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@grok I think Massachusetts citizens and investors around the world need to be worried about my PERAC discovery.
What do you think Grok, should people worry or are they safe and you think they can ignore what I found?
Felicia M. Baruffi
+
recordsrequests@sec.state.
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|
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.
⚠️
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
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.
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)
•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 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)
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.
⚠️
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
Springfield, MA
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