Ensign Peak Advisor’s investment fund, currently valued at about $44.4 billion, is back in the national news. This week, the settlement deal regarding the violation of reporting laws was released. Ensign Peak is going to pay a $4 million dollar fine and the Church will pay a $1 million dollar fine to the U.S. Securities and Exchange Commission. The money to pay the fine is coming from the investment returns. Fitting, I suppose, the Church wouldn’t want to pay that directly from tithing. I also don’t know what the distinction is between Ensign Peak making a payment and the Church making a payment. Does it come from separate bank accounts? Is this going to affect the budget to pay janitors to clean the Church buildings? (Just kidding. Five million is pocket change when your fund is worth $44 billion; we can still pay janitors. Just kidding again – the Church doesn’t pay janitors.)

Before this news story broke, I hadn’t realized that the Church was supposed to report its enormous wealth to the government. I knew the Church kept the $44B a secret from Church members, but I didn’t realize the Church was fudging the reporting laws to the SEC. In order to fudge those laws, the Church had to get separate reporting numbers for each entity. My point is, this was a deliberate decision to conceal their wealth from the government too. Some Church members have defended the Church’s concealment by saying it wasn’t dishonest. The Church didn’t lie to us; it just didn’t tell us how much money it had. But it turns out the Church was SUPPOSED TO TELL the government how much money it had, and it chose to institute a shell game instead.

“Securities laws require investment managers with control over at least $100 million in publicly traded stocks to disclose the fair market value of the assets under their management. And throughout most of its 26-year history, the SEC said, Ensign Peak was aware of this requirement to file such disclosures, known as Form 13F, and brought the rule to the attention of senior church leaders — along with a plan to get around it.” Source: Salt Lake Tribune, Feb. 22, 2023.

The plan was to create a network of shell companies, beginning with just a few but eventually creating thirteen of them, registered in different locations in the United States. The shell companies then separated out Ensign Peak’s enormous portfolio and disclosed the smaller holdings to the SEC, using names that weren’t immediately obvious as affiliated with the LDS Church. This began in 1992 and continued until 2019, when whistleblower David Nielsen filed a complaint with the IRS. The now-defunct MormonLeaks published the names of the LLCs and the size of the holdings in 2018.

The SEC brought charges against Ensign Peak, and against the Church, for deliberately creating those shell companies to conceal the size of the Church’s investment portfolio and the Church’s control of that portfolio. The fine settles the charges and closes out the SEC’s investigation.

The Salt Lake Tribune article describes how this developed. Internal Church investment managers noticed that the fund reporting was attracting attention, and took steps to conceal the amounts, to register LLCs in other states, to choose names that weren’t easily associated with the Church. All this to avoid the negative publicity that the Church feared if the size of its stock portfolio became public. Here’s a creepy allegation: “And when Ensign Peak obtained the signatures of business managers over the LLCs, it gave them only signature pages and not the complete documents.” Employees were being asked to sign documents that they weren’t allowed to read. That’s a huge red flag in corporate practices and after the MormonLeaks information became public, two of those business managers resigned in protest. They were replaced, and the pattern continued until publicity and the SEC forced the change.

Here’s something to be entirely clear about: This shell game was done with the approval and knowledge of the highest Church leaders. Internal Church auditors apparently told the higher-ups that the SEC might disagree with spreading the reporting among multiple entities. I have a hard time believing that Kirton McConkie didn’t at least suggest that this shell game skirted the line of legality (though we’ll never know for sure). Church leadership decided to take the risk. Church leadership controls Ensign Peak. Church leaders are not victims of bad legal advice or incompetent accounting staff. They knew that the SEC required reporting; they made a plan to technically report everything, but to do it in a way that broke the rules of transparency.


  1. Did you know that the Church had to take steps to actively conceal Ensign Peak’s value from the SEC?
  2. Do you think this reporting scheme is a big deal? Why or why not?
  3. Are you willing to blame this on someone besides the Q15?