, including but not
limited to Riot Platforms, Marathon Digital Holdings, and Bitdeer
Technologies.
•
• All communications, meeting minutes, and correspondence from January 1,
2024, to present between PERAC officials and:
◦ Larry Fink (BlackRock CEO)
6 of 8
◦ Maura Healey (Governor of Massachusetts)
◦ Representatives of BlackRock
◦ Representatives of cryptocurrency companies
•
If the total cost to fulfill this request will exceed $50, please contact me with an
estimate before proceeding. If possible, I prefer to receive records electronically via
email.
If any part of this request is denied, please provide the specific exemption(s) you
believe justify withholding the records and inform me of the appeal process.
Thank you for your attention to this request. I look forward to your response within
the 10 business days provided under Massachusetts law.
Sincerely,
Richard stebbins
54 Hope st
Springfield, MA 01119
413-949-1925
CONFIDENTIALITY NOTICE This electronic message and any attachments are intended only for the addressee(s) and contains information that may be privileged
and confidential. If you are not the intended recipient, please notify the sender by reply email and immediately delete this message. Use, disclosure or
reproduction of this email by anyone other than the intended recipient(s) is strictly prohibited. Thank you.
7 of 8
Re_ Hi John!!.pdf
265.3 KB
RE_ PROSPER Application Access - BlackRock.pdf
224.6 KB
Pi-002-2025-7-7-to-2025-7-8-RE_ PROSPER Application Access - BlackRock-2
From: Ricky Stebbins (thestebbman@yahoo.com)
To: felicia.m.mcginniss@mass.gov
Date: Wednesday, July 9, 2025 at 09:51 AM EDT
To: Felicia McGinniss, Esq.
Senior Associate General Counsel
Public Employee Retirement Administration Commission (PERAC)
Dear Ms. McGinniss,
Thank you for your response and for providing the two emails between PERAC and
BlackRock. I appreciate your time and transparency.
However, after carefully reviewing these emails and cross-referencing them with public
records and vendor access logs, I now have several follow-up questions and requests for
clarification. These are based on inconsistencies between your written statements and
the role PERAC appears to play in pension vendor coordination and disclosures.
Clarification Questions
1. Vendor Coordination and Investment Gatekeeping
1 of 8
• Why is PERAC advising vendors such as BlackRock on how to respond to
individual retirement board RFPs if PERAC does not conduct or influence
investments?
• What legal or regulatory authority allows PERAC to instruct vendors on
compliance for board-specific RFPs (e.g., MWRA)?
• How frequently does PERAC correspond directly with private investment
firms about open RFPs?
2.
3. PROSPER Portal Access
• What data fields or modules within the PROSPER portal were accessed by
BlackRock employees?
• Are outside vendors’ portal access logs retained? If so, I formally request
them for the BlackRock accounts added in the attached emails.
• Under what criteria does PERAC grant vendor access to PROSPER?
4.
5. Undisclosed Investment Influence
• How many vendors have contacted PERAC to clarify or satisfy PERAC
disclosures before responding to RFPs over the last 5 years?
• Is PERAC involved in the review, guidance, or approval of investment firms
participating in retirement board selections?
• Has PERAC ever provided verbal guidance or informal steering that is not
documented in email or written form?
6.
7. Disclosure Gaps and Transparency Compliance
• Do PERAC officers or contractors (e.g., John Galvin) attend investment
committee meetings or vendor pitches, even informally?
• Does PERAC maintain internal records of vendor-related communications
that are not cataloged under public procurement systems?
• Has PERAC coordinated with third-party platforms such as BlackRock,
Hamilton Lane, or PRIM to shape or influence RFP outcomes?
8.
2 of 8
Public Records Request Expansion
In accordance with Massachusetts public records law, I hereby formally request:
1. All communications (email, internal memos, meeting notes) between PERAC
employees and any vendor or investment firm from 2018 to 2025 that reference:
• PROSPER portal access
• RFP responses or disclosures
• BlackRock, PRIM, Hamilton Lane, or any vendor managing public
retirement funds
2.
3. All access logs to the PROSPER system from external IP addresses or users
affiliated with investment vendors, including but not limited to:
• BlackRock
• Hamilton Lane
• State Street
• Vanguard
• PRIM-affiliated firms
4.
5. All internal policies, memos, or training materials that:
• Define PERAC’s role in vendor guidance
• Explain what constitutes “investment influence” or “advisory capacity”
within PERAC’s compliance obligations
6.
3 of 8 12/8/2025, 9:58 PM
Notice of Legal and Public Oversight Interest
Due to the serious financial and ethical implications of possible undisclosed influence
over public retirement funds, this request is part of a larger transparency initiative
involving oversight bodies, investigative journalists, and legal analysts.
If PERAC has in any way misrepresented its level of involvement in pension
investment decisions or vendor guidance, that would constitute a breach of public trust
with implications under state ethics and procurement laws (e.g., M.G.L. c. 268A and c.
30B).
This is not a generic fishing expedition. It is a focused inquiry into patterns of selective
access, behind-the-scenes gatekeeping, and potential conflicts of interest affecting
millions in public retirement assets.
I respectfully ask that you treat this request with the seriousness it deserves.
Sincerely,
Ricky Stebbins
On Jul 8, 2025, at 9:36 AM, McGinniss, Felicia M. (PER) <Felicia.M.McGinniss@mass.gov> wrote:
Good Morning Mr. Stebbins,
PERAC has received your below Public Records Request; however, we are unable to comply with a majority of
said request as PERAC itself does not conduct any type of investments.
4 of 8
PERAC is the regulatory agency that oversees the 104 retirement systems in the Commonwealth. We assist the
retirement boards and ensure that our retirement law, Chapter 32, is applied uniformly throughout the systems.
PERAC itself does not enter into or handle any investments. Each of the 104 retirement boards conduct their own
investments and handle the management of the funds of that system. As such, we are unable to supply any
investment schedules or asset allocation reports.
I have attached copies of 2 emails between PERAC and Blackrock, but again, these are only advisory emails
about responding to RFPs sent out by retirement boards.
I would suggest that you send this request to each of the 104 retirement systems to see if any of them can
provide the information that you seek. I would also suggest sending this request to the Massachusetts Pension
Reserves Investment Management (IPRIM) Board as they are the ones that handle investing funds of certain
retirement boards.
Best,
Felicia
Felicia McGinniss, Esq.
Senior Associate General Counsel
Public Employee Retirement Administration Commission
10 Cabot Road, Suite 300
Medford, MA 02155
(617) 666-4446, ext. 909
www.mass.gov/perac
**Please note our new address (effective immediately).
From: Ricky Stebbins <thestebbman@yahoo.com>
Sent: Monday, July 7, 2025 1:11 AM
To: McGinniss, Felicia M. (PER) <Felicia.M.McGinniss@mass.gov>;
5 of 8 12/8/2025, 9:58 PM
CAUTION: This email originated from a sender outside of the Commonwealth of
Massachusetts mail system. Do not click on links or open attachments unless you
recognize the sender and know the content is safe.
recordsrequests@sec.state.ma.us; Dunker, Natacha A. (PER) <Natacha.A.Dunker@mass.gov>;
Bowman, Christopher (CSC) <christopher.bowman@mass.gov>; Stein, Paul (CSC)
<paul.m.stein@mass.gov>; Cynthia.Ittleman@state.ma.us; Camuso, Paul A. (CSC)
<paul.a.camuso@mass.gov>; zzTivnan, Kevin M (CSC) <kevin.m.tivnan@mass.gov>; Diaz, Medes
(CSC) <medes.diaz@mass.gov>; treasury.web@tre.state.ma.us; EOEEA (EEA) <EEA@mass.gov>
Subject: Public Records Request – PERAC Investment Records 2024–2025
Dear Records Access Officer,
Under the Massachusetts Public Records Law, M.G.L. c. 66, I am requesting access
to the following public records:
• All investment schedules and asset allocation reports from January 1, 2024, to
present related to the Massachusetts Public Employee Retirement
Administration Commission (PERAC), specifically including:
◦ BlackRock Exchange Traded Fund (ETF) holdings, including but not
limited to crypto ETFs.
◦ Investments in cryptocurrency mining companies, including but not
limited to Riot Platforms, Marathon Digital Holdings, and Bitdeer
Technologies.
•
• All communications, meeting minutes, and correspondence from January 1,
2024, to present between PERAC officials and:
◦ Larry Fink (BlackRock CEO)
6 of 8
◦ Maura Healey (Governor of Massachusetts)
◦ Representatives of BlackRock
◦ Representatives of cryptocurrency companies
•
If the total cost to fulfill this request will exceed $50, please contact me with an
estimate before proceeding. If possible, I prefer to receive records electronically via
email.
If any part of this request is denied, please provide the specific exemption(s) you
believe justify withholding the records and inform me of the appeal process.
Thank you for your attention to this request. I look forward to your response within
the 10 business days provided under Massachusetts law.
Sincerely,
Richard stebbins
54 Hope st
Springfield, MA 01119
413-949-1925
CONFIDENTIALITY NOTICE This electronic message and any attachments are intended only for the addressee(s) and contains information that may be privileged
and confidential. If you are not the intended recipient, please notify the sender by reply email and immediately delete this message. Use, disclosure or
reproduction of this email by anyone other than the intended recipient(s) is strictly prohibited. Thank you.
7 of 8
Re_ Hi John!!.pdf
265.3 KB
RE_ PROSPER Application Access - BlackRock.pdf
224.6 KB
Pi-002-2025-7-7-to-2025-7-8-RE_ PROSPER Application Access - BlackRock-2
From: Galvin, John P. (PER)
To: Dasaro, James
Cc: Brandwein, Sarah; Xiao, Miley; Ford, Conor
Subject: RE: PROSPER Application Access - BlackRock
Date: Tuesday, July 8, 2025 7:44:00 AM
Attachments: image001.png
Hi James,
Yes, great long weekend and I hope the same for all of you!
Sara, Miley, Conor- a registration email will come under separate cover for access to the
site.
If you need any help , or have questions using the site, please let me know.
Thank you,
John
John Galvin
Compliance Manager
Public Employee Retirement Administration Commission
10 Cabot Road, Suite 300
Medford, MA 02155
Phone: 617-591-8927
John.P.Galvin@mass.gov
From: Dasaro, James <james.dasaro@blackrock.com>
Sent: Monday, July 7, 2025 10:07 AM
To: Galvin, John P. (PER) <John.P.Galvin@mass.gov>
Cc: Brandwein, Sarah <sarah.brandwein@blackrock.com>; Xiao, Miley <aiyin.xiao@blackrock.com>;
Ford, Conor <Conor.Ford@blackrock.com>
Subject: PROSPER Application Access - BlackRock
Hi John,
Hope all has been well and that you enjoyed the long weekend! Would you be able to help provide
access to the PROSPER portal to my colleagues copied in here?
Best,
James
James Dasaro
Director, Client Experience Management
Phone: +1.212.810.8872
Email: james.dasaro@blackrock.com
BLK Logo
This message may contain information that is confidential or privileged. If you are not the intended recipient, please
advise the sender immediately and delete this message. See
https://www.blackrock.com/corporate/compliance/email-disclaimers for further information. Please refer to
https://www.blackrock.com/corporate/compliance/privacy-policy for more information about BlackRock’s Privacy
Policy.
For a list of BlackRock's office addresses worldwide, see https://www.blackrock.com/corporate/about-us/contactslocations.
© 2025 BlackRock, Inc. All rights reserved
Pi-003-2025-7-21-Stebbins-McGinniss
RE: Public Records Request – PERAC Investment Records 2024–2025
From: McGinniss, Felicia M. (PER) (felicia.m.mcginniss@mass.gov)
To: thestebbman@yahoo.com
Cc: doreen.m.duane@mass.gov
Date: Monday, July 21, 2025 at 08:48 AM EDT
Hi Mr. Stebbins,
Here is email #2 of 3.
Felicia
Felicia McGinniss, Esq.
Senior Associate General Counsel
Public Employee Retirement Administration Commission
10 Cabot Road, Suite 300
Medford, MA 02155
(617) 666-4446, ext. 909
www.mass.gov/perac
**Please note our new address (effective immediately).
From: McGinniss, Felicia M. (PER)
Sent: Monday, July 21, 2025 8:44 AM
To: thestebbman@yahoo.com
Cc: Duane, Doreen M. (PER) <doreen.m.duane@mass.gov>
Subject: Public Records Request – PERAC Investment Records 2024–2025
Good Morning Mr. Stebbins,
#30 Investment Fraud Alert (10-26-2021).pdf
229.1 KB
#30 Tobacco Company List (3-29-2012).pdf
359.8 KB
#30 Tobacco Company List (9-18-2014).pdf
360.4 KB
#31 Tobacco Company List (11-5-2013).pdf
365.4 KB
Pursuant to your public records request, attached please find a portion of the documents that are responsive to
your request. I will be sending 3 separate (this is #1) emails that have the requested Memos and Presentations
that PERAC has released/given regarding compliance and investment. We are still currently in the process of
searching through emails for the other portion of your request. As previously indicated, that will take additional
time as the emails encompass over 15 PERAC employees over a span of almost 10 years. We should hopefully
be able to provide the documents by the end of September, but I will keep you updated.
Thank you,
Felicia
Felicia McGinniss, Esq.
Senior Associate General Counsel
Public Employee Retirement Administration Commission
10 Cabot Road, Suite 300
Medford, MA 02155
(617) 666-4446, ext. 909
www.mass.gov/perac
**Please note our new address (effective immediately).
CONFIDENTIALITY NOTICE This electronic message and any a achments are intended only for the addressee(s) and contains informa on that may be privileged
and confiden al. If you are not the intended recipient, please no fy the sender by reply email and immediately delete this message. Use, disclosure or
reproduc on of this email by anyone other than the intended recipient(s) is strictly prohibited. Thank you.
#32 Procurement (11-5-2018).pdf
512.2 KB
#32 Tobacco Company List (10-6-2017).pdf
378.2 KB
#33 Tobacco Company List (12-9-2021).pdf
369.3 KB
#34 Tobacco Company List (12-14-2018).pdf
379.5 KB
#35 Chapter 176 of the Acts of 2011, An Act Providing for Pension Reform and Benefit Modernization (Governance
Provisions) (12-2-2011).pdf
647.5 KB
#37 Tobacco Company List (12-17-2014).pdf
364.3 KB
#39 Tobacco Company List (12-30-2020).pdf
370 KB
#45 Tobacco Company List (8-2-2012).pdf
360.5 KB
#49 Investment Under Chapter 176 of the Acts of 2011 - #2 (10-10-2012).pdf
582.9 KB
#50 Tobacco Company List (10-10-2012).pdf
360.4 KB
#51 Chapter 32, Section 23B Contract Terms, Indemnification, Disclosure, and Fiduciary Duty (10-18-2012).pdf
478.7 KB
#56 Tobacco Company List (12-12-2012).pdf
363.1 KB
Attachment (2014 Schedule 7 Investment Fees).pdf
8.2 MB
PERAC MEMO #8 2025.pdf
284 KB
PERAC MEMO #9 2023.pdf
361.1 KB
PERAC MEMO #10 2024.pdf
360.3 KB
PERAC MEMO #10 2025.pdf
356.3 KB
PERAC MEMO #10-2022.pdf
60.3 KB
PERAC Memo #14 2023.pdf
363 KB
PERAC MEMO #14 2024.pdf
358.5 KB
PERAC Memo #15 2022.pdf
141.9 KB
PERAC MEMO #16 2025.pdf
617.9 KB
PERAC MEMO #19 2023.pdf
359.9 KB
PERAC MEMO #24 2023.pdf
382.1 KB
PERAC MEMO #24 2024.pdf
357.3 KB
PERAC Memo #25-2022.pdf
366.9 KB
PERAC MEMO #29 2023.pdf
363.5 KB
PERAC Memo #32 2024.pdf
360.5 KB
PERAC MEMO #32-2022.pdf
367.2 KB
07_ComplianceOverview_Roadshow032124.pdf
767.7 KB
2013 MACRS - Board Governance.pdf
218.6 KB
2013 MACRS - Competitive Process.pdf
412.2 KB
2013 MACRS - How to Review Vendor Disclosures.pdf
330.6 KB
2013 MACRS - Overview of Financial Data.pdf
312.9 KB
2014 MACRS - New Investment Changes.pdf
2.8 MB
Pi-004-2025-7-28-Stebbins-William_Keefe_letter
PERAC
COMMONWEALTH OF MASSACHUSETTS | PUBLIC EMPLOYEE RETIREMENT ADMINISTRATION COMMISSION
PHILIP Y. BROWN, ESQ., Chair WILLIAM T. KEEFE, Executive Director
Auditor DIANA DIZOGLIO | KATHLEEN M. FALLON | KATE FITZPATRICK | JAMES J. GUIDO | RICHARD MACKINNON, JR. | JENNIFER F. SULLIVAN, ESQ.
Richard Stebbins
July 28, 2025
54 Hope Street
Springfield, MA 01119
Dear Mr. Stebbins:
This is in response to your email, dated July 9, 2025, concerning PERAC's role in retirement
system vendor coordination and disclosures pertaining to investment management advisors. This
request was submitted in addition to a Public Records Request for documents related to these
questions. Those documents are currently being compiled and will be sent to you as soon as
possible.
You presented a series of questions, which will be answered below in turn.
1. Vendor Coordination and Investment Gatekeeping
Why is PERAC advising vendors such as BlackRock on how to respond to
individual retirement board RFPs if PERAC does not conduct or influence
investments?
What legal or regulatory authority allows PERAC to instruct vendors on
compliance for board-specific RFPs (e.g., MWRA)?
How frequently does PERAC correspond directly with private investment
firms about open RFPs?
PERAC Response: As the regulatory agency of the 104 retirement systems, PERAC’s role is to
ensure the uniform application of our retirement law, Chapter 32. Regarding the procurements of
investment services, retirement boards are required to perform them pursuant to G.L. c. 32, § 23B.
Section 23B addresses how procurements should be undertaken and that PERAC must review all
procurements of vendors, such as investment, actuarial, legal, and accounting services. Section
23B also requires annual vendor disclosures to be filed with the retirement board and PERAC.
Additionally, PERAC has formally adopted regulations regarding investments at 840 CMR 16.00-
23B.
18.00, 21.00, and 26.00-27.00. РERAC's role is to ensure that each retirement board is correctly
following the procurement process and requesting the required documentation outlined in Section
To that end, PERAC regularly corresponds with retirement boards and some potential
vendors - legal, actuarial, investment, etc. - to ensure that proper documentation is being provided
in response to RFPs. PERAC does not advise vendors on how to respond so that they will "win"
10 CABOТ ROAD, SUITE 300 | MEDFORD, MA 02155
PH 617 666 4446 | FAX 617 628 4002 | WWW.MASS.GOV/PERAC
FUBLICENPLOTE PERAC
Richard Stebbins
54 Hope Street
Springfield, MA 01119
July 28, 2025
Page Two
the RFP or influence investments. Instead, PERAC merely answers questions about the
requirements of Section 23B and what must be submitted to retirement boards in response to RFPs.
The only exception to the above statements is if a retirement board's return of investment falls
below the determined benchmark. If that occurs, then the retirement board would be subject to the
transfer of their assets over to PRIM in accordance with the provisions of Chapter 21 of the Acts
of 2009. PERAC would oversee and ensure that the assets were promptly transferred to PRIM.
2. PROPSER Portal Access
• What data fields or modules within the PROSPER portal were accessed by
BlackRock employees?
Are outside vendors' portal access logs retained? If so, I formally request
them for the BlackRock accounts added in the attached emails.
Under what criteria does PERAC grant vendor access to PROSPER?
PERAC Response: PROSPER is an internal system that is available to all PERAC staff,
retirement board members and staff, and vendors. Each group is able to access different parts of
the PROSPER system depending on how they are classified. Vendors have limited access to
PROSPER so that they can upload the required annual vendor disclosure filings. To gain access
to PROSPER, the vendor must be a current, authorized vendor of a retirement board who has
complied with and been selected by a retirement board through the RFP process. Access is only
given to authorized employees of the vendor.
3. Undisclosed Investment Influence
•
How many vendors have contacted PERAC to clarify or satisfy PERAC
disclosures before responding to RFPs over the last 5 years?
Is PERAC involved in the review, guidance, or approval of investment firms
participating in retirement board selections?
Has PERAC ever provided verbal guidance or informal steering that is not
documented in email or written form?
PERAC Response: Pursuant to our statutory mandate, PERAC is not involved in the review,
guidance, or approval of investment firms that are contracted by retirement boards. Again,
we will answer any general questions about required documents but will not assist a vendor
in "winning" an RFP. PERAC will conduct a review of all completed RFPs to ensure that the
vendor was selected in accordance with the procedures of G.L. c. 32, § 23B and PERAC
regulations at 840 CMR. PERAC does not track how many vendors have been in contact with
questions regarding RFPs.
Richard Stebbins
54 Hope Street
Springfield, MA 01119
July 28, 2025
Page Three
4. Disclosure Gaps and Transparency Compliance
Do PERAC officers or contractors (e.g., John Galvin) attend investment committee
meetings or vendor pitches, even informally?
• Does PERAC maintain internal records of vendor-related communications that are
not cataloged under public procurement systems?
• Has PERAC coordinated with third-party platforms such as BlackRock, Hamilton
Lane, or PRIM to shape or influence RFP outcomes?
PERAC Response: PERAC staff attend retirement board meetings and the quarterly PRIM board
meetings. However, PERAC staff have no role in these meetings unless invited to speak on a
topic. If a retirement board is conducting a meeting in open session with an investment vendor,
PERAC staff are not involved in the meeting and their attendance is treated as if they were a
member of the public. Additionally, PERAC has never coordinated with third-party platforms to
shape or influence RFP outcomes as that would directly violate our role in the procurement
process. Vendor decisions for investment services lie solely with each individual retirement board.
PERAC is merely available to help ensure that the requirements of G.L. c. 32, § 23B are followed
and to answer any questions regarding documents that are required to be provided in response to
RFPs.
We trust the foregoing will be of assistance to you. Please contact this office if you have
questions or concerns about this.
Sincerely,
William T. Keefe Executive Director
Pi-005-2025-8-1-to-2025-8-8-Stebbins-McGinniss
RE: Public Records Request – PERAC Investment Records 2024–2025
From: McGinniss, Felicia M. (PER) (felicia.m.mcginniss@mass.gov)
To: thestebbman@yahoo.com
Date: Friday, August 1, 2025 at 10:22 AM EDT
Mr. Stebbins,
Please understand that we are not “sitting on 8 years of logs.” The logs do not exist in report
form. PROSPER is handled by a third-party vendor who hosts and runs our system. They are
currently compiling a report of all of those who have logged in for investment purposes. This
information does not exist in the form that you are requesting. We, and our PROSPER host
site, have to search all of the logs, pull out the relevant users, and create the report from
scratch. We also cannot access this directly as it is not stored with PERAC, but with the third-party site.
Searching internal emails that are protected by multiple levels of encryption and stored in
archived sites cannot be easily achieved via AI automation tools. While the general public may
be able to access some tools, State agencies are required to follow much stricter
requirements. The emails that are older are achieved solely with the State IT department, not
at PERAC. I cannot do a search on my email for anything older than one year, as it is stored in
internal systems and with the State IT. As such, this is a coordinated effort between two
agencies to obtain the documents you have requested. Any delay in this process is not
because of a shield, it is because of an extensive effort that must be undertaken to obtain all
documents.
Regarding the use of AI, State Agencies were just given notice that it was allowed to be used
in certain circumstances in January 2025. Please see the guidance put out by EOTSS:
https://www.mass.gov/policy-advisory/enterprise-use-and-development-of-generative-ai-policy.
If you have further questions about the use of AI, please contact them directly.
Regarding our records retention schedule, please see the following document published by the
State that we must follow: https://www.sec.state.ma.us/divisions/public-records/download/
MA_Statewide_Records_Schedule_updated2022-10-31.pdf.
Again, I would like to highlight that we have been extremely responsive and transparent in
responding to all your questions about PERAC, and sending you the requested Memoranda
1 of 6
CAUTION: This email originated from a sender outside of the Commonwealth of
Massachusetts mail system. Do not click on links or open attachments unless you
recognize the sender and know the content is safe.
and training materials regarding procurements and investments.
I will not be providing you a schedule of how the request is being processed each week as that
is not a requirement of our Public Records Law. I will keep you updated if we are unable to
respond within the next two months as previously indicated.
Best,
Felicia
Felicia McGinniss, Esq.
Senior Associate General Counsel
Public Employee Retirement Administration Commission
10 Cabot Road, Suite 300
Medford, MA 02155
(617) 666-4446, ext. 909
www.mass.gov/perac
**Please note our new address (effective immediately).
From: Ricky Stebbins <thestebbman@yahoo.com>
Sent: Friday, August 1, 2025 9:57 AM
CONFIDENTIALITY NOTICE This electronic message and any attachments are intended only for the addressee(s) and contains information that may be privileged and
confidential. If you are not the intended recipient, please no fy the sender by reply email and immediately delete this message. Use, disclosure or reproduction of
this email by anyone other than the intended recipient(s) is strictly prohibited. Thank you.
To: McGinniss, Felicia M. (PER) <Felicia.M.McGinniss@mass.gov>
Subject: Re: Public Records Request – PERAC Investment Records 2024–2025
2 of 6
Hi Felicia,
Thank you for the update.
I want to be clear: I’m not upset about technical delays—I’m upset that you’re
using delays as a shield.
You’ve now admitted that PERAC is sitting on 8 years of logs, vendor data, and
internal emails—while refusing to use any of the available AI or automation tools
that could make this retrieval, triage, and review process almost immediate.
Here’s what that looks like from my perspective as a disabled individual:
I used my disability income to purchase an
iPhone and a laptop specifically so I could use
AI to investigate corruption and demand
accountability. The state of Massachusetts, and
agencies like PERAC, are sitting on billions of
dollars in public assets—yet you’re still acting
like this is 1995.
If I need toast and I already bought a toaster, but I still tell people “Sorry, no toast
today,” something’s wrong. Either I’m willfully avoiding the truth, or I’m hoping
3 of 6
the bread goes stale before anyone asks questions.
PERAC has the tools. It has the data. And now it has a very public record of what
it’s choosing not to do.
I’m not requesting miracles. I’m requesting accountability—using the same tools
and technology that are available to the public.
I’m copying this to my blog archive and public record. Please consider this a
formal request for:
• A copy of the data retention policy covering PROSPER logs and email
archiving.
• A clear explanation of why AI tools are not being used to process these
requests in a timely fashion.
• A rolling schedule, showing which accounts and timeframes are being
processed each week.
If this request is too much for PERAC, let me know and I’ll forward it to the
State Auditor, DOJ, and any AI task force interested in public sector
modernization.
Thank you,
Richard Stebbins
4 of 6
On Aug 1, 2025, at 9:47 AM, McGinniss, Felicia M. (PER) <Felicia.M.McGinniss@mass.gov> wrote:
Good Morning Mr. Stebbins,
I would like to respectfully note that PERAC’s July 28, 2025 letter was neither evasive nor meant to “shield
misconduct” regarding our role in the investment process for retirement systems. The letter was meant to answer
all your questions in detail, which specifically asked for laws and regulations that demonstrated PERAC’s role in
investments and procurements. No specific details or information were omitted.
As noted in the letter and my prior emails, the letter itself was meant to solely address your questions that were
submitted in addition to your original public records request. No documents or data were intended to be provided
with that letter. I have already provided all documents requested concerning PERAC Memoranda and trainings
given that pertained to procurements and investments. As I previously indicted, we would need at least 2 months
to respond to the rest of your request, possibly more. We are in contact with our PROSPER vendor to obtain
login information, but it is 8 years of logs that you are requesting. Additionally, our internal IT team and the State
IT team are currently in the process of searching the emails of relevant PERAC employees to provide documents
that are responsive to your request.
I will keep you abreast of the status of your public records request but appreciate your continued understanding
and patience in this process.
Best,
Felicia
Felicia McGinniss, Esq.
Senior Associate General Counsel
Public Employee Retirement Administration Commission
10 Cabot Road, Suite 300
5 of 6
Medford, MA 02155
(617) 666-4446, ext. 909
www.mass.gov/perac
6 of 6
Pi-006-2025-12-8-to-2025-10-20-Stebbins-Baruffi
Fwd: Public Records Request – PERAC Investment Records 2024–2025
From: Ricky Stebbins (thestebbman@yahoo.com)
To: caroline.e.deluca@mass.gov
Date: Monday, December 8, 2025 at 11:41 AM EST
Hi Ms. De Luca,
I received an out-of-office from Christopher
Bowman and was directed to you as an alternate
contact.
I’m currently raising concerns about PERAC’s
oversight failures and vendor access to its
PROSPER system (including BlackRock and other
investment firms) that could affect public
employees’ pensions and investors worldwide.
I’ve already submitted detailed public records
requests and received partial responses from
PERAC’s counsel. I’m flagging this for you so there
is no question later that regulators and oversight
bodies were informed.
If your office has a defined process for escalating
systemic oversight concerns like this, I’m happy to
summarize the key patterns and provide links to the
documents and logs I’ve already published.
1 of 1 this one was never responded to.
Best,
Richard (Ricky) Stebbins
Fwd: Public Records Request – PERAC Investment Records 2024–2025
From: Ricky Stebbins (thestebbman@yahoo.com)
To: caryn.m.shea@mass.gov
Date: Monday, December 8, 2025 at 11:40 AM EST
Hi Ms. Shea,
I received an automated response that Veronica
Colon is no longer with PERAC, with a note that I
should contact you for assistance.
I want to make sure you’re aware that I have an
ongoing public records request and oversight
concern involving:
– PROSPER investment-vendor logins
(BlackRock and others)
– Late / inconsistent fee reporting
– Multiple emails showing consultants and
vendors shaping disclosures and reports across
many boards
These issues involve years of emails and
documents where Ms. Colon appears centrally
involved (report chasing, fee analysis, pooled fund
worksheets, CD requests, etc.).
1 of 15
Because of that, I want explicit confirmation that:
1. All of Ms. Colon’s emails and associated records
are being preserved in full, not deleted or altered,
and
2. They are being included in the ongoing response
to my records requests already being handled by
Ms. Baruffi.
I’m not making accusations about Ms. Colon
personally — my concern is systemic: the
documents show serious delays, gaps, and
dependencies on outside vendors that raise
questions about whether PERAC can actually
perform the oversight it describes in statute. That’s
why I’ve also copied oversight offices and am
preserving everything publicly.
Please confirm that her records are preserved and
within the scope of PERAC’s response.
Thank you,
Richard (Ricky) Stebbins
Begin forwarded message:
2 of 15
From: Ricky Stebbins <thestebbman@yahoo.com>
Date: December 8, 2025 at 9:55:34 AM EST
To: "Felicia M. Baruffi" <Felicia.M.Baruffi@mass.gov>, recordsrequests@sec.state.ma.us,
natacha.a.dunker@mass.gov, Christopher.Bowman@state.ma.us, paul.m.stein@state.ma.us,
Cynthia.Ittleman@state.ma.us, paul.a.camuso@state.ma.us, kevin.m.tivnan@state.ma.us,
Medes.Diaz@state.ma.us, veronica.colon@mass.gov
Cc: "Doreen M. Duane" <doreen.m.duane@mass.gov>
Subject: Re: Public Records Request – PERAC Investment Records 2024–2025
Good Morning Ms. Baruffi,
Thank you for providing the initial batch of emails and the vendor login
information from the PROSPER system. I appreciate that PERAC is working
through a large volume of material, and I recognize that coordinating with
State IT and a third-party vendor adds significant complexity.
However, after reviewing the materials provided so far, several issues have
emerged that raise serious questions about process integrity, oversight
limitations, and potential data-handling vulnerabilities. Before I publish or
escalate any concerns, I want to give PERAC the opportunity to explain its
position clearly and transparently.
To be very clear:
I am not making accusations.
I am giving PERAC the chance to clarify the situation before this is shared
with state oversight bodies, journalists, or EU data protection authorities who
may have jurisdiction due to the involvement of European vendors and funds.
Below is a structured explanation of why additional records and clarifications
are now necessary.
3 of 15
1. PROSPER Vendor Access Appears
Broader Than Expected
The logs you sent show a surprisingly large number of outside vendors
accessing the PROSPER investment portal, including:
• BlackRock
• Hamilton Lane
• State Street
• PRIM-affiliated entities
• Multiple private fund administrators
This volume of access — and the lack of detail about what each login
accessed — raises several concerns:
• There is no audit trail showing which files or disclosures were viewed or
downloaded.
• There is no geographic information, IP metadata, or device information.
• No access revocation logs were provided.
• No internal oversight or monitoring documentation appears to exist.
Under M.G.L. c. 66 (Public Records) and 201 CMR 17.00 (Data Security
Regulations), agencies must maintain:
• audit trails
• access logs
• retention logs
• documentation of third-party access to regulated systems
4 of 15
I am therefore requesting additional metadata because it appears that PERAC
may not have full visibility into how investment vendors interact with the
pension oversight system.
This is a potential oversight gap—one I want you to be able to explain before
I take it further.
2. Multiple Emails Show Confusion, Delays,
and Missing Reports Across Many Boards
The older emails (2018–2022) reveal a pattern:
• consultants repeatedly sending late, corrected, or missing reports
• pooled fund worksheets “out of balance”
• fee analysis reports missing or inconsistent
• PERAC staff asking vendors to re-send documents multiple times
• reports released only after private meetings with consultants
• inconsistent treatment of “net vs. gross of fees” performance data
• repeated reminders from PERAC to vendors about failing to submit
required disclosures
This is concerning because PERAC is the compliance authority for 104
retirement boards.
5 of 15
Under Chapter 32 and PERAC regulations, the Commission is obligated to
ensure:
• uniform reporting
• timely disclosures
• proper fee analysis
• vendor compliance
• audit readiness
The emails paint a picture of a system where private consultants and fund
managers control the flow of information — and PERAC spends a lot of time
asking for missing documents.
Again: I am not accusing PERAC of wrongdoing.
But the appearance of systemic disorganization is something the public,
pensioners, and possibly EU regulators would take seriously.
3. GDPR and EU Data Protection
Considerations
Several investment firms involved in this process are headquartered in or
operate under EU jurisdiction, including:
• Unigestion (Switzerland/EU operations)
• Mesirow (EU operations)
6 of 15
• Hamilton Lane (EU LP investors)
• RhumbLine funds with EU clients
• BlackRock (significant EU operations, GDPR-bound)
If European citizens’ data — or EU-regulated financial disclosures — flow
through PROSPER or Massachusetts systems, then:
GDPR Articles 5, 30, 32, and 33 impose:
• audit trails
• access logs
• documentation of data processors
• breach notification obligations
Right now, based on what you’ve provided:
It is unclear whether PERAC has met those obligations.
This is why I need the additional information below — not to accuse
PERAC, but to determine whether PERAC is even aware of the compliance
implications.
I want PERAC to have the opportunity to clarify this before I raise it with EU
partners or compliance monitors.
4. Why I Am Requesting Broader
7 of 15
Preservation and Documentation
Given the gaps above, I am formally requesting preservation of the following
categories so that no material is inadvertently deleted during PERAC’s search
process:
A. Full PROSPER system metadata
Because the login summary you provided lacks detail required under state
retention laws.
B. Email server metadata and archive restoration logs
Because multiple employees indicated they cannot access emails older than
12 months, which raises questions about retention compliance.
C. Device and VPN access logs
Because PERAC staff and vendors may access PROSPER remotely, which
matters for regulatory oversight.
D. Informal communications (texts, Teams, personal email used
for work)
8 of 15
These count as public records under Massachusetts law and could contain
key procurement or disclosure information.
E. Vendor communications involving PERAC
Because vendors are directly contacting PERAC about RFPs and disclosures.
F. Retention and deletion logs
This will confirm that nothing related to this matter was deleted
automatically.
G. Internal meeting notes, briefing memos, and directives
To understand PERAC’s internal process for vendor oversight.
H. Documentation of search terms, custodians, and systems
accessed
To ensure the transparency and completeness of the Public Records search.
None of this is an accusation.
It is due diligence — something I would do with ANY agency where the
documentary record appears incomplete or inconsistent.
9 of 15
Final Point: Giving PERAC the Chance to
Explain Before This Goes Public
I want to emphasize this in good faith:
I am giving PERAC an opportunity to explain, clarify, and correct the record
before I take any of this to:
• Massachusetts State Auditor
• AG’s Office
• Federal oversight partners
• EU GDPR regulators (if applicable)
• Investigative journalists and watchdogs
If I misunderstood the situation or if there is a reasonable explanation, I
genuinely want to hear it.
Transparency helps everyone — PERAC, retirees, vendors, and the public.
Please confirm receipt of this message and the preservation request. I look
forward to your clarification.
Sincerely,
Ricky Stebbins
10 of 15
Springfield, MA
413-949-1925
On Oct 23, 2025, at 9:32 AM, Baruffi, Felicia M. (PER) <Felicia.M.Baruffi@mass.gov>
wrote:
Good Morning Mr. Stebbins,
Pursuant to your Public Records Request, attached please find the login
information for investment vendor access in PROSPER. We are unable
to provide the IP addresses due to cybersecurity concerns; however, the
report includes the name of the individual, the vendor they are
associated with, and the date/time of the login into PROSPER.
The report starts in January 2020 because that is when the Investment
Portal in PROSPER was launched for investment vendors to upload
their required disclosures to PERAC. Prior to January 2020, investment
vendors did not have a portal in PROSPER to access, and so there is
no login information prior to then.
Best,
Felicia
Felicia Baruffi, Esq.
Senior Associate General Counsel
Public Employee Retirement Administration Commission
10 Cabot Road, Suite 300
Medford, MA 02155
(617) 666-4446, ext. 909
www.mass.gov/perac
**Please note my new email address: felicia.m.baruffi@mass.gov
From: Baruffi, Felicia M. (PER)
Sent: Monday, October 20, 2025 9:08 AM
To: Ricky Stebbins <thestebbman@yahoo.com>
11 of 15
Cc: Duane, Doreen M. (PER) <doreen.m.duane@mass.gov>
Subject: RE: RE: Public Records Request – PERAC Investment Records
2024–2025
Mr. Stebbins,
I apologize, this is a additional email. I wasn’t able to fit it all in the
expected 5 emails. This is the 6th and final one for this batch.
Felicia
Felicia Baruffi, Esq.
Senior Associate General Counsel
Public Employee Retirement Administration Commission
10 Cabot Road, Suite 300
Medford, MA 02155
(617) 666-4446, ext. 909
www.mass.gov/perac
**Please note my new email address: felicia.m.baruffi@mass.gov
From: Baruffi, Felicia M. (PER)
Sent: Monday, October 20, 2025 9:07 AM
To: 'Ricky Stebbins' <thestebbman@yahoo.com>
Cc: Duane, Doreen M. (PER) <doreen.m.duane@mass.gov>
Subject: RE: RE: Public Records Request – PERAC Investment Records
2024–2025
Email 5 of 5
Felicia Baruffi, Esq.
Senior Associate General Counsel
Public Employee Retirement Administration Commission
10 Cabot Road, Suite 300
Medford, MA 02155
(617) 666-4446, ext. 909
www.mass.gov/perac
12 of 15
**Please note my new email address: felicia.m.baruffi@mass.gov
From: Baruffi, Felicia M. (PER)
Sent: Monday, October 20, 2025 9:06 AM
To: 'Ricky Stebbins' <thestebbman@yahoo.com>
Cc: Duane, Doreen M. (PER) <doreen.m.duane@mass.gov>
Subject: RE: RE: Public Records Request – PERAC Investment Records
2024–2025
Email 4 of 5
Felicia Baruffi, Esq.
Senior Associate General Counsel
Public Employee Retirement Administration Commission
10 Cabot Road, Suite 300
Medford, MA 02155
(617) 666-4446, ext. 909
www.mass.gov/perac
**Please note my new email address: felicia.m.baruffi@mass.gov
From: Baruffi, Felicia M. (PER)
Sent: Monday, October 20, 2025 9:05 AM
To: 'Ricky Stebbins' <thestebbman@yahoo.com>
Cc: Duane, Doreen M. (PER) <doreen.m.duane@mass.gov>
Subject: RE: RE: Public Records Request – PERAC Investment Records
2024–2025
Email 3 of 5
Felicia Baruffi, Esq.
Senior Associate General Counsel
Public Employee Retirement Administration Commission
10 Cabot Road, Suite 300
Medford, MA 02155
(617) 666-4446, ext. 909
13 of 15
www.mass.gov/perac
**Please note my new email address: felicia.m.baruffi@mass.gov
From: Baruffi, Felicia M. (PER)
Sent: Monday, October 20, 2025 9:03 AM
To: 'Ricky Stebbins' <thestebbman@yahoo.com>
Cc: Duane, Doreen M. (PER) <doreen.m.duane@mass.gov>
Subject: RE: RE: Public Records Request – PERAC Investment Records
2024–2025
Email 2 of 5
Felicia Baruffi, Esq.
Senior Associate General Counsel
Public Employee Retirement Administration Commission
10 Cabot Road, Suite 300
Medford, MA 02155
(617) 666-4446, ext. 909
www.mass.gov/perac
**Please note my new email address: felicia.m.baruffi@mass.gov
From: Baruffi, Felicia M. (PER)
Sent: Monday, October 20, 2025 9:01 AM
To: 'Ricky Stebbins' <thestebbman@yahoo.com>
Cc: Duane, Doreen M. (PER) <doreen.m.duane@mass.gov>
Subject: RE: Public Records Request – PERAC Investment Records 2024–
2025
Good Morning Mr. Stebbins,
Pursuant to your Public Records request, attached please find the first
round of emails that is responsive to your request. This will be email 1
of 5. The rest of the emails are still being reviewed we are still working
on the PROSPER login information. I will send additional documents as
soon as I am able.
14 of 15
PROSPER FinancialVendorUserAccess_v1.pdf
337.5 KB
Best,
Felicia
Felicia Baruffi, Esq.
Senior Associate General Counsel
Public Employee Retirement Administration Commission
10 Cabot Road, Suite 300
Medford, MA 02155
(617) 666-4446, ext. 909
www.mass.gov/perac
**Please note my new email address: felicia.m.baruffi@mass.gov
CONFIDENTIALITY NOTICE This electronic message and any attachments are intended only for the addressee(s) and contains
information that may be privileged and confidential. If you are not the intended recipient, please no fy the sender by reply
email and immediately delete this message. Use, disclosure or reproduction of this email by anyone other than the intended
recipient(s) is strictly prohibited. Thank you.
15 of 15
Pi-007-2026-1-7-to-2025-12-14-Stebbins-Baruffi
From: felicia.m.baruffi@mass.gov
To: me, Cc: Duane,, and 1 other · Wed, Jan 7 at 12:14 PM
Cc:
< thestebbman@yahoo.com >,
Duane, Doreen M. (PER),< doreen.m.duane@mass.gov >,
Taylor, Daniel (PER),< daniel.taylor2@mass.gov >
Message Body
Good Afternoon Mr. Stebbins,
This email is in response to your public records request dated December 27, 2025. In response to Item A, PERAC has no records in its possession that are responsive. Mr. Ford was never at PERAC’s offices from June 2024-December 2025, and BlackRock was not informed of your July 7, 2025 public records request. In response to Item B, this is a specific test account that was created for a business user to check PROSPER functionality and how it works – aka a demo. The account does not have any access to any data.
In response to Item 4, PROSPER is a custom application hosted in Microsoft Azure Gov Cloud. It is managed by PERAC IT engineers and developers in conjunction with 2 of PERAC Main IT vendors. SMX whom is on the Commonwealth blanket contract provides 7x24 Managed security services and managed hosting services. In addition to PERACs internal developers, PERAC has contracted with CGI whom created PROSPER and continue to provide enhancements and bug fixes in conjunction with PERAC IT staff. PROSPER adheres to FISMA moderate with crosswalk to HIPPA compliance. In addition, we use another third party intra systems for security testing. The SLA for Microsoft Azure can be found here: https://www.microsoft.com/licensing/docs/view/Service-Level-Agreements-SLA-for-Online-Services?lang=1. Azure Government Compliance can be found here: https://learn.microsoft.com/en-us/azure/azure-government/documentation-government-plan-compliance.
PERAC has no records in its possession responsive to Items 3, 4, 5, and 6. Further, to the extent that these items constitute a list of questions, please be aware that the Public Records Law does not require custodians to answer questions, conduct research, or create new records.
Given the scope of your request, PERAC will be assessing a reasonable fee to produce responsive records, as permitted by the Public Records Law and its associated regulations. As a state agency, we will not be assessing a fee for the first four hours of staff time spent responding to the request. The lowest paid individual with the skill necessary to respond to the requests is compensated at a rate greater than $25 per hour, so our assessed hourly rate will be the maximum of $25 per hour allowed under the law. Additionally, PERAC will be filing a petition with the Supervisor of Records, seeking an extension of time to produce records, and permission to charge for redaction under Exemptions (c), (n), (o), and (t).
As of today’s date, PERAC has spent four hours of staff time conducting preliminary searches for responsive records. Our IT unit has indicated that it will take 30 hours to generate and redact the PROSPER access logs requested in Item 1 due to the over one million events that occurred during your time range. These logs will contain IP addresses, login credentials, and other sensitive information, the disclosure of which may compromise the cybersecurity of PERAC’s systems, as well as the systems of retirement boards and vendors. This information will be redacted pursuant to Exemption (n).
Our compliance and investment team has estimated that there are approximately 287 reports and related documents responsive to Item 2 of your request, each between 2 and 20 pages. Based on similar past requests, we estimate that locating, compiling, and reviewing the report for the requested data fields will require up to 30 minutes for each report. Accordingly, we will require 140 total hours of staff time to locate and compile all reports and data responsive to Item 2.
Our preliminary search for communications responsive to Item 3 of your request has returned more than 9,670 potentially responsive email communications and attachments. Our legal team will require at least 30 seconds to review each email communication and its attachments for responsiveness and exempt material, for a total of 80 hours of staff time. Given the nature of the work performed by our agency, these communications are likely to contain personal and financial information (e.g., social security numbers, personnel records, and medical and disability information) exempt from disclosure under Exemption (c), as well as the home addresses and personal contact information of public employees, exempt from disclosure under Exemption (o). The emails may also contain statements filed under Section 20C of Chapter 32, which are exempt from disclosure under Exemption (t).
Total Fee
(4 hours + 30 hours + 140 hours + 80 hours – 4 hours) x $25/hr = $6,250.00
If you would like PERAC to proceed with the production of responsive records, please provide our office with a check in the above amount, payable to the Public Employee Retirement Administration Commission. Once we have received payment, we will begin compiling responsive records. Alternatively, you may narrow the scope of your requests, providing a more limited time frame, list of parties, or set of search terms, and we will revise our fee estimate accordingly. Please note that simpler, narrower requests are less likely to require such significant expenditures of staff time.
Regarding your concerns about the preservation of records, PERAC can again confirm that it adheres to the MA Records Retention Schedule for maintaining documents and organizational records as well as the Public Records Law.
Best,
Felicia
Felicia Baruffi, Esq.
Senior Associate General Counsel
Public Employee Retirement Administration Commission
10 Cabot Road, Suite 300
Medford, MA 02155
(617) 666-4446, ext. 909
www.mass.gov/perac
**Please note my new email address: felicia.m.baruffi@mass.gov
CONFIDENTIALITY NOTICE This electronic message and any attachments are intended only for the addressee(s) and contains information that may be privileged and confidential. If you are not the intended recipient, please notify the sender by reply email and immediately delete this message. Use, disclosure or reproduction of this email by anyone other than the intended recipient(s) is strictly prohibited. Thank you.
From: Ricky Stebbins <thestebbman@yahoo.com>
Sent: Saturday, December 27, 2025 10:41 PM
To: Taylor, Daniel (PER) <Daniel.Taylor2@mass.gov>
Cc: Baruffi, Felicia M. (PER) <Felicia.M.Baruffi@mass.gov>; Duane, Doreen M. (PER) <doreen.m.duane@mass.gov>; MA-IGO-TRAINING (IGO) <ma-igo-training@mass.gov>
Subject: Refined Public Records Request: PROSPER Access Logs (2025), Native Financial Data, Vendor Coordination Documentation
CAUTION: This email originated from a sender outside of the Commonwealth of Massachusetts mail system. Do not click on links or open attachments unless you recognize the sender and know the content is safe.
Dear Records Access Officer,
This is a refined and narrowed public records request submitted pursuant to M.G.L. c. 66 and 950 CMR 32.00. It replaces previous overlapping requests and focuses on a limited set of records essential to understanding vendor access patterns, fee transparency, and data custody practices within PERAC’s oversight systems.
This request emerges from documented inconsistencies between PERAC’s public statements and internal records already produced via prior FOIA responses. It seeks to resolve evidentiary conflicts, clarify statutory obligations, and preserve audit trails for systems managing over $90 billion in public pension assets.
The records requested below are structured to minimize processing burden while maximizing auditability. Where machine-readable formats already exist, this request explicitly declines PDF substitutes that degrade data integrity.
-----
## **OVERVIEW: TEMPORAL PATTERN REQUIRING DOCUMENTATION**
**July 7, 2025 (1:10 AM):**
I submitted a public records request to 10+ Massachusetts state officials, including PERAC, requesting:
> “All access logs to the PROSPER system from external IP addresses or users affiliated with investment vendors, including but not limited to: BlackRock, Hamilton Lane, State Street, Vanguard, PRIM-affiliated firms”
**Recipients included:**
- Felicia McGinniss (PERAC Senior Associate General Counsel)
- Natacha Dunker (PERAC)
- Secretary of State Records Office
- Christopher Bowman, Paul Stein, Cynthia Ittleman, Paul Camuso, Kevin Tivnan, Medes Diaz (State oversight officials)
- Treasury Department
- EOEEA
**BlackRock was not on the recipient list.**
**July 7, 2025 (10:07 AM) - Nine hours later:**
James Dasaro (BlackRock Director, Client Experience Management) emails John Galvin (PERAC Compliance Manager):
> “Would you be able to help provide access to the PROSPER portal to my colleagues copied in here?”
**Requested credentials for:**
- Sarah Brandwein (sarah.brandwein@blackrock.com)
- Miley Xiao (aiyin.xiao@blackrock.com)
- Conor Ford (Conor.Ford@blackrock.com)
**July 8, 2025 (7:44 AM):**
John Galvin responds:
> “Sara, Miley, Conor- a registration email will come under separate cover for access to the site.”
**July 8 - August 19, 2025:**
Intensive PROSPER access activity by newly-credentialed accounts, followed by complete cessation.
This temporal pattern—FOIA submission, credential request by non-recipient within hours, intensive access, then cessation—forms the evidentiary foundation for the records requested below.
-----
## **1. PROSPER ACCESS LOGS – Calendar Year 2025**
### **Public Interest Context:**
PERAC’s PROSPER system grants external vendors direct access to pension fund disclosures, performance data, and fee reports. Massachusetts pension systems serve over 300,000 active and retired employees across 104 retirement boards. Access logs are the only mechanism for detecting unauthorized use, coordinated disclosure manipulation, or preferential information sharing.
**As PERAC Vice-Chair, State Auditor Diana DiZoglio has authority to conduct performance audits of PERAC’s operations—reviewing policy compliance and operational procedures. However, performance audits typically do not examine underlying financial data integrity, vendor fee validation, or investment performance verification. This records request seeks access and financial data necessary for comprehensive financial audit capabilities beyond current performance review scope.**
### **Request:**
All PROSPER access logs from **January 1, 2025 through December 31, 2025**, in CSV or XLSX format.
**Required data fields (if maintained):**
- Timestamp (with timezone)
- Username
- User role or privilege level
- Organization or vendor affiliation
- Event type (login, view, edit, upload, download, delete)
- Device ID or IP address
- Session ID or duration
**Technical Compatibility Note:** Please do not convert structured logs to flattened PDFs. Provide native export format (CSV, JSON, or XLSX) to preserve column integrity and enable proper filtering.
**Sample Output Request:** Before full production, provide a 1-page sample to confirm field alignment and completeness.
-----
### **A. Conor Ford – BlackRock Advisors LLC: Access Pattern Following FOIA Request**
**Employment and Access Timeline:**
Public FINRA records (BrokerCheck, CRD# 7312440) confirm Conor Ford has been employed by BlackRock Investments, LLC for approximately 4 years, working from BlackRock’s Boston office at 60 State Street—approximately 2.3 miles from PERAC’s Medford headquarters.
|Period |Ford Employment Status |PROSPER Access |
|-------------------|------------------------------|----------------|
|~2022-2024 |BlackRock employee (Years 1-3)|0 logins |
|Jan-July 7, 2025 |BlackRock employee (Year 4) |0 logins |
|July 8, 2025 |BlackRock employee |First login ever|
|July 8-Aug 19, 2025|BlackRock employee |34 logins |
|Aug 20-Dec 2025 |BlackRock employee |0 logins |
**Access Event Summary:**
**July 7, 2025 (1:10 AM):** I submit FOIA requesting BlackRock PROSPER access logs
**July 7, 2025 (10:07 AM):** BlackRock requests credentials for Brandwein, Xiao, Ford
**July 8, 2025 (7:44 AM):** PERAC approves credentials
**July 8, 2025 (10:44 AM):** Ford’s first PROSPER login in 4-year employment history
**August 19, 2025 (5:13 PM):** Ford’s last login (17 logins that day: 10:01 AM - 5:13 PM)
**After August 19:** Zero activity
**Comparison:**
|Account |Credentials Requested|Total Logins|Pattern |
|---------------|---------------------|------------|--------------------------|
|Sarah Brandwein|YES |0 |Never used |
|Miley Xiao |YES |1 |Single login July 8 |
|Conor Ford |YES |34 |July 8-Aug 19, then ceased|
**Documentation Requested:**
**1. Notification and Coordination**
Please produce any communications showing how BlackRock became aware of my July 7, 1:10 AM FOIA request by 10:07 AM the same day:
- Any emails, phone logs, or meeting records between PERAC staff and BlackRock on July 7, 2025
- Any internal PERAC emails or messages discussing my FOIA request and whether to notify vendors
- Any written PERAC policy governing vendor notification during public records reviews
- Any calendar entries, visitor logs, or meeting documentation showing Ford at PERAC offices (July 2024-December 2025)
**2. Access Activity During Ford Sessions**
Please provide:
- Action-level logs showing which PROSPER files, modules, or data were viewed, downloaded, modified, or deleted during the 34 Ford sessions
- Whether any Schedule 7 disclosures, fee reports, or performance data were accessed
- Whether any records responsive to my FOIA request were accessed
- Session duration and specific activity timestamps for each login
If action-level logs do not exist, please provide:
- Written explanation of why such logs are not retained
- How PERAC ensures compliance with 201 CMR 17.00 audit trail requirements without action-level logging
- Whether PERAC can verify that no records were modified or deleted during vendor access
**3. Employment History and Access Pattern**
Ford worked at BlackRock for approximately 3 years (2022-2024) with zero PROSPER access. Please provide:
- Documentation explaining why PROSPER access was not needed during Ford’s first three years of employment
- Whether Ford’s role, title, or responsibilities changed in July 2025
- Whether another BlackRock employee previously handled PROSPER access for Massachusetts pension accounts
- Business justification for requesting credentials on July 7, 2025 (nine hours after my FOIA submission)
**4. Credential Request for Multiple Accounts**
Three credentials were requested but usage varied dramatically. Please clarify:
- Business purpose stated or implied in BlackRock’s July 7 credential request
- Whether Brandwein, Xiao, and Ford were expected to perform different tasks or the same review
- Why Brandwein never logged in despite credential approval
- Why Xiao logged in only once
**5. Account Activity Cessation**
After 3+ years without PROSPER access, Ford accessed the system 34 times over 6 weeks, then stopped completely. Please provide:
- Documentation of what task was completed on or around August 19 that no longer required access
- Whether Ford’s account was deactivated or whether the user simply stopped accessing
- Whether Ford’s role, access privileges, or responsibilities changed after August 19
- Whether the timing of cessation coincided with any PERAC decisions or actions regarding my FOIA request
**6. Identity Verification Documentation**
Please provide:
- Employment verification or documentation submitted when BlackRock requested credentials
- Any organizational chart or directory listing showing Ford’s role with respect to Massachusetts pension systems
- Any correspondence from Ford or about Ford beyond the July 7-8 credential exchange
-----
### **B. Test Account – “zzTest PERAC Vendor money manager1”**
**Timeline:**
**August 19, 2025 (5:13 PM):** Ford’s last login
**September 5, 2025 (1:19 PM):** First and only login by “Financial_Vendor, Test Zztest PERAC Vendor money manager1”
**Historical Context:** Cross-referencing logs from 2020-2024 shows zero instances of this account designation.
**Documentation Requested:**
Please provide:
- Account creation date, creator identity, and authorization documentation
- Business purpose for maintaining test or generic accounts in production oversight systems
- Whether this account was used for system testing, vendor training, data review, or other purposes
- Whether the September 5 login can be attributed to a specific individual or organization
- Whether this is a shared account accessible by multiple users
- How PERAC tracks accountability for actions taken under non-attributable accounts
- How generic account use complies with 201 CMR 17.00 access control and audit trail requirements
- Why this account appeared for the first time in 2025
- Any relationship between Ford account cessation (August 19) and zzTest account appearance (September 5)
-----
### **C. Pattern Summary Across Complete Historical Record**
Cross-referencing all five PROSPER access log files (January 2020 through December 2025) confirms:
|Pattern |2020-2024 |2025 |Significance |
|----------------------------------|--------------------|------------------|---------------------------|
|Conor Ford employment at BlackRock|~3 years (2022-2024)|Year 4 |Employed but zero access |
|Conor Ford PROSPER logins |0 |34 (July-Aug only)|First access after 3+ years|
|Ford activity cessation |N/A |August 19 |Complete stop after 6 weeks|
|zzTest account |0 logins |1 login (Sept 5) |First appearance ever |
|Same-day clusters (17+ logins) |0 instances |1 (Aug 19) |Unprecedented pattern |
Both unprecedented patterns appear exclusively in 2025, during the two-month period following my FOIA request.
**Methodological Note:** This pattern analysis was conducted by cross-referencing all five PROSPER access log files provided by PERAC (covering January 2020 through December 2025), using both manual review and systematic data analysis to detect anomalous access clusters, credential timing patterns, and metadata inconsistencies. The findings are based on complete data sets provided by PERAC itself.
-----
## **2. NATIVE FORMAT FINANCIAL DATA – Gross vs. Net Returns (2018–2024)**
### **Public Interest Context:**
**State Auditor DiZoglio’s office conducts performance audits—reviewing whether agencies follow policies and procedures. Performance audits typically do not examine whether reported investment performance is mathematically accurate, whether fees extracted match contractual agreements, or whether gross vs. net disclosures enable independent verification of vendor billing.**
**This records request seeks underlying financial data necessary for comprehensive financial audit capabilities—examining whether reported numbers can be independently validated, whether fees align with contracts, and whether performance claims can be verified through source data.**
The difference between gross and net investment returns represents total management costs—including fees, carried interest, and administrative expenses. For Massachusetts pension funds, this difference can amount to hundreds of millions of dollars annually.
Internal PERAC communications—including an email dated February 2021—reference decisions to omit or consolidate gross vs. net fields for “formatting” purposes. This design choice materially affects the ability to conduct independent financial verification.
### **Request:**
For all private equity, private credit, real assets, and fund-of-funds investments reported to PERAC between **2018–2024**, provide the following data fields in machine-readable format:
**Required data fields (as separate columns):**
- Fund name
- Vintage year
- Commitment amount
- Capital called
- Capital distributed
- Gross IRR (internal rate of return)
- Net IRR (internal rate of return)
- Gross MOIC (multiple on invested capital)
- Net MOIC (multiple on invested capital)
- Management fees (annual and cumulative)
- Performance fees / carried interest
- Fee offsets or rebates
- Valuation methodology used
- Reporting entity (e.g., Meketa, BlackRock, HarbourVest, NEPC)
**Format requirement:** Excel (.XLSX), CSV, or similar structured formats only. PDFs are not acceptable where native structured data exists.
**Technical Compatibility Note:** If vendors provided these reports in Excel or CSV format, please provide those native files without converting them to PDF. PDF conversion strips formulas, cell lineage, and reconciliation logic—rendering the data non-auditable.
**Sample Output Request:** Please provide a 1-page sample showing column structure and field completeness before full production.
-----
### **Basis for Request:**
Without both gross and net figures:
- Fees cannot be independently verified against contractual agreements
- Performance cannot be reconciled across report types or time periods
- Carried interest calculations cannot be validated
- Long-term underperformance can be masked by selective presentation
**If Data Is Unavailable:**
If PERAC does not possess the requested gross/net data, please provide:
- Specification of which fields are missing
- Date when data was discarded
- Records retention authority permitting destruction
- Name and title of person who authorized discarding structured data
If data exists but is being withheld:
- Specific statutory exemption with supporting case law
- Any segregable portions that can be disclosed
-----
## **3. TARGETED COMMUNICATIONS – July 1, 2025 to Present**
### **Public Interest Context:**
PERAC has provided contradictory statements regarding its role in vendor coordination and investment oversight. Understanding what communications occurred after my FOIA requests were filed is essential to resolving these documented inconsistencies.
### **Request:**
Communications (internal PERAC or between PERAC and vendors) from **July 1, 2025 to present** containing any of the following terms:
**Keywords:**
- “Conor Ford”
- “BlackRock”
- “public records request” or “FOIA” or “Stebbins”
- “logs” or “access logs”
- “zztest”
- “gross” and “net” (in same email)
- “PROSPER access” or “PROSPER login”
- “vendor access”
- “Schedule 7”
**Priority subject lines** (based on prior FOIA productions):
- “RE: PROSPER Application Access – BlackRock”
- “Fee Report”
- “RE: 2019 Annual Vendor Disclosures”
- “RE: Unigestion – Opportunity to Meet”
- “FW MA Consultant RFPs”
**If records are withheld or redacted:**
- Indicate volume withheld
- Cite specific statutory exemption with supporting case law
- Confirm whether any segregable content exists
-----
## **4. PROSPER SYSTEM CUSTODY AND VENDOR DOCUMENTATION**
### **Public Interest Context:**
PERAC’s August 1, 2025 response stated:
> “We are not sitting on 8 years of logs… They are compiling a report from scratch.”
Yet PROSPER login records dating to January 2020 were subsequently produced, confirming that historical logs exist in some form. Under M.G.L. c. 7, § 22C, state IT contracts must be publicly disclosed.
### **Request:**
Please provide:
**1. Vendor Identity:**
The name of the entity (internal PERAC unit, Commonwealth IT division, or external vendor) responsible for hosting, maintaining, or compiling PROSPER access logs
**2. Contract Documentation:**
Any contract, statement of work, or service agreement governing:
- Log retention policies and timeframes
- Audit export procedures and formats
- Security and access control requirements
- Data ownership and custody arrangements
**3. Request Documentation:**
A copy of the specific request PERAC sent to this entity in response to my July 2025 FOIA request, including:
- Date sent
- Scope of data requested
- Fields or formats specified
- Any stated limitations or exclusions
**4. Data Integrity Confirmation:**
Please provide:
- Written confirmation of whether this vendor has deleted, archived, modified, or migrated any PROSPER access logs since January 1, 2020
- Documentation of any log retention schedule or data lifecycle policies
- Verification procedures PERAC uses to ensure completeness and integrity of vendor-provided access logs
-----
## **5. FEE ESTIMATE REVISION AND JUSTIFICATION**
### **Context:**
Your December 24, 2025 response estimated **$6,575** based on:
- 27,000 emails × 30 seconds each = 225 hours
- 250 documents × 1 minute = 40 hours
- Total: 263 hours – 4 free hours = $6,575
This refined request materially reduces that burden:
- **Section 1:** Requests only 2025 logs (1 year, not 8)
- **Section 2:** Requests native files already received from vendors (no new record creation)
- **Section 3:** Limits communications to 6 months (July 2025–present)
- **Section 4:** Requests existing contract documentation
### **Revised Estimate Request:**
Pursuant to **950 CMR 32.07(2)**, please provide a revised fee estimate specific to this narrowed scope, including:
**Itemization by section:**
- Estimated hours per section
- Specific employee roles and hourly rates
- Description of tasks required (e.g., database query, manual review, redaction)
**Automation explanation:**
- Whether automated search tools, e-discovery platforms, or database exports are being used
- If not, explanation of why manual review is necessary when state agencies typically have access to enterprise document management systems
**Reconciliation with prior statements:**
- Your office stated PROSPER logs must be “compiled from scratch” by a vendor, suggesting automated extraction capability
- If automated log compilation is possible, please explain why email review would require 225 hours of manual labor
**Sample output option:**
- If significant processing costs are anticipated, please provide sample outputs for Sections 1 and 2 to confirm data completeness and format before incurring full processing fees
-----
## **6. DOCUMENTED INCONSISTENCIES – REQUEST FOR RECONCILIATION**
The following statements, when viewed together, create contradictory representations about PERAC’s role, capabilities, and data practices:
|Date |Statement |Source |
|-----------------|----------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------|
|July 8, 2025 |“PERAC itself does not conduct any type of investments” |Email response to public records request |
|July 28, 2025 |“PERAC regularly corresponds with retirement boards and some potential vendors… to ensure that proper documentation is being provided in response to RFPs”|Official letter response |
|August 1, 2025 |“We are not sitting on 8 years of logs… They are compiling a report from scratch” |Email response regarding PROSPER data |
|October 23, 2025 |Production of PROSPER login records dating to January 2020 |Attachment: PROSPER_FinancialVendorUserAccess_v1.pdf|
|December 24, 2025|Claims 27,000 emails exist but also states emails older than 12 months “cannot be easily searched” |Fee estimate letter |
The records requested in Sections 1–4 are designed to resolve these documented inconsistencies by providing primary source documentation rather than summary characterizations.
-----
## **7. PURPOSE AND BROADER CONTEXT**
### **Public Interest Foundation:**
This request is submitted as part of a broader review of public pension vendor oversight practices across Massachusetts retirement systems. Massachusetts pension systems collectively manage over $90 billion in public assets on behalf of more than 300,000 active and retired public employees, including:
- State police and correctional officer pensions
- Teacher and university employee retirement systems
- Municipal worker and utility employee funds
- Regional and county retirement boards
Transparency in vendor access patterns, fee reporting, and data integrity directly affects these beneficiaries and Massachusetts taxpayers.
### **Analytical Framework:**
This request has been developed through systematic review of publicly available documents, including:
- PERAC annual reports (2018–2024)
- Schedule 7 fee disclosures
- Prior FOIA responses from PERAC (2025)
- PROSPER access logs
- Internal PERAC-vendor communications
Pattern analysis was conducted through cross-referencing of publicly available FOIA disclosures using analytical review frameworks designed to identify systematic gaps in audit capability and data transparency.
### **Relationship to State Auditor Oversight:**
State Auditor Diana DiZoglio serves as PERAC Vice-Chair and has authority to conduct performance audits of PERAC operations. Performance audits typically review policy compliance, operational procedures, and adherence to regulations—essential oversight functions that ensure agencies follow established rules.
However, performance audits generally do not examine:
- Whether reported investment performance numbers are mathematically accurate
- Whether vendor fees extracted match contractual agreements
- Whether gross vs. net disclosures enable independent financial verification
- Whether access controls prevent unauthorized data manipulation
The records requested above seek underlying access logs and financial data necessary for comprehensive financial audit capabilities that complement, but extend beyond, current performance review scope.
Given the State Auditor’s oversight role and commitment to transparency in government operations, I respectfully request that her office consider whether the patterns documented in this request—including vendor notification during FOIA reviews, unprecedented access timing, missing financial data fields, and third-party custody gaps—warrant additional review within the State Auditor’s statutory authority.
-----
## **8. PRESERVATION NOTICE**
Please preserve all relevant materials pending production and any potential administrative review, including:
- PROSPER access logs (2020–2025, complete period)
- Vendor communications regarding RFP guidance, disclosure formatting, or fee reporting
- Structured financial files received from vendors in native formats
- Internal emails regarding my public records requests
- Contracts or documentation governing third-party data custody
- Any communications between PERAC staff and vendors on July 7, 2025
**If any requested records no longer exist, please provide:**
- Specific record category
- Date of deletion or destruction
- Records retention authority cited (with specific citation)
- Name and title of person who authorized destruction
-----
## **CLOSING**
This request is submitted in good faith to obtain machine-readable, auditable data necessary for understanding vendor access patterns, fee transparency, and fiduciary oversight practices affecting billions in public pension assets.
If any requested record is unavailable, is not in PERAC’s custody, or is claimed to be exempt from disclosure:
- Identify the specific record
- Provide the legal basis for non-production with statutory citation
- Confirm whether any segregable portion can be produced
Please confirm receipt of this request and provide a revised fee estimate within **10 business days** as required by M.G.L. c. 66, § 10.
Thank you for your attention to this matter.
Sincerely,
**Ricky Stebbins**
54 Hope Street
Springfield, MA 01119
Ricky
On Wednesday, December 24, 2025 at 09:40:13 AM EST, Taylor, Daniel (PER) <daniel.taylor2@mass.gov> wrote:
Good morning Mr. Stebbins,
This email is in response to your public records requests dated December 15 and December 18, 2025. In response to Item I of your 12/15 request, please see the attached, as well as the reports publicly posted at the following links: https://www.mass.gov/lists/perac-investment-schedule-7-fee-reports, https://www.mass.gov/perac-annual-reports.
PERAC has no records in its possession responsive to Items III, V, VI, VII and VIII of your 12/15 request, or Items IV, V, and VII of your 12/18 request. Further, to the extent that these items constitute a list of questions, please be aware that the Public Records Law does not require custodians to answer questions, conduct research, or create new records.
Given the scope of your requests, PERAC will be assessing a reasonable fee to produce responsive records, as permitted by the Public Records Law and its associated regulations. As a state agency, we will not be assessing a fee for the first four hours of staff time spent responding to the requests. The lowest paid individual with the skill necessary to respond to the requests is compensated at a rate greater than $25 per hour, so our assessed hourly rate will be the maximum of $25 per hour.
As of today’s date, PERAC has spent two hours of staff time developing search terms and conducting preliminary searches for responsive records. Our compliance and investment team has estimated that there are approximately 250 reports and related documents responsive to Item I of your 12/18 request, and more than 2,200 reports and related documents responsive to Item II of your 12/18 request. Based on similar past requests, we estimate that locating and compiling each report and any related documentation will require up to a minute. Accordingly, we will require 40 total hours of staff time to locate and compile all reports responsive to Items I and II of your 12/18 request.
Our preliminary search for communications responsive to Items II and IV of your 12/15 request and Items III and VI of your 12/18 request has returned more than 27,000 potentially responsive email communications. Our legal team will require at least 30 seconds to review each email communication and its attachments for responsiveness, for a total of 225 hours of staff time. Please note, while the responsive records are likely to contain information which is exempt from disclosure under Exemptions (a), (c), (n), and (o) of the Public Records Law, PERAC is not currently assessing a fee for the segregation and redaction of exempt material.
Total Fee
(2 hours + 40 hours + 225 hours – 4 hours) x $25/hr = $6,575.00
If you would like PERAC to proceed with the production of responsive records, please provide our office with a check in the above amount, payable to the Public Employee Retirement Administration Commission. Once we have received payment, we will begin compiling responsive records. Alternatively, you may narrow the scope of your requests, providing a more limited time frame, list of parties, or set of search terms, and we will revise our fee estimate accordingly. Please note that simpler, narrower requests are less likely to require such significant expenditures of staff time.
Thank you,
Dan
Daniel Taylor, Esq.
Associate General Counsel
Public Employee Retirement Administration Commission
10 Cabot Road, Suite 300
Medford, MA 02155
(617) 666-4446, ext. 912
www.mass.gov/perac
From: Ricky Stebbins <thestebbman@yahoo.com>
Sent: Thursday, December 18, 2025 7:26 PM
To: Baruffi, Felicia M. (PER) <Felicia.M.Baruffi@mass.gov>
Subject: Public Records Request (Parallel) – Vendor Gross/Net Performance Reports (2018–2024)
CAUTION: This email originated from a sender outside of the Commonwealth of Massachusetts mail system. Do not click on links or open attachments unless you recognize the sender and know the content is safe.
Dear Ms. Baruffi,
I am submitting this as a new and separate Public Records Request, to proceed in parallel with my pending consolidated request and not to replace it.
This request is focused on a single, documented issue reflected in PERAC–vendor correspondence:
whether gross and net performance data were calculated or available but omitted from distributed reports, and how PERAC ensures accuracy, reconcilability, and oversight when that occurs.
This request seeks existing records only.
It does not ask PERAC to create new analyses, calculations, reconciliations, or reports.
I. Meketa Investment Group – Gross/Net Performance Data and Report Version History (2018–2024)
PERAC–vendor correspondence from February 2021 states that including both gross and net performance in the Trailing Performance Summary would make the “net/gross column” in the Fee Expense Analysis “no longer applicable” and could “cause more confusion than clarity.”
That statement indicates that:
Gross and net performance data existed or were calculable, and
A reporting-format decision was made that affected reconcilability across report types and periods.
A. Systems / Boards
For the period January 1, 2018 through December 31, 2024, please produce Meketa-prepared reports for the following systems:
Massachusetts Housing Finance Agency (MassHousing / “Mass HFA”)
Norwood Retirement System
Plymouth County Retirement System
Plymouth Retirement System
Worcester Retirement System
Hingham Retirement System
Lexington Retirement System
Marlborough Retirement System
Quincy Retirement System
B. Report Types
For each system listed above, please produce all versions of:
Trailing Performance Summary reports (quarterly and/or annual)
Fee Expense Analysis reports
Any quarterly, annual, or multi-year performance or fee reports prepared by Meketa that were provided to PERAC, transmitted through PERAC, or relied upon by PERAC
C. Versions, Columns, and Explanations
For each system, report type, and year, please produce:
Any version(s) that include both gross and net performance figures in the Trailing Performance Summary
Any version(s) where such figures or columns were omitted, removed, suppressed, or altered
Any emails, cover memoranda, internal notes, or attachments explaining:
why the figures or columns were omitted or altered,
who requested, approved, or accepted the change, and
whether PERAC staff (including Veronica Colon) discussed, reviewed, relied upon, or responded to this issue in any communication, whether or not a formal response was issued
If PERAC does not retain multiple versions, please explicitly confirm whether:
such versions were never received,
such versions were received but not retained, or
PERAC retains PDFs only and not native or working files
D. Attachments, Native Files, and Underlying Data
Please also produce any attachments or native files (e.g., XLS, XLSX, CSV, or similar structured formats) received, reviewed, or relied upon by PERAC that contain performance or fee data underlying these reports, regardless of whether the final distributed reports omitted certain fields.
This request includes records reflecting PERAC’s receipt, review, awareness of, or reliance upon such data, even if the underlying files are retained by vendors.
If PERAC does not retain such attachments, please confirm whether:
they were received but not retained, or
PERAC does not retain non-PDF formats as a matter of practice
II. Other Vendors – Identification of Similar Omission Practices (2018–2024)
Beyond Meketa, please provide records sufficient to determine whether any other PERAC-associated investment consultants or vendors:
calculated gross and net performance data (or advised that such data were available internally), but
omitted those figures from distributed reports, or
altered report formats in a way that prevents year-over-year or cross-report reconciliation
This includes, but is not limited to:
BlackRock
State Street / State Street Global Advisors
Hamilton Lane
Gen II Fund Services
Any private equity or real estate fund administrators or consultants providing performance or fee reporting
For each vendor where this applies, please produce:
Vendor name and affected report type(s)
Systems or boards affected
Any versions retained by PERAC that include omitted data
Records describing what data the vendor tracks internally, what data is distributed externally, and what PERAC knew, reviewed, or relied upon
If PERAC does not track, verify, or evaluate whether vendors omit reconcilable fields, please confirm that in writing.
III. PERAC–Vendor Correspondence Regarding Omission or Avoidance of Reconcilable Data (2018–2024)
Please produce correspondence between PERAC and vendors from January 1, 2018 through December 31, 2024 that discusses omitting, removing, discouraging, or avoiding inclusion of performance or fee data, including communications containing language such as:
“cause more confusion than clarity”
“no longer applicable”
“not intended to represent actual fees paid”
“fee estimates not included”
“outside scope of service”
“management or performance fee verification”
“carried interest”
“tedious” or “imprecise”
“not an audit” / “not verified” / “do not calculate”
This includes emails, attachments, internal notes, and vendor explanations.
IV. Responsibility for Reconciliation and Oversight
Please produce any records from 2018–2024 identifying:
which entity (PERAC, vendor, retirement board, or other) is responsible for reconciling performance and fee data when vendor reports are acknowledged to be incomplete, estimated, or not independently verifiable, and
what action, if any, is taken when PERAC becomes aware that reports cannot be reconciled across report types or reporting periods
If no such responsibility, escalation, or oversight documentation exists, please confirm that in writing.
V. Basis for Accuracy of Annual Reports
Please produce any records describing how PERAC determines that annual reports are accurate when underlying vendor reports are incomplete, estimated, or not independently verified.
If no such records exist, please confirm that in writing.
VI. Vendor Clarification Requests Initiated by PERAC
If PERAC has contacted vendors to clarify omitted performance or fee data, please produce:
the requests sent,
the vendors’ responses, and
any resulting updates or decisions not to update reports
If PERAC has not contacted vendors regarding this issue, please confirm that no such clarification requests were made.
VII. Distribution of Updated or Corrected Reports
If any corrected or reissued reports exist, please produce records showing:
whether PERAC redistributed them to boards or systems,
whether recipients were notified that earlier versions were incomplete or non-reconcilable, and
the distribution lists used (board/system level only)
If PERAC does not redistribute corrected reports when reconciliation issues are identified, please confirm that practice.
Purpose (Clarifying, Not Accusatory)
This request is made to allow boards, unions, retirees, and the public to understand whether reported performance and fees are structurally reconcilable over time, and how accuracy and oversight are ensured when certain figures are omitted or not verified.
I am not alleging wrongdoing. I am requesting records that vendor correspondence indicates exist, or documentation clarifying responsibility when reconciliation is not possible.
Please confirm receipt and advise if any clarification is required.
Sincerely,
Ricky Stebbins
CONFIDENTIALITY NOTICE This electronic message and any attachments are intended only for the addressee(s) and contains information that may be privileged and confidential. If you are not the intended recipient, please notify the sender by reply email and immediately delete this message. Use, disclosure or reproduction of this email by anyone other than the intended recipient(s) is strictly prohibited. Thank you.
CONFIDENTIALITY NOTICE This electronic message and any attachments are intended only for the addressee(s) and contains information that may be privileged and confidential. If you are not the intended recipient, please notify the sender by reply email and immediately delete this message. Use, disclosure or reproduction of this email by anyone other than the intended recipient(s) is strictly prohibited. Thank you.
To: pre, Cc: me, and 2 others · Wed, Jan 7 at 12:21 PM
Message Body
Good Afternoon,
PERAC has received the below public records request from Mr. Ricky Stebbins. Also below is our agency’s response to this request. Given the magnitude of the request, we are petitioning for a time extension of 20 business days. Additionally, we are seeking permission to assess fees for time spent redacting responsive records pursuant to Exemptions (c), (n), (o), and (t). Our response below sets forth the reasons this request cannot prudently be completed without segregation and redaction.
Please let me know if you require any further information.
Thank you,
Felicia
Felicia Baruffi, Esq.
Senior Associate General Counsel
Public Employee Retirement Administration Commission
10 Cabot Road, Suite 300
Medford, MA 02155
(617) 666-4446, ext. 909
www.mass.gov/perac
**Please note my new email address: felicia.m.baruffi@mass.gov
From: felicia.m.baruffi@mass.gov
To: pre, Cc: me, and 2 others · Wed, Jan 7 at 12:21 PM
pre,< pre@sec.state.ma.us >
Cc:
< thestebbman@yahoo.com >,
Duane, Doreen M. (PER),< doreen.m.duane@mass.gov >,
Taylor, Daniel (PER),< daniel.taylor2@mass.gov >
Message Body
Good Afternoon,
PERAC has received the below public records request from Mr. Ricky Stebbins. Also below is our agency’s response to this request. Given the magnitude of the request, we are petitioning for a time extension of 20 business days. Additionally, we are seeking permission to assess fees for time spent redacting responsive records pursuant to Exemptions (c), (n), (o), and (t). Our response below sets forth the reasons this request cannot prudently be completed without segregation and redaction.
Please let me know if you require any further information.
Thank you,
Felicia
Felicia Baruffi, Esq.
Senior Associate General Counsel
Public Employee Retirement Administration Commission
10 Cabot Road, Suite 300
Medford, MA 02155
(617) 666-4446, ext. 909
Pi-008-2024-5-7-2024-5-9-Re_Hi John!!
From: Galvin, John P. (PER)
To: D"Arcy, Tim
Subject: Re: Hi John!!
Date: Thursday, May 9, 2024 10:01:33 AM
Attachments: image004.png
image005.png
image001.png
image.png
hey- just waiting for this to load..
From: D'Arcy, Tim
Sent: Tuesday, May 7, 2024 1:49 PM
To: Galvin, John P. (PER)
Subject: RE: Hi John!!
10:00 – 11:00 works! I’ll send a calendar invite.
TD
Timothy R. D’Arcy
Managing Director I BlackRock
Alternatives Specialist Team
Mobile: (+1) 617.571.9767
Office: (+1) 617.342.1633
BlackRock logo
From: Galvin, John P. (PER)
Sent: Tuesday, May 7, 2024 1:13 PM
To: D'Arcy, Tim
Subject: RE: Hi John!!
External Email: Use caution with links and attachments
I’m free after 9 till 12.
Thank you,
John
John Galvin
Compliance Officer
Public Employee Retirement Administration Commission
5 Middlesex Ave., Suite 304
Somerville, MA 02145
Phone: 617-591-8927
John.P.Galvin@mass.gov
From: D'Arcy, Tim <timothy.darcy@blackrock.com>
Sent: Tuesday, May 7, 2024 1:02 PM
To: Galvin, John P. (PER) <John.P.Galvin@mass.gov>
Subject: RE: Hi John!!
CAUTION: This email originated from a sender outside of the Commonwealth of
Massachusetts mail system. Do not click on links or open attachments unless you
recognize the sender and know the content is safe.
CAUTION: This email originated from a sender outside of the Commonwealth of
Massachusetts mail system. Do not click on links or open attachments unless you
recognize the sender and know the content is safe.
Thanks so much John! Yes! What time is good for you?
Timothy R. D’Arcy
Managing Director I BlackRock
Alternatives Specialist Team
Mobile: (+1) 617.571.9767
Office: (+1) 617.342.1633
BlackRock logo
From: Galvin, John P. (PER) <John.P.Galvin@mass.gov>
Sent: Tuesday, May 7, 2024 1:01 PM
To: D'Arcy, Tim <timothy.darcy@blackrock.com>
Subject: RE: Hi John!!
External Email: Use caution with links and attachments
Hi Tim,
Good to hear from you and congratulations on the move!
Yes, of course I can help. Will Thursday morning work?
Thank you,
John
John Galvin
Compliance Officer
Public Employee Retirement Administration Commission
5 Middlesex Ave., Suite 304
Somerville, MA 02145
Phone: 617-591-8927
John.P.Galvin@mass.gov
From: D'Arcy, Tim <timothy.darcy@blackrock.com>
Sent: Tuesday, May 7, 2024 12:58 PM
To: Galvin, John P. (PER) <John.P.Galvin@mass.gov>
Subject: Hi John!!
Hi John! I hope you’re well!
Coming to you from BlackRock now! I miss talking to you guys on the Boston business at
Hamilton Lane, I hope things are going smoothly. They will be extremely helpful in
developing and executing the plan I’m sure of it. If you have any questions or concerns on
that front, please reach out to me and I’m sure I can be helpful.
One quick question from my side. Now that I’m here at BlackRock, I’m trying got be helpful
to them on the Mass Public Pensions and how to work with the plan directly as well as work
closely with PERAC. To that end, there is a live example that BlackRock has some
questions on. Specifically, as it relates to the active RFP MWRA has targeting secondaries
investments.
BlackRock would like to respond to the RFP but wants to make sure they are doing
everything they can to satisfy the PERAC disclosures.
Would you mind getting on the phone with me and a colleague from BlackRock just to
answer a few short questions related to the disclosures at the front-end of an RFP process?
Thanks so much in advance John, I really appreciate it.
Be well,
TD
Timothy R. D’Arcy
Managing Director I BlackRock
Alternatives Specialist Team
Mobile: (+1) 617.571.9767
Office: (+1) 617.342.1633
BlackRock logo
This message may contain information that is confidential or privileged. If you are not the intended
recipient, please advise the sender immediately and delete this message. See
http://www.blackrock.com/corporate/compliance/email-disclaimers for further information. Please refer to
http://www.blackrock.com/corporate/compliance/privacy-policy for more information about BlackRock’s
Privacy Policy.
For a list of BlackRock's office addresses worldwide, see http://www.blackrock.com/corporate/aboutus/contacts-locations.
© 2024 BlackRock, Inc. All rights reserved
Pi-009-2022-6-16-to-2021-5-27-Tech Valuations A Blind Spot in Private Markets
RE: Tech Valuations: A Blind Spot in Private Markets
From Yolanda Vasquez <yvasquez@gagpartners.com>
on behalf of
GQG Onboarding <onboarding@gqgpartners.com>
Date Thu 6/16/2022 10:47 AM
To Colon, Veronica (PER) <veronica.colon@mass.gov>
Cc GQG Onboarding <onboarding@gqgpartners.com>
CAUTION: This email originated from a sender outside of the Commonwealth of Massachusetts mail system. Do not click on links or open attachments unless you recognize the sender and know the
content is safe.
Good morning Veronica,
Just circling back on the below. Please let me know if we should expect to receive the executed Client Update
Form.
Thank you,
Yolanda
From: Yolanda Vasquez < yvasquez@gagpartners.com> On Behalf Of GQG Onboarding
Sent: Tuesday, June 7, 2022 12:45 PM
To: veronica.colon@mass.gov
Cc: GQG Onboarding<onboarding@gagpartners.com>
Subject: RE: Tech Valuations: A Blind Spot in Private Markets
Good afternoon Veronica, I am following up on the below correspondence. Please let me know when we should expect to receive the
executed Client Update Form.
Should you have any questions, please let me know.
Thank you,
Yolanda
From: Yolanda Vasquez <yvasquez@gggpartners.com> On Behalf Of GQG Onboarding
Sent: Tuesday, May 31, 2022 11:24 AM
To: veronica.colon@mass.gov
Cc: GQG Onboarding <onboarding@gggpartners.com>
Subiect: FW: Tech Valuations: A Blind Soot in Private Markets
Good morning Veronica,
1/3
To regrant you portal access please update your email address by completing the Client Update Form attached and have it signed by an authorized signer for the investment. Please send the executed form to
GQGFundsUSTA@ntrs.com with onboarding@gggpartners.com on copy.
Kindly note, portal access is granted should you elect to receive monthly statement and/or holdings
correspondence.
Please let me know if you have any questions.
Thank you,
Yolanda Vasquez
Associate, Client Onboarding | GQG Partners
280 Park Avenue, Suite 27E
New York, NY 10017
mobile: +1 347 752 7370/ email: yvasquez@gggpartners.com
GQG
PARTNERS
gqgpartners.com
Follow GOG Partners on LinkedIn
*Please reply all to onboarding@gqgpartners.com
From: Colon, Veronica (PER) <veronica.colon@mass.gov>
Sent: Friday, May 27, 2022 11:04 AM
To: Elizabeth Colquitt<ecolquitt@gagpartners.com>
Subject: Automatic reply: Tech Valuations: A Blind Spot in Private Markets
Caution: This email is from outside the organization. DO NOT CLICK a link or open an attachment unless you know the content is safe and are expecting it from the
sender. If in doubt, contact the sender separately to verify the content.
*** My email has been change to veronica.colon@mass.gov, please update your records immediately and avoid any kickbacks. If you have any questions, please contact me at (617) 591-8926. ***
Image
CONFIDENTIALITY NOTICE This electronic message and any attachments are intended only for the addressee(s) and contains information that may be privileged and confidential. If you are not the intended recipient, please notify the sender by reply email and immediately delete this message. Use, disclosure or reproduction of this
email by anyone other than the intended recipients) is strictly prohibited. Thank you.
This message, and any attachments, is for the intended recipients) only and may contain information that is privileged, confidential and/or proprietary. If you are not the intended recipient, please notify the sender by replying to this email and delete this message. Do not use, disclose, disseminate or copy any part of it. Opinions expressed are subject to change and are not intended to be investment advice, a forecast of future events, or a guarantee of future results. This information is neither an offer to sell nor a solicitation of any offer to buy an interest in any fund or other investment vehicle sponsored or
managed by GQG Partners LLC. Figures are unaudited, and may not be representative of the current or
2/3
future performance of any investment. Past performance does not guarantee future results. In Australia, GQG Partners LLC is an authorized representative (number 001283168) of GQG Partners (Australia) Pty Ltd ACN 626132572, AFS number 515673, and this information and our services may
only be provided to wholesale clients (as defined in the Australian Corporations Act).
3/3
Pi-010-2021-5-6-to-2021-4-22-MA client 4Q20 reports
Re: MA client 4020 reports
From Colon, Veronica (PER) <veronica.colon@mass.gov>
Date Thu 5/6/2021 12:37 PM
To Goulart, Maura <mgoulart@fiducint.com>
Yes, I'll you right now.
From: Goulart, Maura <mgoulart@fiducient.com>
Sent: Thursday, May 6, 2021 12:19 PM
To: Colon, Veronica (PER)
Subject: RE: MA client 4Q20 reports
CAUTION: This email originated from a sender outside of the Commonwealth of Massachusetts mail system. Do not click on links or open attachments unless you recognize
the sender and know the content is safe.
Hi Veronica Can you please call me at 413-478-0657 when you have a moment? We don't' calculate gross returns so not sure where you received these from.
Did you receive gross returns from us?
From: Colon, Veronica (PER) <veronica.colon@state.ma.us>
Sent: Tuesday, May 4, 2021 2:52 PM
To: Goulart, Maura <mgoulart@fiducient.com>
Cc: Flynn, Tracey <tflynn@fiducient.com>
Subject: Re: MA client 4Q20 reports
ATTENTION - EXTERNAL EMAIL - The sender of this email is EXTERNAL to our email system. Do not click links or open attachments unless you recognize the sender and know the content is safe. The Original Sender of
this email is Veronica.Colon@MassMail.State.MA.US
5/4/2021
Hi Maura, Hope all is well. I have a question. Could you you double check the number I grabbed from the reports
are correct? Look forward to hearing from you soon. Have a nice day and week. Take care and stay safe!
1/3
Boards: FIA - 4th QTR Net of Fees • FIA - YTD Net of Fees • FIA - 4th QTR Gross of Fees • FIA - YTD
Gross of Fees
Concord • 9.60 • 9.70 • 8.50 • 12.20
Plymouth • 9.90 • 9.30 • 11.60 • 12.70
Waltham • 11.40 • 13.40 • 10.70 • 12.90
Watertown • 12.00 • 12.50 • 10.20 • 13.10
Weymouth • 10.90 • 13.50 • 11.20 • 13.00
Best,
Veronica
From: Colon, Veronica (PER)
Sent: Thursday, April 22, 2021 9:47 AM To: Goulart, Maura
Cc: Flynn, Tracey
Subject: Re: MA client 4Q20 reports
4/22/2021
Hi Maura,
Hope all is well. Just to be and I double checking that the performance numbers are "Net of Fees" and not "Gross of Fees?" If so, could you forward me the report attached for 2020 to see "Gross of Fees," please
and thank you. Look forward to hearing from you soon. Have a nice day and week. Stay safe!
Best,
Veronica
From: Goulart, Maura <mgoulart@dimeoschneider.com>
Sent: Wednesday, February 24, 2021 7:15 AM
To: Colon, Veronica (PER)
Cc: Flynn, Tracey
Subject: MA client 4Q20 reports
CAUTION: This email originated from a sender outside of the Commonwealth of Massachusetts mail system. Do not click on links or open attachments unless you recognize the sender and know the
content is safe.
Citrix Attachments
Concord - 4020 QIR.pdf 2.8 MB
Plymouth - 4Q20 QIR.pdf 2.7 MB
Reading - 4Q20 QIR.pdf 2.1 MB
Expires August 23, 2021
2/3
Citrix Attachments
Stoneham - 4Q20 QIR.pdf 2.7 MB
Waltham - 4Q20 QIR.pdf 2.3 MB
Watertown - 4Q20 QIR.pdf 2.8 MB
Weymouth - 4Q20 QIR.pdf 3.2 MB
Expires August 23, 2021
Download Attachments
Maura Goulart uses Citrix Files to share documents securely.
Hi Veronica
Please see the 4th quarter QIRs as requested. Note Concord is not completed yet.
Thank you,
Maura
Maura K. Goulart, CFA | Director of Client Analytics (Allocation)
DiMeo Schneider & Associates, L.L.C.
100 Northfield Drive, 4th Floor | Windsor, Connecticut 06095
866.466.9412 | 860.697.7423 | Mobile: 413.478.0657
mgoulart@dimeoschneider.com | dimeoschneider.com
This e-mail may contain information that is privileged, confidential or protected under state or federal law. If you are not an intended recipient of this email, please delete it, notify the sender immediately, and do not copy, use or disseminate any information in the e-mail. Any tax advice in this email may not be used to avoid any penalties imposed under U.S. tax laws. E-mail sent to or from this e-mail address may
be monitored, reviewed and archived.
CONFIDENTIALITY NOTICE This electronic message and any attachments are intended only for the addressee(s) and contains information that may be privileged and confidential. If you are not the intended recipient, please notify the sender by reply email and immediately delete this message. Use, disclosure or reproduction of this
email by anyone other than the intended recipients) is strictly prohibited. Thank you.
This message is intended only for the use of the individual to whom it is addressed and may contain information that is privileged and confidential. If you are not the intended recipient of this message, your use, dissemination, forwarding, printing or copying of this information is prohibited. If you have received this e-mail in error, kindly notify the sender by reply e-mail and destroy this message. Opinions, conclusions and other information in this message that do not relate to the official business of Fiducient
Advisors. do not reflect the official position of Fiducient Advisors.
3/3
Pi-011-2021-2-24-to-2021-2-22-[EXTERNALJRE The Town of Norwood - Q42020 -
Outlook
RE: [EXTERNALJRE: The Town of Norwood Retirement System - Q42020 - QUESTION
From Sara Davis <sdavis@meketa.com>
Date Wed 2/24/2021 4:10 PM
To Colon, Veronica (PER) < veronica.colon@mass.gov>
Cc Rachel Evicci <revicci@meketa.com>
CAUTION: This email originated from a sender outside of the Commonwealth of Massachusetts mail system. Do not click on links or open attachments unless you recognize the sender and know the
content is safe.
Hi Veronica,
Upon further thought, if we provide both gross and net performance in the Trailing Performance Summary for all reports you have mentioned below it would then make the "net/gross column" in the Fee
Expense Analysis no longer applicable and may potentially cause more confusion than clarity.
My main goal in bringing this up is I want to ensure that you are receiving the data that is most helpful to
you.
If you prefer to see both net and gross performance in the Trailing Performance Summary, would it be
okay if the net/gross column was removed from the Fee Expense Analysis due to my reasoning above?
Please let me know what you think of this. I am happy to clarify anything I stated above as well.
Thank you,
Sara
From: Sara Davis
Sent: Wednesday, February 24, 2021 9:43 AM
To: 'Colon, Veronica (PER)' <veronica.colon@state.ma.us>
Cc: Rachel Evicci <revicci@meketa.com>
Subject: RE: [EXTERNAL]RE: The Town of Norwood Retirement System - Q42020 - QUESTION
Thank you Veronica. We will work on getting you the reports you have listed below as samples showing
both net and gross performance in the Trailing Performance Summary section.
Thank you,
Sara
From: Colon, Veronica (PER) <veronica.colon@state.ma.us>
Sent: Wednesday, February 24, 2021 5:29 AM
To: Sara Davis <sdavis@meketa.com>
Cc: Rachel Evicci <revicci@meketa.com>
Subject: Re: [EXTERNAL]RE: The Town of Norwood Retirement System - Q42020 - QUESTION
2/24/2021
1/7
Hi Sara,
Both "Net and Gross Net Performance" in the "Trailing ... section. Could you provide me a revised/updated report for 4th QTR 2020 ONLY for these clients just for a sample. Hopefully, going
forward it will be sent with the updated data.
1.) Mass. H.F.A
2.) Norwood
3.) Plymouth County
4.) Worcester
5.) Hingham
6.) Lexington
7.) Marlborough
8.) Quincy
Look forward to hearing from you soon. Have a nice day and week. Stay safe!
Best,
Veronica
From: Sara Davis <sdavis@meketa.com>
Sent: Tuesday, February 23, 2021 4:11 PM
To: Colon, Veronica (PER)
Cc: Rachel Evicci
Subject: RE: [EXTERNAL]RE: The Town of Norwood Retirement System - Q42020 - QUESTION
CAUTION: This email originated from a sender outside of the Commonwealth of Massachusetts mail system. Do not click on links or open attachments unless you recognize
the sender and know the content is safe.
Hi Veronica, I
have one last clarifying question for you. In the Norwood report, the Trailing Net Performance section shows both net and gross performance for each account. For all Meketa clients that send PERAC quarterly reports, would you prefer to see both net and gross performance in the Trailing Net Performance section or do you not have a preference on what is shown? (typically most of client reports
only show net performance)
Thank you,
Sara
From: Colon, Veronica (PER) <veronica.colon@state.ma.us>
Sent: Tuesday, February 23, 2021 3:02 PM
To: Sara Davis <sdavis@meketa.com>
Cc: Rachel Evicci <revicci@meketa.com>
Subject: Re: [EXTERNAL]RE: The Town of Norwood Retirement System - Q42020 - QUESTION
Sara,
Thank you for everything.
2/7
Best,
Veronica
From: Sara Davis <sdavis@meketa.com>
Sent: Tuesday, February 23, 2021 2:41 PM
To: Colon, Veronica (PER)
Cc: Rachel Evicci
Subject: RE: [EXTERNAL]RE: The Town of Norwood Retirement System - Q42020 - QUESTION
CAUTION: This email originated from a sender outside of the Commonwealth of Massachusetts mail system. Do not click on links or open attachments unless you recognize
the sender and know the content is safe.
Hi Veronica,
Please see the response below with regards to your question on PE fund fees:
The fee tables shown in our reports are the extent of our fee analysis reporting for these clients and are not supposed to represent actual fees paid or an audit. We don't include fee estimates for private equity and other closed end fund structures in our reporting due to the process being tedious and potentially imprecise due to complex fee structures with carried interest etc. We do offer a management and performance fee verification service, but that is not included in our scope of services for these clients and additionally is quite expensive due to the time it takes. If you have specific questions about a manager, it would be best if you reach out to the manager or the clients auditor directly for further
clarification.
If there is any additional information I can provide or answer any further questions please let me know. I
would be happy to do so.
Thank you,
Sara
From: Sara Davis
Sent: Tuesday, February 23, 2021 1:01 PM
To: 'Colon, Veronica (PER)' <veronica.colon@state.ma.us>
Cc: Rachel Evicci <revicci@meketa.com>
Subject: RE: [EXTERNAL]RE: The Town of Norwood Retirement System - Q42020 - QUESTION
Hi Veronica,
Thank you for your email. I just reached out to a couple of my colleagues to discuss this. I will get back
to you as soon as I can with an answer.
I appreciate your patience with this.
Thank you,
Sara
From: Colon, Veronica (PER) <veronica.colon@state.ma.us>
Sent: Tuesday, February 23, 2021 12:14 PM
3/7
To: Sara Davis <sdavis@meketa.com>
Cc: Rachel Evicci <revicci@meketa.com>
Subject: Re: [EXTERNALJRE: The Town of Norwood Retirement System - Q42020 - QUESTION
2/23/2021
Hi Sara:
Yes, I understand. Will you be processing them manually? Also, will it be done for all the clients
managers?
Veronica
From: Sara Davis <sdavis@meketa.com>
Sent: Tuesday, February 23, 2021 10:26 AM
To: Colon, Veronica (PER)
Cc: Rachel Evicci
Subject: RE: [EXTERNAL]RE: The Town of Norwood Retirement System - Q42020 - QUESTION
CAUTION: This email originated from a sender outside of the Commonwealth of Massachusetts mail system. Do not click on links or open attachments unless you recognize
the sender and know the content is safe.
Hi Veronica,
I hope you are doing well. With regards to your question, are you specifically referencing the Private
Equity accounts or something different?
For the Town of Norwood Fee Table for example, all managers other than Private Equity have "estimated
fee values" and "estimated fees". The Private Equity accounts do not show an estimated fee value or estimated fee due to the fee not being a flat percentage. As you can see in the "Fee Schedule" column
there is more detailed language on the Private Equity fees.
For Private Equity accounts, the estimated fee values would need to be added into the table manually.
Please let me know if this is helpful.
Thank you,
Sara
Sara Davis
Specialist, Performance Analyst
The Westwood office has moved - please update our address!
Meketa Investment Group, Inc.
80 University Ave
Westwood, MA 02090
Main 781.471.3500 | Fax 781.471.3411
sdavis@meketa.com
4/7
meketa.com
INVESTMENT GROUP This message, including any attachments, may contain information that is confidential or privileged, and is intended only for the addressee(s). If you are not the intended recipient, you are hereby notified that any use, dissemination, distribution, printing, copying, or disclosure of this information is strictly
prohibited. If you received this message in error, please delete it from your system and notify the sender immediately by return email or by calling (781)
471-3500.
From: Colon, Veronica (PER) <veronica.colon@state.ma.us>
Sent: Tuesday, February 23, 2021 10:03 AM
To: Rachel Evicci <revicci@meketa.com>
Cc: Sara Davis <sdavis@meketa.com>
Subject: [EXTERNAL]RE: The Town of Norwood Retirement System - Q42020 - QUESTION
2/23/2021
Hi Rachel,
The reports were fine. Just a one question, "Why don't all managers have values for fees?" Could you share why? Will you be providing all the clients fee analysis within their normal quarterly reports? If not, will it be submitted
separate? Look forward to hearing from you soon. Have a nice day and week. Stay safe!
Best,
Veronica
From: Rachel Evicci <revicci@meketa.com>
Sent: Tuesday, February 23, 2021 9:42 AM
To: Colon, Veronica (PER) <Veronica.Colon@MassMail.State.MA.US>
Cc: Sara Davis <sdavis@meketa.com>
Subject: RE: The Town of Norwood Retirement System - Q42020 - QUESTION
Importance: High
CAUTION: This email originated from a sender outside of the Commonwealth of Massachusetts mail system. Do not click on links or open attachments unless you recognize the sender and know the
content is safe.
Good morning Veronica,
Just a quick note to circle back asking if this recently sent report is exactly what you are looking for? If so we will make sure all Meketa reports to PERAC are uniform.
Thank you in advance,
Rachel
5/7
Rachel Evicci
Specialist, General Consulting Client Service Assistant
The Westwood office has moved - please update our address!
Meketa Investment Group, Inc.
80 University Ave
Westwood, MA 02090
Main 781.471.3500 | Fax 781.471.3411
revicci@meketa.com
meketa.com
žmeketa-sig This message, including any attachments, may contain information that is confidential or privileged, and is intended only for the addressee(s). If you are not the intended recipient, you are hereby notified that any use, dissemination, distribution, printing, copying, or disclosure of this information is strictly
prohibited. If you received this message in error, please delete it from your system and notify the sender immediately by return email or by calling (781)
471-3500.
From: Rachel Evicci <revicci@meketa.com>
Sent: Monday, February 22, 2021 2:24 PM
To: Colon, Veronica (PER) <veronica.colon@state.ma.us>
Cc: Sara Davis <sdavis@meketa.com>
Subject: The Town of Norwood Retirement System - Q42020
Good afternoon Veronica,
Attached please find the Fourth Quarter 2020 for the Town of Norwood Retirement System, with Net Fee Analysis
included. If you have any questions or need further assistance, please contact us by email or at 781) 471-3500.
Best,
Rachel
Rachel Evicci
Specialist, General Consulting Client Service Assistant
The Westwood office has moved - please update our address!
Meketa Investment Group, Inc.
80 University Ave
Westwood, MA 02090
Main 781.471.3500 | Fax 781.471.3411
6/7
revicci@meketa.com
meketa.com
Zmeketa-sig
This message, including any attachments, may contain information that is confidential or privileged, and is intended only for the addressee(s). If you are not the intended recipient, you are hereby notified that any use, dissemination, distribution, printing, copying, or disclosure of this information is strictly
prohibited. If you received this message in error, please delete it from your system and notify the sender immediately by return email or by calling (781)
471-3500.
CONFIDENTIALITY NOTICE This electronic message and any attachments are intended only for the addressee(s) and contains information that may be privileged and confidential. If you are not the intended recipient, please notify the sender by reply email and immediately delete this message. Use, disclosure or reproduction of this
email by anyone other than the intended recipient(s) is strictly prohibited. Thank you.
CONFIDENTIALITY NOTICE This electronic message and any attachments are intended only for the addressee(s) and contains information that may be privileged and confidential. If you are not the intended recipient, please notify the sender by reply email and immediately delete this message. Use, disclosure or reproduction of this
email by anyone other than the intended recipients) is strictly prohibited. Thank you.
CONFIDENTIALITY NOTICE This electronic message and any attachments are intended only for the addressee(s) and contains information that may be privileged and confidential. If you are not the intended recipient, please notify the sender by reply email and immediately delete this message. Use, disclosure or reproduction of this
email by anyone other than the intended recipients) is strictly prohibited. Thank you.
CONFIDENTIALITY NOTICE This electronic message and any attachments are intended only for the addressee(s) and contains information that may be privileged and confidential. If you are not the intended recipient, please notify the sender by reply email and immediately delete this message. Use, disclosure or reproduction of this
email by anyone other than the intended recipients) is strictly prohibited. Thank you.
7/7
Pi-012-2021-2-17-to-2021-1-Fee Report
Re: Fee Report
From Colon, Veronica (PER) < veronica.colon@mass.gov>
Date Wed 2/17/2021 10:20 AM
To
Fischer, Kiley <KFischer@nepc.com>
2/17/2021
Hi Kiley,
Q: Is this something that you usually receive from the Fund Administrators? A: Yes, see the fee section of the qtrly reports. Looking for a more detail in the Private (P.E.) and Real Estate
(R.E.) managers.
Q: Or is this the first time you've requested?
A: Yes, ONLY for the PE & RE manager since all the others are listed.
Best,
Veronica
From: Fischer, Kiley <KFischer@nepc.com>
Sent: Friday, February 12, 2021 3:02 PM
To: Colon, Veronica (PER)
Subject: RE: Fee Report
CAUTION: This email originated from a sender outside of the Commonwealth of Massachusetts mail system. Do not click on links or open attachments unless you recognize
the sender and know the content is safe.
Hi Veronica,
I hope all is well. I just wanted to check on the Fee request as I don't recall sending these reports to you in past years. Is this something that you usually receive from the Fund Administrators? Or is this the first time you've
requested?
Thanks,
Kiley
From: Colon, Veronica (PER) <veronica.colon@state.ma.us>
Sent: Friday, February 12, 2021 12:08 PM
Subject: Re: Fee Report
Importance: High
MESSAGE FROM EXTERNAL SENDER
2/12/2021
Hi Everyone,
1/3
Hope all is well. Following up with my request. Thank you for for those you have supplied me the request. Since the report you produce is "Gross of Fees" and I need to see what you calculate or receive for fee amounts to prepare the reports. If you are not supplied or perform your own estimate fee analysis,
please share. The image reflects the missing reports for 2020. Look forward to hear from everyone soon.
Have a nice day and long holiday weekend. As always, stay safe!
Board • Consultant • 1st QTR 202 • 2nd QTR 20 • 3rd QTR 20 • 4th QTR 20: -
Boston • NEPC • 1/13/2021 • 1/13/2021 • 1/13/2021 •
Brockton • SEI • • • •
Chicopee • FIA • • • •
Concord • FIA • • • •
Dukes Cty. • DAHAB • 1/11/2021 • 1/11/2021 • 1/11/2021 •
Franklin Cty.• DAHAB • 1/11/2021 • 1/11/2021 • 1/11/2021 •
Hampden CI • SEGAL • • • •
Hampshire C • NEPC • • • •
MASS H.F.A. • MEKETA • 5/15/2020 • 8/13/2020 • 12/1/220 • 2/12/2021
MASS P.A. • WILSHIRE • 5/26/2020 • 8/19/2020 • 11/30/2020 • 2/10/2021
Medford • NEPC • • • •
Norfolk Cty • PEOPLE'S UNITED BANK • • • •
North Adam • DEBURLO •
North Attlebi • DAHAB • 1/11/2021 • 1/11/2021 • 1/11/2021 •
Northamptor • DEBURLO • •
Norwood • MEKETA • 1/14/2021 • 1/14/2021 • 1/14/2021 •
Plymouth • FIA • •
Plymouth Cly • WAINWRIGHT (SSIA) • 1/14/2021 • 1/14/2021 • 1/14/2021
Reading • FIA • • • •
Saugus • PEOPLE'S UNITED BANK • • • •
Shrewsb ury • DAHAB • 1/11/2021 • 1/11/2021 • 1/11/2021 •
Stoneham • FIA • • • •
Swampscott • DAHAB • • • •
Waltham • FIA • • •
Watertown • FIA • • •
Weymouth • FIA • • • •
Wobum • PEOPLE'S UNITED BANK • • • •
Worcester • MEKETA • • • •
Total
Best,
Veronica
From: Colon, Veronica (PER)
Sent: Wednesday, January 13, 2021 7:13 AM
Subject: Re: Fee Report
2/3
1/13/2021
Re: Fee Report - Baruffi, Felicia M. (PER) - Outlook
Hi Everyone,
Following up with my request. Thank you for for those you have supplied me the request. Since the report is Gross of Fees and need to see what you receive for fee amounts to prepare the reports. If you are not supplied or perform your own estimate fee analysis, please share. Look forward to hear from you or
someone else you assign soon. Have a nice day and week. Stay safe!
Best,
Veronica
From: Colon, Veronica (PER)
Sent: Friday, January 8, 2021 7:12 AM
Subject: RE: Fee Report
January 8, 2021
Hi Everyone,
Hope all is well and you are having a great morning. Happy New Year! Could you please forward the 1st,
2nd, and 3rd QTR 2020 fee analysis report plus identify if it's "Gross" or "Net.".
. If any of them are no longer your client or other, please update me; I greatly appreciate it a lot. Look forward to hearing from
everyone soon. Have a nice day and weekend E. Stay safe C!
Sincerely,
Veronica
CONFIDENTIALITY NOTICE This electronic message and any attachments are intended only for the addressee(s) and contains information that may be privileged and confidential. If you are not the intended recipient, please notify the sender by reply email and immediately delete this message. Use, disclosure or reproduction of this
email by anyone other than the intended recipients) is strictly prohibited. Thank you. This e-mail and any attachments may contain private, confidential or privileged material for the sole use of the intended recipient. If you are not the intended recipient, you may not review, copy or distribute this message. If you received this message in error, please notify the sender by reply e-mail and delete this
message and any attachments. Thank you.
3/3
Pi-013-2020-4-14-to-2020-4-13-New comment - [#5780] Re New PERAC
From: McGinniss, Felicia M. (PER) (felicia.m.mcginniss@mass.gov)
To: thestebbman@yahoo.com
Cc: doreen.m.duane@mass.gov
Date: Monday, July 21, 2025 at 08:48 AM EDT
Hi Mr. Stebbins,
Here is email #2 of 3.
Felicia
Felicia McGinniss, Esq.
Senior Associate General Counsel
Public Employee Retirement Administration Commission
10 Cabot Road, Suite 300
Medford, MA 02155
(617) 666-4446, ext. 909
www.mass.gov/perac
**Please note our new address (effective immediately).
From: McGinniss, Felicia M. (PER)
Sent: Monday, July 21, 2025 8:44 AM
To: thestebbman@yahoo.com
Cc: Duane, Doreen M. (PER) <doreen.m.duane@mass.gov>
Subject: Public Records Request – PERAC Investment Records 2024–2025
Good Morning Mr. Stebbins,
#30 Investment Fraud Alert (10-26-2021).pdf
229.1 KB
#30 Tobacco Company List (3-29-2012).pdf
359.8 KB
#30 Tobacco Company List (9-18-2014).pdf
360.4 KB
#31 Tobacco Company List (11-5-2013).pdf
365.4 KB
Pursuant to your public records request, attached please find a portion of the documents that are responsive to
your request. I will be sending 3 separate (this is #1) emails that have the requested Memos and Presentations
that PERAC has released/given regarding compliance and investment. We are still currently in the process of
searching through emails for the other portion of your request. As previously indicated, that will take additional
time as the emails encompass over 15 PERAC employees over a span of almost 10 years. We should hopefully
be able to provide the documents by the end of September, but I will keep you updated.
Thank you,
Felicia
Felicia McGinniss, Esq.
Senior Associate General Counsel
Public Employee Retirement Administration Commission
10 Cabot Road, Suite 300
Medford, MA 02155
(617) 666-4446, ext. 909
www.mass.gov/perac
**Please note our new address (effective immediately).
CONFIDENTIALITY NOTICE This electronic message and any a achments are intended only for the addressee(s) and contains informa on that may be privileged
and confiden al. If you are not the intended recipient, please no fy the sender by reply email and immediately delete this message. Use, disclosure or
reproduc on of this email by anyone other than the intended recipient(s) is strictly prohibited. Thank you.
#32 Procurement (11-5-2018).pdf
512.2 KB
#32 Tobacco Company List (10-6-2017).pdf
378.2 KB
#33 Tobacco Company List (12-9-2021).pdf
369.3 KB
#34 Tobacco Company List (12-14-2018).pdf
379.5 KB
#35 Chapter 176 of the Acts of 2011, An Act Providing for Pension Reform and Benefit Modernization (Governance
Provisions) (12-2-2011).pdf
647.5 KB
#37 Tobacco Company List (12-17-2014).pdf
364.3 KB
#39 Tobacco Company List (12-30-2020).pdf
370 KB
#45 Tobacco Company List (8-2-2012).pdf
360.5 KB
#49 Investment Under Chapter 176 of the Acts of 2011 - #2 (10-10-2012).pdf
582.9 KB
#50 Tobacco Company List (10-10-2012).pdf
360.4 KB
#51 Chapter 32, Section 23B Contract Terms, Indemnification, Disclosure, and Fiduciary Duty (10-18-2012).pdf
478.7 KB
#56 Tobacco Company List (12-12-2012).pdf
363.1 KB
Attachment (2014 Schedule 7 Investment Fees).pdf
8.2 MB
PERAC MEMO #8 2025.pdf
284 KB
PERAC MEMO #9 2023.pdf
361.1 KB
PERAC MEMO #10 2024.pdf
360.3 KB
PERAC MEMO #10 2025.pdf
356.3 KB
PERAC MEMO #10-2022.pdf
60.3 KB
PERAC Memo #14 2023.pdf
363 KB
PERAC MEMO #14 2024.pdf
358.5 KB
PERAC Memo #15 2022.pdf
141.9 KB
PERAC MEMO #16 2025.pdf
617.9 KB
PERAC MEMO #19 2023.pdf
359.9 KB
PERAC MEMO #24 2023.pdf
382.1 KB
PERAC MEMO #24 2024.pdf
357.3 KB
PERAC Memo #25-2022.pdf
366.9 KB
PERAC MEMO #29 2023.pdf
363.5 KB
PERAC Memo #32 2024.pdf
360.5 KB
PERAC MEMO #32-2022.pdf
367.2 KB
07_ComplianceOverview_Roadshow032124.pdf
767.7 KB
2013 MACRS - Board Governance.pdf
218.6 KB
2013 MACRS - Competitive Process.pdf
412.2 KB
2013 MACRS - How to Review Vendor Disclosures.pdf
330.6 KB
2013 MACRS - Overview of Financial Data.pdf
312.9 KB
2014 MACRS - New Investment Changes.pdf
2.8 MB
Pi-004-2025-7-28-Stebbins-William_Keefe_letter
PERAC
COMMONWEALTH OF MASSACHUSETTS | PUBLIC EMPLOYEE RETIREMENT ADMINISTRATION COMMISSION
PHILIP Y. BROWN, ESQ., Chair WILLIAM T. KEEFE, Executive Director
Auditor DIANA DIZOGLIO | KATHLEEN M. FALLON | KATE FITZPATRICK | JAMES J. GUIDO | RICHARD MACKINNON, JR. | JENNIFER F. SULLIVAN, ESQ.
Richard Stebbins
July 28, 2025
54 Hope Street
Springfield, MA 01119
Dear Mr. Stebbins:
This is in response to your email, dated July 9, 2025, concerning PERAC's role in retirement
system vendor coordination and disclosures pertaining to investment management advisors. This
request was submitted in addition to a Public Records Request for documents related to these
questions. Those documents are currently being compiled and will be sent to you as soon as
possible.
You presented a series of questions, which will be answered below in turn.
1. Vendor Coordination and Investment Gatekeeping
Why is PERAC advising vendors such as BlackRock on how to respond to
individual retirement board RFPs if PERAC does not conduct or influence
investments?
What legal or regulatory authority allows PERAC to instruct vendors on
compliance for board-specific RFPs (e.g., MWRA)?
How frequently does PERAC correspond directly with private investment
firms about open RFPs?
PERAC Response: As the regulatory agency of the 104 retirement systems, PERAC’s role is to
ensure the uniform application of our retirement law, Chapter 32. Regarding the procurements of
investment services, retirement boards are required to perform them pursuant to G.L. c. 32, § 23B.
Section 23B addresses how procurements should be undertaken and that PERAC must review all
procurements of vendors, such as investment, actuarial, legal, and accounting services. Section
23B also requires annual vendor disclosures to be filed with the retirement board and PERAC.
Additionally, PERAC has formally adopted regulations regarding investments at 840 CMR 16.00-
23B.
18.00, 21.00, and 26.00-27.00. РERAC's role is to ensure that each retirement board is correctly
following the procurement process and requesting the required documentation outlined in Section
To that end, PERAC regularly corresponds with retirement boards and some potential
vendors - legal, actuarial, investment, etc. - to ensure that proper documentation is being provided
in response to RFPs. PERAC does not advise vendors on how to respond so that they will "win"
10 CABOТ ROAD, SUITE 300 | MEDFORD, MA 02155
PH 617 666 4446 | FAX 617 628 4002 | WWW.MASS.GOV/PERAC
FUBLICENPLOTE PERAC
Richard Stebbins
54 Hope Street
Springfield, MA 01119
July 28, 2025
Page Two
the RFP or influence investments. Instead, PERAC merely answers questions about the
requirements of Section 23B and what must be submitted to retirement boards in response to RFPs.
The only exception to the above statements is if a retirement board's return of investment falls
below the determined benchmark. If that occurs, then the retirement board would be subject to the
transfer of their assets over to PRIM in accordance with the provisions of Chapter 21 of the Acts
of 2009. PERAC would oversee and ensure that the assets were promptly transferred to PRIM.
2. PROPSER Portal Access
• What data fields or modules within the PROSPER portal were accessed by
BlackRock employees?
Are outside vendors' portal access logs retained? If so, I formally request
them for the BlackRock accounts added in the attached emails.
Under what criteria does PERAC grant vendor access to PROSPER?
PERAC Response: PROSPER is an internal system that is available to all PERAC staff,
retirement board members and staff, and vendors. Each group is able to access different parts of
the PROSPER system depending on how they are classified. Vendors have limited access to
PROSPER so that they can upload the required annual vendor disclosure filings. To gain access
to PROSPER, the vendor must be a current, authorized vendor of a retirement board who has
complied with and been selected by a retirement board through the RFP process. Access is only
given to authorized employees of the vendor.
3. Undisclosed Investment Influence
•
How many vendors have contacted PERAC to clarify or satisfy PERAC
disclosures before responding to RFPs over the last 5 years?
Is PERAC involved in the review, guidance, or approval of investment firms
participating in retirement board selections?
Has PERAC ever provided verbal guidance or informal steering that is not
documented in email or written form?
PERAC Response: Pursuant to our statutory mandate, PERAC is not involved in the review,
guidance, or approval of investment firms that are contracted by retirement boards. Again,
we will answer any general questions about required documents but will not assist a vendor
in "winning" an RFP. PERAC will conduct a review of all completed RFPs to ensure that the
vendor was selected in accordance with the procedures of G.L. c. 32, § 23B and PERAC
regulations at 840 CMR. PERAC does not track how many vendors have been in contact with
questions regarding RFPs.
Richard Stebbins
54 Hope Street
Springfield, MA 01119
July 28, 2025
Page Three
4. Disclosure Gaps and Transparency Compliance
Do PERAC officers or contractors (e.g., John Galvin) attend investment committee
meetings or vendor pitches, even informally?
• Does PERAC maintain internal records of vendor-related communications that are
not cataloged under public procurement systems?
• Has PERAC coordinated with third-party platforms such as BlackRock, Hamilton
Lane, or PRIM to shape or influence RFP outcomes?
PERAC Response: PERAC staff attend retirement board meetings and the quarterly PRIM board
meetings. However, PERAC staff have no role in these meetings unless invited to speak on a
topic. If a retirement board is conducting a meeting in open session with an investment vendor,
PERAC staff are not involved in the meeting and their attendance is treated as if they were a
member of the public. Additionally, PERAC has never coordinated with third-party platforms to
shape or influence RFP outcomes as that would directly violate our role in the procurement
process. Vendor decisions for investment services lie solely with each individual retirement board.
PERAC is merely available to help ensure that the requirements of G.L. c. 32, § 23B are followed
and to answer any questions regarding documents that are required to be provided in response to
RFPs.
We trust the foregoing will be of assistance to you. Please contact this office if you have
questions or concerns about this.
Sincerely,
William T. Keefe Executive Director
Pi-005-2025-8-1-to-2025-8-8-Stebbins-McGinniss
RE: Public Records Request – PERAC Investment Records 2024–2025
From: McGinniss, Felicia M. (PER) (felicia.m.mcginniss@mass.gov)
To: thestebbman@yahoo.com
Date: Friday, August 1, 2025 at 10:22 AM EDT
Mr. Stebbins,
Please understand that we are not “sitting on 8 years of logs.” The logs do not exist in report
form. PROSPER is handled by a third-party vendor who hosts and runs our system. They are
currently compiling a report of all of those who have logged in for investment purposes. This
information does not exist in the form that you are requesting. We, and our PROSPER host
site, have to search all of the logs, pull out the relevant users, and create the report from
scratch. We also cannot access this directly as it is not stored with PERAC, but with the third-party site.
Searching internal emails that are protected by multiple levels of encryption and stored in
archived sites cannot be easily achieved via AI automation tools. While the general public may
be able to access some tools, State agencies are required to follow much stricter
requirements. The emails that are older are achieved solely with the State IT department, not
at PERAC. I cannot do a search on my email for anything older than one year, as it is stored in
internal systems and with the State IT. As such, this is a coordinated effort between two
agencies to obtain the documents you have requested. Any delay in this process is not
because of a shield, it is because of an extensive effort that must be undertaken to obtain all
documents.
Regarding the use of AI, State Agencies were just given notice that it was allowed to be used
in certain circumstances in January 2025. Please see the guidance put out by EOTSS:
https://www.mass.gov/policy-advisory/enterprise-use-and-development-of-generative-ai-policy.
If you have further questions about the use of AI, please contact them directly.
Regarding our records retention schedule, please see the following document published by the
State that we must follow: https://www.sec.state.ma.us/divisions/public-records/download/
MA_Statewide_Records_Schedule_updated2022-10-31.pdf.
Again, I would like to highlight that we have been extremely responsive and transparent in
responding to all your questions about PERAC, and sending you the requested Memoranda
1 of 6
CAUTION: This email originated from a sender outside of the Commonwealth of
Massachusetts mail system. Do not click on links or open attachments unless you
recognize the sender and know the content is safe.
and training materials regarding procurements and investments.
I will not be providing you a schedule of how the request is being processed each week as that
is not a requirement of our Public Records Law. I will keep you updated if we are unable to
respond within the next two months as previously indicated.
Best,
Felicia
Felicia McGinniss, Esq.
Senior Associate General Counsel
Public Employee Retirement Administration Commission
10 Cabot Road, Suite 300
Medford, MA 02155
(617) 666-4446, ext. 909
www.mass.gov/perac
**Please note our new address (effective immediately).
From: Ricky Stebbins <thestebbman@yahoo.com>
Sent: Friday, August 1, 2025 9:57 AM
CONFIDENTIALITY NOTICE This electronic message and any attachments are intended only for the addressee(s) and contains information that may be privileged and
confidential. If you are not the intended recipient, please no fy the sender by reply email and immediately delete this message. Use, disclosure or reproduction of
this email by anyone other than the intended recipient(s) is strictly prohibited. Thank you.
To: McGinniss, Felicia M. (PER) <Felicia.M.McGinniss@mass.gov>
Subject: Re: Public Records Request – PERAC Investment Records 2024–2025
2 of 6
Hi Felicia,
Thank you for the update.
I want to be clear: I’m not upset about technical delays—I’m upset that you’re
using delays as a shield.
You’ve now admitted that PERAC is sitting on 8 years of logs, vendor data, and
internal emails—while refusing to use any of the available AI or automation tools
that could make this retrieval, triage, and review process almost immediate.
Here’s what that looks like from my perspective as a disabled individual:
I used my disability income to purchase an
iPhone and a laptop specifically so I could use
AI to investigate corruption and demand
accountability. The state of Massachusetts, and
agencies like PERAC, are sitting on billions of
dollars in public assets—yet you’re still acting
like this is 1995.
If I need toast and I already bought a toaster, but I still tell people “Sorry, no toast
today,” something’s wrong. Either I’m willfully avoiding the truth, or I’m hoping
3 of 6
the bread goes stale before anyone asks questions.
PERAC has the tools. It has the data. And now it has a very public record of what
it’s choosing not to do.
I’m not requesting miracles. I’m requesting accountability—using the same tools
and technology that are available to the public.
I’m copying this to my blog archive and public record. Please consider this a
formal request for:
• A copy of the data retention policy covering PROSPER logs and email
archiving.
• A clear explanation of why AI tools are not being used to process these
requests in a timely fashion.
• A rolling schedule, showing which accounts and timeframes are being
processed each week.
If this request is too much for PERAC, let me know and I’ll forward it to the
State Auditor, DOJ, and any AI task force interested in public sector
modernization.
Thank you,
Richard Stebbins
4 of 6
On Aug 1, 2025, at 9:47 AM, McGinniss, Felicia M. (PER) <Felicia.M.McGinniss@mass.gov> wrote:
Good Morning Mr. Stebbins,
I would like to respectfully note that PERAC’s July 28, 2025 letter was neither evasive nor meant to “shield
misconduct” regarding our role in the investment process for retirement systems. The letter was meant to answer
all your questions in detail, which specifically asked for laws and regulations that demonstrated PERAC’s role in
investments and procurements. No specific details or information were omitted.
As noted in the letter and my prior emails, the letter itself was meant to solely address your questions that were
submitted in addition to your original public records request. No documents or data were intended to be provided
with that letter. I have already provided all documents requested concerning PERAC Memoranda and trainings
given that pertained to procurements and investments. As I previously indicted, we would need at least 2 months
to respond to the rest of your request, possibly more. We are in contact with our PROSPER vendor to obtain
login information, but it is 8 years of logs that you are requesting. Additionally, our internal IT team and the State
IT team are currently in the process of searching the emails of relevant PERAC employees to provide documents
that are responsive to your request.
I will keep you abreast of the status of your public records request but appreciate your continued understanding
and patience in this process.
Best,
Felicia
Felicia McGinniss, Esq.
Senior Associate General Counsel
Public Employee Retirement Administration Commission
10 Cabot Road, Suite 300
5 of 6
Medford, MA 02155
(617) 666-4446, ext. 909
www.mass.gov/perac
6 of 6
Pi-006-2025-12-8-to-2025-10-20-Stebbins-Baruffi
Fwd: Public Records Request – PERAC Investment Records 2024–2025
From: Ricky Stebbins (thestebbman@yahoo.com)
To: caroline.e.deluca@mass.gov
Date: Monday, December 8, 2025 at 11:41 AM EST
Hi Ms. De Luca,
I received an out-of-office from Christopher
Bowman and was directed to you as an alternate
contact.
I’m currently raising concerns about PERAC’s
oversight failures and vendor access to its
PROSPER system (including BlackRock and other
investment firms) that could affect public
employees’ pensions and investors worldwide.
I’ve already submitted detailed public records
requests and received partial responses from
PERAC’s counsel. I’m flagging this for you so there
is no question later that regulators and oversight
bodies were informed.
If your office has a defined process for escalating
systemic oversight concerns like this, I’m happy to
summarize the key patterns and provide links to the
documents and logs I’ve already published.
1 of 1 this one was never responded to.
Best,
Richard (Ricky) Stebbins
Fwd: Public Records Request – PERAC Investment Records 2024–2025
From: Ricky Stebbins (thestebbman@yahoo.com)
To: caryn.m.shea@mass.gov
Date: Monday, December 8, 2025 at 11:40 AM EST
Hi Ms. Shea,
I received an automated response that Veronica
Colon is no longer with PERAC, with a note that I
should contact you for assistance.
I want to make sure you’re aware that I have an
ongoing public records request and oversight
concern involving:
– PROSPER investment-vendor logins
(BlackRock and others)
– Late / inconsistent fee reporting
– Multiple emails showing consultants and
vendors shaping disclosures and reports across
many boards
These issues involve years of emails and
documents where Ms. Colon appears centrally
involved (report chasing, fee analysis, pooled fund
worksheets, CD requests, etc.).
1 of 15
Because of that, I want explicit confirmation that:
1. All of Ms. Colon’s emails and associated records
are being preserved in full, not deleted or altered,
and
2. They are being included in the ongoing response
to my records requests already being handled by
Ms. Baruffi.
I’m not making accusations about Ms. Colon
personally — my concern is systemic: the
documents show serious delays, gaps, and
dependencies on outside vendors that raise
questions about whether PERAC can actually
perform the oversight it describes in statute. That’s
why I’ve also copied oversight offices and am
preserving everything publicly.
Please confirm that her records are preserved and
within the scope of PERAC’s response.
Thank you,
Richard (Ricky) Stebbins
Begin forwarded message:
2 of 15
From: Ricky Stebbins <thestebbman@yahoo.com>
Date: December 8, 2025 at 9:55:34 AM EST
To: "Felicia M. Baruffi" <Felicia.M.Baruffi@mass.gov>, recordsrequests@sec.state.ma.us,
natacha.a.dunker@mass.gov, Christopher.Bowman@state.ma.us, paul.m.stein@state.ma.us,
Cynthia.Ittleman@state.ma.us, paul.a.camuso@state.ma.us, kevin.m.tivnan@state.ma.us,
Medes.Diaz@state.ma.us, veronica.colon@mass.gov
Cc: "Doreen M. Duane" <doreen.m.duane@mass.gov>
Subject: Re: Public Records Request – PERAC Investment Records 2024–2025
Good Morning Ms. Baruffi,
Thank you for providing the initial batch of emails and the vendor login
information from the PROSPER system. I appreciate that PERAC is working
through a large volume of material, and I recognize that coordinating with
State IT and a third-party vendor adds significant complexity.
However, after reviewing the materials provided so far, several issues have
emerged that raise serious questions about process integrity, oversight
limitations, and potential data-handling vulnerabilities. Before I publish or
escalate any concerns, I want to give PERAC the opportunity to explain its
position clearly and transparently.
To be very clear:
I am not making accusations.
I am giving PERAC the chance to clarify the situation before this is shared
with state oversight bodies, journalists, or EU data protection authorities who
may have jurisdiction due to the involvement of European vendors and funds.
Below is a structured explanation of why additional records and clarifications
are now necessary.
3 of 15
1. PROSPER Vendor Access Appears
Broader Than Expected
The logs you sent show a surprisingly large number of outside vendors
accessing the PROSPER investment portal, including:
• BlackRock
• Hamilton Lane
• State Street
• PRIM-affiliated entities
• Multiple private fund administrators
This volume of access — and the lack of detail about what each login
accessed — raises several concerns:
• There is no audit trail showing which files or disclosures were viewed or
downloaded.
• There is no geographic information, IP metadata, or device information.
• No access revocation logs were provided.
• No internal oversight or monitoring documentation appears to exist.
Under M.G.L. c. 66 (Public Records) and 201 CMR 17.00 (Data Security
Regulations), agencies must maintain:
• audit trails
• access logs
• retention logs
• documentation of third-party access to regulated systems
4 of 15
I am therefore requesting additional metadata because it appears that PERAC
may not have full visibility into how investment vendors interact with the
pension oversight system.
This is a potential oversight gap—one I want you to be able to explain before
I take it further.
2. Multiple Emails Show Confusion, Delays,
and Missing Reports Across Many Boards
The older emails (2018–2022) reveal a pattern:
• consultants repeatedly sending late, corrected, or missing reports
• pooled fund worksheets “out of balance”
• fee analysis reports missing or inconsistent
• PERAC staff asking vendors to re-send documents multiple times
• reports released only after private meetings with consultants
• inconsistent treatment of “net vs. gross of fees” performance data
• repeated reminders from PERAC to vendors about failing to submit
required disclosures
This is concerning because PERAC is the compliance authority for 104
retirement boards.
5 of 15
Under Chapter 32 and PERAC regulations, the Commission is obligated to
ensure:
• uniform reporting
• timely disclosures
• proper fee analysis
• vendor compliance
• audit readiness
The emails paint a picture of a system where private consultants and fund
managers control the flow of information — and PERAC spends a lot of time
asking for missing documents.
Again: I am not accusing PERAC of wrongdoing.
But the appearance of systemic disorganization is something the public,
pensioners, and possibly EU regulators would take seriously.
3. GDPR and EU Data Protection
Considerations
Several investment firms involved in this process are headquartered in or
operate under EU jurisdiction, including:
• Unigestion (Switzerland/EU operations)
• Mesirow (EU operations)
6 of 15
• Hamilton Lane (EU LP investors)
• RhumbLine funds with EU clients
• BlackRock (significant EU operations, GDPR-bound)
If European citizens’ data — or EU-regulated financial disclosures — flow
through PROSPER or Massachusetts systems, then:
GDPR Articles 5, 30, 32, and 33 impose:
• audit trails
• access logs
• documentation of data processors
• breach notification obligations
Right now, based on what you’ve provided:
It is unclear whether PERAC has met those obligations.
This is why I need the additional information below — not to accuse
PERAC, but to determine whether PERAC is even aware of the compliance
implications.
I want PERAC to have the opportunity to clarify this before I raise it with EU
partners or compliance monitors.
4. Why I Am Requesting Broader
7 of 15
Preservation and Documentation
Given the gaps above, I am formally requesting preservation of the following
categories so that no material is inadvertently deleted during PERAC’s search
process:
A. Full PROSPER system metadata
Because the login summary you provided lacks detail required under state
retention laws.
B. Email server metadata and archive restoration logs
Because multiple employees indicated they cannot access emails older than
12 months, which raises questions about retention compliance.
C. Device and VPN access logs
Because PERAC staff and vendors may access PROSPER remotely, which
matters for regulatory oversight.
D. Informal communications (texts, Teams, personal email used
for work)
8 of 15
These count as public records under Massachusetts law and could contain
key procurement or disclosure information.
E. Vendor communications involving PERAC
Because vendors are directly contacting PERAC about RFPs and disclosures.
F. Retention and deletion logs
This will confirm that nothing related to this matter was deleted
automatically.
G. Internal meeting notes, briefing memos, and directives
To understand PERAC’s internal process for vendor oversight.
H. Documentation of search terms, custodians, and systems
accessed
To ensure the transparency and completeness of the Public Records search.
None of this is an accusation.
It is due diligence — something I would do with ANY agency where the
documentary record appears incomplete or inconsistent.
9 of 15
Final Point: Giving PERAC the Chance to
Explain Before This Goes Public
I want to emphasize this in good faith:
I am giving PERAC an opportunity to explain, clarify, and correct the record
before I take any of this to:
• Massachusetts State Auditor
• AG’s Office
• Federal oversight partners
• EU GDPR regulators (if applicable)
• Investigative journalists and watchdogs
If I misunderstood the situation or if there is a reasonable explanation, I
genuinely want to hear it.
Transparency helps everyone — PERAC, retirees, vendors, and the public.
Please confirm receipt of this message and the preservation request. I look
forward to your clarification.
Sincerely,
Ricky Stebbins
10 of 15
Springfield, MA
413-949-1925
On Oct 23, 2025, at 9:32 AM, Baruffi, Felicia M. (PER) <Felicia.M.Baruffi@mass.gov>
wrote:
Good Morning Mr. Stebbins,
Pursuant to your Public Records Request, attached please find the login
information for investment vendor access in PROSPER. We are unable
to provide the IP addresses due to cybersecurity concerns; however, the
report includes the name of the individual, the vendor they are
associated with, and the date/time of the login into PROSPER.
The report starts in January 2020 because that is when the Investment
Portal in PROSPER was launched for investment vendors to upload
their required disclosures to PERAC. Prior to January 2020, investment
vendors did not have a portal in PROSPER to access, and so there is
no login information prior to then.
Best,
Felicia
Felicia Baruffi, Esq.
Senior Associate General Counsel
Public Employee Retirement Administration Commission
10 Cabot Road, Suite 300
Medford, MA 02155
(617) 666-4446, ext. 909
www.mass.gov/perac
**Please note my new email address: felicia.m.baruffi@mass.gov
From: Baruffi, Felicia M. (PER)
Sent: Monday, October 20, 2025 9:08 AM
To: Ricky Stebbins <thestebbman@yahoo.com>
11 of 15
Cc: Duane, Doreen M. (PER) <doreen.m.duane@mass.gov>
Subject: RE: RE: Public Records Request – PERAC Investment Records
2024–2025
Mr. Stebbins,
I apologize, this is a additional email. I wasn’t able to fit it all in the
expected 5 emails. This is the 6th and final one for this batch.
Felicia
Felicia Baruffi, Esq.
Senior Associate General Counsel
Public Employee Retirement Administration Commission
10 Cabot Road, Suite 300
Medford, MA 02155
(617) 666-4446, ext. 909
www.mass.gov/perac
**Please note my new email address: felicia.m.baruffi@mass.gov
From: Baruffi, Felicia M. (PER)
Sent: Monday, October 20, 2025 9:07 AM
To: 'Ricky Stebbins' <thestebbman@yahoo.com>
Cc: Duane, Doreen M. (PER) <doreen.m.duane@mass.gov>
Subject: RE: RE: Public Records Request – PERAC Investment Records
2024–2025
Email 5 of 5
Felicia Baruffi, Esq.
Senior Associate General Counsel
Public Employee Retirement Administration Commission
10 Cabot Road, Suite 300
Medford, MA 02155
(617) 666-4446, ext. 909
www.mass.gov/perac
12 of 15
**Please note my new email address: felicia.m.baruffi@mass.gov
From: Baruffi, Felicia M. (PER)
Sent: Monday, October 20, 2025 9:06 AM
To: 'Ricky Stebbins' <thestebbman@yahoo.com>
Cc: Duane, Doreen M. (PER) <doreen.m.duane@mass.gov>
Subject: RE: RE: Public Records Request – PERAC Investment Records
2024–2025
Email 4 of 5
Felicia Baruffi, Esq.
Senior Associate General Counsel
Public Employee Retirement Administration Commission
10 Cabot Road, Suite 300
Medford, MA 02155
(617) 666-4446, ext. 909
www.mass.gov/perac
**Please note my new email address: felicia.m.baruffi@mass.gov
From: Baruffi, Felicia M. (PER)
Sent: Monday, October 20, 2025 9:05 AM
To: 'Ricky Stebbins' <thestebbman@yahoo.com>
Cc: Duane, Doreen M. (PER) <doreen.m.duane@mass.gov>
Subject: RE: RE: Public Records Request – PERAC Investment Records
2024–2025
Email 3 of 5
Felicia Baruffi, Esq.
Senior Associate General Counsel
Public Employee Retirement Administration Commission
10 Cabot Road, Suite 300
Medford, MA 02155
(617) 666-4446, ext. 909
13 of 15
www.mass.gov/perac
**Please note my new email address: felicia.m.baruffi@mass.gov
From: Baruffi, Felicia M. (PER)
Sent: Monday, October 20, 2025 9:03 AM
To: 'Ricky Stebbins' <thestebbman@yahoo.com>
Cc: Duane, Doreen M. (PER) <doreen.m.duane@mass.gov>
Subject: RE: RE: Public Records Request – PERAC Investment Records
2024–2025
Email 2 of 5
Felicia Baruffi, Esq.
Senior Associate General Counsel
Public Employee Retirement Administration Commission
10 Cabot Road, Suite 300
Medford, MA 02155
(617) 666-4446, ext. 909
www.mass.gov/perac
**Please note my new email address: felicia.m.baruffi@mass.gov
From: Baruffi, Felicia M. (PER)
Sent: Monday, October 20, 2025 9:01 AM
To: 'Ricky Stebbins' <thestebbman@yahoo.com>
Cc: Duane, Doreen M. (PER) <doreen.m.duane@mass.gov>
Subject: RE: Public Records Request – PERAC Investment Records 2024–
2025
Good Morning Mr. Stebbins,
Pursuant to your Public Records request, attached please find the first
round of emails that is responsive to your request. This will be email 1
of 5. The rest of the emails are still being reviewed we are still working
on the PROSPER login information. I will send additional documents as
soon as I am able.
14 of 15
PROSPER FinancialVendorUserAccess_v1.pdf
337.5 KB
Best,
Felicia
Felicia Baruffi, Esq.
Senior Associate General Counsel
Public Employee Retirement Administration Commission
10 Cabot Road, Suite 300
Medford, MA 02155
(617) 666-4446, ext. 909
www.mass.gov/perac
**Please note my new email address: felicia.m.baruffi@mass.gov
CONFIDENTIALITY NOTICE This electronic message and any attachments are intended only for the addressee(s) and contains
information that may be privileged and confidential. If you are not the intended recipient, please no fy the sender by reply
email and immediately delete this message. Use, disclosure or reproduction of this email by anyone other than the intended
recipient(s) is strictly prohibited. Thank you.
15 of 15
Pi-007-2026-1-7-to-2025-12-14-Stebbins-Baruffi
From: felicia.m.baruffi@mass.gov
To: me, Cc: Duane,, and 1 other · Wed, Jan 7 at 12:14 PM
Cc:
< thestebbman@yahoo.com >,
Duane, Doreen M. (PER),< doreen.m.duane@mass.gov >,
Taylor, Daniel (PER),< daniel.taylor2@mass.gov >
Message Body
Good Afternoon Mr. Stebbins,
This email is in response to your public records request dated December 27, 2025. In response to Item A, PERAC has no records in its possession that are responsive. Mr. Ford was never at PERAC’s offices from June 2024-December 2025, and BlackRock was not informed of your July 7, 2025 public records request. In response to Item B, this is a specific test account that was created for a business user to check PROSPER functionality and how it works – aka a demo. The account does not have any access to any data.
In response to Item 4, PROSPER is a custom application hosted in Microsoft Azure Gov Cloud. It is managed by PERAC IT engineers and developers in conjunction with 2 of PERAC Main IT vendors. SMX whom is on the Commonwealth blanket contract provides 7x24 Managed security services and managed hosting services. In addition to PERACs internal developers, PERAC has contracted with CGI whom created PROSPER and continue to provide enhancements and bug fixes in conjunction with PERAC IT staff. PROSPER adheres to FISMA moderate with crosswalk to HIPPA compliance. In addition, we use another third party intra systems for security testing. The SLA for Microsoft Azure can be found here: https://www.microsoft.com/licensing/docs/view/Service-Level-Agreements-SLA-for-Online-Services?lang=1. Azure Government Compliance can be found here: https://learn.microsoft.com/en-us/azure/azure-government/documentation-government-plan-compliance.
PERAC has no records in its possession responsive to Items 3, 4, 5, and 6. Further, to the extent that these items constitute a list of questions, please be aware that the Public Records Law does not require custodians to answer questions, conduct research, or create new records.
Given the scope of your request, PERAC will be assessing a reasonable fee to produce responsive records, as permitted by the Public Records Law and its associated regulations. As a state agency, we will not be assessing a fee for the first four hours of staff time spent responding to the request. The lowest paid individual with the skill necessary to respond to the requests is compensated at a rate greater than $25 per hour, so our assessed hourly rate will be the maximum of $25 per hour allowed under the law. Additionally, PERAC will be filing a petition with the Supervisor of Records, seeking an extension of time to produce records, and permission to charge for redaction under Exemptions (c), (n), (o), and (t).
As of today’s date, PERAC has spent four hours of staff time conducting preliminary searches for responsive records. Our IT unit has indicated that it will take 30 hours to generate and redact the PROSPER access logs requested in Item 1 due to the over one million events that occurred during your time range. These logs will contain IP addresses, login credentials, and other sensitive information, the disclosure of which may compromise the cybersecurity of PERAC’s systems, as well as the systems of retirement boards and vendors. This information will be redacted pursuant to Exemption (n).
Our compliance and investment team has estimated that there are approximately 287 reports and related documents responsive to Item 2 of your request, each between 2 and 20 pages. Based on similar past requests, we estimate that locating, compiling, and reviewing the report for the requested data fields will require up to 30 minutes for each report. Accordingly, we will require 140 total hours of staff time to locate and compile all reports and data responsive to Item 2.
Our preliminary search for communications responsive to Item 3 of your request has returned more than 9,670 potentially responsive email communications and attachments. Our legal team will require at least 30 seconds to review each email communication and its attachments for responsiveness and exempt material, for a total of 80 hours of staff time. Given the nature of the work performed by our agency, these communications are likely to contain personal and financial information (e.g., social security numbers, personnel records, and medical and disability information) exempt from disclosure under Exemption (c), as well as the home addresses and personal contact information of public employees, exempt from disclosure under Exemption (o). The emails may also contain statements filed under Section 20C of Chapter 32, which are exempt from disclosure under Exemption (t).
Total Fee
(4 hours + 30 hours + 140 hours + 80 hours – 4 hours) x $25/hr = $6,250.00
If you would like PERAC to proceed with the production of responsive records, please provide our office with a check in the above amount, payable to the Public Employee Retirement Administration Commission. Once we have received payment, we will begin compiling responsive records. Alternatively, you may narrow the scope of your requests, providing a more limited time frame, list of parties, or set of search terms, and we will revise our fee estimate accordingly. Please note that simpler, narrower requests are less likely to require such significant expenditures of staff time.
Regarding your concerns about the preservation of records, PERAC can again confirm that it adheres to the MA Records Retention Schedule for maintaining documents and organizational records as well as the Public Records Law.
Best,
Felicia
Felicia Baruffi, Esq.
Senior Associate General Counsel
Public Employee Retirement Administration Commission
10 Cabot Road, Suite 300
Medford, MA 02155
(617) 666-4446, ext. 909
www.mass.gov/perac
**Please note my new email address: felicia.m.baruffi@mass.gov
CONFIDENTIALITY NOTICE This electronic message and any attachments are intended only for the addressee(s) and contains information that may be privileged and confidential. If you are not the intended recipient, please notify the sender by reply email and immediately delete this message. Use, disclosure or reproduction of this email by anyone other than the intended recipient(s) is strictly prohibited. Thank you.
From: Ricky Stebbins <thestebbman@yahoo.com>
Sent: Saturday, December 27, 2025 10:41 PM
To: Taylor, Daniel (PER) <Daniel.Taylor2@mass.gov>
Cc: Baruffi, Felicia M. (PER) <Felicia.M.Baruffi@mass.gov>; Duane, Doreen M. (PER) <doreen.m.duane@mass.gov>; MA-IGO-TRAINING (IGO) <ma-igo-training@mass.gov>
Subject: Refined Public Records Request: PROSPER Access Logs (2025), Native Financial Data, Vendor Coordination Documentation
CAUTION: This email originated from a sender outside of the Commonwealth of Massachusetts mail system. Do not click on links or open attachments unless you recognize the sender and know the content is safe.
Dear Records Access Officer,
This is a refined and narrowed public records request submitted pursuant to M.G.L. c. 66 and 950 CMR 32.00. It replaces previous overlapping requests and focuses on a limited set of records essential to understanding vendor access patterns, fee transparency, and data custody practices within PERAC’s oversight systems.
This request emerges from documented inconsistencies between PERAC’s public statements and internal records already produced via prior FOIA responses. It seeks to resolve evidentiary conflicts, clarify statutory obligations, and preserve audit trails for systems managing over $90 billion in public pension assets.
The records requested below are structured to minimize processing burden while maximizing auditability. Where machine-readable formats already exist, this request explicitly declines PDF substitutes that degrade data integrity.
-----
## **OVERVIEW: TEMPORAL PATTERN REQUIRING DOCUMENTATION**
**July 7, 2025 (1:10 AM):**
I submitted a public records request to 10+ Massachusetts state officials, including PERAC, requesting:
> “All access logs to the PROSPER system from external IP addresses or users affiliated with investment vendors, including but not limited to: BlackRock, Hamilton Lane, State Street, Vanguard, PRIM-affiliated firms”
**Recipients included:**
- Felicia McGinniss (PERAC Senior Associate General Counsel)
- Natacha Dunker (PERAC)
- Secretary of State Records Office
- Christopher Bowman, Paul Stein, Cynthia Ittleman, Paul Camuso, Kevin Tivnan, Medes Diaz (State oversight officials)
- Treasury Department
- EOEEA
**BlackRock was not on the recipient list.**
**July 7, 2025 (10:07 AM) - Nine hours later:**
James Dasaro (BlackRock Director, Client Experience Management) emails John Galvin (PERAC Compliance Manager):
> “Would you be able to help provide access to the PROSPER portal to my colleagues copied in here?”
**Requested credentials for:**
- Sarah Brandwein (sarah.brandwein@blackrock.com)
- Miley Xiao (aiyin.xiao@blackrock.com)
- Conor Ford (Conor.Ford@blackrock.com)
**July 8, 2025 (7:44 AM):**
John Galvin responds:
> “Sara, Miley, Conor- a registration email will come under separate cover for access to the site.”
**July 8 - August 19, 2025:**
Intensive PROSPER access activity by newly-credentialed accounts, followed by complete cessation.
This temporal pattern—FOIA submission, credential request by non-recipient within hours, intensive access, then cessation—forms the evidentiary foundation for the records requested below.
-----
## **1. PROSPER ACCESS LOGS – Calendar Year 2025**
### **Public Interest Context:**
PERAC’s PROSPER system grants external vendors direct access to pension fund disclosures, performance data, and fee reports. Massachusetts pension systems serve over 300,000 active and retired employees across 104 retirement boards. Access logs are the only mechanism for detecting unauthorized use, coordinated disclosure manipulation, or preferential information sharing.
**As PERAC Vice-Chair, State Auditor Diana DiZoglio has authority to conduct performance audits of PERAC’s operations—reviewing policy compliance and operational procedures. However, performance audits typically do not examine underlying financial data integrity, vendor fee validation, or investment performance verification. This records request seeks access and financial data necessary for comprehensive financial audit capabilities beyond current performance review scope.**
### **Request:**
All PROSPER access logs from **January 1, 2025 through December 31, 2025**, in CSV or XLSX format.
**Required data fields (if maintained):**
- Timestamp (with timezone)
- Username
- User role or privilege level
- Organization or vendor affiliation
- Event type (login, view, edit, upload, download, delete)
- Device ID or IP address
- Session ID or duration
**Technical Compatibility Note:** Please do not convert structured logs to flattened PDFs. Provide native export format (CSV, JSON, or XLSX) to preserve column integrity and enable proper filtering.
**Sample Output Request:** Before full production, provide a 1-page sample to confirm field alignment and completeness.
-----
### **A. Conor Ford – BlackRock Advisors LLC: Access Pattern Following FOIA Request**
**Employment and Access Timeline:**
Public FINRA records (BrokerCheck, CRD# 7312440) confirm Conor Ford has been employed by BlackRock Investments, LLC for approximately 4 years, working from BlackRock’s Boston office at 60 State Street—approximately 2.3 miles from PERAC’s Medford headquarters.
|Period |Ford Employment Status |PROSPER Access |
|-------------------|------------------------------|----------------|
|~2022-2024 |BlackRock employee (Years 1-3)|0 logins |
|Jan-July 7, 2025 |BlackRock employee (Year 4) |0 logins |
|July 8, 2025 |BlackRock employee |First login ever|
|July 8-Aug 19, 2025|BlackRock employee |34 logins |
|Aug 20-Dec 2025 |BlackRock employee |0 logins |
**Access Event Summary:**
**July 7, 2025 (1:10 AM):** I submit FOIA requesting BlackRock PROSPER access logs
**July 7, 2025 (10:07 AM):** BlackRock requests credentials for Brandwein, Xiao, Ford
**July 8, 2025 (7:44 AM):** PERAC approves credentials
**July 8, 2025 (10:44 AM):** Ford’s first PROSPER login in 4-year employment history
**August 19, 2025 (5:13 PM):** Ford’s last login (17 logins that day: 10:01 AM - 5:13 PM)
**After August 19:** Zero activity
**Comparison:**
|Account |Credentials Requested|Total Logins|Pattern |
|---------------|---------------------|------------|--------------------------|
|Sarah Brandwein|YES |0 |Never used |
|Miley Xiao |YES |1 |Single login July 8 |
|Conor Ford |YES |34 |July 8-Aug 19, then ceased|
**Documentation Requested:**
**1. Notification and Coordination**
Please produce any communications showing how BlackRock became aware of my July 7, 1:10 AM FOIA request by 10:07 AM the same day:
- Any emails, phone logs, or meeting records between PERAC staff and BlackRock on July 7, 2025
- Any internal PERAC emails or messages discussing my FOIA request and whether to notify vendors
- Any written PERAC policy governing vendor notification during public records reviews
- Any calendar entries, visitor logs, or meeting documentation showing Ford at PERAC offices (July 2024-December 2025)
**2. Access Activity During Ford Sessions**
Please provide:
- Action-level logs showing which PROSPER files, modules, or data were viewed, downloaded, modified, or deleted during the 34 Ford sessions
- Whether any Schedule 7 disclosures, fee reports, or performance data were accessed
- Whether any records responsive to my FOIA request were accessed
- Session duration and specific activity timestamps for each login
If action-level logs do not exist, please provide:
- Written explanation of why such logs are not retained
- How PERAC ensures compliance with 201 CMR 17.00 audit trail requirements without action-level logging
- Whether PERAC can verify that no records were modified or deleted during vendor access
**3. Employment History and Access Pattern**
Ford worked at BlackRock for approximately 3 years (2022-2024) with zero PROSPER access. Please provide:
- Documentation explaining why PROSPER access was not needed during Ford’s first three years of employment
- Whether Ford’s role, title, or responsibilities changed in July 2025
- Whether another BlackRock employee previously handled PROSPER access for Massachusetts pension accounts
- Business justification for requesting credentials on July 7, 2025 (nine hours after my FOIA submission)
**4. Credential Request for Multiple Accounts**
Three credentials were requested but usage varied dramatically. Please clarify:
- Business purpose stated or implied in BlackRock’s July 7 credential request
- Whether Brandwein, Xiao, and Ford were expected to perform different tasks or the same review
- Why Brandwein never logged in despite credential approval
- Why Xiao logged in only once
**5. Account Activity Cessation**
After 3+ years without PROSPER access, Ford accessed the system 34 times over 6 weeks, then stopped completely. Please provide:
- Documentation of what task was completed on or around August 19 that no longer required access
- Whether Ford’s account was deactivated or whether the user simply stopped accessing
- Whether Ford’s role, access privileges, or responsibilities changed after August 19
- Whether the timing of cessation coincided with any PERAC decisions or actions regarding my FOIA request
**6. Identity Verification Documentation**
Please provide:
- Employment verification or documentation submitted when BlackRock requested credentials
- Any organizational chart or directory listing showing Ford’s role with respect to Massachusetts pension systems
- Any correspondence from Ford or about Ford beyond the July 7-8 credential exchange
-----
### **B. Test Account – “zzTest PERAC Vendor money manager1”**
**Timeline:**
**August 19, 2025 (5:13 PM):** Ford’s last login
**September 5, 2025 (1:19 PM):** First and only login by “Financial_Vendor, Test Zztest PERAC Vendor money manager1”
**Historical Context:** Cross-referencing logs from 2020-2024 shows zero instances of this account designation.
**Documentation Requested:**
Please provide:
- Account creation date, creator identity, and authorization documentation
- Business purpose for maintaining test or generic accounts in production oversight systems
- Whether this account was used for system testing, vendor training, data review, or other purposes
- Whether the September 5 login can be attributed to a specific individual or organization
- Whether this is a shared account accessible by multiple users
- How PERAC tracks accountability for actions taken under non-attributable accounts
- How generic account use complies with 201 CMR 17.00 access control and audit trail requirements
- Why this account appeared for the first time in 2025
- Any relationship between Ford account cessation (August 19) and zzTest account appearance (September 5)
-----
### **C. Pattern Summary Across Complete Historical Record**
Cross-referencing all five PROSPER access log files (January 2020 through December 2025) confirms:
|Pattern |2020-2024 |2025 |Significance |
|----------------------------------|--------------------|------------------|---------------------------|
|Conor Ford employment at BlackRock|~3 years (2022-2024)|Year 4 |Employed but zero access |
|Conor Ford PROSPER logins |0 |34 (July-Aug only)|First access after 3+ years|
|Ford activity cessation |N/A |August 19 |Complete stop after 6 weeks|
|zzTest account |0 logins |1 login (Sept 5) |First appearance ever |
|Same-day clusters (17+ logins) |0 instances |1 (Aug 19) |Unprecedented pattern |
Both unprecedented patterns appear exclusively in 2025, during the two-month period following my FOIA request.
**Methodological Note:** This pattern analysis was conducted by cross-referencing all five PROSPER access log files provided by PERAC (covering January 2020 through December 2025), using both manual review and systematic data analysis to detect anomalous access clusters, credential timing patterns, and metadata inconsistencies. The findings are based on complete data sets provided by PERAC itself.
-----
## **2. NATIVE FORMAT FINANCIAL DATA – Gross vs. Net Returns (2018–2024)**
### **Public Interest Context:**
**State Auditor DiZoglio’s office conducts performance audits—reviewing whether agencies follow policies and procedures. Performance audits typically do not examine whether reported investment performance is mathematically accurate, whether fees extracted match contractual agreements, or whether gross vs. net disclosures enable independent verification of vendor billing.**
**This records request seeks underlying financial data necessary for comprehensive financial audit capabilities—examining whether reported numbers can be independently validated, whether fees align with contracts, and whether performance claims can be verified through source data.**
The difference between gross and net investment returns represents total management costs—including fees, carried interest, and administrative expenses. For Massachusetts pension funds, this difference can amount to hundreds of millions of dollars annually.
Internal PERAC communications—including an email dated February 2021—reference decisions to omit or consolidate gross vs. net fields for “formatting” purposes. This design choice materially affects the ability to conduct independent financial verification.
### **Request:**
For all private equity, private credit, real assets, and fund-of-funds investments reported to PERAC between **2018–2024**, provide the following data fields in machine-readable format:
**Required data fields (as separate columns):**
- Fund name
- Vintage year
- Commitment amount
- Capital called
- Capital distributed
- Gross IRR (internal rate of return)
- Net IRR (internal rate of return)
- Gross MOIC (multiple on invested capital)
- Net MOIC (multiple on invested capital)
- Management fees (annual and cumulative)
- Performance fees / carried interest
- Fee offsets or rebates
- Valuation methodology used
- Reporting entity (e.g., Meketa, BlackRock, HarbourVest, NEPC)
**Format requirement:** Excel (.XLSX), CSV, or similar structured formats only. PDFs are not acceptable where native structured data exists.
**Technical Compatibility Note:** If vendors provided these reports in Excel or CSV format, please provide those native files without converting them to PDF. PDF conversion strips formulas, cell lineage, and reconciliation logic—rendering the data non-auditable.
**Sample Output Request:** Please provide a 1-page sample showing column structure and field completeness before full production.
-----
### **Basis for Request:**
Without both gross and net figures:
- Fees cannot be independently verified against contractual agreements
- Performance cannot be reconciled across report types or time periods
- Carried interest calculations cannot be validated
- Long-term underperformance can be masked by selective presentation
**If Data Is Unavailable:**
If PERAC does not possess the requested gross/net data, please provide:
- Specification of which fields are missing
- Date when data was discarded
- Records retention authority permitting destruction
- Name and title of person who authorized discarding structured data
If data exists but is being withheld:
- Specific statutory exemption with supporting case law
- Any segregable portions that can be disclosed
-----
## **3. TARGETED COMMUNICATIONS – July 1, 2025 to Present**
### **Public Interest Context:**
PERAC has provided contradictory statements regarding its role in vendor coordination and investment oversight. Understanding what communications occurred after my FOIA requests were filed is essential to resolving these documented inconsistencies.
### **Request:**
Communications (internal PERAC or between PERAC and vendors) from **July 1, 2025 to present** containing any of the following terms:
**Keywords:**
- “Conor Ford”
- “BlackRock”
- “public records request” or “FOIA” or “Stebbins”
- “logs” or “access logs”
- “zztest”
- “gross” and “net” (in same email)
- “PROSPER access” or “PROSPER login”
- “vendor access”
- “Schedule 7”
**Priority subject lines** (based on prior FOIA productions):
- “RE: PROSPER Application Access – BlackRock”
- “Fee Report”
- “RE: 2019 Annual Vendor Disclosures”
- “RE: Unigestion – Opportunity to Meet”
- “FW MA Consultant RFPs”
**If records are withheld or redacted:**
- Indicate volume withheld
- Cite specific statutory exemption with supporting case law
- Confirm whether any segregable content exists
-----
## **4. PROSPER SYSTEM CUSTODY AND VENDOR DOCUMENTATION**
### **Public Interest Context:**
PERAC’s August 1, 2025 response stated:
> “We are not sitting on 8 years of logs… They are compiling a report from scratch.”
Yet PROSPER login records dating to January 2020 were subsequently produced, confirming that historical logs exist in some form. Under M.G.L. c. 7, § 22C, state IT contracts must be publicly disclosed.
### **Request:**
Please provide:
**1. Vendor Identity:**
The name of the entity (internal PERAC unit, Commonwealth IT division, or external vendor) responsible for hosting, maintaining, or compiling PROSPER access logs
**2. Contract Documentation:**
Any contract, statement of work, or service agreement governing:
- Log retention policies and timeframes
- Audit export procedures and formats
- Security and access control requirements
- Data ownership and custody arrangements
**3. Request Documentation:**
A copy of the specific request PERAC sent to this entity in response to my July 2025 FOIA request, including:
- Date sent
- Scope of data requested
- Fields or formats specified
- Any stated limitations or exclusions
**4. Data Integrity Confirmation:**
Please provide:
- Written confirmation of whether this vendor has deleted, archived, modified, or migrated any PROSPER access logs since January 1, 2020
- Documentation of any log retention schedule or data lifecycle policies
- Verification procedures PERAC uses to ensure completeness and integrity of vendor-provided access logs
-----
## **5. FEE ESTIMATE REVISION AND JUSTIFICATION**
### **Context:**
Your December 24, 2025 response estimated **$6,575** based on:
- 27,000 emails × 30 seconds each = 225 hours
- 250 documents × 1 minute = 40 hours
- Total: 263 hours – 4 free hours = $6,575
This refined request materially reduces that burden:
- **Section 1:** Requests only 2025 logs (1 year, not 8)
- **Section 2:** Requests native files already received from vendors (no new record creation)
- **Section 3:** Limits communications to 6 months (July 2025–present)
- **Section 4:** Requests existing contract documentation
### **Revised Estimate Request:**
Pursuant to **950 CMR 32.07(2)**, please provide a revised fee estimate specific to this narrowed scope, including:
**Itemization by section:**
- Estimated hours per section
- Specific employee roles and hourly rates
- Description of tasks required (e.g., database query, manual review, redaction)
**Automation explanation:**
- Whether automated search tools, e-discovery platforms, or database exports are being used
- If not, explanation of why manual review is necessary when state agencies typically have access to enterprise document management systems
**Reconciliation with prior statements:**
- Your office stated PROSPER logs must be “compiled from scratch” by a vendor, suggesting automated extraction capability
- If automated log compilation is possible, please explain why email review would require 225 hours of manual labor
**Sample output option:**
- If significant processing costs are anticipated, please provide sample outputs for Sections 1 and 2 to confirm data completeness and format before incurring full processing fees
-----
## **6. DOCUMENTED INCONSISTENCIES – REQUEST FOR RECONCILIATION**
The following statements, when viewed together, create contradictory representations about PERAC’s role, capabilities, and data practices:
|Date |Statement |Source |
|-----------------|----------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------|
|July 8, 2025 |“PERAC itself does not conduct any type of investments” |Email response to public records request |
|July 28, 2025 |“PERAC regularly corresponds with retirement boards and some potential vendors… to ensure that proper documentation is being provided in response to RFPs”|Official letter response |
|August 1, 2025 |“We are not sitting on 8 years of logs… They are compiling a report from scratch” |Email response regarding PROSPER data |
|October 23, 2025 |Production of PROSPER login records dating to January 2020 |Attachment: PROSPER_FinancialVendorUserAccess_v1.pdf|
|December 24, 2025|Claims 27,000 emails exist but also states emails older than 12 months “cannot be easily searched” |Fee estimate letter |
The records requested in Sections 1–4 are designed to resolve these documented inconsistencies by providing primary source documentation rather than summary characterizations.
-----
## **7. PURPOSE AND BROADER CONTEXT**
### **Public Interest Foundation:**
This request is submitted as part of a broader review of public pension vendor oversight practices across Massachusetts retirement systems. Massachusetts pension systems collectively manage over $90 billion in public assets on behalf of more than 300,000 active and retired public employees, including:
- State police and correctional officer pensions
- Teacher and university employee retirement systems
- Municipal worker and utility employee funds
- Regional and county retirement boards
Transparency in vendor access patterns, fee reporting, and data integrity directly affects these beneficiaries and Massachusetts taxpayers.
### **Analytical Framework:**
This request has been developed through systematic review of publicly available documents, including:
- PERAC annual reports (2018–2024)
- Schedule 7 fee disclosures
- Prior FOIA responses from PERAC (2025)
- PROSPER access logs
- Internal PERAC-vendor communications
Pattern analysis was conducted through cross-referencing of publicly available FOIA disclosures using analytical review frameworks designed to identify systematic gaps in audit capability and data transparency.
### **Relationship to State Auditor Oversight:**
State Auditor Diana DiZoglio serves as PERAC Vice-Chair and has authority to conduct performance audits of PERAC operations. Performance audits typically review policy compliance, operational procedures, and adherence to regulations—essential oversight functions that ensure agencies follow established rules.
However, performance audits generally do not examine:
- Whether reported investment performance numbers are mathematically accurate
- Whether vendor fees extracted match contractual agreements
- Whether gross vs. net disclosures enable independent financial verification
- Whether access controls prevent unauthorized data manipulation
The records requested above seek underlying access logs and financial data necessary for comprehensive financial audit capabilities that complement, but extend beyond, current performance review scope.
Given the State Auditor’s oversight role and commitment to transparency in government operations, I respectfully request that her office consider whether the patterns documented in this request—including vendor notification during FOIA reviews, unprecedented access timing, missing financial data fields, and third-party custody gaps—warrant additional review within the State Auditor’s statutory authority.
-----
## **8. PRESERVATION NOTICE**
Please preserve all relevant materials pending production and any potential administrative review, including:
- PROSPER access logs (2020–2025, complete period)
- Vendor communications regarding RFP guidance, disclosure formatting, or fee reporting
- Structured financial files received from vendors in native formats
- Internal emails regarding my public records requests
- Contracts or documentation governing third-party data custody
- Any communications between PERAC staff and vendors on July 7, 2025
**If any requested records no longer exist, please provide:**
- Specific record category
- Date of deletion or destruction
- Records retention authority cited (with specific citation)
- Name and title of person who authorized destruction
-----
## **CLOSING**
This request is submitted in good faith to obtain machine-readable, auditable data necessary for understanding vendor access patterns, fee transparency, and fiduciary oversight practices affecting billions in public pension assets.
If any requested record is unavailable, is not in PERAC’s custody, or is claimed to be exempt from disclosure:
- Identify the specific record
- Provide the legal basis for non-production with statutory citation
- Confirm whether any segregable portion can be produced
Please confirm receipt of this request and provide a revised fee estimate within **10 business days** as required by M.G.L. c. 66, § 10.
Thank you for your attention to this matter.
Sincerely,
**Ricky Stebbins**
54 Hope Street
Springfield, MA 01119
Ricky
On Wednesday, December 24, 2025 at 09:40:13 AM EST, Taylor, Daniel (PER) <daniel.taylor2@mass.gov> wrote:
Good morning Mr. Stebbins,
This email is in response to your public records requests dated December 15 and December 18, 2025. In response to Item I of your 12/15 request, please see the attached, as well as the reports publicly posted at the following links: https://www.mass.gov/lists/perac-investment-schedule-7-fee-reports, https://www.mass.gov/perac-annual-reports.
PERAC has no records in its possession responsive to Items III, V, VI, VII and VIII of your 12/15 request, or Items IV, V, and VII of your 12/18 request. Further, to the extent that these items constitute a list of questions, please be aware that the Public Records Law does not require custodians to answer questions, conduct research, or create new records.
Given the scope of your requests, PERAC will be assessing a reasonable fee to produce responsive records, as permitted by the Public Records Law and its associated regulations. As a state agency, we will not be assessing a fee for the first four hours of staff time spent responding to the requests. The lowest paid individual with the skill necessary to respond to the requests is compensated at a rate greater than $25 per hour, so our assessed hourly rate will be the maximum of $25 per hour.
As of today’s date, PERAC has spent two hours of staff time developing search terms and conducting preliminary searches for responsive records. Our compliance and investment team has estimated that there are approximately 250 reports and related documents responsive to Item I of your 12/18 request, and more than 2,200 reports and related documents responsive to Item II of your 12/18 request. Based on similar past requests, we estimate that locating and compiling each report and any related documentation will require up to a minute. Accordingly, we will require 40 total hours of staff time to locate and compile all reports responsive to Items I and II of your 12/18 request.
Our preliminary search for communications responsive to Items II and IV of your 12/15 request and Items III and VI of your 12/18 request has returned more than 27,000 potentially responsive email communications. Our legal team will require at least 30 seconds to review each email communication and its attachments for responsiveness, for a total of 225 hours of staff time. Please note, while the responsive records are likely to contain information which is exempt from disclosure under Exemptions (a), (c), (n), and (o) of the Public Records Law, PERAC is not currently assessing a fee for the segregation and redaction of exempt material.
Total Fee
(2 hours + 40 hours + 225 hours – 4 hours) x $25/hr = $6,575.00
If you would like PERAC to proceed with the production of responsive records, please provide our office with a check in the above amount, payable to the Public Employee Retirement Administration Commission. Once we have received payment, we will begin compiling responsive records. Alternatively, you may narrow the scope of your requests, providing a more limited time frame, list of parties, or set of search terms, and we will revise our fee estimate accordingly. Please note that simpler, narrower requests are less likely to require such significant expenditures of staff time.
Thank you,
Dan
Daniel Taylor, Esq.
Associate General Counsel
Public Employee Retirement Administration Commission
10 Cabot Road, Suite 300
Medford, MA 02155
(617) 666-4446, ext. 912
www.mass.gov/perac
From: Ricky Stebbins <thestebbman@yahoo.com>
Sent: Thursday, December 18, 2025 7:26 PM
To: Baruffi, Felicia M. (PER) <Felicia.M.Baruffi@mass.gov>
Subject: Public Records Request (Parallel) – Vendor Gross/Net Performance Reports (2018–2024)
CAUTION: This email originated from a sender outside of the Commonwealth of Massachusetts mail system. Do not click on links or open attachments unless you recognize the sender and know the content is safe.
Dear Ms. Baruffi,
I am submitting this as a new and separate Public Records Request, to proceed in parallel with my pending consolidated request and not to replace it.
This request is focused on a single, documented issue reflected in PERAC–vendor correspondence:
whether gross and net performance data were calculated or available but omitted from distributed reports, and how PERAC ensures accuracy, reconcilability, and oversight when that occurs.
This request seeks existing records only.
It does not ask PERAC to create new analyses, calculations, reconciliations, or reports.
I. Meketa Investment Group – Gross/Net Performance Data and Report Version History (2018–2024)
PERAC–vendor correspondence from February 2021 states that including both gross and net performance in the Trailing Performance Summary would make the “net/gross column” in the Fee Expense Analysis “no longer applicable” and could “cause more confusion than clarity.”
That statement indicates that:
Gross and net performance data existed or were calculable, and
A reporting-format decision was made that affected reconcilability across report types and periods.
A. Systems / Boards
For the period January 1, 2018 through December 31, 2024, please produce Meketa-prepared reports for the following systems:
Massachusetts Housing Finance Agency (MassHousing / “Mass HFA”)
Norwood Retirement System
Plymouth County Retirement System
Plymouth Retirement System
Worcester Retirement System
Hingham Retirement System
Lexington Retirement System
Marlborough Retirement System
Quincy Retirement System
B. Report Types
For each system listed above, please produce all versions of:
Trailing Performance Summary reports (quarterly and/or annual)
Fee Expense Analysis reports
Any quarterly, annual, or multi-year performance or fee reports prepared by Meketa that were provided to PERAC, transmitted through PERAC, or relied upon by PERAC
C. Versions, Columns, and Explanations
For each system, report type, and year, please produce:
Any version(s) that include both gross and net performance figures in the Trailing Performance Summary
Any version(s) where such figures or columns were omitted, removed, suppressed, or altered
Any emails, cover memoranda, internal notes, or attachments explaining:
why the figures or columns were omitted or altered,
who requested, approved, or accepted the change, and
whether PERAC staff (including Veronica Colon) discussed, reviewed, relied upon, or responded to this issue in any communication, whether or not a formal response was issued
If PERAC does not retain multiple versions, please explicitly confirm whether:
such versions were never received,
such versions were received but not retained, or
PERAC retains PDFs only and not native or working files
D. Attachments, Native Files, and Underlying Data
Please also produce any attachments or native files (e.g., XLS, XLSX, CSV, or similar structured formats) received, reviewed, or relied upon by PERAC that contain performance or fee data underlying these reports, regardless of whether the final distributed reports omitted certain fields.
This request includes records reflecting PERAC’s receipt, review, awareness of, or reliance upon such data, even if the underlying files are retained by vendors.
If PERAC does not retain such attachments, please confirm whether:
they were received but not retained, or
PERAC does not retain non-PDF formats as a matter of practice
II. Other Vendors – Identification of Similar Omission Practices (2018–2024)
Beyond Meketa, please provide records sufficient to determine whether any other PERAC-associated investment consultants or vendors:
calculated gross and net performance data (or advised that such data were available internally), but
omitted those figures from distributed reports, or
altered report formats in a way that prevents year-over-year or cross-report reconciliation
This includes, but is not limited to:
BlackRock
State Street / State Street Global Advisors
Hamilton Lane
Gen II Fund Services
Any private equity or real estate fund administrators or consultants providing performance or fee reporting
For each vendor where this applies, please produce:
Vendor name and affected report type(s)
Systems or boards affected
Any versions retained by PERAC that include omitted data
Records describing what data the vendor tracks internally, what data is distributed externally, and what PERAC knew, reviewed, or relied upon
If PERAC does not track, verify, or evaluate whether vendors omit reconcilable fields, please confirm that in writing.
III. PERAC–Vendor Correspondence Regarding Omission or Avoidance of Reconcilable Data (2018–2024)
Please produce correspondence between PERAC and vendors from January 1, 2018 through December 31, 2024 that discusses omitting, removing, discouraging, or avoiding inclusion of performance or fee data, including communications containing language such as:
“cause more confusion than clarity”
“no longer applicable”
“not intended to represent actual fees paid”
“fee estimates not included”
“outside scope of service”
“management or performance fee verification”
“carried interest”
“tedious” or “imprecise”
“not an audit” / “not verified” / “do not calculate”
This includes emails, attachments, internal notes, and vendor explanations.
IV. Responsibility for Reconciliation and Oversight
Please produce any records from 2018–2024 identifying:
which entity (PERAC, vendor, retirement board, or other) is responsible for reconciling performance and fee data when vendor reports are acknowledged to be incomplete, estimated, or not independently verifiable, and
what action, if any, is taken when PERAC becomes aware that reports cannot be reconciled across report types or reporting periods
If no such responsibility, escalation, or oversight documentation exists, please confirm that in writing.
V. Basis for Accuracy of Annual Reports
Please produce any records describing how PERAC determines that annual reports are accurate when underlying vendor reports are incomplete, estimated, or not independently verified.
If no such records exist, please confirm that in writing.
VI. Vendor Clarification Requests Initiated by PERAC
If PERAC has contacted vendors to clarify omitted performance or fee data, please produce:
the requests sent,
the vendors’ responses, and
any resulting updates or decisions not to update reports
If PERAC has not contacted vendors regarding this issue, please confirm that no such clarification requests were made.
VII. Distribution of Updated or Corrected Reports
If any corrected or reissued reports exist, please produce records showing:
whether PERAC redistributed them to boards or systems,
whether recipients were notified that earlier versions were incomplete or non-reconcilable, and
the distribution lists used (board/system level only)
If PERAC does not redistribute corrected reports when reconciliation issues are identified, please confirm that practice.
Purpose (Clarifying, Not Accusatory)
This request is made to allow boards, unions, retirees, and the public to understand whether reported performance and fees are structurally reconcilable over time, and how accuracy and oversight are ensured when certain figures are omitted or not verified.
I am not alleging wrongdoing. I am requesting records that vendor correspondence indicates exist, or documentation clarifying responsibility when reconciliation is not possible.
Please confirm receipt and advise if any clarification is required.
Sincerely,
Ricky Stebbins
CONFIDENTIALITY NOTICE This electronic message and any attachments are intended only for the addressee(s) and contains information that may be privileged and confidential. If you are not the intended recipient, please notify the sender by reply email and immediately delete this message. Use, disclosure or reproduction of this email by anyone other than the intended recipient(s) is strictly prohibited. Thank you.
CONFIDENTIALITY NOTICE This electronic message and any attachments are intended only for the addressee(s) and contains information that may be privileged and confidential. If you are not the intended recipient, please notify the sender by reply email and immediately delete this message. Use, disclosure or reproduction of this email by anyone other than the intended recipient(s) is strictly prohibited. Thank you.
To: pre, Cc: me, and 2 others · Wed, Jan 7 at 12:21 PM
Message Body
Good Afternoon,
PERAC has received the below public records request from Mr. Ricky Stebbins. Also below is our agency’s response to this request. Given the magnitude of the request, we are petitioning for a time extension of 20 business days. Additionally, we are seeking permission to assess fees for time spent redacting responsive records pursuant to Exemptions (c), (n), (o), and (t). Our response below sets forth the reasons this request cannot prudently be completed without segregation and redaction.
Please let me know if you require any further information.
Thank you,
Felicia
Felicia Baruffi, Esq.
Senior Associate General Counsel
Public Employee Retirement Administration Commission
10 Cabot Road, Suite 300
Medford, MA 02155
(617) 666-4446, ext. 909
www.mass.gov/perac
**Please note my new email address: felicia.m.baruffi@mass.gov
From: felicia.m.baruffi@mass.gov
To: pre, Cc: me, and 2 others · Wed, Jan 7 at 12:21 PM
pre,< pre@sec.state.ma.us >
Cc:
< thestebbman@yahoo.com >,
Duane, Doreen M. (PER),< doreen.m.duane@mass.gov >,
Taylor, Daniel (PER),< daniel.taylor2@mass.gov >
Message Body
Good Afternoon,
PERAC has received the below public records request from Mr. Ricky Stebbins. Also below is our agency’s response to this request. Given the magnitude of the request, we are petitioning for a time extension of 20 business days. Additionally, we are seeking permission to assess fees for time spent redacting responsive records pursuant to Exemptions (c), (n), (o), and (t). Our response below sets forth the reasons this request cannot prudently be completed without segregation and redaction.
Please let me know if you require any further information.
Thank you,
Felicia
Felicia Baruffi, Esq.
Senior Associate General Counsel
Public Employee Retirement Administration Commission
10 Cabot Road, Suite 300
Medford, MA 02155
(617) 666-4446, ext. 909
Pi-008-2024-5-7-2024-5-9-Re_Hi John!!
From: Galvin, John P. (PER)
To: D"Arcy, Tim
Subject: Re: Hi John!!
Date: Thursday, May 9, 2024 10:01:33 AM
Attachments: image004.png
image005.png
image001.png
image.png
hey- just waiting for this to load..
From: D'Arcy, Tim
Sent: Tuesday, May 7, 2024 1:49 PM
To: Galvin, John P. (PER)
Subject: RE: Hi John!!
10:00 – 11:00 works! I’ll send a calendar invite.
TD
Timothy R. D’Arcy
Managing Director I BlackRock
Alternatives Specialist Team
Mobile: (+1) 617.571.9767
Office: (+1) 617.342.1633
BlackRock logo
From: Galvin, John P. (PER)
Sent: Tuesday, May 7, 2024 1:13 PM
To: D'Arcy, Tim
Subject: RE: Hi John!!
External Email: Use caution with links and attachments
I’m free after 9 till 12.
Thank you,
John
John Galvin
Compliance Officer
Public Employee Retirement Administration Commission
5 Middlesex Ave., Suite 304
Somerville, MA 02145
Phone: 617-591-8927
John.P.Galvin@mass.gov
From: D'Arcy, Tim <timothy.darcy@blackrock.com>
Sent: Tuesday, May 7, 2024 1:02 PM
To: Galvin, John P. (PER) <John.P.Galvin@mass.gov>
Subject: RE: Hi John!!
CAUTION: This email originated from a sender outside of the Commonwealth of
Massachusetts mail system. Do not click on links or open attachments unless you
recognize the sender and know the content is safe.
CAUTION: This email originated from a sender outside of the Commonwealth of
Massachusetts mail system. Do not click on links or open attachments unless you
recognize the sender and know the content is safe.
Thanks so much John! Yes! What time is good for you?
Timothy R. D’Arcy
Managing Director I BlackRock
Alternatives Specialist Team
Mobile: (+1) 617.571.9767
Office: (+1) 617.342.1633
BlackRock logo
From: Galvin, John P. (PER) <John.P.Galvin@mass.gov>
Sent: Tuesday, May 7, 2024 1:01 PM
To: D'Arcy, Tim <timothy.darcy@blackrock.com>
Subject: RE: Hi John!!
External Email: Use caution with links and attachments
Hi Tim,
Good to hear from you and congratulations on the move!
Yes, of course I can help. Will Thursday morning work?
Thank you,
John
John Galvin
Compliance Officer
Public Employee Retirement Administration Commission
5 Middlesex Ave., Suite 304
Somerville, MA 02145
Phone: 617-591-8927
John.P.Galvin@mass.gov
From: D'Arcy, Tim <timothy.darcy@blackrock.com>
Sent: Tuesday, May 7, 2024 12:58 PM
To: Galvin, John P. (PER) <John.P.Galvin@mass.gov>
Subject: Hi John!!
Hi John! I hope you’re well!
Coming to you from BlackRock now! I miss talking to you guys on the Boston business at
Hamilton Lane, I hope things are going smoothly. They will be extremely helpful in
developing and executing the plan I’m sure of it. If you have any questions or concerns on
that front, please reach out to me and I’m sure I can be helpful.
One quick question from my side. Now that I’m here at BlackRock, I’m trying got be helpful
to them on the Mass Public Pensions and how to work with the plan directly as well as work
closely with PERAC. To that end, there is a live example that BlackRock has some
questions on. Specifically, as it relates to the active RFP MWRA has targeting secondaries
investments.
BlackRock would like to respond to the RFP but wants to make sure they are doing
everything they can to satisfy the PERAC disclosures.
Would you mind getting on the phone with me and a colleague from BlackRock just to
answer a few short questions related to the disclosures at the front-end of an RFP process?
Thanks so much in advance John, I really appreciate it.
Be well,
TD
Timothy R. D’Arcy
Managing Director I BlackRock
Alternatives Specialist Team
Mobile: (+1) 617.571.9767
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Pi-009-2022-6-16-to-2021-5-27-Tech Valuations A Blind Spot in Private Markets
RE: Tech Valuations: A Blind Spot in Private Markets
From Yolanda Vasquez <yvasquez@gagpartners.com>
on behalf of
GQG Onboarding <onboarding@gqgpartners.com>
Date Thu 6/16/2022 10:47 AM
To Colon, Veronica (PER) <veronica.colon@mass.gov>
Cc GQG Onboarding <onboarding@gqgpartners.com>
CAUTION: This email originated from a sender outside of the Commonwealth of Massachusetts mail system. Do not click on links or open attachments unless you recognize the sender and know the
content is safe.
Good morning Veronica,
Just circling back on the below. Please let me know if we should expect to receive the executed Client Update
Form.
Thank you,
Yolanda
From: Yolanda Vasquez < yvasquez@gagpartners.com> On Behalf Of GQG Onboarding
Sent: Tuesday, June 7, 2022 12:45 PM
To: veronica.colon@mass.gov
Cc: GQG Onboarding<onboarding@gagpartners.com>
Subject: RE: Tech Valuations: A Blind Spot in Private Markets
Good afternoon Veronica, I am following up on the below correspondence. Please let me know when we should expect to receive the
executed Client Update Form.
Should you have any questions, please let me know.
Thank you,
Yolanda
From: Yolanda Vasquez <yvasquez@gggpartners.com> On Behalf Of GQG Onboarding
Sent: Tuesday, May 31, 2022 11:24 AM
To: veronica.colon@mass.gov
Cc: GQG Onboarding <onboarding@gggpartners.com>
Subiect: FW: Tech Valuations: A Blind Soot in Private Markets
Good morning Veronica,
1/3
To regrant you portal access please update your email address by completing the Client Update Form attached and have it signed by an authorized signer for the investment. Please send the executed form to
GQGFundsUSTA@ntrs.com with onboarding@gggpartners.com on copy.
Kindly note, portal access is granted should you elect to receive monthly statement and/or holdings
correspondence.
Please let me know if you have any questions.
Thank you,
Yolanda Vasquez
Associate, Client Onboarding | GQG Partners
280 Park Avenue, Suite 27E
New York, NY 10017
mobile: +1 347 752 7370/ email: yvasquez@gggpartners.com
GQG
PARTNERS
gqgpartners.com
Follow GOG Partners on LinkedIn
*Please reply all to onboarding@gqgpartners.com
From: Colon, Veronica (PER) <veronica.colon@mass.gov>
Sent: Friday, May 27, 2022 11:04 AM
To: Elizabeth Colquitt<ecolquitt@gagpartners.com>
Subject: Automatic reply: Tech Valuations: A Blind Spot in Private Markets
Caution: This email is from outside the organization. DO NOT CLICK a link or open an attachment unless you know the content is safe and are expecting it from the
sender. If in doubt, contact the sender separately to verify the content.
*** My email has been change to veronica.colon@mass.gov, please update your records immediately and avoid any kickbacks. If you have any questions, please contact me at (617) 591-8926. ***
Image
CONFIDENTIALITY NOTICE This electronic message and any attachments are intended only for the addressee(s) and contains information that may be privileged and confidential. If you are not the intended recipient, please notify the sender by reply email and immediately delete this message. Use, disclosure or reproduction of this
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This message, and any attachments, is for the intended recipients) only and may contain information that is privileged, confidential and/or proprietary. If you are not the intended recipient, please notify the sender by replying to this email and delete this message. Do not use, disclose, disseminate or copy any part of it. Opinions expressed are subject to change and are not intended to be investment advice, a forecast of future events, or a guarantee of future results. This information is neither an offer to sell nor a solicitation of any offer to buy an interest in any fund or other investment vehicle sponsored or
managed by GQG Partners LLC. Figures are unaudited, and may not be representative of the current or
2/3
future performance of any investment. Past performance does not guarantee future results. In Australia, GQG Partners LLC is an authorized representative (number 001283168) of GQG Partners (Australia) Pty Ltd ACN 626132572, AFS number 515673, and this information and our services may
only be provided to wholesale clients (as defined in the Australian Corporations Act).
3/3
Pi-010-2021-5-6-to-2021-4-22-MA client 4Q20 reports
Re: MA client 4020 reports
From Colon, Veronica (PER) <veronica.colon@mass.gov>
Date Thu 5/6/2021 12:37 PM
To Goulart, Maura <mgoulart@fiducint.com>
Yes, I'll you right now.
From: Goulart, Maura <mgoulart@fiducient.com>
Sent: Thursday, May 6, 2021 12:19 PM
To: Colon, Veronica (PER)
Subject: RE: MA client 4Q20 reports
CAUTION: This email originated from a sender outside of the Commonwealth of Massachusetts mail system. Do not click on links or open attachments unless you recognize
the sender and know the content is safe.
Hi Veronica Can you please call me at 413-478-0657 when you have a moment? We don't' calculate gross returns so not sure where you received these from.
Did you receive gross returns from us?
From: Colon, Veronica (PER) <veronica.colon@state.ma.us>
Sent: Tuesday, May 4, 2021 2:52 PM
To: Goulart, Maura <mgoulart@fiducient.com>
Cc: Flynn, Tracey <tflynn@fiducient.com>
Subject: Re: MA client 4Q20 reports
ATTENTION - EXTERNAL EMAIL - The sender of this email is EXTERNAL to our email system. Do not click links or open attachments unless you recognize the sender and know the content is safe. The Original Sender of
this email is Veronica.Colon@MassMail.State.MA.US
5/4/2021
Hi Maura, Hope all is well. I have a question. Could you you double check the number I grabbed from the reports
are correct? Look forward to hearing from you soon. Have a nice day and week. Take care and stay safe!
1/3
Boards: FIA - 4th QTR Net of Fees • FIA - YTD Net of Fees • FIA - 4th QTR Gross of Fees • FIA - YTD
Gross of Fees
Concord • 9.60 • 9.70 • 8.50 • 12.20
Plymouth • 9.90 • 9.30 • 11.60 • 12.70
Waltham • 11.40 • 13.40 • 10.70 • 12.90
Watertown • 12.00 • 12.50 • 10.20 • 13.10
Weymouth • 10.90 • 13.50 • 11.20 • 13.00
Best,
Veronica
From: Colon, Veronica (PER)
Sent: Thursday, April 22, 2021 9:47 AM To: Goulart, Maura
Cc: Flynn, Tracey
Subject: Re: MA client 4Q20 reports
4/22/2021
Hi Maura,
Hope all is well. Just to be and I double checking that the performance numbers are "Net of Fees" and not "Gross of Fees?" If so, could you forward me the report attached for 2020 to see "Gross of Fees," please
and thank you. Look forward to hearing from you soon. Have a nice day and week. Stay safe!
Best,
Veronica
From: Goulart, Maura <mgoulart@dimeoschneider.com>
Sent: Wednesday, February 24, 2021 7:15 AM
To: Colon, Veronica (PER)
Cc: Flynn, Tracey
Subject: MA client 4Q20 reports
CAUTION: This email originated from a sender outside of the Commonwealth of Massachusetts mail system. Do not click on links or open attachments unless you recognize the sender and know the
content is safe.
Citrix Attachments
Concord - 4020 QIR.pdf 2.8 MB
Plymouth - 4Q20 QIR.pdf 2.7 MB
Reading - 4Q20 QIR.pdf 2.1 MB
Expires August 23, 2021
2/3
Citrix Attachments
Stoneham - 4Q20 QIR.pdf 2.7 MB
Waltham - 4Q20 QIR.pdf 2.3 MB
Watertown - 4Q20 QIR.pdf 2.8 MB
Weymouth - 4Q20 QIR.pdf 3.2 MB
Expires August 23, 2021
Download Attachments
Maura Goulart uses Citrix Files to share documents securely.
Hi Veronica
Please see the 4th quarter QIRs as requested. Note Concord is not completed yet.
Thank you,
Maura
Maura K. Goulart, CFA | Director of Client Analytics (Allocation)
DiMeo Schneider & Associates, L.L.C.
100 Northfield Drive, 4th Floor | Windsor, Connecticut 06095
866.466.9412 | 860.697.7423 | Mobile: 413.478.0657
mgoulart@dimeoschneider.com | dimeoschneider.com
This e-mail may contain information that is privileged, confidential or protected under state or federal law. If you are not an intended recipient of this email, please delete it, notify the sender immediately, and do not copy, use or disseminate any information in the e-mail. Any tax advice in this email may not be used to avoid any penalties imposed under U.S. tax laws. E-mail sent to or from this e-mail address may
be monitored, reviewed and archived.
CONFIDENTIALITY NOTICE This electronic message and any attachments are intended only for the addressee(s) and contains information that may be privileged and confidential. If you are not the intended recipient, please notify the sender by reply email and immediately delete this message. Use, disclosure or reproduction of this
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This message is intended only for the use of the individual to whom it is addressed and may contain information that is privileged and confidential. If you are not the intended recipient of this message, your use, dissemination, forwarding, printing or copying of this information is prohibited. If you have received this e-mail in error, kindly notify the sender by reply e-mail and destroy this message. Opinions, conclusions and other information in this message that do not relate to the official business of Fiducient
Advisors. do not reflect the official position of Fiducient Advisors.
3/3
Pi-011-2021-2-24-to-2021-2-22-[EXTERNALJRE The Town of Norwood - Q42020 -
Outlook
RE: [EXTERNALJRE: The Town of Norwood Retirement System - Q42020 - QUESTION
From Sara Davis <sdavis@meketa.com>
Date Wed 2/24/2021 4:10 PM
To Colon, Veronica (PER) < veronica.colon@mass.gov>
Cc Rachel Evicci <revicci@meketa.com>
CAUTION: This email originated from a sender outside of the Commonwealth of Massachusetts mail system. Do not click on links or open attachments unless you recognize the sender and know the
content is safe.
Hi Veronica,
Upon further thought, if we provide both gross and net performance in the Trailing Performance Summary for all reports you have mentioned below it would then make the "net/gross column" in the Fee
Expense Analysis no longer applicable and may potentially cause more confusion than clarity.
My main goal in bringing this up is I want to ensure that you are receiving the data that is most helpful to
you.
If you prefer to see both net and gross performance in the Trailing Performance Summary, would it be
okay if the net/gross column was removed from the Fee Expense Analysis due to my reasoning above?
Please let me know what you think of this. I am happy to clarify anything I stated above as well.
Thank you,
Sara
From: Sara Davis
Sent: Wednesday, February 24, 2021 9:43 AM
To: 'Colon, Veronica (PER)' <veronica.colon@state.ma.us>
Cc: Rachel Evicci <revicci@meketa.com>
Subject: RE: [EXTERNAL]RE: The Town of Norwood Retirement System - Q42020 - QUESTION
Thank you Veronica. We will work on getting you the reports you have listed below as samples showing
both net and gross performance in the Trailing Performance Summary section.
Thank you,
Sara
From: Colon, Veronica (PER) <veronica.colon@state.ma.us>
Sent: Wednesday, February 24, 2021 5:29 AM
To: Sara Davis <sdavis@meketa.com>
Cc: Rachel Evicci <revicci@meketa.com>
Subject: Re: [EXTERNAL]RE: The Town of Norwood Retirement System - Q42020 - QUESTION
2/24/2021
1/7
Hi Sara,
Both "Net and Gross Net Performance" in the "Trailing ... section. Could you provide me a revised/updated report for 4th QTR 2020 ONLY for these clients just for a sample. Hopefully, going
forward it will be sent with the updated data.
1.) Mass. H.F.A
2.) Norwood
3.) Plymouth County
4.) Worcester
5.) Hingham
6.) Lexington
7.) Marlborough
8.) Quincy
Look forward to hearing from you soon. Have a nice day and week. Stay safe!
Best,
Veronica
From: Sara Davis <sdavis@meketa.com>
Sent: Tuesday, February 23, 2021 4:11 PM
To: Colon, Veronica (PER)
Cc: Rachel Evicci
Subject: RE: [EXTERNAL]RE: The Town of Norwood Retirement System - Q42020 - QUESTION
CAUTION: This email originated from a sender outside of the Commonwealth of Massachusetts mail system. Do not click on links or open attachments unless you recognize
the sender and know the content is safe.
Hi Veronica, I
have one last clarifying question for you. In the Norwood report, the Trailing Net Performance section shows both net and gross performance for each account. For all Meketa clients that send PERAC quarterly reports, would you prefer to see both net and gross performance in the Trailing Net Performance section or do you not have a preference on what is shown? (typically most of client reports
only show net performance)
Thank you,
Sara
From: Colon, Veronica (PER) <veronica.colon@state.ma.us>
Sent: Tuesday, February 23, 2021 3:02 PM
To: Sara Davis <sdavis@meketa.com>
Cc: Rachel Evicci <revicci@meketa.com>
Subject: Re: [EXTERNAL]RE: The Town of Norwood Retirement System - Q42020 - QUESTION
Sara,
Thank you for everything.
2/7
Best,
Veronica
From: Sara Davis <sdavis@meketa.com>
Sent: Tuesday, February 23, 2021 2:41 PM
To: Colon, Veronica (PER)
Cc: Rachel Evicci
Subject: RE: [EXTERNAL]RE: The Town of Norwood Retirement System - Q42020 - QUESTION
CAUTION: This email originated from a sender outside of the Commonwealth of Massachusetts mail system. Do not click on links or open attachments unless you recognize
the sender and know the content is safe.
Hi Veronica,
Please see the response below with regards to your question on PE fund fees:
The fee tables shown in our reports are the extent of our fee analysis reporting for these clients and are not supposed to represent actual fees paid or an audit. We don't include fee estimates for private equity and other closed end fund structures in our reporting due to the process being tedious and potentially imprecise due to complex fee structures with carried interest etc. We do offer a management and performance fee verification service, but that is not included in our scope of services for these clients and additionally is quite expensive due to the time it takes. If you have specific questions about a manager, it would be best if you reach out to the manager or the clients auditor directly for further
clarification.
If there is any additional information I can provide or answer any further questions please let me know. I
would be happy to do so.
Thank you,
Sara
From: Sara Davis
Sent: Tuesday, February 23, 2021 1:01 PM
To: 'Colon, Veronica (PER)' <veronica.colon@state.ma.us>
Cc: Rachel Evicci <revicci@meketa.com>
Subject: RE: [EXTERNAL]RE: The Town of Norwood Retirement System - Q42020 - QUESTION
Hi Veronica,
Thank you for your email. I just reached out to a couple of my colleagues to discuss this. I will get back
to you as soon as I can with an answer.
I appreciate your patience with this.
Thank you,
Sara
From: Colon, Veronica (PER) <veronica.colon@state.ma.us>
Sent: Tuesday, February 23, 2021 12:14 PM
3/7
To: Sara Davis <sdavis@meketa.com>
Cc: Rachel Evicci <revicci@meketa.com>
Subject: Re: [EXTERNALJRE: The Town of Norwood Retirement System - Q42020 - QUESTION
2/23/2021
Hi Sara:
Yes, I understand. Will you be processing them manually? Also, will it be done for all the clients
managers?
Veronica
From: Sara Davis <sdavis@meketa.com>
Sent: Tuesday, February 23, 2021 10:26 AM
To: Colon, Veronica (PER)
Cc: Rachel Evicci
Subject: RE: [EXTERNAL]RE: The Town of Norwood Retirement System - Q42020 - QUESTION
CAUTION: This email originated from a sender outside of the Commonwealth of Massachusetts mail system. Do not click on links or open attachments unless you recognize
the sender and know the content is safe.
Hi Veronica,
I hope you are doing well. With regards to your question, are you specifically referencing the Private
Equity accounts or something different?
For the Town of Norwood Fee Table for example, all managers other than Private Equity have "estimated
fee values" and "estimated fees". The Private Equity accounts do not show an estimated fee value or estimated fee due to the fee not being a flat percentage. As you can see in the "Fee Schedule" column
there is more detailed language on the Private Equity fees.
For Private Equity accounts, the estimated fee values would need to be added into the table manually.
Please let me know if this is helpful.
Thank you,
Sara
Sara Davis
Specialist, Performance Analyst
The Westwood office has moved - please update our address!
Meketa Investment Group, Inc.
80 University Ave
Westwood, MA 02090
Main 781.471.3500 | Fax 781.471.3411
sdavis@meketa.com
4/7
meketa.com
INVESTMENT GROUP This message, including any attachments, may contain information that is confidential or privileged, and is intended only for the addressee(s). If you are not the intended recipient, you are hereby notified that any use, dissemination, distribution, printing, copying, or disclosure of this information is strictly
prohibited. If you received this message in error, please delete it from your system and notify the sender immediately by return email or by calling (781)
471-3500.
From: Colon, Veronica (PER) <veronica.colon@state.ma.us>
Sent: Tuesday, February 23, 2021 10:03 AM
To: Rachel Evicci <revicci@meketa.com>
Cc: Sara Davis <sdavis@meketa.com>
Subject: [EXTERNAL]RE: The Town of Norwood Retirement System - Q42020 - QUESTION
2/23/2021
Hi Rachel,
The reports were fine. Just a one question, "Why don't all managers have values for fees?" Could you share why? Will you be providing all the clients fee analysis within their normal quarterly reports? If not, will it be submitted
separate? Look forward to hearing from you soon. Have a nice day and week. Stay safe!
Best,
Veronica
From: Rachel Evicci <revicci@meketa.com>
Sent: Tuesday, February 23, 2021 9:42 AM
To: Colon, Veronica (PER) <Veronica.Colon@MassMail.State.MA.US>
Cc: Sara Davis <sdavis@meketa.com>
Subject: RE: The Town of Norwood Retirement System - Q42020 - QUESTION
Importance: High
CAUTION: This email originated from a sender outside of the Commonwealth of Massachusetts mail system. Do not click on links or open attachments unless you recognize the sender and know the
content is safe.
Good morning Veronica,
Just a quick note to circle back asking if this recently sent report is exactly what you are looking for? If so we will make sure all Meketa reports to PERAC are uniform.
Thank you in advance,
Rachel
5/7
Rachel Evicci
Specialist, General Consulting Client Service Assistant
The Westwood office has moved - please update our address!
Meketa Investment Group, Inc.
80 University Ave
Westwood, MA 02090
Main 781.471.3500 | Fax 781.471.3411
revicci@meketa.com
meketa.com
žmeketa-sig This message, including any attachments, may contain information that is confidential or privileged, and is intended only for the addressee(s). If you are not the intended recipient, you are hereby notified that any use, dissemination, distribution, printing, copying, or disclosure of this information is strictly
prohibited. If you received this message in error, please delete it from your system and notify the sender immediately by return email or by calling (781)
471-3500.
From: Rachel Evicci <revicci@meketa.com>
Sent: Monday, February 22, 2021 2:24 PM
To: Colon, Veronica (PER) <veronica.colon@state.ma.us>
Cc: Sara Davis <sdavis@meketa.com>
Subject: The Town of Norwood Retirement System - Q42020
Good afternoon Veronica,
Attached please find the Fourth Quarter 2020 for the Town of Norwood Retirement System, with Net Fee Analysis
included. If you have any questions or need further assistance, please contact us by email or at 781) 471-3500.
Best,
Rachel
Rachel Evicci
Specialist, General Consulting Client Service Assistant
The Westwood office has moved - please update our address!
Meketa Investment Group, Inc.
80 University Ave
Westwood, MA 02090
Main 781.471.3500 | Fax 781.471.3411
6/7
revicci@meketa.com
meketa.com
Zmeketa-sig
This message, including any attachments, may contain information that is confidential or privileged, and is intended only for the addressee(s). If you are not the intended recipient, you are hereby notified that any use, dissemination, distribution, printing, copying, or disclosure of this information is strictly
prohibited. If you received this message in error, please delete it from your system and notify the sender immediately by return email or by calling (781)
471-3500.
CONFIDENTIALITY NOTICE This electronic message and any attachments are intended only for the addressee(s) and contains information that may be privileged and confidential. If you are not the intended recipient, please notify the sender by reply email and immediately delete this message. Use, disclosure or reproduction of this
email by anyone other than the intended recipient(s) is strictly prohibited. Thank you.
CONFIDENTIALITY NOTICE This electronic message and any attachments are intended only for the addressee(s) and contains information that may be privileged and confidential. If you are not the intended recipient, please notify the sender by reply email and immediately delete this message. Use, disclosure or reproduction of this
email by anyone other than the intended recipients) is strictly prohibited. Thank you.
CONFIDENTIALITY NOTICE This electronic message and any attachments are intended only for the addressee(s) and contains information that may be privileged and confidential. If you are not the intended recipient, please notify the sender by reply email and immediately delete this message. Use, disclosure or reproduction of this
email by anyone other than the intended recipients) is strictly prohibited. Thank you.
CONFIDENTIALITY NOTICE This electronic message and any attachments are intended only for the addressee(s) and contains information that may be privileged and confidential. If you are not the intended recipient, please notify the sender by reply email and immediately delete this message. Use, disclosure or reproduction of this
email by anyone other than the intended recipients) is strictly prohibited. Thank you.
7/7
Pi-012-2021-2-17-to-2021-1-Fee Report
Re: Fee Report
From Colon, Veronica (PER) < veronica.colon@mass.gov>
Date Wed 2/17/2021 10:20 AM
To
Fischer, Kiley <KFischer@nepc.com>
2/17/2021
Hi Kiley,
Q: Is this something that you usually receive from the Fund Administrators? A: Yes, see the fee section of the qtrly reports. Looking for a more detail in the Private (P.E.) and Real Estate
(R.E.) managers.
Q: Or is this the first time you've requested?
A: Yes, ONLY for the PE & RE manager since all the others are listed.
Best,
Veronica
From: Fischer, Kiley <KFischer@nepc.com>
Sent: Friday, February 12, 2021 3:02 PM
To: Colon, Veronica (PER)
Subject: RE: Fee Report
CAUTION: This email originated from a sender outside of the Commonwealth of Massachusetts mail system. Do not click on links or open attachments unless you recognize
the sender and know the content is safe.
Hi Veronica,
I hope all is well. I just wanted to check on the Fee request as I don't recall sending these reports to you in past years. Is this something that you usually receive from the Fund Administrators? Or is this the first time you've
requested?
Thanks,
Kiley
From: Colon, Veronica (PER) <veronica.colon@state.ma.us>
Sent: Friday, February 12, 2021 12:08 PM
Subject: Re: Fee Report
Importance: High
MESSAGE FROM EXTERNAL SENDER
2/12/2021
Hi Everyone,
1/3
Hope all is well. Following up with my request. Thank you for for those you have supplied me the request. Since the report you produce is "Gross of Fees" and I need to see what you calculate or receive for fee amounts to prepare the reports. If you are not supplied or perform your own estimate fee analysis,
please share. The image reflects the missing reports for 2020. Look forward to hear from everyone soon.
Have a nice day and long holiday weekend. As always, stay safe!
Board • Consultant • 1st QTR 202 • 2nd QTR 20 • 3rd QTR 20 • 4th QTR 20: -
Boston • NEPC • 1/13/2021 • 1/13/2021 • 1/13/2021 •
Brockton • SEI • • • •
Chicopee • FIA • • • •
Concord • FIA • • • •
Dukes Cty. • DAHAB • 1/11/2021 • 1/11/2021 • 1/11/2021 •
Franklin Cty.• DAHAB • 1/11/2021 • 1/11/2021 • 1/11/2021 •
Hampden CI • SEGAL • • • •
Hampshire C • NEPC • • • •
MASS H.F.A. • MEKETA • 5/15/2020 • 8/13/2020 • 12/1/220 • 2/12/2021
MASS P.A. • WILSHIRE • 5/26/2020 • 8/19/2020 • 11/30/2020 • 2/10/2021
Medford • NEPC • • • •
Norfolk Cty • PEOPLE'S UNITED BANK • • • •
North Adam • DEBURLO •
North Attlebi • DAHAB • 1/11/2021 • 1/11/2021 • 1/11/2021 •
Northamptor • DEBURLO • •
Norwood • MEKETA • 1/14/2021 • 1/14/2021 • 1/14/2021 •
Plymouth • FIA • •
Plymouth Cly • WAINWRIGHT (SSIA) • 1/14/2021 • 1/14/2021 • 1/14/2021
Reading • FIA • • • •
Saugus • PEOPLE'S UNITED BANK • • • •
Shrewsb ury • DAHAB • 1/11/2021 • 1/11/2021 • 1/11/2021 •
Stoneham • FIA • • • •
Swampscott • DAHAB • • • •
Waltham • FIA • • •
Watertown • FIA • • •
Weymouth • FIA • • • •
Wobum • PEOPLE'S UNITED BANK • • • •
Worcester • MEKETA • • • •
Total
Best,
Veronica
From: Colon, Veronica (PER)
Sent: Wednesday, January 13, 2021 7:13 AM
Subject: Re: Fee Report
2/3
1/13/2021
Re: Fee Report - Baruffi, Felicia M. (PER) - Outlook
Hi Everyone,
Following up with my request. Thank you for for those you have supplied me the request. Since the report is Gross of Fees and need to see what you receive for fee amounts to prepare the reports. If you are not supplied or perform your own estimate fee analysis, please share. Look forward to hear from you or
someone else you assign soon. Have a nice day and week. Stay safe!
Best,
Veronica
From: Colon, Veronica (PER)
Sent: Friday, January 8, 2021 7:12 AM
Subject: RE: Fee Report
January 8, 2021
Hi Everyone,
Hope all is well and you are having a great morning. Happy New Year! Could you please forward the 1st,
2nd, and 3rd QTR 2020 fee analysis report plus identify if it's "Gross" or "Net.".
. If any of them are no longer your client or other, please update me; I greatly appreciate it a lot. Look forward to hearing from
everyone soon. Have a nice day and weekend E. Stay safe C!
Sincerely,
Veronica
CONFIDENTIALITY NOTICE This electronic message and any attachments are intended only for the addressee(s) and contains information that may be privileged and confidential. If you are not the intended recipient, please notify the sender by reply email and immediately delete this message. Use, disclosure or reproduction of this
email by anyone other than the intended recipients) is strictly prohibited. Thank you. This e-mail and any attachments may contain private, confidential or privileged material for the sole use of the intended recipient. If you are not the intended recipient, you may not review, copy or distribute this message. If you received this message in error, please notify the sender by reply e-mail and delete this
message and any attachments. Thank you.
3/3
Pi-013-2020-4-14-to-2020-4-13-New comment - [#5780] Re New PERAC
New comment - [#5780] Re: New PERAC User Registration: [eric.mandell@bmo.com]
From PERAC Help Desk<support@perac.freshdesk.com>
Date Tue 4/14/20206:50 PM
To stephen.feenan@bmo.com <stephen.feenan@bmo.com>; Johnson, Cheryl L. (PER) <Cheryl.Johnson@MassMail.State.MA.US>; Morrison, Rose A. (PER) < rose.a.morrison@mass.gov>; PER-DL-
ProsperHelp <PER-DL-ProsperHelp@MassMail.State.MA.US>
Cc
gregory.dow@bmo.com <gregory.dow@bmo.com>; PER-DL-Compliance <PER-DL-
Compliance@MassMail.State.MA.US>
CAUTION: This email originated from a sender outside of the Commonwealth of Massachusetts mail system. Do not click on links or open attachments unless you recognize the sender and know the
content is safe.
There is a new comment in the ticket submitted by O'Donnell, Thomas J (PER) to PERAC
Comment added by : O'Donnell, Thomas J (PER)
Comment Content:
They have 1 acount with Danvers. i will deal with them tomorrow.
Tom
From: Morrison, Rose A. (PER)
Sent: Tuesday, April 14, 2020 6:48 PM
To: PERAC Help Desk
Cc: O'Donnell, Thomas J. (PER); Johnson, Cheryl L. (PER)
Subject: Re: New comment - [#5780] Re: New PERAC User Registration : [eric.mandell@bmo.com]
Hello All.
I see Eric Mandell's name under the contacts but he is listed as "Primary". Does he have to be listed as
"Disclosure"?
Something is happening with PROSPER on my end so I can't get any further than seeing his contact type.
Rose
From: PERAC Help Desk <support@perac.freshdesk.com>
Sent: Tuesday, April 14, 2020 6:12 PM
To: gregory.dow@bmo.com; PER-DL-Compliance
Cc: PER-DL-ProsperHelp; O'Donnell, Thomas J. (PER) Subject: New comment - [#5780] Re: New PERAC User Registration :
[eric.mandell@bmo.com]
CAUTION: This email originated from a sender outside of the Commonwealth of Massachusetts mail system. Do not click on links or open attachments unless you recognize the sender and know the
content is safe.
1/4
There is a new comment in the ticket submitted by O'Donnell, Thomas J (PER) to PERAC
Comment added by : Feenan, Stephen
Comment Content:
Hi All,
Myself and a number of my colleagues have been unable to access the website via the web links
sent to eric.mandell@bmo.com
Is there an alternative option?
Thank you,
Stephen Feenan | Senior Associate | Client Relationship Management ||
BMO Global Asset Management | 115 South LaSalle Street | Chicago, IL 60603
Email: Stephen.Feenan@bmo.com
Office: 312.461.2215
Visit us at www.bmogam.com
From: PERAC Help Desk [mailto:support@perac.freshdesk.com]
Sent: Monday, April 13, 2020 2:30 PM
To: thomas.j.o'donnell@state.ma.us Cc: Dow, Gregory; Feenan, Stephen; per-dl-prosperhelp@massmail.state.ma.us; per-di-
compliance@massmail.state.ma.us; thomas.j.o'donnell@state.ma.us
Subject: Re: Re: New PERAC User Registration : [eric.mandell@bmo.com]
We have sent a new registration email to:
eric.mandell@bmo.com Please be advised that only the most recent link will work. If you try to click any of the
older links, you will get the error that the link has expired.
Please let us know if you need further assistance.
Thanks,
PERAC Help Desk
Ticket: https://perac.freshdesk.com/public/tickets/442279dea1fdb02535fa8d625476fceb
7bdd6a738da104640b453a9c0ed33319
On Mon, 13 Apr at 3:25 PM, Feenan, Stephen
<stephen.feenan@bmo.com> wrote:
Good Afternoon,
The registration link in the attached email does not work or is invalid, can
you please confirm or resend?
Thank you,
Stephen Feenan | Senior Associate | Client Relationship Management |
BMO Global Asset Management | 115 South LaSalle Street | Chicago, IL
60603
Email: Stephen.Feenan@bmo.com
Office: 312.461.2215
Visit us at www.bmogam.com
2/4
From: PERAC Help Desk
[mailto:support@perac.freshdesk.com]
Sent: Monday, April 13, 2020 1:32 PM
To: thomas.j.o'donnell@state.ma.us Cc: Dow, Gregory; Feenan, Stephen; per-di- prosperhelp@massmail.state.ma.us; per-di-
compliance@massmail.state.ma.us Subject: Re: Re: New PERAC User Registration :
[eric.mandell@bmo.com]
We have sent a new registration email to:
eric.mandell@bmo.com
Please let us know if you need further assistance.
Thanks,
PERAC Help Desk
Ticket: https://perac.freshdesk.com/public/tickets/442279dea
1fdb02535fa8d625476fceb7bdd6a738da104640b453a9c0ed
33319
On Mon, 13 Apr at 2:16 PM, Feenan, Stephen
<stephen.feenan@bmo.com> wrote:
Good Afternoon,
Can you please provide an updated
registration link.
Thank you,
Stephen Feenan | Senior Associate | Client
Relationship Management |
BMO Global Asset Management | 115 South
LaSalle Street | Chicago, IL 60603
Email: Stephen.Feenan@bmo.com
Office: 312.461.2215
Visit us at www.bmogam.com
From: perac-
mailing@per.state.ma.us
[mailto: perac-
mailing@per.state.ma.us] Sent: Monday, January 27, 2020
11:33 AM
To: Mandell, Eric
Subject: New PERAC User
Registration :
[eric.mandell@bmo.com]
Importance: High
External Email: Use caution with links
and attachments. | Couriel externe : Faites preuve de prudence en ce qui a trait
aux liens et aux pieces jointes.
Dear Eric Mandell,
You have been invited to PERAC.
3/4
Follow this link to complete your
registration.
https://prosper.perac.state.ma.us/
Account/Register/hABbAF&AOgA
DAAMAtgDuAPcABwDqAKsAmw
CYAEIADAA%3d
CONFIDENTIALITY NOTICE This electronic message and any attachments are intended only for the addressee(s) and contains information that may
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PERAC powered by Freshdesk
PERAC powered by Freshdesk
PERAC powered by Freshdesk
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Use, disclosure or reproduction of this email by anyone other than the intended recipients) is strictly prohibited. Thank you.
PERAC powered by Freshdesk
4/4
Pi-014-2020-2-11-to-2020-2-10-New comment - [#5413] FW RE 2019
New comment - [#5413] FW: RE: 2019 Annual Vendor Disclosures
From PERAC Help Desk <support@perac.freshdesk.com>
Date Tue 2/11/2020 9:58 AM To PER-DL-Compliance <PER-DL-Compliance@ MassMail.State.MA.US>; PER-DL-MIS < PER-DL-
MIS2 @MassMail.State.MA.US>; ODonnell, Thomas J. (PER) <Thomas.J.ODonnell@mass.gov>
Cc
PER-DL-ProsperHelp <PER-DL-ProsperHelp@MassMail.State.MA.US>; ODonnell, Thomas J. (PER)
<Thomas.J.ODonnell@mass.gov>
There is a new comment in the ticket submitted by O'Donnell, Thomas J (PER) to PERAC
Comment added by : Ross Hagan
Comment Content:
Hi Tom,
That would do it! Thanks for clarifying.
As far as Regulatory Compliance, please see below:
Primary contact:
Kate Trevor
Senior Vice President
ktrevor@incomeresearch.com
(617) 330 - 6676
Responsible for all annual filings: Boston Retirement System, Bristol County Retirement System, Cambridge Retirement System, Franklin Regional Retirement System, Haverhill Retirement System, Norfolk County Retirement System, Plymouth County Retirement System, Watertown Contributory Retirement System, Westfield Contributory Retirement System, City of Worcester
Retirement System.
Secondary contact:
Leonie Siragusa
Vice President
Lsiragusa@incomeresearch.com
(617) 330 - 6857
I'll be sure to let Jack know! Thanks again,
Ross Hagan
Senior Legal Analyst
INCOME RESEARCH + MANAGEMENT
100 FEDERAL STREET, 30TH FLOOR, BOSTON, MA 02110
PHONE (617) 330-9333 - FAX (617) 330-9222
www.incomeresearch.com
1/6
P+l Email Logo 2019 - Final
From: O'Donnell, Thomas J (PER) [mailto:thomas.j.o'donnell@state.ma.us]
Sent: Monday, February 10, 2020 5:44 PM
To: Ross Hagan <rhagan@incomeresearch.com> Cc: PER-DL-ProsperHelp <PER-DL-ProsperHelp@MassMail.State.MA.US>; PER-DL-Compliance <PER-
DL-Compliance@MassMail.State.MA.US>; PER-DL-MIS <PER-DL-MIS2 @MassMail.State.MA.US>
Subject: FW: RE: 2019 Annual Vendor Disclosures
Hello Ross,
Thank you for this message. I believe the problem is that the address changed from " per." to "perac-mailing@per.state.ma.us". IT does that to "keep us on our toes". Miss steaks happen, your secret is safe with me!
Please have IRM's regulatory unit provide names, titles, phone numbers and specific instructions on account assignments. In future you will be able to edit this information from your Portal but we are not there yet. PERAC will make the necessary edits. Please give young
Jack Somers my best regards.
Take care,
Tom
Thomas J. O'Donnell
Compliance Director
Public Employee Retirement Administration Commission
5 Middlesex Avenue
Suite 304
Somerville, MA 02145
617-666-4446 Ext. 922
tjodonnell@per.state.ma.us
www.mass.gov/perac
Subscribe to our email list to receive PERAC updates
From: Ross Hagan <rhagan@incomeresearch.com>
Sent: Monday, February 10, 2020 4:52 PM
To: O'Donnell, Thomas J. (PER) <Thomas.ODonnell@MassMail.State.MA.US>
Subject: FW: RE: 2019 Annual Vendor Disclosures
Tom,
As discussed, the kick-back email is below. I'II follow-up with the details on a designated point person under separate cover.
Best,
Ross Hagan
Senior Legal Analyst
INCOME RESEARCH + MANAGEMENT
100 FEDERAL STREET, 30TH FLOOR, BOSTON, MA 02110|
PHONE (617) 330-9333 - FAX (617) 330-9222
www.incomeresearch.com
2/6
P+| Email Logo 2019 - Final
From: postmaster@MassMail.State.MA.US (mailto:postmaster@MassMail.State.MA.US]
Sent: Monday, February 10, 2020 4:20 PM
To: Ross Hagan
Subject: Undeliverable: RE: 2019 Annual Vendor Disclosures
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From: Ross Hagan <rhagan@incomeresearch.com>
To: "per-mailing@per.state.ma.us" < per-mailing@per.state.ma.us>
CC: Regulatory Compliance <RegulatoryCompliance@incomeresearch.com>
Subject: RE: 2019 Annual Vendor Disclosures
Thread-Topic: 2019 Annual Vendor Disclosures
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Date: Mon, 10 Feb 2020 21:19:27 +0000
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Disclaimer THIS MESSAGE IS INTENDED ONLY FOR THE USE OF THE INDIVIDUAL ENTITY TO WHICH IT IS ADDRESSED AND MAY CONTAIN INFORMATION THAT IS PRIVILEGED, CONFIDENTIAL, AND EXEMPT FROM DISCLOSURE. If the reader of this message is not the intended recipient or an employee or agent responsible for delivering the message to the intended recipient, you are hereby notified that any dissemination, distribution or copying of
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5/6
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PERAC powered by Freshdesk
6/6
Pi-015-2019-10-18-to-9-18-MYSS-Wainwright
Outlook
RE: MYSS/Wainwright
From Paul Perdigao <pperdigao@winvcounsel.com >
Date Fri 10/18/2019 11:44 AM
To Colon, Veronica (PER) < veronica.colon@mass.gov>
We do consult for Saugus which is being reported by People's United Bank.
A majority of our Mass State clients are at People's United.
Paul Perdigao
Wainwright Investment Counsel, LLC
One Boston Place 41st Floor
Boston, MA 02108
Phone: 617 531-3131
Fax: 617 531-3140
From: Colon, Veronica (PER) <veronica.colon@state.ma.us>
Sent: Friday, October 18, 2019 11:15 AM
To: Paul Perdigao <pperdigao@winvcounsel.com>
Subject: RE: MYSS/Wainwright
Paul - Just to be clear and not misunderstand you, you are no longer Saugus R.B. consultant or you are
but the reports come from Anthony at People's United Bank?
From: Paul Perdigao [mailto:pperdigao@winvcounsel.com]
Sent: Friday, October 18, 2019 10:19 AM
To: Colon, Veronica (PER)
Subject: RE: MYSS/Wainwright
Veronica,
The only State Street account we have at Wainwright that you would need is Norfolk County which I believe you
have access to their website.
If not, then I can send the September report to you once it has been completed.
Let me know.
Paul Perdigao
Wainwright Investment Counsel, LLC
One Boston Place 41st Floor
Boston, MA 02108
Phone: 617 531-3131
Fax: 617 531-3140
1/5
From: Colon, Veronica (PER) <veronica.colon@state.ma.us>
Sent: Friday, October 18, 2019 9:34 AM
To: Paul Perdigao <pperdigao@winvcounsel.com>
Subject: RE: MYSS/Wainwright
Importance: High
10/18/2019
Hi Paul,
Hope all is well. Would you be submitting quarterly performance reports from Wainwright format not
People's United Bank? Look forward to hear from you soon. Have a nice day and weekend!
Sincerely,
Veronica
From: Paul Perdigao [mailto:pperdigao@winvcounsel.com]
Sent: Wednesday, September 18, 2019 3:21 PM
To: Colon, Veronica (PER)
Subject: RE: MYSS/Wainwright
Veronica,
With the exception of Norfolk County, we do not use State Street's services on the other Mass Pension accounts.
Let me know if I can help in any way.
Paul Perdigao
Wainwright Investment Counsel, LLC
One Boston Place 41St Floor
Boston, MA 02108
Phone: 617 531-3131
Fax: 617 531-3140
From: Colon, Veronica (PER) <veronica.colon@state.ma.us>
Sent: Wednesday, September 18, 2019 3:01 PM
To: Paul Perdigao <pperdigao@winvcounsel.com>
Subject: RE: MYSS/Wainwright
Paul - Since they were receiving some services from you (Wainwright), I thought you would use that
same software to provide their report. If not, please let me know. Thanks - Veronica
From: Paul Perdigao [mailto:pperdigao@winvcounsel.com]
Sent: Wednesday, September 18, 2019 2:55 PM
2/5
To: Colon, Veronica (PER)
Subject: RE: MYSS/Wainwright
Veronica,
Peoples United is the custodian for Saugus so State Street would not have this information.
If you'd like, I can forward your message on to Tony Teberio at People's.
Paul Perdigao
Wainwright Investment Counsel, LLC
One Boston Place 41st Floor
Boston, MA 02108
Phone: 617 531-3131
Fax: 617 531-3140
From: Colon, Veronica (PER) <veronica.colon@state.ma.us>
Sent: Wednesday, September 18, 2019 8:11 AM
To: Ann Quinlan <aquinlan@saugusretirement.org> Cc: StateStreet-PerformanceServices <StateStreet-PerformanceServices@StateStreet.com>; Paul Perdigao
<pperdigao@winvcounsel.com>; Luong, Jam <JLuong@StateStreet.com>; Stoychev, Stefan
<SStoychev@StateStreet.com>; Gus Aristizabal <garistizabal@winvcounsel.com>
Subject: RE: MYSS/Wainwright
Importance: High
9/18/2019
Hi Ann, Hope all is well. Could you add Saugus to MYSS portal to retrieve the monthly/quarterly report as I do
for all Wainwright clients? If not, please request for Paul to add me to the distribution list of the reports.
Look forward to hear from you soon. Have a nice day and week.
Sample of MYSS e-mail:
Information Classification: Limited Access
Your reporting from the GS Performance Services team is now available on https://my.statestreet.com.
Please reach out to your GS Performance Services contact with any questions - Staychev, Stefan -
sStoychev@StateStreet.comor617-662-3346.
This email is generated from a mailbox that does not receive incoming messages.
Thanks and Regards,
State Street Global Services | Performance Services CONFIDENTIALITY NOTICE The information contained in this email and any attachments have been classified as limited access andior privileged State Street informationin communication and are intended solely for the use of the named addressees) Ityou ire not an intended recipient of a person responsible for delivery to an intended recipient, please notity the author and destroy tnis emall. Any snauthorized copying, disclosure, retention or distribution of the malecial in this email is stricty forbidden. Thank
you
CONRDENTIAL
Sincerely,
3/5
Veronica Colon
Veronica Colon, Fund Accountant
Investment Unit
PERAC (Public Employee Retirement Administration Commission)
5 Middlesex Avenue
Third Floor, Suite 304
Somerville, MA 02145
Ph (617) 666-4446 Ext. 926
Main Fax (617) 628-4002
General Fax (617) 628-4414-My location
Email: recolon@per.state.ma.us Veronica. Colon@Massmail.State.MA.US, veronica.colon@state.ma.us
Website: www.mass.gov/perac
Pooled Fund Worksheet Link: https://www.mass.gov/forms/pooled-fund-worksheet
* Please consider the environment before printing this email
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computer/e-mail device. Thank you.
CONFIDENTIALITY NOTICE This electronic message and any attachments are intended only for the addressee(s) and contains information that may be privileged and confidential. If you are not the intended recipient, please notify the sender by reply email and immediately delete this message. Use, disclosure or reproduction of this
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computer/e-mail device. Thank you.
CONFIDENTIALITY NOTICE This electronic message and any attachments are intended only for the addressee(s) and contains information that may be privileged and confidential. If you are not the intended recipient, please notify the sender by reply email and immediately delete this message. Use, disclosure or reproduction of this
email by anyone other than the intended recipients) is strictly prohibited. Thank you. This message is intended only for the use of the individual or entity to which it is addressed, and may contain proprietary information that is privileged, confidential and exempt from disclosure under applicable law. If the reader of this message is not the intended recipient, please be aware that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify the sender and delete the original message from any
computer/e-mail device. Thank you.
4/5
CONFIDENTIALITY NOTICE This electronic message and any attachments are intended only for the addressee(s) and contains information that may be privileged and confidential. If you are not the intended recipient, please notify the sender by reply email and immediately delete this message. Use, disclosure or reproduction of this
email by anyone other than the intended recipients) is strictly prohibited. Thank you. This message is intended only for the use of the individual or entity to which it is addressed, and may contain proprietary information that is privileged, confidential and exempt from disclosure under applicable law. If the reader of this message is not the intended recipient, please be aware that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify the sender and delete the original message from any
computer/e-mail device. Thank you.
5/5
Pi-016-2019-5-22-RE Assistance
RE: Assistance
From O'Donnell, Thomas J. (PER) <Thomas.J.ODonnell@mass.gov>
Date Wed 5/22/2019 11:27 AM
To
Daniele, Francesco <FDaniele@mapension.com>
U 5 attachments (4 MB)
srbsaristotleevaluation.pdf; srblmcgeval.pdf, srarhumpassivecorebond.pdf; sralcappassiveeval.pdf;
sraacknowledgementdocument.pdf;
Hello Francesco,
Here are the product evaluations prepared by consultant as submitted to PERAC. I suggest you read the
Acknowledgement document, it offers clarity on PERAC's role in procurement process.
Keep under your toga please!
Take care,
Tom
From: Daniele, Francesco [mailto:FDaniele@mapension.com]
Sent: Wednesday, May 22, 2019 9:52 AM
To: O'Donnell, Thomas J. (PER)
Subject: Assistance
Importance: High
HI Tom,
Great catching up with you!
Regarding Saugus, could you provide more specific details as to specific strategy within each asset class.
I believe
I have the amounts correct, but please advise.
$5.7 Million US LARGE Cap-https://www.rhumblineadvisers.com/products/largecap.htm
$7.2 Million FIXED Income-https://www.rhumblineadvisers.com/products/fixedincome.htm
$6.3 Million Mid Cap-http://www.lmcg.com/individual-investors/us-equity/
$ 6.7 Million Small Cap - https://www.aristotlecap.com/aristotle-boston/
Thank you in advance.
Francesco
Francesco Daniele
Senior Client Services Officer
1/2
PENSION RESERVES INVESTMENT
MANAGEMENT BOARD
84 State Street, Second Floor
Boston, MA 02109
Office 617-946-8416
E-mail: fdaniele@mapension.com
2/2
Pi-017-2019-3-28-RE PERAC fund of funds guidelines
RE: PERAC fund of funds guidelines
From O'Donnell, Thomas J. (PER) <Thomas.J.ODonnell@mass.gov>
Date Thu 3/28/2019 5:19 PM
To Ghiane Jones <gjones@meketagroup.com>
Cc PER-DL-Compliance <PER-DL-Compliance@MassMail.State.MA.US>
1 attachment (2 MB)
FundofFundViewMemo.pdf;
Ghiané
I believe this is the latest memorandum on the subject. Let me know if you have questions or need additional material.
Take care,
Tom
Thomas J. O'Donnell
Compliance Officer
Public Employee Retirement Administration Commission
5 Middlesex Avenue
Suite 304
Somerville, MA 02145
617-666-4446 Ext. 922
tjodonnell@per.state.ma.us
www.mass.gov/perac
From: Ghiane Jones [mailto:gjones@meketagroup.com]
Sent: Thursday, March 28, 2019 4:21 PM
To: O'Donnell, Thomas J. (PER)
Subject: PERAC fund of funds guidelines
Dear Mr. O'Donnell,
l've been researching the latest fund of funds guidelines for PERAC, but it looks like they are no longer posted on
the website.
Can you please assist me with locating these guidelines?
Thank you,
Ghiané
Ghiané Jones
Vice President, Consultant
1/2
Meketa Investment Group, Inc.
One East Wacker Drive, Suite 1210
Chicago, IL 60601
(312) 474-0900
gjones@meketagroup.com
www.meketagroup.com
This message, including any attachments, may contain information that is confidential or privileged, and is intended only for the addressee(s). If you are not the intended recipient, you are hereby notified that any use, dissemination, distribution, printing, copying, or disclosure of this information is strictly prohibited. If you
received this message in error, please delete it from your system and notify the sender immediately by return email or by calling (781) 471-3500.
2/2
Pi-018-2019-3-15-to-2019-3-14-FW_ MA Consultant RFP's
From:O"Donnell, Thomas I. (PER)
To:Moitoso, Derek M. (PER)
Subject:FW: MA Consultant RFP"'s
Date:Friday, March 15, 2019 10:33:58 AM
Attachments:2017 MA Consultant Comparison QUINCY xlsx
2017 MA Consultant Comparison MHFA.x/sx
2017 MA Consultant Comparison FALMOUTH.x/sx
From: Greg McNeillie [mailto:greg@dahab.com]
Sent: Thursday, March 14, 2019 12:41 PM
To: O'Donnell, Thomas J. (PER)
Subject: MA Consultant RFP's
These searches are starting to become somewhat of a joke. MHFA 2017 returns ranked #100 (5 year) and #94 (10 year) and rumor has it they stayed with Meketa. Quite a similar
story with Quincy...
At some point returns are actually going to have to mean something. If their returns were anywhere near decent I could understand...Falmouth for example has very good returns and I
don't see any reason why they would leave Wainwright.
I don't know why I am wasting my time...
--
Gregory A. McNeillie
Vice Chairman, Principal
Dahab Associates, Inc.
31 Hayward Street, Suite C-3
Franklin, MA 02038
Office 508-520-3800
Cell 508-498-7143
The information contained in this message may be privileged and confidential and protected from disclosure. If the reader of this message is not the intended recipient, or an employee or agent responsible for delivering this message to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify the sender immediately by replying to the message and then
delete it; do not act upon, print, disclose, copy, retain or redistribute any information in this email.
The information contained in this message may be privileged and confidential and protected from disclosure. If the
reader of this message is not the intended recipient, or an employee or agent responsible for delivering this message
Pi-019-2019-3-13-to-2018-10-16-RE Unigestion - Opportunity to Meet
RE: Unigestion - Opportunity to Meet
From O'Donnell, Thomas J. (PER) <Thomas.J.ODonnell@mass.gov>
Date Wed 3/13/2019 2:20 PM
To Bob Meikleham < bmeikleham@unigestion.com>
I'll be here till 6:00
From: Bob Meikleham [mailto:bmeikleham@unigestion.com]
Sent: Wednesday, March 13, 2019 2:18 PM
To: O'Donnell, Thomas J. (PER)
Subject: RE: Unigestion - Opportunity to Meet
Great, is there a time after 3:00 pm that works for you? We have another meeting in the Financial District that
should finish at 3:00.
Best,
Bob
→ UNIGESTION®
Bob Meikleham
Vice President
US Institutional
Business Development
Dir. +1 (201) 714 2415
Fax. +1 (201) 714 2401
Mob. +1 (201) 705 2105
bmeikleham@unigestion.com
Unigestion (US), Ltd
Plaza 10 - Harborside Financial Center Suite 203
Jersey City, NJ 07311
Tel. +1 (201) 714 2400
Fax. +1 (201) 714 2401
www.unigestion.com
Follow Unigestion on LinkedIn.
From: O'Donnell, Thomas J (PER) <thomas.j.o'donnell@state.ma.us>
Sent: Wednesday, March 13, 2019 14:14
To: Bob Meikleham < bmeikleham@unigestion.com>
Subject: RE: Unigestion - Opportunity to Meet
Bob,
That day is ok - Afternoon better.
Take care,
Tom Thomas J. O'Donnell
Compliance Officer
Public Employee Retirement Administration Commission
5 Middlesex Avenue
Suite 304
Somerville, MA 02145
617-666-4446 Ext. 922
tjodonnell@per.state.ma.us
www.mass.gov/perac
From: Bob Meikleham [mailto:bmeikleham@unigestion.com]
Sent: Wednesday, March 13, 2019 2:10 PM
To: O'Donnell, Thomas J. (PER)
Subject: RE: Unigestion - Opportunity to Meet
Tom,
I will now only be in Boston next Thursday, March 21st
, but would look forward to the opportunity to sit down with
you if you have some availability on the day.
Have a great day,
Bob
→ UNIGESTION®
Bob Meikleham
Vice President
US Institutional
Business Development
Dir. +1 (201) 714 2415
Fax. +1 (201) 714 2401
Mob. +1 (201) 705 2105
bmeikleham@unigestion.com
Unigestion (US), Ltd
Plaza 10 - Harborside Financial Center Suite 203
Jersey City, NJ 07311
Tel. +1 (201) 714 2400
Fax. +1 (201) 714 2401
www.unigestion.com
Follow Unigestion on Linkedin.
2/7
From: Bob Meikleham
Sent: Friday, March 08, 2019 09:57
To: thomas.j.o'donnell@state.ma.us
Subject: RE: Unigestion - Opportunity to Meet
Tom,
I hope everything went OK with the knee last week and you're on the road to recovery. We talked about this quickly
last week but I wanted to check and see if you had a clearer picture regarding your schedule March 20th or 21st.
I'll be back in Boston with a member of my firm's PE team and am wondering if you have time to meet.
Look forward to hearing from you,
Bob
» UNIGESTION®
Bob Meikleham
Vice President
US Institutional
Business Development
Unigestion (US), Ltd
Plaza 10 - Harborside Financial Center Suite 203
Jersey City, NJ 07311
Dir. +1 (201) 714 2415
Fax. +1 (201) 714 2401
Tel. +1 (201) 714 2400
Fax. +1 (201) 714 2401
Mob. +1 (201) 705 2105
bmeikleham@unigestion.com
www.unigestion.com
3/7
Employee of Unigestion and Registered Representative with Foreside Global Services, LLC. Unigestion and Foreside Global Services, LLC are
From: Bob Meikleham <bmeikleham@unigestion.com>
Sent: Friday, February 15, 2019 08:18
To: thomas.j.o'donnell@state.ma.us
Subject: RE: Unigestion - Opportunity to Meet
Tom,
I got your voicemail regarding February 27th. Thank you for making yourself available. It sounded like
early afternoon works for you, if so I will send you a calendar invite for 1:30 PM.
Would you like to meet at your offices or is there somewhere else you would prefer.
Look forward to speaking with you,
Bob
Bob Meikleham
Vice President, US Institutional
Tel. +1 (201) 714 2415
Fax. +1 (201) 714 2401
Mob. +1 (201) 705 2105
Unigestion (US), Ltd
Plaza 10 - Harborside Financial Center Suite 203
Jersey City, NJ 07311
Tel. +1 (201) 714 2400
Fax. +1 (201) 714 2401
Follow Unigestion on Linkedin
https://www.linkedin.com/company/unigestion Unigestion: Institutional Fund Manager of the Year, Global Investor Unigestion: Asset Management Firm of the Year (< €20bn), Funds Europe
https://www.unigestion.com/awards/
From: Bob Meikleham
Date: February 14, 2019 at 2:10:38 PM EST
To: thomas.j.o'donnell@state.ma.us
Subject: RE: Unigestion - Opportunity to Meet
Tom,
I hope all is well. My name is Bob Meikleham, and I was referred to you via my old colleague Ken Hedgebeth. You and I shared some back and forth last year regarding a potential meeting but were unable align calendars. I will be in Boston several times over the next month and was wondering if you had any availability February 27th or
March 20 - 21st
If these dates do not work, maybe we could find a day to speak briefly over the phone. I would look forward to the opportunity to better understand the role of PERAC so that my firm can appropriately market to Public Plans in
Massachusetts.
I look forward to hearing from you,
Bob
4/7
UNIGESTION®
Bob Meikleham
Vice President
US Institutional
Business Development
Dir. +1 (201) 714 2415
Fax. +1 (201) 714 2401
Mob. +1 (201) 705 2105
bmeikleham@unigestion.com
InFollow Unigestion on LinkedIn.
Unigestion (US), Ltd
Plaza 10 - Harborside Financial Center Suite 203
Jersey City, NJ 07311
Tel. +1 (201) 714 2400
Fax. +1 (201) 714 2401
www.unigestion.com
lunds toon
anard 2918
Estopean Alternative Investment
Manager of the Ye Awards
2018*
2019 Momingstar Belgium Awards
Beat Equity Find Ficuse
European Pensions
ADS 2013
WINNER Private Equty Manager
of the Year Employee of Unigestion and Registered Representative with Foreside Global Services, LLC. Unigestion and
Foreside Global Services, LLC are not affiliates.
From: Bob Meikleham
Sent: Monday, October 22, 2018 10:51
To: O'Donnell, Thomas J (PER)
Subject: RE: Unigestion - Opportunity to Meet October 22 & 23
Tom, Hopefully you had a nice weekend and are enjoying the day off. I received a confirmation from Chris Bodtker, the Chairman of our Private Equity Investment Committee, that he will be available in Boston on Friday, November
9th.
. Would you be able to meet on that day? We are flexible on timing.
Best,
Bob
UNIGESTION®
Bob Meikleham
Vice President
US Institutional
Business Development
Dir. +1 (201) 714 2415
Fax. +1 (201) 714 2401
Mob. +1 (201) 705 2105
bmeikleham@unigestion.com
Unigestion (US), Ltd
Plaza 10 - Harborside Financial Center Suite 203
Jersey City, NJ 07311
Tel. +1 (201) 714 2400
Fax. +1 (201) 714 2401
www.unigestion.com
Follow Unigestion on LinkedIn.
5/7
10/15/25, 9:12 AM
GLOBAL INVESTOR
GROUP
2017
AWARDS
Boutique Asset
Manager of the Year
Unigestion
WARDS
WINNER
INNOVATION AWARD
From: O'Donnell, Thomas J (PER)
Sent: Tuesday, October 16, 2018 12:44
To: Bob Meikleham
Subject: RE: Unigestion - Opportunity to Meet October 22 & 23
Hello Bob,
I will be happy to meet you. I am planning to be out of the office on the 215t and 22nd Please let me know when you will be here next and I'll be happy to meet with you. Please give Ken my
best regards.
Take care,
Tom
Thomas J. O'Donnell
Compliance Officer
Public Employee Retirement Administration Commission
5 Middlesex Avenue
Suite 304
Somerville, MA 02145
617-666-4446 Ext. 922
tjodonnell@per.state.ma.us
www.mass.gov/perac
From: Bob Meikleham [mailto:bmeikleham@unigestion.com]
Sent: Tuesday, October 16, 2018 12:03 PM
To: O'Donnell, Thomas J. (PER)
Subject: Unigestion - Opportunity to Meet October 22 & 23
Good afternoon Tom, My name is Bob Meikleham with Unigestion, a Swiss Geneva-based asset manager. My friend and former colleague Ken Hedgebeth recommended I reach out to you as we have continued to expand our private equity
marketing efforts across Massachusetts. I will have the Chairman of our Private Equity Investment Committee with me in Boston on Monday, October 22 and Tuesday, October 23 and I was wondering if we can meet with you to learn your thoughts on the private
equity space and to simply introduce our firm and a couple of our best ideas to you.
I look forward to hearing if you have the opportunity to meet with us on Monday 10/22 or Tuesday 10/23.
Thank you for your consideration. Best,
Bob
→ UNIGESTION®
Bob Meikleham
Vice President
US Institutional
Business Development
Dir. +1 (201) 714 2415
Fax. +1 (201) 714 2401
Mob. +1 (201) 705 2105
bmeikleham@unigestion.com
about:blank?windowld=SecondaryReadingPane22
Unigestion (US), Ltd
Plaza 10 - Harborside Financial Center Suite 203
Jersey City, NJ 07311
Tel. +1 (201) 714 2400
Fax. +1 (201) 714 2401
www.unigestion.com
6/7
in Follow Unigestion on LinkedIn. GLOBAL INVESTOR
GROUP
2017
AWARDS
Boutique Asset
Manager of the Year
Unigestion
WARDS
2017
WINNER
INNOVATION AWARD
This email and any files transmitted with it is confidential and may be legally privileged. It is intended solely for the addressee. If you are not the intended recipient, please destroy this e-mail and notify us
immediately. Any disclosure, copying or distribution of this e-mail is prohibited and may be unlawful. There are risks in communicating by c-mail. E-mails may be susceptible to data corruption, delay, interception and unauthorized amendment and neither Unigestion nor any of its subsidiaries or affiliates
do accept liability for any such corruption, delay, interception or amendment or their consequences.
************************www.unigestion.com************************ CONFIDENTIALITY NOTICE This electronic message and any attachments are intended only for the addressee(s) and contains information that may be privileged and confidential. If you are not the intended recipient, please notify the sender by reply email and immediately delete this message. Use, disclosure or reproduction of this
email by anyone other than the intended recipients) is strictly prohibited. Thank you. This email and any files transmitted with it is confidential and may be legally privileged. It is intended solely for the addressee. If you are not the intended recipient, please destroy this e-mail and notify us
immediately. Any disclosure, copying or distribution of this e-mail is prohibited and may be unlawful. There are risks in communicating by e-mail. E-mails may be susceptible to data corruption, delay, interception and unauthorized amendment and neither Unigestion nor any of its subsidiaries or affiliates
do accept liability for any such corruption, delay, interception or amendment or their consequences.
************************www.unigestion.com************************ CONFIDENTIALITY NOTICE This electronic message and any attachments are intended only for the addressee(s) and contains information that may be privileged and confidential. If you are not the intended recipient, please notify the sender by reply email and immediately delete this message. Use, disclosure or reproduction of this
email by anyone other than the intended recipients) is strictly prohibited. Thank you. This email and any files transmitted with it is confidential and may be legally privileged. It is intended solely for the addressee. If you are not the intended recipient, please destroy this e-mail and notify us
immediately. Any disclosure, copying or distribution of this e-mail is prohibited and may be unlawful. There are risks in communicating by e-mail. E-mails may be susceptible to data corruption, delay, interception and unauthorized amendment and neither Unigestion nor any of its subsidiaries or affiliates
do accept liability for any such corruption, delay, interception or amendment or their consequences.
************************www.unigestion.com************************
7/7
Pi-020-2019-2-10-to-2019-1-28-Re Updated PERAC Contact Form_Boston Advisors, LLC
Re: Updated PERAC Contact Form_Boston Advisors, LLC
From O'Donnell, Thomas J. (PER) < Thomas.J.Donnell@mass.gov>
Date Sun 2/10/20196:05 PM
To Glynn, Evelina (Boston Advisors) < evelina.glynn@bostonadvisors.com>
Hello Evelina,
We have updated your firms contact information. I hope to have the annual vendor disclosures to Boston Advisors this week.
Thank you for your patience and cooperation.
Tom
From: Glynn, Evelina (Boston Advisors) <evelina.glynn@bostonadvisors.com>
Sent: Wednesday, February 6, 2019 12:35 PM
To: O'Donnell, Thomas J. (PER)
Subject: FW: Updated PERAC Contact Form_Boston Advisors, LLC
From: Glynn, Evelina (Boston Advisors)
Sent: Tuesday, January 29, 2019 3:47 PM
To: 'cljohnson@per.state.ma.us' <cljohnson@per.state.ma.us>
Cc: Compliance <Compliance@bostonadvisors.com>
Subject: FW: Updated PERAC Contact Form_Boston Advisors, LLC
Importance: High
Hello Cheryl,
Attached please find Boston Advisors updated Contact Form which lists our new CCO, Tim Kirwan,
and an updated email address for the Compliance Department. After this information is updated, would it be possible to push the 3 PERAC notifications to our compliance team
so we have the correct link for each of our accounts. We only received one email to date and should receive 3.
Please let me know if you need anything else.
Thank you for your help,
~ Evelina
Evelina R. Glynn
Compliance
Boston Advisors, LLC | One Liberty Square, 10th Floor | Boston, MA 02109
Office: 617.348.3158 | Fax: 617.348.0084 | Evelina.glynn@bostonadvisors.com
BOSTON ADVISORS
1/3
From: perac-mailing@per.state.ma.us [mailto:perac-mailing@per.state.ma.us]
Sent: Monday, January 28, 2019 9:49 PM
To: Kerrigan, Tanya (Boston Advisors) < tanya.kerrigan@bostonadvisors.com>
Subject: Annual Vendor Disclosure is Due
Importance: High
Dear Tanya Kerrigan:
The nature of the services that you provide either directly, as a sub-adviser, as a fund in a fund of funds or as a securities litigator in connection with the Attleboro Retirement Board requires you to make annual disclosures to the retirement board and PERAC. This Form must also be filed by those involved in the distribution of investment products to the retirement boards (placement agents, third party marketers or
those providing consulting services to those listed).
The 2018 Boston Advisors Inc. Annual Disclosure Form must be accessed, completed and submitted through this link and not sent to PERAC via email or postal mail:
https://prosper.perac.state.ma.us/VendorPortal/Form/928d9f21-a74b-4d8e-ade5-83b448a29d9d
These forms are due no later than 3/1/2019.
For detailed information about how to complete this Form please review PERA Memos #32/2018, #31/2018, #27/2015, #18/2014, and #54/2012. These can be found at https://www.mass.gov/perac-memos.
The statute requires that "
...compensation, in whatever form..." be disclosed. In many instances, such as in the context of cash payments, this term is clear. However, there exist many forms of compensation that may take place in relation to investment activities. For example, directing brokerage to a particular broker, purchase of services from a vendor that provides consulting services to a retirement board as well as payment for attending conferences sponsored by such a vendor, all must be disclosed. In addition, compensation includes shares of portfolio companies, shares of carried interest, limited partner status and other similar arrangements. Recently, some managers have initiated compensation in the form of political and/or charitable contributions made in response to requests by potential or existing investors or their representatives. Any such contributions must be disclosed.
PERAC has also received filings stating that in some instances parties may receive ".... an economic interest in the partnership which will serve as general partner to the Partnership." In some cases these interests have been provided to "Certain Principals" of a law firm that "have also agreed to advise the
Partnership on marketing strategies..."
Vendors have also reported that "The compensation paid by the Partnership and General Partner to [law firm] will be a function of both the time devoted to the project as well as the fund's success in the
marketplace."
The details of these arrangements must be disclosed to the retirement board and PERAC each year.
In the "Compensation Received" section the exact amounts received from the retirement board must be
disclosed as well as other compensation.
In the case of Securities Litigation Service "compensation in whatever form" includes, without limitation, cash, referrals, a share of the amount recovered through litigation and any other consideration provided to others or received with respect to you or your firm's representation of the retirement board. Any compensation paid in connection with the initial selection of you or your firm by the retirement board or as lead counsel in a case must also be disclosed.
2/3
Please contact Thomas O'Donnell, Compliance Officer or Derek Moitoso, Compliance Counsel at (617)
666-4446 if you have any questions or concerns. For amendments to any information regarding this relationship, please email the Contact Change Form to Cheryl Johnson, Compliance/Investment Data Coordinator, at cljohnson@per.state.ma.us. That form can
be found on the PERAC website at https://www.mass.gov/files/documents/2016/03/xe/c-4287.pdf.
Sincerely,
John W. Parsons, Esq.
Executive Director
Public Employee Retirement Administration Commission
5 Middlesex Ave., Suite 304
Somerville, MA 02145
CONFIDENTIALITY NOTICE This electronic message and any attachments are intended only for the addressee(s) and contains information that may be privileged and confidential. If you are not the intended recipient, please notify the sender by reply email and immediately delete this message. Use, disclosure or
reproduction of this email by anyone other than the intended recipients) is strictly prohibited. Thank you. This message is sent by an automated email system. Please do not reply to this email message as this mailbox
is not monitored.
**** Confidentiality Note: Boston Advisors, LLC archives and monitors outgoing and incoming e-mails. This message and any attachments may contain legally privileged and/or confidential information. Any unauthorized disclosure, use or dissemination of this e-mail message or its contents, either in whole or in part, is prohibited. If you are not the intended recipient of this e-mail message, kindly notify the
sender and then destroy it. ****
3/3
From PERAC Help Desk<support@perac.freshdesk.com>
Date Tue 4/14/20206:50 PM
To stephen.feenan@bmo.com <stephen.feenan@bmo.com>; Johnson, Cheryl L. (PER) <Cheryl.Johnson@MassMail.State.MA.US>; Morrison, Rose A. (PER) < rose.a.morrison@mass.gov>; PER-DL-
ProsperHelp <PER-DL-ProsperHelp@MassMail.State.MA.US>
Cc
gregory.dow@bmo.com <gregory.dow@bmo.com>; PER-DL-Compliance <PER-DL-
Compliance@MassMail.State.MA.US>
CAUTION: This email originated from a sender outside of the Commonwealth of Massachusetts mail system. Do not click on links or open attachments unless you recognize the sender and know the
content is safe.
There is a new comment in the ticket submitted by O'Donnell, Thomas J (PER) to PERAC
Comment added by : O'Donnell, Thomas J (PER)
Comment Content:
They have 1 acount with Danvers. i will deal with them tomorrow.
Tom
From: Morrison, Rose A. (PER)
Sent: Tuesday, April 14, 2020 6:48 PM
To: PERAC Help Desk
Cc: O'Donnell, Thomas J. (PER); Johnson, Cheryl L. (PER)
Subject: Re: New comment - [#5780] Re: New PERAC User Registration : [eric.mandell@bmo.com]
Hello All.
I see Eric Mandell's name under the contacts but he is listed as "Primary". Does he have to be listed as
"Disclosure"?
Something is happening with PROSPER on my end so I can't get any further than seeing his contact type.
Rose
From: PERAC Help Desk <support@perac.freshdesk.com>
Sent: Tuesday, April 14, 2020 6:12 PM
To: gregory.dow@bmo.com; PER-DL-Compliance
Cc: PER-DL-ProsperHelp; O'Donnell, Thomas J. (PER) Subject: New comment - [#5780] Re: New PERAC User Registration :
[eric.mandell@bmo.com]
CAUTION: This email originated from a sender outside of the Commonwealth of Massachusetts mail system. Do not click on links or open attachments unless you recognize the sender and know the
content is safe.
1/4
There is a new comment in the ticket submitted by O'Donnell, Thomas J (PER) to PERAC
Comment added by : Feenan, Stephen
Comment Content:
Hi All,
Myself and a number of my colleagues have been unable to access the website via the web links
sent to eric.mandell@bmo.com
Is there an alternative option?
Thank you,
Stephen Feenan | Senior Associate | Client Relationship Management ||
BMO Global Asset Management | 115 South LaSalle Street | Chicago, IL 60603
Email: Stephen.Feenan@bmo.com
Office: 312.461.2215
Visit us at www.bmogam.com
From: PERAC Help Desk [mailto:support@perac.freshdesk.com]
Sent: Monday, April 13, 2020 2:30 PM
To: thomas.j.o'donnell@state.ma.us Cc: Dow, Gregory; Feenan, Stephen; per-dl-prosperhelp@massmail.state.ma.us; per-di-
compliance@massmail.state.ma.us; thomas.j.o'donnell@state.ma.us
Subject: Re: Re: New PERAC User Registration : [eric.mandell@bmo.com]
We have sent a new registration email to:
eric.mandell@bmo.com Please be advised that only the most recent link will work. If you try to click any of the
older links, you will get the error that the link has expired.
Please let us know if you need further assistance.
Thanks,
PERAC Help Desk
Ticket: https://perac.freshdesk.com/public/tickets/442279dea1fdb02535fa8d625476fceb
7bdd6a738da104640b453a9c0ed33319
On Mon, 13 Apr at 3:25 PM, Feenan, Stephen
<stephen.feenan@bmo.com> wrote:
Good Afternoon,
The registration link in the attached email does not work or is invalid, can
you please confirm or resend?
Thank you,
Stephen Feenan | Senior Associate | Client Relationship Management |
BMO Global Asset Management | 115 South LaSalle Street | Chicago, IL
60603
Email: Stephen.Feenan@bmo.com
Office: 312.461.2215
Visit us at www.bmogam.com
2/4
From: PERAC Help Desk
[mailto:support@perac.freshdesk.com]
Sent: Monday, April 13, 2020 1:32 PM
To: thomas.j.o'donnell@state.ma.us Cc: Dow, Gregory; Feenan, Stephen; per-di- prosperhelp@massmail.state.ma.us; per-di-
compliance@massmail.state.ma.us Subject: Re: Re: New PERAC User Registration :
[eric.mandell@bmo.com]
We have sent a new registration email to:
eric.mandell@bmo.com
Please let us know if you need further assistance.
Thanks,
PERAC Help Desk
Ticket: https://perac.freshdesk.com/public/tickets/442279dea
1fdb02535fa8d625476fceb7bdd6a738da104640b453a9c0ed
33319
On Mon, 13 Apr at 2:16 PM, Feenan, Stephen
<stephen.feenan@bmo.com> wrote:
Good Afternoon,
Can you please provide an updated
registration link.
Thank you,
Stephen Feenan | Senior Associate | Client
Relationship Management |
BMO Global Asset Management | 115 South
LaSalle Street | Chicago, IL 60603
Email: Stephen.Feenan@bmo.com
Office: 312.461.2215
Visit us at www.bmogam.com
From: perac-
mailing@per.state.ma.us
[mailto: perac-
mailing@per.state.ma.us] Sent: Monday, January 27, 2020
11:33 AM
To: Mandell, Eric
Subject: New PERAC User
Registration :
[eric.mandell@bmo.com]
Importance: High
External Email: Use caution with links
and attachments. | Couriel externe : Faites preuve de prudence en ce qui a trait
aux liens et aux pieces jointes.
Dear Eric Mandell,
You have been invited to PERAC.
3/4
Follow this link to complete your
registration.
https://prosper.perac.state.ma.us/
Account/Register/hABbAF&AOgA
DAAMAtgDuAPcABwDqAKsAmw
CYAEIADAA%3d
CONFIDENTIALITY NOTICE This electronic message and any attachments are intended only for the addressee(s) and contains information that may
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is not monitored.
PERAC powered by Freshdesk
PERAC powered by Freshdesk
PERAC powered by Freshdesk
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Use, disclosure or reproduction of this email by anyone other than the intended recipients) is strictly prohibited. Thank you.
PERAC powered by Freshdesk
4/4
Pi-014-2020-2-11-to-2020-2-10-New comment - [#5413] FW RE 2019
New comment - [#5413] FW: RE: 2019 Annual Vendor Disclosures
From PERAC Help Desk <support@perac.freshdesk.com>
Date Tue 2/11/2020 9:58 AM To PER-DL-Compliance <PER-DL-Compliance@ MassMail.State.MA.US>; PER-DL-MIS < PER-DL-
MIS2 @MassMail.State.MA.US>; ODonnell, Thomas J. (PER) <Thomas.J.ODonnell@mass.gov>
Cc
PER-DL-ProsperHelp <PER-DL-ProsperHelp@MassMail.State.MA.US>; ODonnell, Thomas J. (PER)
<Thomas.J.ODonnell@mass.gov>
There is a new comment in the ticket submitted by O'Donnell, Thomas J (PER) to PERAC
Comment added by : Ross Hagan
Comment Content:
Hi Tom,
That would do it! Thanks for clarifying.
As far as Regulatory Compliance, please see below:
Primary contact:
Kate Trevor
Senior Vice President
ktrevor@incomeresearch.com
(617) 330 - 6676
Responsible for all annual filings: Boston Retirement System, Bristol County Retirement System, Cambridge Retirement System, Franklin Regional Retirement System, Haverhill Retirement System, Norfolk County Retirement System, Plymouth County Retirement System, Watertown Contributory Retirement System, Westfield Contributory Retirement System, City of Worcester
Retirement System.
Secondary contact:
Leonie Siragusa
Vice President
Lsiragusa@incomeresearch.com
(617) 330 - 6857
I'll be sure to let Jack know! Thanks again,
Ross Hagan
Senior Legal Analyst
INCOME RESEARCH + MANAGEMENT
100 FEDERAL STREET, 30TH FLOOR, BOSTON, MA 02110
PHONE (617) 330-9333 - FAX (617) 330-9222
www.incomeresearch.com
1/6
P+l Email Logo 2019 - Final
From: O'Donnell, Thomas J (PER) [mailto:thomas.j.o'donnell@state.ma.us]
Sent: Monday, February 10, 2020 5:44 PM
To: Ross Hagan <rhagan@incomeresearch.com> Cc: PER-DL-ProsperHelp <PER-DL-ProsperHelp@MassMail.State.MA.US>; PER-DL-Compliance <PER-
DL-Compliance@MassMail.State.MA.US>; PER-DL-MIS <PER-DL-MIS2 @MassMail.State.MA.US>
Subject: FW: RE: 2019 Annual Vendor Disclosures
Hello Ross,
Thank you for this message. I believe the problem is that the address changed from " per." to "perac-mailing@per.state.ma.us". IT does that to "keep us on our toes". Miss steaks happen, your secret is safe with me!
Please have IRM's regulatory unit provide names, titles, phone numbers and specific instructions on account assignments. In future you will be able to edit this information from your Portal but we are not there yet. PERAC will make the necessary edits. Please give young
Jack Somers my best regards.
Take care,
Tom
Thomas J. O'Donnell
Compliance Director
Public Employee Retirement Administration Commission
5 Middlesex Avenue
Suite 304
Somerville, MA 02145
617-666-4446 Ext. 922
tjodonnell@per.state.ma.us
www.mass.gov/perac
Subscribe to our email list to receive PERAC updates
From: Ross Hagan <rhagan@incomeresearch.com>
Sent: Monday, February 10, 2020 4:52 PM
To: O'Donnell, Thomas J. (PER) <Thomas.ODonnell@MassMail.State.MA.US>
Subject: FW: RE: 2019 Annual Vendor Disclosures
Tom,
As discussed, the kick-back email is below. I'II follow-up with the details on a designated point person under separate cover.
Best,
Ross Hagan
Senior Legal Analyst
INCOME RESEARCH + MANAGEMENT
100 FEDERAL STREET, 30TH FLOOR, BOSTON, MA 02110|
PHONE (617) 330-9333 - FAX (617) 330-9222
www.incomeresearch.com
2/6
P+| Email Logo 2019 - Final
From: postmaster@MassMail.State.MA.US (mailto:postmaster@MassMail.State.MA.US]
Sent: Monday, February 10, 2020 4:20 PM
To: Ross Hagan
Subject: Undeliverable: RE: 2019 Annual Vendor Disclosures
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From: Ross Hagan <rhagan@incomeresearch.com>
To: "per-mailing@per.state.ma.us" < per-mailing@per.state.ma.us>
CC: Regulatory Compliance <RegulatoryCompliance@incomeresearch.com>
Subject: RE: 2019 Annual Vendor Disclosures
Thread-Topic: 2019 Annual Vendor Disclosures
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Date: Mon, 10 Feb 2020 21:19:27 +0000
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Disclaimer THIS MESSAGE IS INTENDED ONLY FOR THE USE OF THE INDIVIDUAL ENTITY TO WHICH IT IS ADDRESSED AND MAY CONTAIN INFORMATION THAT IS PRIVILEGED, CONFIDENTIAL, AND EXEMPT FROM DISCLOSURE. If the reader of this message is not the intended recipient or an employee or agent responsible for delivering the message to the intended recipient, you are hereby notified that any dissemination, distribution or copying of
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5/6
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PERAC powered by Freshdesk
6/6
Pi-015-2019-10-18-to-9-18-MYSS-Wainwright
Outlook
RE: MYSS/Wainwright
From Paul Perdigao <pperdigao@winvcounsel.com >
Date Fri 10/18/2019 11:44 AM
To Colon, Veronica (PER) < veronica.colon@mass.gov>
We do consult for Saugus which is being reported by People's United Bank.
A majority of our Mass State clients are at People's United.
Paul Perdigao
Wainwright Investment Counsel, LLC
One Boston Place 41st Floor
Boston, MA 02108
Phone: 617 531-3131
Fax: 617 531-3140
From: Colon, Veronica (PER) <veronica.colon@state.ma.us>
Sent: Friday, October 18, 2019 11:15 AM
To: Paul Perdigao <pperdigao@winvcounsel.com>
Subject: RE: MYSS/Wainwright
Paul - Just to be clear and not misunderstand you, you are no longer Saugus R.B. consultant or you are
but the reports come from Anthony at People's United Bank?
From: Paul Perdigao [mailto:pperdigao@winvcounsel.com]
Sent: Friday, October 18, 2019 10:19 AM
To: Colon, Veronica (PER)
Subject: RE: MYSS/Wainwright
Veronica,
The only State Street account we have at Wainwright that you would need is Norfolk County which I believe you
have access to their website.
If not, then I can send the September report to you once it has been completed.
Let me know.
Paul Perdigao
Wainwright Investment Counsel, LLC
One Boston Place 41st Floor
Boston, MA 02108
Phone: 617 531-3131
Fax: 617 531-3140
1/5
From: Colon, Veronica (PER) <veronica.colon@state.ma.us>
Sent: Friday, October 18, 2019 9:34 AM
To: Paul Perdigao <pperdigao@winvcounsel.com>
Subject: RE: MYSS/Wainwright
Importance: High
10/18/2019
Hi Paul,
Hope all is well. Would you be submitting quarterly performance reports from Wainwright format not
People's United Bank? Look forward to hear from you soon. Have a nice day and weekend!
Sincerely,
Veronica
From: Paul Perdigao [mailto:pperdigao@winvcounsel.com]
Sent: Wednesday, September 18, 2019 3:21 PM
To: Colon, Veronica (PER)
Subject: RE: MYSS/Wainwright
Veronica,
With the exception of Norfolk County, we do not use State Street's services on the other Mass Pension accounts.
Let me know if I can help in any way.
Paul Perdigao
Wainwright Investment Counsel, LLC
One Boston Place 41St Floor
Boston, MA 02108
Phone: 617 531-3131
Fax: 617 531-3140
From: Colon, Veronica (PER) <veronica.colon@state.ma.us>
Sent: Wednesday, September 18, 2019 3:01 PM
To: Paul Perdigao <pperdigao@winvcounsel.com>
Subject: RE: MYSS/Wainwright
Paul - Since they were receiving some services from you (Wainwright), I thought you would use that
same software to provide their report. If not, please let me know. Thanks - Veronica
From: Paul Perdigao [mailto:pperdigao@winvcounsel.com]
Sent: Wednesday, September 18, 2019 2:55 PM
2/5
To: Colon, Veronica (PER)
Subject: RE: MYSS/Wainwright
Veronica,
Peoples United is the custodian for Saugus so State Street would not have this information.
If you'd like, I can forward your message on to Tony Teberio at People's.
Paul Perdigao
Wainwright Investment Counsel, LLC
One Boston Place 41st Floor
Boston, MA 02108
Phone: 617 531-3131
Fax: 617 531-3140
From: Colon, Veronica (PER) <veronica.colon@state.ma.us>
Sent: Wednesday, September 18, 2019 8:11 AM
To: Ann Quinlan <aquinlan@saugusretirement.org> Cc: StateStreet-PerformanceServices <StateStreet-PerformanceServices@StateStreet.com>; Paul Perdigao
<pperdigao@winvcounsel.com>; Luong, Jam <JLuong@StateStreet.com>; Stoychev, Stefan
<SStoychev@StateStreet.com>; Gus Aristizabal <garistizabal@winvcounsel.com>
Subject: RE: MYSS/Wainwright
Importance: High
9/18/2019
Hi Ann, Hope all is well. Could you add Saugus to MYSS portal to retrieve the monthly/quarterly report as I do
for all Wainwright clients? If not, please request for Paul to add me to the distribution list of the reports.
Look forward to hear from you soon. Have a nice day and week.
Sample of MYSS e-mail:
Information Classification: Limited Access
Your reporting from the GS Performance Services team is now available on https://my.statestreet.com.
Please reach out to your GS Performance Services contact with any questions - Staychev, Stefan -
sStoychev@StateStreet.comor617-662-3346.
This email is generated from a mailbox that does not receive incoming messages.
Thanks and Regards,
State Street Global Services | Performance Services CONFIDENTIALITY NOTICE The information contained in this email and any attachments have been classified as limited access andior privileged State Street informationin communication and are intended solely for the use of the named addressees) Ityou ire not an intended recipient of a person responsible for delivery to an intended recipient, please notity the author and destroy tnis emall. Any snauthorized copying, disclosure, retention or distribution of the malecial in this email is stricty forbidden. Thank
you
CONRDENTIAL
Sincerely,
3/5
Veronica Colon
Veronica Colon, Fund Accountant
Investment Unit
PERAC (Public Employee Retirement Administration Commission)
5 Middlesex Avenue
Third Floor, Suite 304
Somerville, MA 02145
Ph (617) 666-4446 Ext. 926
Main Fax (617) 628-4002
General Fax (617) 628-4414-My location
Email: recolon@per.state.ma.us Veronica. Colon@Massmail.State.MA.US, veronica.colon@state.ma.us
Website: www.mass.gov/perac
Pooled Fund Worksheet Link: https://www.mass.gov/forms/pooled-fund-worksheet
* Please consider the environment before printing this email
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email by anyone other than the intended recipients) is strictly prohibited. Thank you. This message is intended only for the use of the individual or entity to which it is addressed, and may contain proprietary information that is privileged, confidential and exempt from disclosure under applicable law. If the reader of this message is not the intended recipient, please be aware that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify the sender and delete the original message from any
computer/e-mail device. Thank you.
CONFIDENTIALITY NOTICE This electronic message and any attachments are intended only for the addressee(s) and contains information that may be privileged and confidential. If you are not the intended recipient, please notify the sender by reply email and immediately delete this message. Use, disclosure or reproduction of this
email by anyone other than the intended recipients) is strictly prohibited. Thank you. This message is intended only for the use of the individual or entity to which it is addressed, and may contain proprietary information that is privileged, confidential and exempt from disclosure under applicable law. If the reader of this message is not the intended recipient, please be aware that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify the sender and delete the original message from any
computer/e-mail device. Thank you.
4/5
CONFIDENTIALITY NOTICE This electronic message and any attachments are intended only for the addressee(s) and contains information that may be privileged and confidential. If you are not the intended recipient, please notify the sender by reply email and immediately delete this message. Use, disclosure or reproduction of this
email by anyone other than the intended recipients) is strictly prohibited. Thank you. This message is intended only for the use of the individual or entity to which it is addressed, and may contain proprietary information that is privileged, confidential and exempt from disclosure under applicable law. If the reader of this message is not the intended recipient, please be aware that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify the sender and delete the original message from any
computer/e-mail device. Thank you.
5/5
Pi-016-2019-5-22-RE Assistance
RE: Assistance
From O'Donnell, Thomas J. (PER) <Thomas.J.ODonnell@mass.gov>
Date Wed 5/22/2019 11:27 AM
To
Daniele, Francesco <FDaniele@mapension.com>
U 5 attachments (4 MB)
srbsaristotleevaluation.pdf; srblmcgeval.pdf, srarhumpassivecorebond.pdf; sralcappassiveeval.pdf;
sraacknowledgementdocument.pdf;
Hello Francesco,
Here are the product evaluations prepared by consultant as submitted to PERAC. I suggest you read the
Acknowledgement document, it offers clarity on PERAC's role in procurement process.
Keep under your toga please!
Take care,
Tom
From: Daniele, Francesco [mailto:FDaniele@mapension.com]
Sent: Wednesday, May 22, 2019 9:52 AM
To: O'Donnell, Thomas J. (PER)
Subject: Assistance
Importance: High
HI Tom,
Great catching up with you!
Regarding Saugus, could you provide more specific details as to specific strategy within each asset class.
I believe
I have the amounts correct, but please advise.
$5.7 Million US LARGE Cap-https://www.rhumblineadvisers.com/products/largecap.htm
$7.2 Million FIXED Income-https://www.rhumblineadvisers.com/products/fixedincome.htm
$6.3 Million Mid Cap-http://www.lmcg.com/individual-investors/us-equity/
$ 6.7 Million Small Cap - https://www.aristotlecap.com/aristotle-boston/
Thank you in advance.
Francesco
Francesco Daniele
Senior Client Services Officer
1/2
PENSION RESERVES INVESTMENT
MANAGEMENT BOARD
84 State Street, Second Floor
Boston, MA 02109
Office 617-946-8416
E-mail: fdaniele@mapension.com
2/2
Pi-017-2019-3-28-RE PERAC fund of funds guidelines
RE: PERAC fund of funds guidelines
From O'Donnell, Thomas J. (PER) <Thomas.J.ODonnell@mass.gov>
Date Thu 3/28/2019 5:19 PM
To Ghiane Jones <gjones@meketagroup.com>
Cc PER-DL-Compliance <PER-DL-Compliance@MassMail.State.MA.US>
1 attachment (2 MB)
FundofFundViewMemo.pdf;
Ghiané
I believe this is the latest memorandum on the subject. Let me know if you have questions or need additional material.
Take care,
Tom
Thomas J. O'Donnell
Compliance Officer
Public Employee Retirement Administration Commission
5 Middlesex Avenue
Suite 304
Somerville, MA 02145
617-666-4446 Ext. 922
tjodonnell@per.state.ma.us
www.mass.gov/perac
From: Ghiane Jones [mailto:gjones@meketagroup.com]
Sent: Thursday, March 28, 2019 4:21 PM
To: O'Donnell, Thomas J. (PER)
Subject: PERAC fund of funds guidelines
Dear Mr. O'Donnell,
l've been researching the latest fund of funds guidelines for PERAC, but it looks like they are no longer posted on
the website.
Can you please assist me with locating these guidelines?
Thank you,
Ghiané
Ghiané Jones
Vice President, Consultant
1/2
Meketa Investment Group, Inc.
One East Wacker Drive, Suite 1210
Chicago, IL 60601
(312) 474-0900
gjones@meketagroup.com
www.meketagroup.com
This message, including any attachments, may contain information that is confidential or privileged, and is intended only for the addressee(s). If you are not the intended recipient, you are hereby notified that any use, dissemination, distribution, printing, copying, or disclosure of this information is strictly prohibited. If you
received this message in error, please delete it from your system and notify the sender immediately by return email or by calling (781) 471-3500.
2/2
Pi-018-2019-3-15-to-2019-3-14-FW_ MA Consultant RFP's
From:O"Donnell, Thomas I. (PER)
To:Moitoso, Derek M. (PER)
Subject:FW: MA Consultant RFP"'s
Date:Friday, March 15, 2019 10:33:58 AM
Attachments:2017 MA Consultant Comparison QUINCY xlsx
2017 MA Consultant Comparison MHFA.x/sx
2017 MA Consultant Comparison FALMOUTH.x/sx
From: Greg McNeillie [mailto:greg@dahab.com]
Sent: Thursday, March 14, 2019 12:41 PM
To: O'Donnell, Thomas J. (PER)
Subject: MA Consultant RFP's
These searches are starting to become somewhat of a joke. MHFA 2017 returns ranked #100 (5 year) and #94 (10 year) and rumor has it they stayed with Meketa. Quite a similar
story with Quincy...
At some point returns are actually going to have to mean something. If their returns were anywhere near decent I could understand...Falmouth for example has very good returns and I
don't see any reason why they would leave Wainwright.
I don't know why I am wasting my time...
--
Gregory A. McNeillie
Vice Chairman, Principal
Dahab Associates, Inc.
31 Hayward Street, Suite C-3
Franklin, MA 02038
Office 508-520-3800
Cell 508-498-7143
The information contained in this message may be privileged and confidential and protected from disclosure. If the reader of this message is not the intended recipient, or an employee or agent responsible for delivering this message to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify the sender immediately by replying to the message and then
delete it; do not act upon, print, disclose, copy, retain or redistribute any information in this email.
The information contained in this message may be privileged and confidential and protected from disclosure. If the
reader of this message is not the intended recipient, or an employee or agent responsible for delivering this message
Pi-019-2019-3-13-to-2018-10-16-RE Unigestion - Opportunity to Meet
RE: Unigestion - Opportunity to Meet
From O'Donnell, Thomas J. (PER) <Thomas.J.ODonnell@mass.gov>
Date Wed 3/13/2019 2:20 PM
To Bob Meikleham < bmeikleham@unigestion.com>
I'll be here till 6:00
From: Bob Meikleham [mailto:bmeikleham@unigestion.com]
Sent: Wednesday, March 13, 2019 2:18 PM
To: O'Donnell, Thomas J. (PER)
Subject: RE: Unigestion - Opportunity to Meet
Great, is there a time after 3:00 pm that works for you? We have another meeting in the Financial District that
should finish at 3:00.
Best,
Bob
→ UNIGESTION®
Bob Meikleham
Vice President
US Institutional
Business Development
Dir. +1 (201) 714 2415
Fax. +1 (201) 714 2401
Mob. +1 (201) 705 2105
bmeikleham@unigestion.com
Unigestion (US), Ltd
Plaza 10 - Harborside Financial Center Suite 203
Jersey City, NJ 07311
Tel. +1 (201) 714 2400
Fax. +1 (201) 714 2401
www.unigestion.com
Follow Unigestion on LinkedIn.
From: O'Donnell, Thomas J (PER) <thomas.j.o'donnell@state.ma.us>
Sent: Wednesday, March 13, 2019 14:14
To: Bob Meikleham < bmeikleham@unigestion.com>
Subject: RE: Unigestion - Opportunity to Meet
Bob,
That day is ok - Afternoon better.
Take care,
Tom Thomas J. O'Donnell
Compliance Officer
Public Employee Retirement Administration Commission
5 Middlesex Avenue
Suite 304
Somerville, MA 02145
617-666-4446 Ext. 922
tjodonnell@per.state.ma.us
www.mass.gov/perac
From: Bob Meikleham [mailto:bmeikleham@unigestion.com]
Sent: Wednesday, March 13, 2019 2:10 PM
To: O'Donnell, Thomas J. (PER)
Subject: RE: Unigestion - Opportunity to Meet
Tom,
I will now only be in Boston next Thursday, March 21st
, but would look forward to the opportunity to sit down with
you if you have some availability on the day.
Have a great day,
Bob
→ UNIGESTION®
Bob Meikleham
Vice President
US Institutional
Business Development
Dir. +1 (201) 714 2415
Fax. +1 (201) 714 2401
Mob. +1 (201) 705 2105
bmeikleham@unigestion.com
Unigestion (US), Ltd
Plaza 10 - Harborside Financial Center Suite 203
Jersey City, NJ 07311
Tel. +1 (201) 714 2400
Fax. +1 (201) 714 2401
www.unigestion.com
Follow Unigestion on Linkedin.
2/7
From: Bob Meikleham
Sent: Friday, March 08, 2019 09:57
To: thomas.j.o'donnell@state.ma.us
Subject: RE: Unigestion - Opportunity to Meet
Tom,
I hope everything went OK with the knee last week and you're on the road to recovery. We talked about this quickly
last week but I wanted to check and see if you had a clearer picture regarding your schedule March 20th or 21st.
I'll be back in Boston with a member of my firm's PE team and am wondering if you have time to meet.
Look forward to hearing from you,
Bob
» UNIGESTION®
Bob Meikleham
Vice President
US Institutional
Business Development
Unigestion (US), Ltd
Plaza 10 - Harborside Financial Center Suite 203
Jersey City, NJ 07311
Dir. +1 (201) 714 2415
Fax. +1 (201) 714 2401
Tel. +1 (201) 714 2400
Fax. +1 (201) 714 2401
Mob. +1 (201) 705 2105
bmeikleham@unigestion.com
www.unigestion.com
3/7
Employee of Unigestion and Registered Representative with Foreside Global Services, LLC. Unigestion and Foreside Global Services, LLC are
From: Bob Meikleham <bmeikleham@unigestion.com>
Sent: Friday, February 15, 2019 08:18
To: thomas.j.o'donnell@state.ma.us
Subject: RE: Unigestion - Opportunity to Meet
Tom,
I got your voicemail regarding February 27th. Thank you for making yourself available. It sounded like
early afternoon works for you, if so I will send you a calendar invite for 1:30 PM.
Would you like to meet at your offices or is there somewhere else you would prefer.
Look forward to speaking with you,
Bob
Bob Meikleham
Vice President, US Institutional
Tel. +1 (201) 714 2415
Fax. +1 (201) 714 2401
Mob. +1 (201) 705 2105
Unigestion (US), Ltd
Plaza 10 - Harborside Financial Center Suite 203
Jersey City, NJ 07311
Tel. +1 (201) 714 2400
Fax. +1 (201) 714 2401
Follow Unigestion on Linkedin
https://www.linkedin.com/company/unigestion Unigestion: Institutional Fund Manager of the Year, Global Investor Unigestion: Asset Management Firm of the Year (< €20bn), Funds Europe
https://www.unigestion.com/awards/
From: Bob Meikleham
Date: February 14, 2019 at 2:10:38 PM EST
To: thomas.j.o'donnell@state.ma.us
Subject: RE: Unigestion - Opportunity to Meet
Tom,
I hope all is well. My name is Bob Meikleham, and I was referred to you via my old colleague Ken Hedgebeth. You and I shared some back and forth last year regarding a potential meeting but were unable align calendars. I will be in Boston several times over the next month and was wondering if you had any availability February 27th or
March 20 - 21st
If these dates do not work, maybe we could find a day to speak briefly over the phone. I would look forward to the opportunity to better understand the role of PERAC so that my firm can appropriately market to Public Plans in
Massachusetts.
I look forward to hearing from you,
Bob
4/7
UNIGESTION®
Bob Meikleham
Vice President
US Institutional
Business Development
Dir. +1 (201) 714 2415
Fax. +1 (201) 714 2401
Mob. +1 (201) 705 2105
bmeikleham@unigestion.com
InFollow Unigestion on LinkedIn.
Unigestion (US), Ltd
Plaza 10 - Harborside Financial Center Suite 203
Jersey City, NJ 07311
Tel. +1 (201) 714 2400
Fax. +1 (201) 714 2401
www.unigestion.com
lunds toon
anard 2918
Estopean Alternative Investment
Manager of the Ye Awards
2018*
2019 Momingstar Belgium Awards
Beat Equity Find Ficuse
European Pensions
ADS 2013
WINNER Private Equty Manager
of the Year Employee of Unigestion and Registered Representative with Foreside Global Services, LLC. Unigestion and
Foreside Global Services, LLC are not affiliates.
From: Bob Meikleham
Sent: Monday, October 22, 2018 10:51
To: O'Donnell, Thomas J (PER)
Subject: RE: Unigestion - Opportunity to Meet October 22 & 23
Tom, Hopefully you had a nice weekend and are enjoying the day off. I received a confirmation from Chris Bodtker, the Chairman of our Private Equity Investment Committee, that he will be available in Boston on Friday, November
9th.
. Would you be able to meet on that day? We are flexible on timing.
Best,
Bob
UNIGESTION®
Bob Meikleham
Vice President
US Institutional
Business Development
Dir. +1 (201) 714 2415
Fax. +1 (201) 714 2401
Mob. +1 (201) 705 2105
bmeikleham@unigestion.com
Unigestion (US), Ltd
Plaza 10 - Harborside Financial Center Suite 203
Jersey City, NJ 07311
Tel. +1 (201) 714 2400
Fax. +1 (201) 714 2401
www.unigestion.com
Follow Unigestion on LinkedIn.
5/7
10/15/25, 9:12 AM
GLOBAL INVESTOR
GROUP
2017
AWARDS
Boutique Asset
Manager of the Year
Unigestion
WARDS
WINNER
INNOVATION AWARD
From: O'Donnell, Thomas J (PER)
Sent: Tuesday, October 16, 2018 12:44
To: Bob Meikleham
Subject: RE: Unigestion - Opportunity to Meet October 22 & 23
Hello Bob,
I will be happy to meet you. I am planning to be out of the office on the 215t and 22nd Please let me know when you will be here next and I'll be happy to meet with you. Please give Ken my
best regards.
Take care,
Tom
Thomas J. O'Donnell
Compliance Officer
Public Employee Retirement Administration Commission
5 Middlesex Avenue
Suite 304
Somerville, MA 02145
617-666-4446 Ext. 922
tjodonnell@per.state.ma.us
www.mass.gov/perac
From: Bob Meikleham [mailto:bmeikleham@unigestion.com]
Sent: Tuesday, October 16, 2018 12:03 PM
To: O'Donnell, Thomas J. (PER)
Subject: Unigestion - Opportunity to Meet October 22 & 23
Good afternoon Tom, My name is Bob Meikleham with Unigestion, a Swiss Geneva-based asset manager. My friend and former colleague Ken Hedgebeth recommended I reach out to you as we have continued to expand our private equity
marketing efforts across Massachusetts. I will have the Chairman of our Private Equity Investment Committee with me in Boston on Monday, October 22 and Tuesday, October 23 and I was wondering if we can meet with you to learn your thoughts on the private
equity space and to simply introduce our firm and a couple of our best ideas to you.
I look forward to hearing if you have the opportunity to meet with us on Monday 10/22 or Tuesday 10/23.
Thank you for your consideration. Best,
Bob
→ UNIGESTION®
Bob Meikleham
Vice President
US Institutional
Business Development
Dir. +1 (201) 714 2415
Fax. +1 (201) 714 2401
Mob. +1 (201) 705 2105
bmeikleham@unigestion.com
about:blank?windowld=SecondaryReadingPane22
Unigestion (US), Ltd
Plaza 10 - Harborside Financial Center Suite 203
Jersey City, NJ 07311
Tel. +1 (201) 714 2400
Fax. +1 (201) 714 2401
www.unigestion.com
6/7
in Follow Unigestion on LinkedIn. GLOBAL INVESTOR
GROUP
2017
AWARDS
Boutique Asset
Manager of the Year
Unigestion
WARDS
2017
WINNER
INNOVATION AWARD
This email and any files transmitted with it is confidential and may be legally privileged. It is intended solely for the addressee. If you are not the intended recipient, please destroy this e-mail and notify us
immediately. Any disclosure, copying or distribution of this e-mail is prohibited and may be unlawful. There are risks in communicating by c-mail. E-mails may be susceptible to data corruption, delay, interception and unauthorized amendment and neither Unigestion nor any of its subsidiaries or affiliates
do accept liability for any such corruption, delay, interception or amendment or their consequences.
************************www.unigestion.com************************ CONFIDENTIALITY NOTICE This electronic message and any attachments are intended only for the addressee(s) and contains information that may be privileged and confidential. If you are not the intended recipient, please notify the sender by reply email and immediately delete this message. Use, disclosure or reproduction of this
email by anyone other than the intended recipients) is strictly prohibited. Thank you. This email and any files transmitted with it is confidential and may be legally privileged. It is intended solely for the addressee. If you are not the intended recipient, please destroy this e-mail and notify us
immediately. Any disclosure, copying or distribution of this e-mail is prohibited and may be unlawful. There are risks in communicating by e-mail. E-mails may be susceptible to data corruption, delay, interception and unauthorized amendment and neither Unigestion nor any of its subsidiaries or affiliates
do accept liability for any such corruption, delay, interception or amendment or their consequences.
************************www.unigestion.com************************ CONFIDENTIALITY NOTICE This electronic message and any attachments are intended only for the addressee(s) and contains information that may be privileged and confidential. If you are not the intended recipient, please notify the sender by reply email and immediately delete this message. Use, disclosure or reproduction of this
email by anyone other than the intended recipients) is strictly prohibited. Thank you. This email and any files transmitted with it is confidential and may be legally privileged. It is intended solely for the addressee. If you are not the intended recipient, please destroy this e-mail and notify us
immediately. Any disclosure, copying or distribution of this e-mail is prohibited and may be unlawful. There are risks in communicating by e-mail. E-mails may be susceptible to data corruption, delay, interception and unauthorized amendment and neither Unigestion nor any of its subsidiaries or affiliates
do accept liability for any such corruption, delay, interception or amendment or their consequences.
************************www.unigestion.com************************
7/7
Pi-020-2019-2-10-to-2019-1-28-Re Updated PERAC Contact Form_Boston Advisors, LLC
Re: Updated PERAC Contact Form_Boston Advisors, LLC
From O'Donnell, Thomas J. (PER) < Thomas.J.Donnell@mass.gov>
Date Sun 2/10/20196:05 PM
To Glynn, Evelina (Boston Advisors) < evelina.glynn@bostonadvisors.com>
Hello Evelina,
We have updated your firms contact information. I hope to have the annual vendor disclosures to Boston Advisors this week.
Thank you for your patience and cooperation.
Tom
From: Glynn, Evelina (Boston Advisors) <evelina.glynn@bostonadvisors.com>
Sent: Wednesday, February 6, 2019 12:35 PM
To: O'Donnell, Thomas J. (PER)
Subject: FW: Updated PERAC Contact Form_Boston Advisors, LLC
From: Glynn, Evelina (Boston Advisors)
Sent: Tuesday, January 29, 2019 3:47 PM
To: 'cljohnson@per.state.ma.us' <cljohnson@per.state.ma.us>
Cc: Compliance <Compliance@bostonadvisors.com>
Subject: FW: Updated PERAC Contact Form_Boston Advisors, LLC
Importance: High
Hello Cheryl,
Attached please find Boston Advisors updated Contact Form which lists our new CCO, Tim Kirwan,
and an updated email address for the Compliance Department. After this information is updated, would it be possible to push the 3 PERAC notifications to our compliance team
so we have the correct link for each of our accounts. We only received one email to date and should receive 3.
Please let me know if you need anything else.
Thank you for your help,
~ Evelina
Evelina R. Glynn
Compliance
Boston Advisors, LLC | One Liberty Square, 10th Floor | Boston, MA 02109
Office: 617.348.3158 | Fax: 617.348.0084 | Evelina.glynn@bostonadvisors.com
BOSTON ADVISORS
1/3
From: perac-mailing@per.state.ma.us [mailto:perac-mailing@per.state.ma.us]
Sent: Monday, January 28, 2019 9:49 PM
To: Kerrigan, Tanya (Boston Advisors) < tanya.kerrigan@bostonadvisors.com>
Subject: Annual Vendor Disclosure is Due
Importance: High
Dear Tanya Kerrigan:
The nature of the services that you provide either directly, as a sub-adviser, as a fund in a fund of funds or as a securities litigator in connection with the Attleboro Retirement Board requires you to make annual disclosures to the retirement board and PERAC. This Form must also be filed by those involved in the distribution of investment products to the retirement boards (placement agents, third party marketers or
those providing consulting services to those listed).
The 2018 Boston Advisors Inc. Annual Disclosure Form must be accessed, completed and submitted through this link and not sent to PERAC via email or postal mail:
https://prosper.perac.state.ma.us/VendorPortal/Form/928d9f21-a74b-4d8e-ade5-83b448a29d9d
These forms are due no later than 3/1/2019.
For detailed information about how to complete this Form please review PERA Memos #32/2018, #31/2018, #27/2015, #18/2014, and #54/2012. These can be found at https://www.mass.gov/perac-memos.
The statute requires that "
...compensation, in whatever form..." be disclosed. In many instances, such as in the context of cash payments, this term is clear. However, there exist many forms of compensation that may take place in relation to investment activities. For example, directing brokerage to a particular broker, purchase of services from a vendor that provides consulting services to a retirement board as well as payment for attending conferences sponsored by such a vendor, all must be disclosed. In addition, compensation includes shares of portfolio companies, shares of carried interest, limited partner status and other similar arrangements. Recently, some managers have initiated compensation in the form of political and/or charitable contributions made in response to requests by potential or existing investors or their representatives. Any such contributions must be disclosed.
PERAC has also received filings stating that in some instances parties may receive ".... an economic interest in the partnership which will serve as general partner to the Partnership." In some cases these interests have been provided to "Certain Principals" of a law firm that "have also agreed to advise the
Partnership on marketing strategies..."
Vendors have also reported that "The compensation paid by the Partnership and General Partner to [law firm] will be a function of both the time devoted to the project as well as the fund's success in the
marketplace."
The details of these arrangements must be disclosed to the retirement board and PERAC each year.
In the "Compensation Received" section the exact amounts received from the retirement board must be
disclosed as well as other compensation.
In the case of Securities Litigation Service "compensation in whatever form" includes, without limitation, cash, referrals, a share of the amount recovered through litigation and any other consideration provided to others or received with respect to you or your firm's representation of the retirement board. Any compensation paid in connection with the initial selection of you or your firm by the retirement board or as lead counsel in a case must also be disclosed.
2/3
Please contact Thomas O'Donnell, Compliance Officer or Derek Moitoso, Compliance Counsel at (617)
666-4446 if you have any questions or concerns. For amendments to any information regarding this relationship, please email the Contact Change Form to Cheryl Johnson, Compliance/Investment Data Coordinator, at cljohnson@per.state.ma.us. That form can
be found on the PERAC website at https://www.mass.gov/files/documents/2016/03/xe/c-4287.pdf.
Sincerely,
John W. Parsons, Esq.
Executive Director
Public Employee Retirement Administration Commission
5 Middlesex Ave., Suite 304
Somerville, MA 02145
CONFIDENTIALITY NOTICE This electronic message and any attachments are intended only for the addressee(s) and contains information that may be privileged and confidential. If you are not the intended recipient, please notify the sender by reply email and immediately delete this message. Use, disclosure or
reproduction of this email by anyone other than the intended recipients) is strictly prohibited. Thank you. This message is sent by an automated email system. Please do not reply to this email message as this mailbox
is not monitored.
**** Confidentiality Note: Boston Advisors, LLC archives and monitors outgoing and incoming e-mails. This message and any attachments may contain legally privileged and/or confidential information. Any unauthorized disclosure, use or dissemination of this e-mail message or its contents, either in whole or in part, is prohibited. If you are not the intended recipient of this e-mail message, kindly notify the
sender and then destroy it. ****
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