The $100 Billion Fund

Does the Church have a $100 billion fund?

Yes, although estimates as to the size of the fund vary from $38 billion to over $100 billion.[1] The fund is characterized by the Church as a "reserve fund"[2] managed by its investment arm,[3] Ensign Peak Advisors, Inc. (EPA).[4]

Why don't we know the exact size of the fund? Doesn't the Church have to disclose how much is in the fund?

No, not by law—most nonprofits are required to file information reports to the IRS, but this requirement does not apply to churches and their auxiliaries.[5] Church leaders and EPA managers do not publish details publicly about the reserve fund.[6]

If the Church doesn't have to disclose how much is in the fund, how do we know it's a "$100 billion fund"?

There are only two sources of information about the size of the fund[7]—one is from the SEC[8] and the other is from a former EPA employee David Nielsen[BIO] who left EPA and disassociated with the Church in 2019[9] and claimed that the EPA had wrongfully accumulated a "reserve of the reserves" of over $100 billion and contacted the IRS Whistleblower Office.[10][11]

Shortly after David Nielsen resigned, David's twin brother Lars contacted various media outlets,[12] including the Washington Post and Newsweek,[13] and since then, the "$100 Billion fund" has come up in the news from time to time.[14] See table below.

Table of Primary Sources about the Fund

Amount	Source	Publication
$81.2 billion in 2018.[15]	David Nielsen	"Memorandum of David A. Nielsen submitted to the U.S. Senate Finance Committee and its Subcommittee on Taxation and IRS Oversight," 2023[16]
$124 billion in 2019.[17]	David and Lars Nielsen	"Letter to an IRS Director," 2019[18]
$37.8 billion in 2020.[19]	SEC Order	ADMINISTRATIVE PROCEEDING File No. 3-21306 In the Matter of ENSIGN PEAK ADVISORS, INC., and THE CHURCH OF JESUS CHRIST OF LATTER-DAY SAINTS, 2023[20]
$44.4 billion in 2022.[21]	Filings to the SEC	2022 Q4, Form 13F, filed with the SEC[22]
Over $100 billion in 2023.[23]	David Nielsen	"Mormon Church Investment Fund Whistleblower," 60 Minutes, May 14, 2023[24]

Key events in the history of the Church's reserve fund

Historic Financial Troubles

1880s

Anti-polygamy laws cripple Church finances by dissolving the Church's legal identity, confiscating Church assets, and blocking the Church's ability to secure loans.[25]

1893

The Panic of 1893 worsens the Church's financial situation and it accrues between one and two million dollars of debt and is unable to make its payroll.[26]

1907

President Joseph F. Smith[BIO] announces in General Conference that the Church is out of debt and no longer needs to borrow money.[27]

1929-1939

The Great Depression (1929 – 1939) results in as much as 36% unemployment and a 49% decrease in per capita income in Utah.[28] The Church operated at a deficit during the Depression.[29]

April 1940

J. Reuben Clark[BIO] attempts to limit Church spending[30] to build a financial reserve.[31]

1959

The Church resumes borrowing money, primarily for building construction.[32]

1962-1963

Church reserves are depleted, having spent $32 million more than revenue, the Church has a cash-flow crisis and nears bankruptcy.[33]

October 4, 1963

Former businessman[34] N. Eldon Tanner[BIO] is sustained as second counselor to President David O. McKay[BIO][35] and enacts strict financial policies including maintaining a budget, saving a surplus, and spending from reserves.[36]

The Modern Era of Church Finance

1995

In the October General Conference[37], Gordon B. Hinckley[BIO] describes the Church's goal to build a reserve fund that "should there come a time of economic distress, we would hope to have the means to weather the storm."[38]

1997

Ensign Peak Advisors, Inc., (EPA) is formed to manage Church investments and is given $7 billion of Church assets to start with.[39]

2001

At EPA's suggestion, the Church creates an LLC registered in California[40] through which to file public disclosures to the SEC in to keep the EPA's portfolio disassociated with the Church.[41]

2005

The Church and EPA create a second LLC registered in Delaware[42] and file Forms 13F through it.[43]

2009

EPA distributes approximately $600 million to "bailout" a for-profit insurance business owned by the Church, Beneficial Financial Group, that was in danger of failing due to the financial crisis in 2008-2009.[44]

2010-2014

Between 2010 and 2014, EPA distributes $1.4 billion to Property Reserve, Inc. for the construction of City Creek Center.[45]

September 2010

David Nielsen[BIO] begins employment at EPA.[46]

2011

To avoid attracting attention to one large public filing,[47] EPA creates five "Clone LLCs"[48] through which to file multiple public filings.[49]

2015

EPA creates six additional "Clone LLCs"[50] and files public disclosures through them,[51] for a total of twelve companies.[52]

May 2018

MormonLeaks,[BIO] a whistleblowing organization inspired by WikiLeaks focusing on the Church, connects various LLCs that totals holdings of about $32 billion to the Church.[53]

June 2019

The SEC notifies the Church that it is concerned with how it is filing its public disclosure forms across multiple LLCs. The Church responds by consolidating its filings into a single form through EPA.[54]

September 2019

David Nielsen leaves employment at EPA by mutual decision.[55]

Media Attention on the Church's Billions

November 21, 2019

The IRS Whistleblower Office receives a complaint from David and Lars Nielsen, which alleged that EPA had about $100 billion in nonprofit accounts; among the grievances listed include the charge that EPA made no religious, educational, or charitable distributions in 22 years and that EPA unlawfully distributed $1.4 billion towards a non-legitimate purpose as per EPA's AOI and per IRS rules.[56]

December 2019

Lars Nielsen[BIO], David Nielsen's brother, goes public with their whistleblowing report and posts a series of videos on YouTube.[57] David Nielsen states that he did not approve of his brother postings, and that Lars does not represent him.[58]

2021

Former Latter-day Saint and film distributor James Huntsman[BIO] files a lawsuit against the Church for misuse of tithing funds.[59] David Nielsen testifies.[60] The suit is dismissed[61], but reinstated on appeal.[62] The lawsuit was later unanimously dismissed by the 9th Circuit Court of Appeals.[63]

January 31, 2023

David Nielsen submits a petition to the U.S. Senate Finance Committee and its Subcommittee on Taxation and IRS Oversight with an updated memorandum on EPA asking the federal government to "recover" $20 Billion in taxes.[64]

February 21, 2023

The SEC charges[65] and fines[66] the Church and EPA $5 million for failing to disclose their portfolio correctly when filing public disclosure forms from 2001-2019.[67]

May 14, 2023

David Nielsen makes his first public interview about EPA's "$100 billion fund" on 60 Minutes on CBS.[68]

Expand Timeline

What does the Church need all this money for?

Church leaders refer to this money as a reserve meant to ensure the continued operation of the Church in case of a "rainy day"[69] or to "weather the storm"[70] of any future economic distress.[71] The Church claims that "all church funds exist for no other reason than to support the church's divinely appointed mission"[72] and that it is "a sound doctrinal and financial principle taught by the Savior in the Parable of the Talents."[73]

A detail from "EXHIBIT D" from "Letter to an IRS Director," page 44, reportedly a "slide from EPA’s IPC preparation deck" from March 2013, “Framework and Exposures,” which summarizes the internally-understood purpose of EPA and its reserve funds.[74]

Read More Difficult Questions

446 Primary Sources

Footnotes

BIODavid Nielsen
David A. Nielsen (1978 - ) is a former employee of Ensign Peak Advisors, the church's investment arm. He had been a senior portfolio manager. Nielsen had resigned from his job in August of 2019. In November 2019, Nielsen and his twin brother, Lars, filed an IRS whistleblower complaint, alleging that the church should be taxed because it invested tithing money in commercial ventures.
BIOJoseph F. Smith
Joseph F. Smith (1838–1918) was born in Far West, Missouri to Hyrum and Mary Fielding Smith. At age 15, he was called to serve his first mission to the Sandwich Islands under the direction of apostle Parley P. Pratt. During the 1858-59 session of the Utah territorial legislature, he served as the sergeant-at-arms. He served another mission for the Church in Great Britain from 1860 to 1863.
Smith was ordained an apostle by Brigham Young in July 1866. He served as a counselor in the First Presidency under John Taylor, Wilford Woodruff, and Lorenzo Snow. He became the president of the Church in 1901. Smith issued the Second Manifesto, declaring that any church officer who performed a plural marriage would be excommunicated, alongside the couple themselves. He also received what is now canonized as section 138 of the Doctrine and Covenants, a vision of the spirit world in 1918.
BIOJ. Reuben Clark
Joshua Reuben Clark Jr. (September 1, 1871 – October 6, 1961) was an American attorney and an apostle for the Church of Jesus Christ of Latter-day Saints. Clark was born and raised in Grantsville, Utah, and received his education around the Utah Valley. Despite financial difficulties, Clark was intelligent and excelled in his schoolwork, graduating as valedictorian form his University of Utah class in 1898.Later, Clark attended Columbia University Law School, graduating in 1906. Clark worked as an attorney in the Department of State, and as Undersecretary of State for the U.S. President Calvin Coolidge. Clark also served as the United States Ambassador to Mexico in 1930. Following his ambassadorship, Clark was ordained an apostle in 1934.
BION. Eldon Tanner
Nathan Eldon Tanner (May 9, 1898 – November 27, 1982) was born in Salt Lake City, Utah. His family eventually emigrated to Canada, where he served as a politician for many years. In 1960, Tanner was called as an Assistant to the Quorum of the Twelve Apostles; an in 1962, was called as an Apostle. Tanner served as a counselor to four different Church Presidents.
BIODavid O. McKay
David Oman McKay (1873 – 1970) was born in Huntsville, Utah. He was the ninth president of the Church from 1951 to 1970. At the age of 32, he was ordained an apostle. President McKay expanded the mission of the Church worldwide, including creating the first stakes outside of the United States. He also emphasized family life and education. He died at age 96.
BIOGordon B. Hinckley
Gordon B. Hinckley (1910-2008) was born in Salt Lake City, Utah. He served as the fifteenth president of the Church of Jesus Christ of Latter-day Saints. Hinckley graduated from the University of Utah in English literature. After serving a mission to Great Britain, he became a secretary under the Church's Radio, Publicity, and Missionary Literature division. He became an apostle in 1961 and then a member of the First Presidency in 1981. In 1995, he became Church president. He oversaw the expansion of temple construction, increased standards for missionary worthiness, the expansion of the Church into West Africa and East Asia (particularly South Korea).
BIOMormonLeaks
MormonLeaks (originally named MormonWikiLeaks) was founded in 2016 by Ryan McKnight as a project of the nonprofit Truth and Transparency Foundation, a group that worked to increase transparency within religious organizations. MormonLeaks was the original project of the group, dedicated to releasing documents that would result in "fewer untruths, less corruption, and less abuse within Mormonism." In 2022, the Truth and Transparency Foundation ceased to operate, citing lack of funding and directional changes in the lives of the founders.
BIOLars Nielsen
Lars Pauling Nielsen is the author of "Letter to an IRS Director", which alleges the Church deliberately mislead the IRS to disguise the size of their investment fund. He leaked the report to various news agencies. He resigned from the Church in 2010. He has also authored the book, "How the Book of Mormon Came to Pass," which claims to tell the true Mormon origin story.
BIOJames Huntsman
James Huntsman (1971 - ) is the son of the late philanthropist Jon M. Huntsman. In 1987, at the age of 16, Huntsman was held for ransom before being rescued by the FBI. He later worked at Huntsman Corp. before cofounding Blue Fox Entertainment, a film distribution company, in 2015. In 2020 he resigned from the Church and in 2021, he filed a lawsuit against the church, accusing it of tithing fraud. The suit was unanimously dismissed in 2025 by the 9th Circuit Court of Appeals.
BIOEdward Partridge
Edward Partridge (August 27, 1793 – May 27, 1840) owned a hat store in Ohio when he encountered the Latter-day Saint missionaries. He was baptized after traveling to New York and meeting Joseph Smith, and was later ordained as the first bishop of the Church. He moved to Independence, Missouri and facilitated the law of consecration among the Saints there. On July 10, 1833, he was tarred and feathered by a mob and eventually forced out of Jackson County with the Saints. He continued serving as a bishop after moving to Nauvoo, where he eventually died.
BIOBrigham Young
Brigham Young (1801–1877) was an early Latter-day Saint leader. He was born in Whitingham, Vermont, and joined the faith in his twenties after two years of deliberation. He became the President of the Quorum of the Twelve Apostles following the fractionalization of the Church in Kirtland, Ohio. After Joseph Smith's martyrdom in 1844, Young assumed the presidency and led the Latter-day Saints to settle in the Great Basin region. He was married to fifty-five women and fathered fifty-nine children from sixteen of his wives. He also served as the Territorial Governor for Utah Territory until 1857 and as the prophet until his death.
BIOJohn Taylor
John Taylor (1808–1887) was born in Westmorland, England. He was the third president of The Church of Jesus Christ of Latter-day Saints. He moved to Canada in 1832 and joined the Church four years later. Taylor was soon appointed to the apostleship and became a prominent advocate for Latter-day Saint doctrine during his mission to the United Kingdom. Taylor accompanied Joseph Smith to Carthage Jail in 1844, where Joseph and Hyrum Smith were martyred. Taylor received a bullet wound to the thigh. He served in the apostleship and First Presidency until his appointment to the Presidency in 1880. Taylor oversaw the Church administration as the Church faced sustained prosecution from federal authorities for the practice of polygamy. He died while in hiding from federal authorities in Kaysville at the age of 79.
[1]↩︎
For example, news coverage (like Forbes in 2020), has advanced the claim that "Mormon Church Investment Fund Had Nearly $38 Billion" based on EPA's filings with the SEC. An official order from the SEC in 2023 corroborated these filings and a value of $37.8 billion in 2020.
Adding SEC filings for 2022 totals $44.4 billion.
Estimates from whistleblower and former EPA employee David Nielsen about the Church's reserve fund include $81.2 billion in 2018, $124 billion in 2019, and "over $100 billion" in 2023.
Others suppose far higher, like The Widow's Mite Report, which estimated church investments totaling $180 billion in 2021 and $157 billion in 2022.
[2]↩︎
In 1991, 1995, and 2001 General Conferences, Gordon B. Hinckley discussed Church finances and Church "reserves." He described a goal for the Church to save and invest a portion of its surplus income for a "rainy day" or to "weather the storm."
The characteristics of this "reserve" have been discussed in remarks from the Presiding Bishop, from the Church Newsroom, and in statements from the First Presidency, among other places. Surplus income from tithing and other sources is invested in "stocks and bonds; majority interests in taxable businesses (some of which date to the Church’s early Utah history); commercial, industrial, and residential property; and agricultural interests," according to Bishop Gérald Caussé and quoted in the Newsroom.
[3]↩︎
The Deseret News referred to Ensign Peak Advisors as "the church’s investment arm." The Wall Street Journal called Ensign Peak Advisors "one of the world’s largest investment funds."
A federal court ruling established that in 1997, the Church made Ensign Peak Advisors the "primary investment vehicle" for "reserve tithing funds," which included investment in stocks, bonds, and securities. The initial grant or "seed money" for EPA came from the Corporation of the Church of Jesus Christ of Latter-day Saints. Some, like in the Deseret News, refer to the Church's real estate, agricultural, and other assets as part of the reserve fund. David Nielsen's "Letter to an IRS Director" claims that while "technically, EPA itself currently owns between $99 and $101 billion," EPA "manages the assets in a broader allocation mandate" that includes the Church's real estate and agriculture arms—as part of a broad "EPA Universe."
[4]↩︎
Ensign Peak Advisors Inc (EIN 84-1432969) is a 501(c)(3) nonprofit, ruled by the IRS in 1941. EPA is based in Salt Lake City.
According to Tad Walch writing in the Deseret News, the IRS recognizes EPA as both a "supporting organization" and an "integrated auxiliary" to the Church, which comes with its own legal requirements and privileges.
[5]↩︎
On the IRS website, for instance, on a page titled "Filing Requirements for Churches and Religious Organizations," it explains that "generally, tax-exempt organizations" are required to file an "annual information return" but that "churches" and "church-affiliated organizations" are not required to file.
The IRS also provides a full list of these excepted organizations, including an "integrated auxiliary of a church," which describes EPA.
The Tax Reform Act of 1969 codified significant changes to tax law, including to the treatment of "private foundations" including charities and churches. The Act requires tax-exempt organizations to file annual information reports to the IRS, but excludes churches from that requirement.
EPA does file an annual Form 990-T with the IRS to report "unrelated business income," but this provides little insight into the church reserves.
[6]↩︎
In 2020, then-EPA-president Roger Clarke interviewed with the Wall Street Journal. In regards to EPA and its fund, he told reporters, "We’ve tried to be somewhat anonymous.” And EPA manager Dean Davies told the WSJ that the church doesn’t publicly share its assets because “these funds are sacred” and “we don’t flaunt them for public review and critique.” Other details from WSJ reporting include:
- EPA doesn’t tell business partners how much money it manages.
- EPA employees sign lifetime confidentiality agreements.
- Most EPA employees are no longer told the firm’s total assets under management.
- Church officials "acknowledged the size of the fund is a tightly held secret."
Lars and David Nielsen's "Letter to an IRS Director" whistleblower report emphasized the Church's desire for "continued anonymity."
A First Presidency statement from this time emphasized the responsible management of Church finances and full legal compliance but did not disclose particulars about the fund.
[7]↩︎
While there are may news articles that have been published about the EPA and the fund, primary sources of information are limited. As a nonprofit, private company, EPA is only compelled to publicly share information that is required by law.
The two main sources of primary information are disclosures from EPA made to the SEC, and current or former EPA employees.
[8]↩︎
According to US law, all institutional investment managers that conduct commerce in the United States and manage more than $100 million in Section 13(f) securities are required to file Form 13F with the SEC. Form 13F is a quarterly investment report that discloses SEC securities, such as stocks in US companies.
However, Form 13F does not disclose other categories of assets such as non-US stocks, cash, bonds, real estate, private equities, or mutual funds. This is what accounts for the large difference in estimates for Church reserves between whistleblower David Nielsen and what Form 13F discloses. Nielsen includes more asset categories, including treasury, cash, international and private equity, credit, and real estate.
[9]↩︎
Nielsen explained that his wife and children left the Church which influenced his decision to resign from his job at Ensigh Peak Advisors in August of 2019.
- Tad Walch in Deseret News reports on Church's response to $100 billion whistleblower.
[10]↩︎
The IRS received the Nielsen complaint on November 21, 2019.
The authorship of the document might be best described as joint between Lars and David. On the fourth page of the 74-page "Letter to an IRS Director," in the "From the Author" section, Lars Nielsen writes:
"I wrote every word and composed every exhibit of “Letter to an IRS Director” and solely produced the online videos that go by the same name. I did so with information that the whistleblower freely supplied, and with his permission I filed his claim."
The full submission to the IRS included the official IRS filing Form 211, a notarized cover letter, EPA internal emails, graphs, tables, projections, and analysis and commentary from Lars.
[11]↩︎
Repeated throughout the complaint document, titled "Letter to an IRS Director," are claims of EPA wrongdoing and petitions for the IRS to seek remedy. For example, in the "Executive Summary" on page 2:
Its owned assets under management (OAUM) have grown from $10 billion to ~$101 billion in 22 years without making a single religious, educational or charitable distribution.
Other claims from the document include two unlawful distributions to for-profit or noncharitable businesses, private inurement, intentionally defrauding or evading taxes, and the deception of the IRS, church members, and the public.
Further wrongdoing is implied, such as on page 22:
If so undaunted by the spirit of the law, what other “Anti-501c3-ing” activities could Mormons, Inc. be into? Is this a one-off or does cockroach theory apply here?
- The text of Lars Nielsen's "Letter to an IRS Director."
[12]↩︎
As The Washington Post reports, the Nielsens' plan was "to go public as soon as possible" with their whistleblowing report, but as David received legal advice he no longer wanted the report to be shared publicly.
Lars published the report and 84 minutes of accompanying YouTube videos online. Then Lars went to the news and the story was published in Religion Unplugged on December 16, 2019 and the day after in The Washington Post.
On December 20, Religion Unplugged published a statement from David:
“No one has been authorized to speak for me, including my brother, Lars Nielsen. Any public disclosure of information that has been in my possession was unauthorized by me. Repeated attempts to dissuade my brother, Lars Nielsen, from making public disclosures have been ignored. I will have no further comment on this matter.”
In a feature about David and Lars Nielsen's relationship at this time, The Washington Post said the whistleblowing report "tore them apart."
[13]↩︎
Coverage was first published by Religion Unplugged and then The Washington Post. Ahead of those publications, Lars Nielsen uploaded a version of "Letter to an IRS Director" to Scribd with David Nielsen's name removed.
[14]↩︎
In addition to general discussion, opinion pieces, and small news about the Church's "100 billion," headline events involving David Nielsen's testimony churned up more attention. For example:
- In March of 2021, film distributor James Huntsman sued the Church for the misuse of tithing and leveraged David Nielsen's testimony.
- In January 2023, David Nielsen filed a petition with the US Senate Finance Committee asking for oversight on EPA's wrongdoing.
- In May 2023, David Nielsen gave his first public interview on 60 Minutes about EPA.
[15]↩︎
David Nielsen's memorandum describes EPA as a "100 billion investment business" throughout the document (on page i, ii, 1, 3, 4, 5, 6, 7, 9, 11, 12, 37, 38, 39, 44, 50, 51, 52, 66, and A-2). However, when justifying that claim, the document uses passive voice and points to this footnote:
. . . a huge, diversified investment fund, the value of which is currently estimated to be in excess of $100 billion. [140] Mr. Nielsen estimated that EPA’s fund had a value in excess of $81 billion in 2018. In 2020, EPA’s then-President stated publicly it had a value of $100 billion.
The more comprehensive claim Nielsen makes is that "Total EPA Assets" are $81.2 billion. This figure comes from a chart on page A-3 constructed by David Nielsen from his personal estimations, SEC Form 13F filings, and "actual position-level detail and other risk and asset allocation reports in 2018."
- Text of David Nielsen 's affidavit concerning Ensign Peaks Advisors, Inc., submitted to the U. S. Senate Finance Committee.
[16]↩︎
Following the submission of the complaint including "Letter to an IRS Director" in 2019, David Nielsen with legal counsel sent additional evidence and analysis to the IRS and DOJ Tax Division in November 2020 and March 2022. Then in January 2023, David Nielsen submitted a new version compiling this evidence and analysis to the U.S. Senate Finance Committee and its Subcommittee on Taxation and I.R.S. Oversight.
This new memorandum to the Senate "substantially expands" on Nielsen's 2019 report to the IRS, which the memorandum describes as a "pro se placeholder submission." In the document, Nielsen and counsel describe fraud, deception, and conspiracy committed by EPA and asks the Senate for oversight and intervention in response.
- Text of David Nielsen 's affidavit concerning Ensign Peaks Advisors, Inc., submitted to the U. S. Senate Finance Committee.
- Religion Unplugged on the 2023 David memorandum to senate.
[17]↩︎
The claim of "$124 billion" is repeated on pages 3, 5, 6, 17, 21, 41, 48, and 63 of "Letter to an IRS Director," however, Footnote B on page 5 indicates that "The $124 billion figure is the whistleblower’s best present approximation" (which was November 2019).
A more concrete claim made in the document is that the Church's investment assets totaled $105.6 billion in February 2018. Rather than an estimate, this number is "Constructed by the whistleblower in 2019 using actual positions [of EPA] from Feb 2018."
- The text of Lars Nielsen's "Letter to an IRS Director."
[18]↩︎
"Letter to an IRS Director" is the central component of a complaint received by the IRS Whistleblower Office on November 21, 2019. The primary source information in the complaint comes from former EPA employee David Nielsen (referred to in the document as "the whistleblower"), but the document appears written and arranged by his brother Lars Nielsen. In the "From the Author" page of the document, Lars writes:
"I wrote every word and composed every exhibit of “Letter to an IRS Director” and solely produced the online videos that go by the same name. I did so with information that the whistleblower freely supplied, and with his permission I filed his claim."
The sum of the Nielsens' submissions to the IRS included the official IRS filing Form 211, a notarized cover letter, EPA internal emails, graphs, tables, projections, and what Lars calls "my full analysis." Contrary to David Nielsen's wishes, Lars went public with "Letter to an IRS Director," which was published online and covered by news outlets. The available-online version of the complaint is 74 pages and features an updated cover page with links to its news coverage and 84 minutes of YouTube exposés by Lars. The complaint was also revised to hide the identity of David Nielsen (as noted in an updated "From the Author" page). Each page has the footer, "© 2019 Lars Nielsen, IRSletter@protonmail.com." It's unclear which elements in the now-online report were present in the private IRS filing.
[19]↩︎
The official cease-and-desist order from the U.S. Securities Exchange Commission contains a small number of claims about the funds managed by EPA, including (emphasis added):
- When EPA was founded, it "managed approximately $7 billion of Church assets, a significant percentage of which consisted of Section 13(f) Securities."
- The portion of EPA's portfolio that was 13F securities was "approximately $37.8 billion by 2020."
- The document repeats a claim made by MormonLeaks: "In May 2018, a public website reported that various entities that appeared to have ties to the Church had filed Forms 13F revealing holdings of approximately $32 billion."
[20]↩︎
In February 2023, the U.S. Securities and Exchange Commission instituted a cease-and-desist order and announced charges against Ensign Peak Advisers Inc. and the Church. As summarized in an article from the SEC, the charges were:
"for failing to file forms that would have disclosed the Church’s equity investments, and for instead filing forms for shell companies that obscured the Church’s portfolio and misstated Ensign Peak’s control over the Church’s investment decisions. The SEC also announced charges against the Church for causing these violations. To settle the charges, Ensign Peak agreed to pay a $4 million penalty and the Church agreed to pay a $1 million penalty."
[21]↩︎
Starting in 2019, EPA began filing Form 13F quarterly with the SEC. In quarter 4 of 2022, EPA declared their managed SEC securities were $44,397,568,449 dollars across 1,786 table entries.
- Ensign Peak Advisory, Inc.'s quarter 4, 2022 SEC Report.
- Ensign Peak Advisory, Inc.'s quarter 4, 2022 SEC Report.
[22]↩︎
All institutional investment managers that conduct commerce in the United States and manage more than $100 million in Section 13(f) securities are required to file Form 13F with the SEC. EPA began filing 13F in its own name in February 2020, for the last quarter of 2019. Previously, EPA had filed various Forms 13F under the name of what the SEC later referred to as "Clone LLCs" meant to obscure and decentralize EPA's full portfolio.
[23]↩︎
Though the 60 Minutes story does not directly quote David Nielsen on the size of the EPA fund, 60 Minutes journalist Sharyn Alfonsi does repeat Nielsen's previous claims, saying:
"David Nielsen says that during his nine years managing money at the church firm, the value of its investments ballooned past 100 billion dollars." Nielsen alludes to this figure, saying "You could solve big problems with 100 billion dollars."
Bishop Waddell would not speak to the total value of EPA estimates, and instead acknowledged the existence of estimates and said, "Um, we have significant resources."
- Transcription of CBS's "60 Minutes" coverage of the whistleblower report.
[24]↩︎
David Nielsen's May 2023 appearance on CBS's 60 Minutes marks his first public interview about his whistleblowing message first filed in 2019.
When asked by interviewer Sharyn Alfonsi, "Why are you speaking now?", Nielsen replied:
"It’s time, Sharon. We gave the IRS and the SEC all the professional courtesy, this is just too important to fall through the cracks."
First Counselor in the Presiding Bishopric Christopher Waddell also appeared on 60 Minutes and offered a defense and explanation of EPA, though did not volunteer details on the fund's size.
Nielsen's interview represents a repetition and exploration of the claims he made in 2019 to the IRS and in 2023 to the U.S. Senate. Loyola University Chicago School of Law professor Sam Brunson summarized the 60 Minutes information in a blog post:
"And honestly, if you’ve been following the story closely (I have!), there’s not a lot of new information here."
- Transcription of CBS's "60 Minutes" coverage of the whistleblower report.
- Sam Brunson discusses CBS's "60 Minutes" report on the whistleblower report; notes that it does not provide much new information.
[25]↩︎
During this period, various acts were legislated, such as the Morrill Act (1862) and the Poland Act (1874). In 1887, the Edmunds-Tucker Act was passed, which increased fines against polygamy and resulted in the seizure of Church assets worth more than $50,000.
In the essay "Church Finances" on the Church's Website, it read:
Fluctuating markets and poor investments further depleted the Church’s remaining resources, presenting Church Presidents Wilford Woodruff and Lorenzo Snow with significant debts. After the 1890 Manifesto, President Woodruff worked with lawmakers and court officials to recover Church property and transition many Church-affiliated enterprises into private businesses, a process his successors continued. In 1899, President Snow called on Latter-day Saints to increase their commitment to tithing contributions, which in time helped return the Church to financial solvency.
[26]↩︎
Historians Ronald W. Walker and D. Michael Quinn describe an era of financial crisis for the Church that was exacerbated by the national panic in 1893.
Walker calls the Panic "among the most disastrous in American history," but that finances for Church members were hard even before then due to a land speculation bubble bursting. A depression followed the panic for Latter-day Saints—Walker summarized,
Appropriations for Church education were halted, twenty schools were closed, and the opening of the new Church University in Salt Lake City was postponed indefinitely. Clerks struggled to pay even the low-priced fares of returning missionaries, and sometimes failed.
As a result, the Church failed to meet its payroll on July 1.
Though official Church histories attribute the $1-2 million dollars of debt accrued at this time to federal anti-polygamy confiscations, D. Michael Quinn argues the debt came from "massive losses in the Church's interlocked mining, sugar, real estate, banking, and investment firms."
- Ronald W. Walker discusses Heber J. Grant and the Church's financial problems in 1893.
- Ronald W. Walker discusses Heber J. Grant and the Utah Loan and Trust Company.
[27]↩︎
In a 1907 General Conference, then-President of the Church Joseph F. Smith said:
I want to say another thing to you, and I do so by way of congratulation, and that is, that we have, by the blessing of the Lord and the faithfulness of the Saints in paying their tithing, been able to pay off our bonded indebtedness. Today the Church of Jesus Christ of Latter-day Saints owes not a dollar that it cannot pay at once. At last we are in a position that we can pay as we go. We do not have to borrow any more, and we wont have to if the Latter-day Saints continue to live their religion and observe this law of tithing, It is the law of revenue to the Church.
- Joseph F. Smith, during the April 1907 General Conference, states that the church "owes not a dollar that it cannot pay at once."
[28]↩︎
In 1947, Utah Economic and Business Review published a 106-page review inclusive of the Great Depression years (1929 – 1939) called, "Measures of Economic Changes in Utah, 1847–1947.”
In a section titled "Estimated Labor Force and Employment in Utah, 1930-1947," the worst year for employment was recorded in 1932, where 61,500 workers were unemployed out of that year's state workforce of 171,500 (or 35.86% unemployment).
In a section titled "Income Payments to Individuals in Utah, 1929-1946," Utah per capita income is recorded at a high point of $537 in 1929. Compared to the lowest point in that range—$313 in 1934—the drop constitutes a 48.79% decrease.
- December 1947 issue of the Utah Economic Business Review publishes an entire issue dedicated to the Great Depression years (1929-1936); notes that 1932 was the worst year for employment in Utah.
[29]↩︎
J. Reuben Clark, who was First Counselor in the First Presidency at the time, said in an auxiliary leadership meeting that Church expenses exceeded Church revenue by $100,000 in 1937.
Clark also wrote in his office diary on date January 23, 1939, that the Church had spent "between $800,000 and $900,000 more than our revenues" in 1938.
- J. Reuben Clark makes a number of suggestions to Church auxiliaries; notes that, in 1938, the Church had a deficit of $100,000.
- J. Reuben Clark reports in his journal that the Church's expenditure was between $800,000 to $900,000 more than their revenues for 1938.
[30]↩︎
In his April 1, 1940 "Suggestions to Auxiliaries," Clark wrote that
. . . our income was limited and that its expenditure had to be carefully watched; that in 1938 we had a deficit of over $100,000., from the point of view of income and expenditures; that in 1938 the deficit approaching a half million dollars; that in 1939, by the most scrupulous care, we had again brought our budget into balance with our income; and, that we had <so> planned our budget this year in such a way as likewise to come within our income; and that the Presidency was determined that it should so conduct its financial affairs as to live with the regular Church income so far as that could be done, in view of the fact that our income was uncertain.
- J. Reuben Clark makes a number of suggestions to Church auxiliaries; notes that, in 1938, the Church had a deficit of $100,000.
[31]↩︎
In General Conference on April 5, 1940, President Clark described his understanding of the Church's financial position:
We, the Authorities of the Church must therefore be extremely careful as to our commitments, else we shall find ourselves, as we have occasionally in the past, spending more than our income.
Preceding this statement, Clark emphasized that the income of the Church "depends wholly upon the prosperity of the people" and that even if every member paid tithing faithfully, Church finances would still be subject to "the uncertainty of weather, crops, business, and other elements that no one can forecast."
Clark also makes a statement with significance to a discussion of Church reserve funds:
"These things are pointed out so that no one can be under the delusion that the Church has a pile of gold to which it may go for any amount of money that it wishes."
- J. Reuben Clark teaches the importance for the Church and individuals to be free from debt; warns against living beyond one's income.
- J. Reuben Clark makes a number of suggestions to Church auxiliaries; notes that, in 1938, the Church had a deficit of $100,000.
[32]↩︎
This spending came under the direction of Henry D. Moyle, First Counselor in the First Presidency, who anticipated a need for many new church buildings to accompany increased baptisms (and that these new converts would provide increased tithing).
Within six months of Moyle's appointment to the First Presidency, the Church closed out 1959 with a deficit of $8 million, a contrast to the previous year when the Church enjoyed a surplus of $7 million after expenses.
- D. Michael Quinn discusses Henry D. Moyle and the practice of "baseball baptisms"; notes that, under Moyle, the Church spent $8 million more than it received in 1959.
[33]↩︎
D. Michael Quinn, in his essay, "LDS Church Finances from the 1830s to the 1990s," noted that
At the end of 1962, the Church was deficit-spending $32 million annually New York financiers had to advise against the First Presidency's proposal "to finance such spending by selling Church securities for the next fifty The new year looked no better. By the end of February, there was already a $5 million shortfall, and 1963 threatened to equal or exceed the spending deficit of 1962.
- D. Michael Quinn surveys Church finances from the 1830s to 1990s.
[34]↩︎
N. Eldon Tanner was a principal of Cardston High School, a Cardston City Council member, a provincial delegate, a cabinet member for two Canadian government Departments, and a top executive for two petroleum companies—including for a trans-Canadian oil pipeline.
- Susan Easton Black's biography of N. Eldon tanner on the Doctrine and Covenants Central Website.
[35]↩︎
Tanner was called as an assistant to the Quorum of the Twelve on October 8, 1960; then ordained an Apostle on October 11, 1962, at age 64; then called as Second Counselor to President McKay on October 4, 1963.
[36]↩︎
In a Church History Topics essay on the Church website, Tanner's financial policies upon entering the First Presidency are summarized as:
- "strict budgetary controls on Church operations"
- "building a surplus"
- "maintaining a strict budget"
- "spending from reserves"
In General Conference in 1979, Tanner offered a framework for financial security based on five "constancies":
- "Pay an honest tithing."
- "Live on less than you earn."
- "Learn to distinguish between needs and wants."
- "Develop and live within a budget."
- "Be honest in all your financial affairs."
- The Church website hosts an article on "Church Finances" in Church History Topics.
- During General Conference, N. Eldon Tanner describes his philosophy for financial "constancies."
[37]↩︎
In a 1995 October General Conference talk about Church administration, President of the Church Gordon B. Hinckley discussed a "compelling trust" to use tithing income "carefully and wisely," and then said:
Not only are we determined to live within the means of the Church, but each year we put into the reserves of the Church a portion of our annual budget. We are only doing what we have suggested every family do. Should there come a time of economic distress, we would hope to have the means to weather the storm.
- Gordon B. Hinckley describes "a portion of our annual budget" invested into reserves.
[38]↩︎
Hinckley has made other statements on Church finances in General Conference, including in 1985 and 2003.
In 1985, Hinckley posed and answered the question, "Is the Church an institution of great wealth, as some claim?" and reported the Church's wealth was mostly in buildings and money-consuming assets, adding: "We have a few income-producing business properties, but the return from these would keep the Church going only for a very short time. Tithing is the Lord’s law of finance."
In 2003, Hinckley announced plans that would become the construction of City Creek mall and asserted it would be paid for not with tithing but through the Church's commercial properties and "the earnings of invested reserve funds."
- Hinckley Questions and answers "is the church wealthy".
- Gordon B. Hinckley refers to "invested reserve funds."
[39]↩︎
Ensign Peak Advisors, Inc. was incorporated in the state of Utah as a domestic nonprofit corporation. Its entity ID number is 1376719-0140 and is registered under the NAICS category of "8132-Grantmaking and Giving Services." It initially managed $7 billion in Church assets.
In an order in 2023, the SEC described EPA's formation:
"The Church created Ensign Peak in 1997 as an integrated auxiliary of the Church to manage the Church’s investment securities. Ensign Peak has no shareholders or members. The securities portfolio managed by Ensign Peak consists of what the Church calls “reserve funds” or “reserves,” which include U.S. equity and debt securities purchased with excess tithing, income and returns generated by Ensign Peak, and the assets of other Church integrated auxiliaries.
- Utah Business Search's listing for Ensign Peak Advisors, Inc.
- The SEC order of the LCC registered by the Church and Ensign Peak Advisory Inc., in Delaware.
[40]↩︎
The creation of an LLC in Glendale, California is described in the filing from the SEC ordering a cease-and-desist and fine against EPA, though the SEC does not name the LLC.
The LLC is most likely Whitney Asset Management (EIN 95-4884497) because it matches the information the SEC provides, including state of origin and filing dates. Also, the name of the person signing the Forms 13F for Whitney Asset Management was also listed in a public directory as a Church employee.
The SEC describes this LLC's filing history, which can be corroborated with the publicly searchable filings for its EDGAR page hosted at sec.gov:
"Ensign Peak filed the first Form 13F in the name of this LLC on February 26, 2003, for the year ended December 31, 2002. Ensign Peak filed later Forms 13F using the name of the LLC through the quarter ended September 30, 2006."
[41]↩︎
The order from the SEC describes the rationale for EPA and Church leadership to file through an LLC instead of in EPA's own name:
To prevent disclosure of the securities portfolio managed by Ensign Peak, the Church approved Ensign Peak’s plan of using other entities, instead of Ensign Peak, to file Forms 13F. The Church was concerned that disclosure of the assets in the name of Ensign Peak, a known Church affiliate, would lead to negative consequences in light of the size of the Church’s portfolio.
- The SEC order of the LCC registered by the Church and Ensign Peak Advisory Inc., in Delaware.
[42]↩︎
The creation of this second LLC is described in the SEC order, but the LLC is not named.
This second LLC is likely Argyll Research, LLC (EIN 01-0837111), as the timeline and description offered by the SEC correspond to publicly-available information about Argyll Research.
The SEC order summarizes the formation of this second LLC:
On December 1, 2005, Ensign Peak formed a second LLC as a Delaware nonprofit corporation, located in Wilmington, and named Ensign Peak’s Managing Director as its general manager. Ensign Peak then filed Forms 13F in the name of this new LLC.
Argyll Research filed Form 13F from 2007 to 2019.
- Argyll Research LLC's 13f's from 2013 to 2019.
- The SEC order of the LCC registered by the Church and Ensign Peak Advisory Inc., in Delaware.
[43]↩︎
The SEC order offers this brief summary of the motives behind the creation of this second LLC, including an unattributed quote:
On March 15, 2005, the Church became aware that the public might link this first LLC to the Church because the person signing the Forms 13F was listed in a public directory as a Church employee. To address this issue, on March 21, 2005, the senior leadership of the Church approved a new reporting entity to be created with “better care being taken to ensure that neither the ‘Street’ nor the media [could] connect the new entity to Ensign Peak.”
- The SEC order of the LCC registered by the Church and Ensign Peak Advisory Inc., in Delaware.
[44]↩︎
Whistleblower David Nielsen, in both "Letter to an IRS Director" and his memorandum to the U.S. Senate, repeats the claim that in 2009 EPA distributed $600 million to Church-owned, for-profit insurance and financial services company, Beneficial Financial Group (BFG). Nielsen's claim is based on what is reported to be a "slide from EPA’s IPC preparation deck" from March 2013, “Framework and Exposures.”
As Nielsen claims, and as corroborated by details from Deseret News coverage of the transaction, BFG received the $600 million through its parent company, Deseret Management Corp.
First Counselor in the Presiding Bishopric, Bishop Waddell, confirmed the existence of the payout and characterizes it as a "bailout", saying on 60 Minutes:
"The church actually owned Beneficial Life and, fortunately, the Church had the resources to bail out Beneficial Life during the financial crisis, 2008-2009."
[45]↩︎
In "Letter to an IRS Director," the payment from EPA to City Creek Mall is substantiated by what is reported to be a "slide from EPA’s IPC preparation deck" from March 2013, “Framework and Exposures.” That slide shows "$1,400mm over 5 years" withdrawn from EPA for "City Creek" but does not list exact dates.
As repeated in both "Letter to an IRS Director" and David Nielsen's memorandum to the U.S. Senate, Nielsen associates the years 2010-2014 with the series of payments from EPA to finance City Creek.
In the 2023 60 Minutes episode on the subject, Bishop Waddell acknowledged the distribution from EPA to City Creek, and said:
The Mall is not a bailout. The mall is an investment.
[46]↩︎
David Nielsen's LinkedIn profile, as of March 2023, shows an employment history at EPA of 9 years and 1 month, from September 2010 to September 2019.
CBS, in both an article and a 60 Minutes episode,The Washington Post and Nielsen's memorandum to the U.S. Senate state that he spent nine years at EPA.
Nielsen began employment as a Portfolio Manager for EPA in 2010, and was a Senior Portfolio Manager at the end of his employment there.
Nielsen characterizes his employment at EPA as recruitment away from a more lucrative job on Wall Street. Nielsen's memorandum to the U.S. Senate reads:
Although Mr. Nielsen could have earned significantly more working for a traditional hedge fund, Mr. Nielsen accepted EPA’s offer because he believed at that time that EPA actually supported the Church’s religious and charitable activities.
[47]↩︎
The SEC order to the Church and EPA provides the following motivation for forming more LLCs:
Several years later, in 2011, Ensign Peak became concerned that its portfolio had become so large that the Form 13F filings it made using the name of the second LLC might attract unwanted attention and sought the Church’s approval to form additional LLCs to file Forms 13F.
- The SEC order of the LCC registered by the Church and Ensign Peak Advisory Inc., in Delaware.
[48]↩︎
The SEC order provides minimal identifying information—only state and date of incorporation, date ranges for when these entities filed Form 13F with the SEC, and occasional total dollar values associated with those SEC filings.
Based on publicly available information, these five "Clone LLCs" may be identified from a pool of six:
- Ashmore Wealth Management (EIN 45-3763119)
- Cortland Advisers (EIN 45-3049815)
- Green Valley Investors (EIN 45-3049946)
- Riverhead Capital Management (EIN 45-3557628)
- Tiverton Asset Management (EIN 45-3074062)
- Clifton Park Capital Management (EIN 45-3122370)
There are 13F filings for these five companies from 2012 to 2019, with the exception of Clifton Park Capital Management, which only filed from 2012 to 2016.
[49]↩︎
MormonLeaks published an identification of 13 LLCs (including the above) based on public information and independent reporting:
- Web domain names matching the LLC names were registered to “Intellectual Reserve, Inc.,” a Church subsidiary, on the same day.
- The DNS records of these domains were hosted on servers that also host those for lds.org, mormon.org, and other Church domains.
- The Form 13F for each LLC lists a "Business Manager" matching finance or executive employees from a leaked 2015 Church employee directory
Using those LLC names, others like the Widow's Mite Report have gathered the LLC's 13F filings with the SEC. Those filings show portfolio totals and filing dates, which can be corroborated with details in the SEC order, making the above LLCs a fair guess for the unnamed LLCs mentioned in the SEC order.
[50]↩︎
The SEC order does not specifically name these six additional LLCs, but possible identification can be made by comparing the information the SEC does give and publicly-available information.
These six companies are most likely:
- Elkfork Partners (EIN 81-1624104),
- Flinton Capital Management (EIN 81-1874235),
- Glen Harbor Capital Management (EIN 81-1206371),
- Meadow Creek Investment Management (EIN 81-1188461),
- Neuburgh Advisers (EIN 81-2074261), and
- Tyers Asset Management (81-1573810).
[51]↩︎
The SEC relates that following approval from Church leadership on November 6, 2015, EPA created another wave of LLCs "to further prevent disclosure of the Church’s holdings managed by Ensign Peak."
These six additional LLCs probably filed 13Fs from 2013 to 2019.
- The SEC order of the LCC registered by the Church and Ensign Peak Advisory Inc., in Delaware.
[52]↩︎
The SEC order refers to "bringing the total to twelve" in 2015 through the creation of six additional "Clone LLCs." Though the SEC order does not name them explicitly, the twelve LLCs are most likely in this pool of fourteen:
- Argyll Research (EIN 01-0837111)
- Ashmore Wealth Management (EIN 45-3763119)
- Cortland Advisers (EIN 45-3049815)
- Green Valley Investors (EIN 45-3049946)
- Riverhead Capital Management (EIN 45-3557628)
- Tiverton Asset Management (EIN 45-3074062)
- Elkfork Partners (EIN 81-1624104)
- Flinton Capital Management (EIN 81-1874235)
- Glen Harbor Capital Management (EIN 81-1206371)
- Meadow Creek Investment Management (EIN 81-1188461)
- Neuburgh Advisers (EIN 81-2074261)
- Tyers Asset Management (81-1573810)
- Whitney Asset Management (EIN 95-4884497)
- Clifton Park Capital Management (EIN 45-3122370)
The SEC is likely not counting Whitnet Asset Management and Clifton Park Capital Management, as these ceased filing Form 13F in 2005 and 2016, respectively. In the SEC order document, the twelve companies likely refer to concurrently-filing LLCs, and the remaining twelve above all filed Form 13F concurrently from 2017 to 2019.
[53]↩︎
Despite efforts by EPA to obscure the connection between the EPA and LLCs, MormonLeaks discovered
several pieces of evidence that tie these 13 companies to the Church. While none of them particularly stand out on their own, together they provide room for the reasonable conclusion that these organizations are related to the Church in some way.
Those pieces of evidence include web domain names, servers hosting DNS records, and employees connected to the Church.
Using those LLC names, others like the Widow's Mite Report have gathered the LLC's 13F filings with the SEC. Those filings show portfolio totals and filing dates, which can be corroborated with details in the SEC order, making the above LLCs a fair guess for the unnamed LLCs mentioned in the SEC order.
[54]↩︎
The SEC order document reads:
Ensign Peak continued to file Forms 13F through the Clone LLCs until February 14, 2020, when Ensign Peak filed a consolidated Form 13F for the quarter ended December 31, 2019.
An official Church statement in Church Newsroom, as part of a Q&A on the SEC fine, said:
Q: Has the reporting practice that prompted the SEC cease and desist order now stopped? A: Yes. In June 2019, the SEC first expressed concern about Ensign Peak’s reporting approach. Ensign Peak adjusted its approach and began filing a single aggregated report. Since that time, 13 quarterly reports have been filed in full accordance with SEC requirements.
- The SEC order of the LCC registered by the Church and Ensign Peak Advisory Inc., in Delaware.
- Church Newsroom publishes the Church's response concerning the SEC filing.
[55]↩︎
In Nielsen's memorandum to the Senate and his appearance on 60 Minutes, he frames his departure from EPA as a resignation on moral grounds. However, his resignation letter to EPA (as reported by The Washington Post) describes a more complex situation involving Nielsen's decreased church attendance and manager policies. The Post reports:
On July 23, David went to his managers at Ensign with a dilemma, he recounted later in a resignation letter. . . . David decided to leave his job, writing in the Aug. 29 resignation letter that among his reasons was that “my supervisor intimated” that if David was not fully committed to the church, his being in the office might “distract others from their work.” He said his last day would be Oct. 4. But on Sept. 3, David received a reply from human resources informing him that managers had decided that, “in the best interest of all parties,” he should leave that day, according to the copy of the company letter. He would receive a month’s pay and two months’ health insurance.
[56]↩︎
The full submission to the IRS included the official IRS filing Form 211, a notarized cover letter, EPA internal emails, graphs, tables, projections, and the 74-page "Letter to an IRS Director." In the "From the Author" page of the document, Lars writes:
"I wrote every word and composed every exhibit of “Letter to an IRS Director” and solely produced the online videos that go by the same name. I did so with information that the whistleblower freely supplied, and with his permission I filed his claim."
- The text of Lars Nielsen's "Letter to an IRS Director."
[57]↩︎
Lars Nielsen published an amended version of the IRS report online meant to anonymize David, copyright "Letter to an IRS Director," and link to news and social media coverage. Lars also published 84 minutes of exposés on YouTube. Then Lars went to the news media and the story was published in Religion Unplugged on December 16, 2019, and the day after in The Washington Post.
On December 18, Lars wrote an article in Newsweek describing his motivations:
I wrote 'Letter to an IRS Director' in the style (and in admiration) of 'Letter to a CES Director' because isolated, questioning Mormons need hours of immersive, binge-worthy, relatable, and rich content when their 'shelves begins to break.'"
[58]↩︎
On December 20, Religion Unplugged published a statement from David:
“No one has been authorized to speak for me, including my brother, Lars Nielsen. Any public disclosure of information that has been in my possession was unauthorized by me. Repeated attempts to dissuade my brother, Lars Nielsen, from making public disclosures have been ignored. I will have no further comment on this matter.”
In a feature about David and Lars Nielsen's relationship at this time, The Washington Post said the whistleblowing report "tore them apart."
- Paul Glader and Emma Penrod report on the Church's finances and the whistleblower report for Religion Uplugged.
- Washington Post reports on David Nielsen and the Church's $100 billion fund; notes that Nielsen was asked to sign a nondisclosure agreement that would bind him and his heirs.
[59]↩︎
Huntsman filed his lawsuit March 22, 2021.
Central to the Huntsman lawsuit was information and statements from David Nielsen. The suit accused the Church of "fraud and corporate greed" and “repeatedly and publicly" lying about the use of tithing, including in the funding of City Creek Center. Huntsman sought to reclaim millions in tithing he had paid back from the Church.
In court, however, the accusations were narrowed. Federal Judge Stephen Wilson recognized that Huntsman did not present "any specific flaws in the accounting or calculations" of Church finances, but "simply argues that there is no distinction between tithing funds and earnings on invested tithing funds."
Given the plaintiff's arguments and evidence, Judge Wilson decided that the case was not about tithing use but whether President Hinckley lied about tithing use.
[60]↩︎
Nielsen's report to the IRS was not submitted as evidence in the Huntsman suit. Instead, David Nielsen submitted a new sworn declaration, claiming, among other things, that the Church spent $2 billion of tithing on City Creek Center and a life insurance company.
- David Nielsen submits a sworn statement on Ensign Peak Advisory Inc.'s tithing use in Huntsman lawsuit against the Church.
- Tony Semerad in The Salt Lake Tribune reports on David Nielsen's new sworn statement for Huntsman lawsuit.
[61]↩︎
U.S. District Judge Stephen Wilson dismissed the case on September 10.
The crux of the lawsuit was the statement by President Hinckley in 2003 when he said 'tithing funds have not and will not be used" but that commercial gains and "invested reserve funds" would be used to finance City Creek. Huntsman argued that the difference between what Church leaders said was tithing and gains from invested tithing was “distinction without a difference."
Judge Wilson ruled that Hinckley's statement was factual and that no reasonable juror could "ignore the distinction within his statement." He also found two problems with the Nielsen report as evidence:
- "Neilsen conflates tithing funds with earnings on invested tithing funds."
- "Neilsen was not employed by EPA when the funds that were used to develop the City Creek project were allocated for that purpose."
[62]↩︎
In response to the dismissal of the lawsuit by judge Stephen Wilson, Huntsman's lawyer said,
While we are obviously disappointed with Judge Wilson’s order, we look forward to vindicating Mr. Huntsman’s position in the Ninth Circuit Court of Appeals.
- James Huntsman lawsuit thrown out by federal judge Stephen Wilson, FOX 13 reports.
- Paighten Harkins of of The Salt Lake Tribune reports federal judge Stephen Wilson dismissing Huntsman tithing lawsuit.
[63]↩︎
On January 31, 2025, Tad Walch for the Deseret News reported:
A panel of 11 judges in the 9th Circuit issued a unanimous ruling Friday dismissing James Huntsman’s lawsuit seeking the return of $5 million he donated to The Church of Jesus Christ of Latter-day Saints. It is the second time the lawsuit has been dismissed in four years.
- Circuit Court unanimously dismisses Huntsman’s tithing lawsuit, Deseret News reports.
[64]↩︎
With legal counsel from Finch McCranie, LLP and Rubin Law Assoc. PC, David Nielsen petitioned the U.S. Senate for oversight and intervention for EPA.
Nielsen accuses EPA of Klein conspiracy, fraudulent filings and statements, tax evasion, no charitable activities, funding for-profit private interests, and private investment. To conclude his memorandum, he called for congressional oversight to "recover the tax owed by EPA."
The Nielsen memorandum received coverage in the Salt Lake Tribune and Religion Unplugged, and both speculated whether any action would be taken. Sam Brunson, Law professor at Loyola University, Chicago, and author of God and the IRS, characterized the memorandum as a "publicity stunt" that "if it gets opened, it'll be ignored." Brunson criticized the language, arguments, evidence, and rhetoric of the document on Twitter.
[65]↩︎
In the official SEC order and ruling, EPA and the Church's violations are listed:
Ensign Peak violated Section 13(f)(1) of the Exchange Act and Rule 13f-1 thereunder by failing to file Forms 13F in Ensign Peak’s name. Ensign Peak also violated Section 13(f)(1) of the Exchange Act and Rule 13f-1 thereunder by filing misstated Forms 13F in the names of LLCs created for the sole purpose of filing Forms 13F.
[66]↩︎
The SEC officially issued four orders:
- EPA must cease violating Section 13(f) of the Exchange Act
- The Church must cease violating Section 13(f) of the Exchange Act
- EPA must pay a penalty of $4 million to the SEC
- The Church must pay a penalty of $1 million to the SEC
[67]↩︎
Following the charges and fine, the Church released a brief Q&A in the Church Newsroom, including their commitment to pay the penalties, and the statement:
We reached resolution with the SEC. We affirm our commitment to comply with the law, regret mistakes made, and now consider this matter closed.
- Church Newsroom publishes the Church's response concerning the SEC filing.
[68]↩︎
CBS 60 Minutes is an American television news program known for its in-depth investigative reporting, feature stories, and interviews with prominent figures. 60 Minutes reporter Sharyn Alfonsi traveled to Salt Lake City and spoke with David Nielsen, First Counselor in the Presiding Bishopric Christopher Waddell, and tax professor Phil Hackney for a 13 minute video segment and three short, supplementary videos.
Nielsen, who had not publicly interviewed before this time, explained why he made the appearance:
It’s time, Sharon. We gave the IRS and the SEC all the professional courtesy, this is just too important to fall through the cracks.
The interview received secondary media coverage and discussion in Deseret News, The Salt Lake Tribune, Religion Unplugged, Fox News, and other outlets.
[69]↩︎
In an address titled "The State of the Church" in the April 1991 General Conference, Gordon B. Hinckley (then First Counselor in the First Presidency) gave answers to several questions about church finance. Some key points from Hinckley summarized:
- The Church aims to "live within its means" and "not spend more than it receives."
- A "fixed percentage of the income" of the Church will be "set aside to build reserves against what might be called a 'rainy day.'"
- The Church aims to follow the principles it teaches members—to set aside resources to take care of emergency needs that might arise.
- Some Church leaders are old enough to remember the Great Depression.
- The Church has no debt.
- Gordon B. Hinckley says "fixed percentage" of income will be "set aside to build reserves" for a "rainy day."
[70]↩︎
In an address titled "Of Missions, Temples, and Stewardship" given in October 1995 General Conference, then-President of the Church Gordon B Hinckley shared several details related church finance:
- The Church "lives within its means" and has no debt (except where required for business).
- Tithing is "the Lord’s plan for financing the work of His kingdom" and there is no compulsion to pay it (except that it is a commandment from God).
- Tithing is sacred and must be responsibly used.
- Each year the Church puts a portion of its annual budget into reserves.
Hinckley describes the motivation behind these reserves:
We are only doing what we have suggested every family do. Should there come a time of economic distress, we would hope to have the means to weather the storm.
- Gordon B. Hinckley describes "a portion of our annual budget" invested into reserves.
[71]↩︎
In its coverage of the initial 2019 whistleblowing report, The Wall Street Journal interviewed EPA employees about their work and the reserve fund's purpose, and summarized:
"Mr. Clarke and church officials who oversee the firm said it was a rainy-day account to be used in difficult economic times. As the church continues to grow in poorer areas of the world like Africa, where members cannot donate as much, it will need Ensign Peak’s holdings to help fund basic operations, they said."
Bishop Waddell is directly quoted and cites the 2008 financial crash:
“We don’t know when the next 2008 is going to take place. If something like that were to happen again, we won’t have to stop missionary work.”
In a discussion published in the Church Newsroom about Church reserve investments, Presiding Bishop Gérald Caussé said:
These invested funds can be accessed in times of hardship to ensure the ongoing, uninterrupted work of the Church’s mission, programs, and operations and to meet emergency financial needs.
In 2013, Apostle David A. Bednar described church reserves as for "contingencies and unanticipated needs."
[72]↩︎
In an official release from the Church Newsroom titled "First Presidency Statement on Church Finances - Statement provided in response to media stories," the Church responded to the December 2019 Nielsen whistleblowing report news coverage.
In their statement, Church officials emphasized the responsibility of caring for tithes and offerings, covering church expenses, and the use of excess these funds "to maintain prudent reserve for the future."
All Church funds exist for no other reason than to support the Church’s divinely appointed mission.
- Church Newsroom publishes the First Presidency's Reply to the Whistleblower Report.
[73]↩︎
In the official release from the Church Newsroom responding to the 2019 whistleblowing story in the news, the Church said this of their reserve fund:
This is a sound doctrinal and financial principle taught by the Savior in the Parable of the Talents and lived by the Church and its members.
In a discussion of Church finances published in the Church Newsroom in 2018, the Presiding Bishop Gérald Caussé said:
"Members have been counseled frequently to practice provident living, live within their means, avoid unnecessary debt, and prepare for the future by developing temporal reserves, including food and financial assets. As these temporal principles have been taught to members throughout the Church, Church leaders have also implemented them on a larger scale for the entire Church. In its finance and investment policies, the Church as an entity simply practices the principles that it teaches to its individual members."
- Church Newsroom publishes the First Presidency's Reply to the Whistleblower Report.
- Mormon Newsroom reports on Gérald Caussé teaching the importance for financial self-reliance.
[74]↩︎
David and Lars Nielsen's "Letter to an IRS Director" whistleblower complaint contains an alleged "slide from EPA’s IPC preparation deck from March 2013" titled "Ensign Peak & Portfolio Purposes." This slide details the role of EPA as a wealth manager, the purpose of the investment reserve as a backstop and collateral, and examples of withdrawals. The slide indicates only two withdrawals from the investment reserve (City Creek and Beneficial Life) and explains that withdrawals from the reserve "have been relatively small due to the conservative nature of Church finances and operations—i.e. a balanced budget." The slide characterizes this conservative budgeting as "a very strong first line of defense."
- The text of Lars Nielsen's "Letter to an IRS Director."
[75]↩︎
First Counselor in the Presiding Bishopric Christopher Waddell told interviewer Sharyn Alfonsi in a 60 Minutes May 2023 episode that the Church's reserve fund is not for the Second Coming, but for the continued operation of the Church. He continued:
"We've looked at it based on needs, to make sure that we're comfortable with how many years worth we have in case of financial difficulties, in case of finanical crisis, to make sure that we can continue Church operations. We just want to make sure that that is sufficient."
In The Washington Post, then-president of EPA Roger Clarke contradicted the idea that the funds were for the Second Coming, saying, "we don’t have any idea whether financial assets will have any value at all. The issue is what happens before that, not at the second coming.”
- Transcription of CBS's "60 Minutes" coverage of the whistleblower report.
[76]↩︎
Nielsen, who worked at EPA from 2010 to 2019, records this answer of the "Second Coming" from EPA leadership in his whistleblowing reports, such as this excerpt in "Letter to an IRS Director":
"'In 2010, I asked Roger Clarke, EPA's Managing Director, point blank: How has EPA never funded a prophetic initiative in the past 13 years . . .' . . . Mr. Clarke responded by saying that he didn't know what EPA would be used for and that he didn't know whether the Lord would ever reveal what it would be used for to the Prophet. In the past couple of years, Mr. Clarke has started saying that this money would be used in the 'Second Coming.'"
- The text of Lars Nielsen's "Letter to an IRS Director."
[77]↩︎
Nielsen shared this response in a 60 Minutes interview with correspondent Sharyn Alfonsi, to her question, "Did any of your former bosses explain how the money was gonna be used one day?"
One anonymous former EPA employee interviewed by the Wall Street Journal said that EPA employees would occasionally ask Church leaders what the money was being saved for. Reportedly, Church leaders said they wanted to know that, too. That employee said: “It was always, ‘When we have direction from the prophet.’ Everyone was waiting, as it were, for direction from God.”
[78]↩︎
EPA's "Portfolio Purposes" are described an alleged internal EPA slide from "March 2013, 'Framework and Exposures'" included as "Exhibit D" in whistleblower David Nielsen's "Letter to an IRS Director."
"Examples of withdrawals" are listed on this slide, though only two withdrawals are given ("City Creek" and "Beneficial Life). Attached to this list by asterisk is a note, which reads:
"The draw on the investment reserves has been relatively small due to the conservative nature of Church finances—i.e. a balanced budget. This is a very strong first line of defense. Furthermore, over the past several years, approximately $1bn has been granted to EPA on an annual basis."
- The text of Lars Nielsen's "Letter to an IRS Director."
[79]↩︎
In an interview on CBS' 60 Minutes, First Counselor in the Presiding Bishopric Christopher Waddell said:
"In any given month, you may have an average of nine transfers going from Ensign Peak back to the Church to fund all church operations—all humanitarian work, all education work, all the work of the church—they fund."
- Transcription of CBS's "60 Minutes" coverage of the whistleblower report.
[80]↩︎
On CBS' 60 Minutes, David Nielsen told the interviewer:
"Money's going in and out of the cash accounts all the time, but Ensign Peak's funds were never used for any charitable purpose, to my knowledge, the whole time I was there. There's a bit of a distinction here that's important."
When asked to explain that distinction, Nielsen continued:
"Well, it's the difference between your checking account and maybe your retirement account. They're used for different purposes, and you don't get to pretend that one is affecting the other."
These statements echo what Nielsen has said in his whistleblowing reports, where he claims EPA does not serve charitable purposes.
[81]↩︎
David Nielsen makes this claim in both of his whistleblowing reports (to the IRS and to the Senate) and also includes what he alleges to be an internal EPA slide detailing the Church-owned City Creek Center mall and Beneficial Financial Group (Beneficial Life) as examples of withdrawals.
In a 60 Minutes inteview, Bishop Waddell corroborates that EPA money paid for Beneficial Life and City Creek mall.
[82]↩︎
That insurance group is Beneficial Life, referred to by its DBA name Beneficial Finance Group by David Nielsen. At the time of the transaction from EPA to Beneficial Life, the company was registered with the state of Utah as "Beneficial Life Insurance Agency, Inc." entity number 1431179-0142 (today it seems the company is registered as "Beneficial Life Insurance Company" entity number 552719-0142.)
Beneficial Life / Beneficial Finance Group is a for-profit company classified with a NAICS code "5242-Agencies, Brokerages, and Other Ins." It provides insurance to customers in exchange for premiums and is taxed.
On 60 Minutes, Bishop Waddell described the EPA payment as a "bailout":
"The Church actually owned Beneficial Life, and, and fortunately the Church had the resources to bail out Beneficial Life during the financial crisis, 2008, 2009."
[83]↩︎
City Creek Center finished construction in downtown Salt Lake City in 2012, and it's total cost was probably around $1.5 billion. David Nielsen alleges that EPA distributed the money for City Creek to the nonprofit Church subsidiary Property Reserve Inc. (EIN 20-8152281), the real estate development arm for the Church.
According to alleged internal slides from EPA included in David Nielsen's report to the IRS, the disbursement to fund City Creek took place "over five years."
[84]↩︎
Church President Gordon B. Hinckley explained in the October 1995 General Conference that the Church reserve is meant to be "the means to weather the storm" in case of "a time of economic distress."
In a 2018 article in the Church Newsroom, Presiding Bishop Gérald Caussé described how the Church's "invested funds" could be "accessed in times of hardship to ensure the ongoing, uninterrupted work of the Church’s mission."
In a May 2023 60 Minutes interview, First Counselor in the Presiding Bishopric Christopher Waddell said that EPA's funds are measured by "how many years worth we have in case of financial difficulties, in case of finanical crisis, to make sure that we can continue Church operations."
[85]↩︎
Reportedly, an internal presentation slide from EPA's New Staff Orientation refers to EPA's investment reserves as a "Temporal Anchor for Building Zion" directly tied to the Church's mission (sharing the gospel, gathering Israel, caring for the poor and needy, and doing proxy work) and the accessible, simple, and affordable sharing of gospel teachings, resources, and services. This internal slide is featured in David and Lars Nielsen's "Letter to an IRS Director" as "Exhibit G" on page 50.
- The text of Lars Nielsen's "Letter to an IRS Director."
[86]↩︎
This 60 Minutes episode was published May 14, 2023, and prominently featured the first public interview of former EPA employee and whistleblower David Nielsen.
First Counselor in the Presiding Bishopric Christopher Waddell was also interviewed to provide an additional perspective. 60 Minutes corespondent Sharyn Alfonsi asked this question and received this answer from Waddell:
Alfonsi: Give us a sense of what percentage is going out the door of the money under management.
Waddell: Well, to be honest, we've never looked at it as a percentage. We've looked at it based on needs, to make sure that we're comfortable with how many years' worth we have in case of finciancial difficulties, in case of financial crisis, to make sure that we can continue church operations. We just want to make sure that that is sufficient.
- Transcription of CBS's "60 Minutes" coverage of the whistleblower report.
[87]↩︎
In 2016, Dallin H. Oaks said that Church welfare and humanitarian aid averaged $40 million a year since 1985.
According to reports from LDS Charities, the Church averaged $152.5 million a year in humanitarian aid between 2016 and 2020.
The average annual "expended to help those in need" from the Church in 2021-2022 was $963 million.
[88]↩︎
The lack of nonprofit activity or charitable giving is a central claim in Lars and David Nielsen's "Letter to an IRS Director" and further petitions by David.
In a 2020 article written by Peggy Fletcher Stack, retired tax attorney Julia Miner told the Salt Lake Tribune:
“Isn’t amassing wealth and then saving it the equivalent of ‘burying talents,’ that Christ condemned in the biblical parable? At some point, saving needs to be converted into good works and charitable giving.”
Senior columnist and author Jana Riess has documented her decision to stop paying tithing following the news of the Church's reserve fund. In 2022, Riess wrote:
I’m not saying the church does not engage in any charitable activities . . . Such efforts are beautiful and important — and not nearly enough.
[89]↩︎
In May 2023, Nate Oman, law professor at The College of William and Mary, wrote about the ratio of Church saving to spending:
I am surprised by that number . . . But it seems that relative to its size and revenues the Church spends at more or less exactly the rate of a conservatively managed university. Viewed in another way, the Church spends at exactly the rate it needs to spend in order to operate indefinitely.
- Nate Oman discusses the charge that the Church is hoarding wealth; argues that it appears that the Church is not, but the Church's lack of financial transparency means we cannot know for certain.
[90]↩︎
In response to initial whistleblower coverage in 2019, Hal Boyd and Lynn Chapman wrote an article in the Deseret News titled "The Washington Post says the Church of Jesus Christ has billions. Thank goodness" that defended the idea that the Church "actually stays out of debt and saves for a rainy day."
Reportedly, in response to the 2019 coverage, Mitt Romney told reporter Thomas Burr:
"I just noted that my church has a 100 billion dollar safety fund. I'm happy that they've not only saved for a rainy day, but for a rainy decade."
Both Tadd Walch of Deseret News and Aaron Miller of Public Square Magazine defended Church reserves as reasonable in May 2023, in response to whistleblower news coverage.
[91]↩︎
In 2019, Hal Boyd and Lynn Chapman wrote an article in the Deseret News lauding the idea that the Church "actually stays out of debt and saves for a rainy day." The headline read, "The Washington Post says the Church of Jesus Christ has billions. Thank goodness."
Reporter Thomas Burr claims that in 2019, then-Utah Senator Mitt Romney told him:
"I just noted that my church has a 100 billion dollar safety fund. I'm happy that they've not only saved for a rainy day, but for a rainy decade."
In 2023, Nate Oman, law professor at William and Mary, wrote about the ratio of Church saving to spending:
I am surprised by that number . . . But it seems that relative to its size and revenues the Church spends at more or less exactly the rate of a conservatively managed university. Viewed in another way, the Church spends at exactly the rate it needs to spend in order to operate indefinitely.
In 2023, both Tadd Walch in The Deseret News and Aaron Miller in Public Square Magazine defended Church reserves as reasonable.
Miller wrote:
If the whistleblower numbers are correct, the Church of Jesus Christ is maintaining an endowment equal to about 16 times its annual budget, a ratio that is within typical practices for endowed 501(c)(3)s. Many private foundations annually distribute a minimum of 5% of their total assets, making endowments equal to 20 times an annual budget very common.
Walch wrote:
This is the story of how the Church of Jesus Christ rose from a small band of believers with little to no money to become a global faith that has achieved a sweeping economic sufficiency that its earliest leaders sought from the start.
[92]↩︎
The whistleblowing message of former EPA employee David Nielsen objects to the amount in EPA's reserve fund relative to its spending on charitable actions.
Jana Riess said in Religion News Service in 2020 that she had decided to stop paying tithing in response to news of the Church's "nest egg in excess of $100 billion." In 2023, Riess wrote that Church charitable donations "are beautiful and important — and not nearly enough" when compared to the size of the Church's stockpile.
Eric Johnson with the Mormon Research Ministry wrote that:
While I think the church should be allowed to have some money in reserve (how much that ought to be can be a discussion for another time), I maintain that $100 billion is far too much for a nonprofit religious organization to hold.
[93]↩︎
The Church reports 17,002,461 total members worldwide (as of July 2023). Though exact numbers aren't available for the Church's reserve fund, $100,000,000,000 divided equally amongst those total members results in $5,881.50 per member.
- Church Newsroom reports that there are 17 million Church members.
[94]↩︎
In 2023, Aaron Miller in the BYU Marriot School estimated that if all market variables and church growth rate were entirely predictable, the church could operate without additional tithing revenue using EPA funds for about 16 years. Miller appeared on Let's Get Real with Stephen Jones and Faith Matters.
[95]↩︎
However, in Lars and David Nielsen's 2019 "Letter to an IRS Director," they offer an analysis that if every member stopped paying tithing, EPA "would still be able to cover all of the [Church's] unchanged costs in perpetuity," assuming the Church's expenses and investment growth rates stayed the same forever.
The Widow's Mite Report estimates that if the Church's reserve fund was used like an endowment, it would be "more than sufficient for all of the Church's needs" and could "support the Church indefinitely, even if all donations stopped this year."
[96]↩︎
Church expenses are not public knowledge, so estimation is required—but most estimates are around an annual expense of $6 billion.
60 Minutes repeated an estimated $6 billion in Church expenses without citing a source, but this number was also suggested by their interview guest, former EPA employee and whistleblower David Nielsen. David and Lars Nielsen's Letter to an IRS Director claimed:
"[The Church] is famously tight lipped about what its total tithes and donations are, but one EPA senior leader suspected in 2019 . . . maybe $5–$6 billion in expenses."
The Widow's Mite Report published a "2022 Estimated Church Inflows and Outflows" report estimating $6 billion in expenses for the Church.
Assuming $6 billion in expenses and $100 billion in the reserve fund, the reserve fund is 16.66 times greater than annual expenses.
[97]↩︎
According to Harvard's "Financial Report for Fiscal Year 2022," the value of Harvard's endowment was $50.9 billion at the end of 2022. That same report gives $5.4 billion in "total operating expenses" for the year 2022, For the year 2022, Harvard's endowment was 9.42 times larger than its annual expense. For the year 2021, Harvard's endowment was $53.2 billion with $5 billion in expenses, for a fund of 10.64 times its annual expense.
According to the "Consolidated Statements of Financial Position" of The Bill and Melinda Gates Foundation for 2022 and 2021, the foundation's total assets in 2022 were $69.02 billion in 2022 and $55.07 billion in 2021. The foundation's total expenses were 7.42 billion in 2022 and 5.36 billion in 2021. In 2022, the foundation's reserve was 9.33 times its expenses, and in 2021 its reserve was 10.27 times its expenses.
[98]↩︎
According to the Caring for Those in Need 2021 Annual Report, the Church spent $906 million on needs-based charitable giving.
The 2022 Those in Need Annual Report described a charitable expenditure totaling $1.02 billion.
The average of charitable expenditures for 2021 and 2022 is $963 million, or $1 billion rounded.
- The Church's 2021 Annual Report notes that it spent $906,000,000 on needs-based charitable giving for that year.
- The Church's 2022 "Caring for Those in Need" annual report reports a charitable expenditure of $1.02 billion.
[99]↩︎
In 2016, Dallin H. Oaks said that Church welfare and humanitarian aid averaged $40 million a year since 1985.
According to reports from LDS Charities, the Church averaged $152.5 million a year in humanitarian aid between 2016 and 2020.
The average annual "expended to help those in need" from the Church in 2021-2022 was $963 million.
The reason for the significant giving increase from 2016-2020 to 2021-2022 is the addition of fast offerings, bishop's orders, and charitable church operations to the total starting in 2021.
[100]↩︎
Starting with 2021, the Church made changes to its annual charitable giving report to be more broadly inclusive of more types of Church charitable giving. In contrast to previous years, these new reports are retitled as "Caring for Those in Need" instead of "LDS Charities" and feature a new distinguishment between two categories of giving.
The category of "Services Offered Primarily to Church Members" includes:
- Fast offering assistance.
- Bishop's orders for goods from storehouses and Deseret Industries.
- Church operations including Family Services counseling, employment centers, farms and food processing, and Deseret Industries.
The category of "Services Offered Generally" includes:
- Humanitarian projects "including charitable relief in communities across the world."
- Donated commodities of Church-produced goods, like to food banks or other agencies.
- Donated or discounted clothing through Deseret Industries,
- The Church's 2021 Annual Report notes that it spent $906,000,000 on needs-based charitable giving for that year.
- The Church's 2022 "Caring for Those in Need" annual report reports a charitable expenditure of $1.02 billion.
[101]↩︎
The Washington Post summarized the legal landscape around EPA when it first broke the whistleblowing story in 2019:
"IRS rules dictate that a nonprofit organization must carry out charitable activity that is 'commensurate in scope with its financial resources' to maintain its tax-exempt status. No threshold for this test is specified, and the agency instead considers examples case by case."
Relevant legal information can be found on the IRS.gov website and the U.S. Code of Laws.
[102]↩︎
Various tax law experts have also commented on the issue.
Sam Brunson, law professor and author of God and the IRS, has written on EPA's legality and tax status and cedes that, while complicated, EPA appears to be above board. In 2019 he wrote:
I know that many of you came to get an answer to the question whether the church broke the law. The short answer is no, it didn’t.
In response to initial whistleblower coverage about Church reserves in 2019, tax correspondent for Forbes Peter J Reilly wrote:
"Nothing To See Here Folks . . . there is nothing in the tax law that prevents churches from accumulating wealth."
Law professor at A&M University College of Law, Daryl Jones, wrote in a blog article in response to the 2023 60 Minutes Church fund whistleblower episode:
"Although the Church ran afoul of SEC laws by its own admission, I still don't see much from a tax exemption standpoint . . . Churches can do whatever they want with their tax exemption."
[103]↩︎
In 2023, the SEC fined the Church and EPA a total of $5 million for obscuring their investments by filing Form 13F (which discloses investments) through "clone LLCs."
An article from the SEC summarized the violation as "failing to file forms that would have disclosed the Church’s equity investments, and for instead filing forms for shell companies that obscured the Church’s portfolio and misstated Ensign Peak’s control over the Church’s investment decisions."
The Church described the result of the SEC's order:
"We reached resolution with the SEC. We affirm our commitment to comply with the law, regret mistakes made, and now consider this matter closed."
[104]↩︎
In a 2016 paper published by Texas A&M University School of Law, law professor Terri Lynn Helge briefly summarized tests applied to nonprofits:
In general, organizations described in Section 501(c)(3) must satisfy a five-part test: (i) the organizational test; (ii) the operational test; (Ili) the prohibition on private inurement; (iv) the prohibition on political campaign intervention; and (v) the limitation on lobbying activity.
Full requirements for nonprofits can be found on IRS.gov or in tax law repositories.
[105]↩︎
As summarized from law professor Terri Lynn in 2016, the organizational test requires that a nonprofit be organized for one of the approved exempt purposes listed in Section 501(c)(3), and that purpose must be reflected in their articles of organization.
According to IRS.gov, exempt purposes are:
charitable, religious, educational, scientific, literary, testing for public safety, fostering national or international amateur sports competition, and preventing cruelty to children or animals. The term charitable is used in its generally accepted legal sense and includes relief of the poor, the distressed, or the underprivileged; advancement of religion; advancement of education or science; erecting or maintaining public buildings, monuments, or works; lessening the burdens of government; lessening neighborhood tensions; eliminating prejudice and discrimination; defending human and civil rights secured by law; and combating community deterioration and juvenile delinquency.
[106]↩︎
In a 2016 paper, law professor Terri Lynn said the operational requirement means a nonprofit must operate primarily in activities that accomplish exempt purposes.
One part of the operational test—"the private benefit doctrine"—requires a nonprofit to serve a public interest and not a private one, or to primarily help people who are part of the charitable class set out by the nonprofit's purpose.
Another part of the operational test—the "commerciality doctrine"—states that a nonprofit should not engage in too much nonexempt commercial activity. How much is "substantial nonexempt commercial activity" can be determined by two alternate tests: the commensurate in scope test and the primary purpose test.
[107]↩︎
According to a summary of IRS requirements by law professor Terri Lynn, a nonprofit must serve a "charitable class" primarily and only be permitted to incidentally benefit private persons. As per the IRS, these charitable classes include the poor, needy, and distressed as well as for the advancement of social goods like religion, education, and public works.
Private inurement, then, is when a nonprofit "insider" deliberately and substantially leverages an organization's assets not to benefit a charitable class but to enrich private purposes.
- IRS defines different approved charitable classes and definitions of charity.
- Terri Lynn Helge of Texas A&M University School of Law summarizes requirements and tests for tax-exempt organizations.
[108]↩︎
As summarized by tax professor Terri Lynn, if a charitable nonprofit engages in substantial lobbying (advocating for or against legislation or rallying others to do so), it becomes an "action" organization and no longer qualifies for tax exemption.
Further, as declared on IRS.gov, "all section 501(c)(3) organizations are absolutely prohibited from directly or indirectly participating in, or intervening in, any political campaign on behalf of (or in opposition to) any candidate for elective public office."
[109]↩︎
In 2019 the Washington Post explained a particular test to see if a non-profit is sufficiently carrying out charitable activities. This test is referred to as the "commensurate test":
"IRS rules dictate that a nonprofit organization must carry out charitable activity that is 'commensurate in scope with its financial resources' to maintain its tax-exempt status. No threshold for this test is specified, and the agency instead considers examples case by case."
The commensurate test was established by Revenue Ruling 64-182, 1964-1 C.B. 186 in 1964.
In educational material about Revenue Ruling 64-182, the IRS Exempt Organizations division explains that if a fundraising nonprofit passes the commensurate test, including through fundraising for another charitable nonprofit, it can continue being tax-exempt:
"If this test is met, exemption will not be foreclosed to an organization notwithstanding that its primary fundraising activity in carrying out its purposes is not inherently charitable or is an unrelated trade or business."
[110]↩︎
The full text of the Revenue Ruling that establishes the commensurate test for determining whether a non-profit organization is carrying out charitable activities reads:
Rev. Rul. 64-182, 1964-1 C.B. 186
A corporation organized exclusively for charitable purposes derives its income principally from the rental of space in a large commercial office building which it owns, maintains and operates. The charitable purposes of the corporation are carried out by aiding other charitable organizations, selected in the discretion of its governing body, through contributions and grants to such organizations for charitable purposes. Held, the corporation is deemed to meet the primary purpose test of section 1.501(c)(3)-1(e)(1) of the Income Tax Regulations, and to be entitled to exemption from Federal income tax as a corporation organized and operated exclusively for charitable purposes within the meaning of section 501(c)(3) of the Internal Revenue Code of 1954, where it is shown to be carrying on through such contributions and grants a charitable program commensurate in scope with its financial resources.
An organization may not consider itself exempt from tax merely because it falls within the scope of this Revenue Ruling. In order to establish its status, an organization claiming exemption under section 501(c)(3) of the Code should file its application on Form 1023, Exemption Application, with the District Director of Internal Revenue for the internal revenue district in which is located the principal office of the organization. See section 1.501(a)-1 of the Income Tax Regulations.
- The IRS publishes the text of "Rev. Rul. 64-182, 1964-1 C.B. 186," the commensurate test.
[111]↩︎
The commensurate test was first established in a ruling about the nonprofit status of a corporation that rented out a commercial office building to raise funds to aid other charitable organizations.
According to NEO Law Group, since its inception, the commensurate test was only used once in 1990 before being neglected until 2008. The high-profile 1990 ruling which revoked an organization's tax exemption, as well as the commensurate test in general, was seen as controversial and worryingly arbitrary.
In 2008, Commissioner Steven Miller of the tax-exempt and government-entities division of the IRS declared a new commitment to utilize the commensurate test.
[112]↩︎
An informational text produced by the Exempt Organizations division of the IRS titled "Update on Fundraising" (1986 EO CPE Text) discussed the ambiguous or "flexible" nature of the commensurate test on a case-by-case basis:
We believe that the commensurate test of Rev. Rul. 64-182 is sufficiently flexible . . . Inherent in the application of the commensurate test is a resort to the particular facts and circumstances of each fundraising organization. There is no fixed percentage of income that an organization must pay out for charitable purposes.
CharityLawyer, a law blog for nonprofits produced by Caritas Law Group P.C., summarized the issue:
Unfortunately, neither the Code nor the Treasury Regulations state what it means to be commensurate in scope. The IRS first introduced the concept in a relatively obscure 1964 ruling . . . Since then, the IRS has applied the test to reach the desired result, often without a clear legal rationale. As a result, the IRS' various applications of the commensurate test have muddied the waters so that no uniform understanding of what it means to be commensurate in scope has taken shape. Historically, the IRS has applied the commensurate in scope test differently in different contexts.
- IRS discusses the commensurate rule; if an organization meets the test outlined in Rev. Rul. 64-182, "exemption will not be foreclosed."
- Ellis Carter discusses the Commensurate Test on the Charity Lawyer Website.
[113]↩︎
The Washington Post, who first broke the 2019 Nielsen whistleblowing story in the mainstream news, wrote of David Nielsen:
He is seeking a reward from the IRS, which offers whistleblowers a cut of unpaid taxes that it recovers.
This claim was repeated in the Deseret News.
Neither David or Lars Nielsen disputed this claim. Concerning the whistleblower program and potential rewards associated with it, David stated, "I don't profess to understand it. I'll tell ya I'm grateful for it. I really am." Lars Nielsen claimed that people would be "honored by how Dave would choose to spend any reward granted by the IRS."
[114]↩︎
The specific violation was stated by the SEC:
Ensign Peak violated Section 13(f)(1) of the Exchange Act and Rule 13f-1 thereunder by failing to file Forms 13F in Ensign Peak’s name.
Ensign Peak also violated Section 13(f)(1) of the Exchange Act and Rule 13f-1 thereunder by filing misstated Forms 13F in the names of LLCs created for the sole purpose of filing Forms 13F.
- SEC filing article addressed against the Church.
- The SEC order of the LCC registered by the Church and Ensign Peak Advisory Inc., in Delaware.
[115]↩︎
The SEC press release stated:
“We allege that the LDS Church’s investment manager, with the Church’s knowledge, went to great lengths to avoid disclosing the Church’s investments, depriving the Commission and the investing public of accurate market information,” said Gurbir S. Grewal, Director of the SEC’s Division of Enforcement.
The Church responded by stating:
"We affirm our commitment to comply with the law, regret mistakes made, and now consider this matter closed."
- Church Newsroom publishes the Church's response concerning the SEC filing.
- SEC filing article addressed against the Church.
[116]↩︎
During the 2023 fiscal year, which was from October 1, 2022 to September 30, 2023, the SEC filed 784 enforcement actions, which resulted in $4.949 billion in fines. The EPA fine was just one of these 784 enforcements actions. The resulting average fine for the fiscal year 2023 would have been $6,312,500 dollars, making the $5 million fine a below-average fine.
- SEC Announces Enforcement Results for Fiscal Year 2023, the year the Church was fined.
- SEC filing article addressed against the Church.
[117]↩︎
In 2024, the SEC charged 11 institutional investment managers with "failing to file reports, known as Forms 13F, that they were required to file because they have discretion over more than $100 million in certain securities." 9 of the 11 firms were required to to pay fines, ranging in value from $175,000 to $725,000. Unlike Ensign Peak Advisors, these firms had failed to file any Forms 13F, rather than filing various Forms 13F under different "shell companies".
Previous publicized Form 13F violations have resulted in a $100,000 fine in 2007, and a $12,500 fine in both 2001 and 1996.
[118]↩︎
The Church owns many for-profit companies, including Bonneville International, Bonneville Communications, Deseret News, Deseret Books, and Beneficial Life.
The Church states that:
The Church and its affiliates follow the tax laws of countries where the Church has a presence. The Church pays taxes, which may consist of income, property, sales, value-added, and other taxes.
- Church issues article about Church finances and how they are administered.
- Deseret Management Corporation website lists for-profit corporations owned by the Church.
[119]↩︎
This report is read in the annual General Conference meetings during April. It has been read in every General Conference since at least 1906.
The 2024 report concluded:
Based upon audits performed, Church Auditing is of the opinion that, in all material respects, contributions received, expenditures made, and assets of the Church for the year 2024 have been recorded and administered in accordance with Church-approved budgets, accounting practices, and policies. The Church follows the practices taught to its members of living within a budget, avoiding debt, and saving against a time of need.
Auditing reports from previous years have all concluded similarly, noting that Church spending is in alignment with Church budgets, practices, and policies. The Church is not audited by any external agencies.
- Samuel D. Brunson publishes a history of the Church's financial transparency in Dialogue.
- Church Auditing Department Report, 2024.
[120]↩︎
Registered charities in Canada are required to file a T3010 Registered Charity Information Return on a yearly basis. This form requires disclosure of various financial information, including charity revenues, expenses, assets, and liabilities. The return must be submitted within 6 months of the end of the previous fiscal year, and becomes a publicly available document.
- Summary of annual financial reporting requirements according to Canadian law.
- Government of Canada Website discusses reporting obligations for Non-for-profit corporations; the Church is required by Canadian law to disclose its financials in Canada.
[121]↩︎
Registered charities in the United Kingdom are required to disclose their finances every year, in a report known as an "Annual Return". This return must be submitted within 10 months of the end of the previous fiscal year. Annual Returns become publicly available documents.
- Guidance from the UK government on finances of faith charities.
- Publication of Church's financials in the United Kingdom.
[122]↩︎
Registered charities in Australia are required to disclose their finances in an annual financial report. For medium and large-sized charities (including the Church), this report must include statements concerning financial position, changes in equity, cash flows, and comprehensive income.
- Annual Financial Report Requirements for charities in Australia.
[123]↩︎
In the United States, most non-profit organizations are required to file an IRS Form 990, which includes financial data about the organization. However, churches are exempt from filing this form. Due to this exemption, the Church has no legal requirement to be financially transparent. Most other countries around the world similarly do not require financial disclosures from the Church.
- IRS report explaining form 990 and exceptions.
[124]↩︎
For example, Edward Partridge gave annual public statements on Church finances beginning in 1832 and ending in 1838, when the Latter-day Saints were forced from Missouri. Partridge only gave an accounting of the Saints under his supervision in Missouri, not of the whole Church.
During his time as Church president, Brigham Young gave irregular financial reports.
- Samuel D. Brunson publishes a history of the Church's financial transparency in Dialogue.
- D. Michael Quinn surveys Church finances from the 1830s to 1990s.
[125]↩︎
President John Taylor stopped the annual financial report in April 1884, stating that "it is none of the business of outsiders to know about our financial matters." This was in response to the federal anti-polygamy laws passed in the 1880s, which greatly harmed Church finances.
- John Taylor states that outsiders don't need to know about church finances.
[126]↩︎
This practice was started by Joseph F. Smith in 1915, with a report concerning the incomes and expenditures of the Church in 1914. For the next forty-four years, Church income and expenditures were reported in the annual General Conference in April. David O. McKay ended the practice after 1959 following significant deficit spending and investment losses.
- D. Michael Quinn surveys Church finances from the 1830s to 1990s.
- Samuel D. Brunson publishes a history of the Church's financial transparency in Dialogue.
[127]↩︎
Ensign Peak Advisors, Inc.'s federal EIN is 84-1432969 and it's entity number registered in Utah is 1376719-0140. EPA is a 501(c)(3) nonprofit and a religious organization, and files a 990T tax return.
[128]↩︎
The terms "support organization" and "integrated auxiliary" are terms defined by the IRS associated with tax exemption that have unique qualifications, legal status, and behaviors. Briefly, a "support organization" is run similarly to a private foundation, provides financial help to a nonprofit, and receives tax benefits in return. An "integrated auxiliary of a church" is affiliated with a church, considered both a 501(c)(3) and a public charity one of three types under 509(a)(1), (2), or (3), and often isn't required to file a tax return (though EPA does).
In its order against the Church and EPA, the SEC described EPA as "an integrated auxiliary of the Church to manage the Church’s investment securities."
[129]↩︎
In a thread of tweets from February 2023, tax professor Sam Brunson responded to the whistleblowing report David Nielsen filed to the US Senate, specifically about EPA's role as an auxiliary nonprofit and investment manager to the Church. Brunson wrote:
In 1971 (Rev. Rule 71-529 for anyone who wants to follow along), the IRS asks whether a putatively tax-exempt org, the purpose of which is to manage and invest funds for other tax-exempt orgs with a below-market fee, qualified as exempt . . . The IRS ruled that it was. This looks really similar to the business model of EPA to me . . . Which is to say, I suspect EPA meets the terms of tax exemption laid out by the IRS.
Revenue Ruling 71-529 of 1954 upholds the tax exemption of a nonprofit that supports another nonprofit by "assisting them to manage more effectively their endowment or investment funds" with some qualifications.
Elsewhere, Brunson has discussed EPA as a "supporting organization" and "integrated auxiliary" and cited two other Revenue Rulings (64-182's "commensurate test" and the "charitable purpose" of a trust fund in 78-41) as reasonable evidence for IRS approval of EPA.
[130]↩︎
In 2022, editor of religious studies and history for Oxford University Press Robert Repino wrote in Sojourners that EPA was an example of why churches should not get automatic tax exemption for activities that don't seem inherently charitable, like building reserve funds.
In the whistleblowing Letter to an IRS Director, Lars and David Nielsen object to EPA's nonprofit status and petition the US Congress and Senate to change the classification of supporting organizations of "behemoth, unchecked religions" to comply with more robust regulation or be stripped of tax exemption.
- Robert Repino argues that Ensign Peak Advisors is an example of why churches should not get automatic tax exemption for activities that do not seem inherently charitable.
- The text of Lars Nielsen's "Letter to an IRS Director."
[131]↩︎
According to David Nielsen in Letter to an IRS Director, "top COP [Church] and EPA leaders" have misled the IRS and the public "because they were afraid of losing their tax-exempt status." EPA's Chief Investment Officer Robert Nydegger allegedly said, “the biggest risk to Ensign Peak is the loss of its tax-exempt status.”
The SEC's characterization of EPA actions preceding the 2023 SEC fine suggest a fear or apprehension of "negative consequences" associated with increased scrutiny of EPA's large investment portfolio, but does not specify what EPA considers those consequences to be.
- The text of Lars Nielsen's "Letter to an IRS Director."
- The SEC order of the LCC registered by the Church and Ensign Peak Advisory Inc., in Delaware.
[132]↩︎
The Church has had a rocky financial history for most of its lifetime, as detailed by historian Leonard Arrington quoted in the Deseret News:
Congress had sought to quash early Latter-day Saints’ polygamy for years. The Edmunds-Tucker Act had real teeth. It attacked church businesses and seized church assets. A combination of government interference, business setbacks and poor investments left the church defenseless against the coming of the second-worst depression in U.S. history...
[133]↩︎
David Nielsen's LinkedIn, CBS's 60 Minutes, The Washington Post, and Nielsen's own memorandum to the Senate confirm this employment timeline.
Nielsen began as a Portfolio Manager and was a Senior Portfolio Manager at the time of his departure. Nielsen raised various concerns about EPA business and administration during his employment. In 2019, Nielsen told his managers he wanted to follow his wife and children in not attending church, which managers informed him was not compatible with continued employment. This problem was not resolved, and Nielsen's employment terminated.
[134]↩︎
The Washington Post story, "These Mormon twins worked together on an IRS whistleblower complaint over the church’s billions — and it tore them apart," relies on Lars Nielsen as their primary source, though Lars provided them with "correspondence from his brother" for David's perspective.
As the Post reports, Lars attended Harvard, read famous evolutionary biologist and atheist Richard Dawkins, and cultivated an "increasingly science-based worldview." This became"a central issue in a protracted divorce from his wife" alongside the tragic loss of a child. After a year of therapy, Lars and his wife split and Lars officially resigned from Church membership. Lars' wife and three children remained Church members, as of the 2020 story. Lars posted more of his experiences with his religion—including discussion of his "faith crisis" and "admiration" of the CES Letter—in a Newsweek article.
And according to the Post, David "became troubled" by EPA operations within months of being hired. He expressed concerns to his managers and was reluctant to sign NDAs. In 2015, David's wife and children stopped attending church and in 2019 David told his managers he wanted to "scale back his attendance, too." This ultimately resulted in ended employment for David, and the whistleblower report to the IRS followed. The Post asked a Church spokesman for comment on David's membership status, to no comment.
- Washington Post reports on David Nielsen and the Church's $100 billion fund; notes that Nielsen was asked to sign a nondisclosure agreement that would bind him and his heirs.
- Lars Nielsen explains to Newsweek on why he published letter to an IRS director.
[135]↩︎
The Washington Post quotes correspondence with Lars Nielsen, where Lars calls the whistleblowing project he worked on with his brother David "the Mormon Giga-Church."
As the Post reports, when David decided to file a complaint with the IRS, he turned to his brother Lars for help, who had left the Church "years before."
For the twin brothers David and Lars, The "Giga-Church" project two months of work and ten-hour days, going through EPA accounts together, temporarily pausing Lars' heath-care consulting business, and taking inspiration from a popular piece of Church critique, "Letter to a CES Director," for the title and spirit of their work, "Letter to an IRS Director."
- Washington Post reports on David Nielsen and the Church's $100 billion fund; notes that Nielsen was asked to sign a nondisclosure agreement that would bind him and his heirs.
- Paul Glader reports on the whistleblower report and the Church's finances for Religion Unplugged.
[136]↩︎
In a Newsweek article, Lars Nielsen shared why he published "Letter to an IRS Director," including mention of what he called "my faith crisis in 2010."
The Washington Post interviewed Lars and reports details about Lars's journey out of the Church, including the adoption of "an increasingly scientific worldview," and reading books by famous atheist Charles Dawkins.
Lars' sentiment towards the Church informed his approach to "Letter to an IRS Director". The title of the complaint was meant as an homage to the famous 2013 Church-critical treatise, "Letter to a CES Director." The document itself includes an often-derisive, sarcastic tone, with scriptural jokes, pop culture references, rebuttals to "apologists", and links to Church-critical sources.
Lars admits to writing "Letter to an IRS Director" "in the style (and in admiration) of 'Letter to a CES Director'" to give Latter-day Saints with questions "hours of immersive, binge-worthy, relatable, and rich content."
[137]↩︎
The Washington Post interviewed Lars Nielsen about working with his brother on their whistleblowing complaint and included personal details about the twin brothers.
As the Post reports, Lars "married into the elite of the church," as his wife was "related to senior figures in the church." Then, as "Lars’s doubts continued to grow" he and his wife "skirmished about their religious views." Then, in 2011, their fourth child was stillborn. In 2012, Lars and his wife filed for divorce. Their religious differences were recorded as a major issue in divorce filings.
- Washington Post reports on David Nielsen and the Church's $100 billion fund; notes that Nielsen was asked to sign a nondisclosure agreement that would bind him and his heirs.
[138]↩︎
In a 60 Minutes interview, David Nielsen expressed disappointment that working for EPA did not feel to him like it was "work for a charity," or "really going to build the kingdom," or would "do good with things"—and instead seemed like his work was a "clandestine hedge fund" and that they "just grew the bank account." When asked why he was speaking now, Nielsen replied, "This is just too important to fall through the cracks."
Nielsen's memorandum to the U.S. Senate briefly summarizes the moral and substantive arguments that Nielsen puts forward:
"David A. Nielsen, a lifelong Church member with Wall Street experience, was recruited by EPA in 2010. He left a financially lucrative career to work for EPA, which he believed would be a worthwhile cause. When Mr. Nielsen became aware that EPA served no charitable or religious purpose, and that EPA’s management led to assets 'going missing' within EPA, he attempted to correct these problems. However, EPA’s principals continuously refused to take corrective action. Finally, in 2019, Mr. Nielsen took the courageous step of resigning, and then provided the IRS Whistleblower Office with a pro se submission in November 2019. "
- Transcription of CBS's "60 Minutes" coverage of the whistleblower report.
- Text of David Nielsen 's affidavit concerning Ensign Peaks Advisors, Inc., submitted to the U. S. Senate Finance Committee.
[139]↩︎
In "Letter to an IRS Director," Lars Nielsen claims to have written "every word" and "did so with information the whistleblower freely supplied." Everywhere in the document, Lars takes steps to conceal the identity of David Nielsen and simply refers to him as "the whistleblower."
The close collaboration between brothers Lars and David Nielsen on the whistleblowing project is reported in Religion Unplugged and The Washington Post, though the process of publishing the report online and with news outlets was carried out by Lars only without David's consent.
[140]↩︎
According to IRS.gov:
The IRS Whistleblower Office pays monetary awards to eligible individuals whose information is used by the IRS. The award percentage depends on several factors, but generally falls between 15 and 30 percent of the proceeds collected and attributable to the whistleblower's information.
- IRS reports that whistleblowers can be awarded between 15% to 30% of total proceeds collected, if the IRS moves ahead based on the information provided.
- IRS Website discusses the monetary award to whistleblowers; reward may fall between 15% to 30% of the proceeds collected by the IRS.
[141]↩︎
In Nielsen's memorandum to the Senate and his appearance on 60 Minutes, he frames his departure from EPA as a resignation on moral grounds. However, his resignation letter to EPA (as reported by The Washington Post) describes a more complex situation involving Nielsen's decreased church attendance and manager policies. The Post reports:
On July 23, David went to his managers at Ensign with a dilemma, he recounted later in a resignation letter. . . . David decided to leave his job, writing in the Aug. 29 resignation letter that among his reasons was that “my supervisor intimated” that if David was not fully committed to the church, his being in the office might “distract others from their work.” He said his last day would be Oct. 4. But on Sept. 3, David received a reply from human resources informing him that managers had decided that, “in the best interest of all parties,” he should leave that day, according to the copy of the company letter. He would receive a month’s pay and two months’ health insurance.
[142]↩︎
"Letter to an IRS Director," though the document purports to be written entirely by Lars Nielsen, features information, emails, and claims from David Nielsen. For instance, in "EXHIBIT O.1" consists of an email from David Nielsen to Roger Clarke expressing concern over "insufficient controls around pending cash receipts." The note in the margin labeled "Comment [2]" asserts this is a "potential mechanism for fraud."
Nielsen's memorandum to the U.S. Senate gives a brief summary of these disagreements:
When Mr. Nielsen became aware that EPA served no charitable or religious purpose, and that EPA’s management led to assets 'going missing' within EPA, he attempted to correct these problems.
- The text of Lars Nielsen's "Letter to an IRS Director."
- Text of David Nielsen 's affidavit concerning Ensign Peaks Advisors, Inc., submitted to the U. S. Senate Finance Committee.
[143]↩︎
According to The Washington Post, which obtained correspondence from David when interviewing his brother Lars, David "bristled at being asked to sign a nondisclosure agreement that would bind not only him but his heirs."
- Washington Post reports on David Nielsen and the Church's $100 billion fund; notes that Nielsen was asked to sign a nondisclosure agreement that would bind him and his heirs.
[144]↩︎
According to The Washington Post a central issue in Nielsen's departure was his lack of Church attendance.
In 2015, David's wife and children stopped attending church. David intended to follow suit, but sought an accommodation to continue working at Ensign Peak Advisors. This accommodation was not granted, and David was told he would need to "remain committed enough to ensure the renewal of his 'temple recommend.'"
David submitted a resignation letter on August 29, 2019 and was told on September 3 that "'in the best interest of both parties', he should leave that day." He received a month of pay and two months' of health insurance.
- Washington Post reports on David Nielsen and the Church's $100 billion fund; notes that Nielsen was asked to sign a nondisclosure agreement that would bind him and his heirs.
[145]↩︎
In 2018, the Church Newsroom cited a talk by Gérald Caussé, “In the Lord’s Way: The Spiritual Foundations of Church Financial Self-Reliance,” and said:
". . . the Church also sets aside funds each year for future needs. These funds are added to Church reserves, which include stocks and bonds, taxable businesses, agricultural interests and commercial and residential property."
Presiding Bishop of the Church Gérald Caussé's talk was published in the Newsroom and the Ensign in 2018. He discussed Church finances, tithing, self-reliance, and provident living. He also included some discussion of how the Church invests:
The Church’s investments are managed by a professional group of employees and outside advisors. Risks are diversified, consistent with wise and prudent stewardship and modern investment management principles. In the parable of the talents, we are taught to “improve ourselves and strive for perfection.”[27] The Lord chastised a servant who had not invested the money entrusted to him but instead had hid that money in the earth. He characterized the servant as “wicked and slothful”[28] for not investing that money for a reasonable financial return. Consistent with this spiritual principle, the Church’s financial reserves are not left idle in nonproductive bank accounts but are instead employed where they can produce a return.
[146]↩︎
David Nielsen describes EPA-managed assets in several categories:
- Treasury Assets
- Affiliate Assets
- US Equity
- International Equity / Foreign Exchange
- Private Equity
- Hybrid
- Credit / Duration
- Cash
- Real Estate
These siloes are arranged in a visualization that serves as "Exhibit A" on page 41 of "Letter to an IRS Director."
As to the composition of those assets in terms of invested tithing versus returns, Nielsen offered an estimation on page 26 of "Letter to an IRS Director":
Using various methods for tracing tithing principal separate from tithing investment returns, the whistleblower’s best estimate for the composition of EPA’s OAUM [owned assets under management] today is: 23% tithing principal, 60% investment returns, and 17% tax breaks.
- The text of Lars Nielsen's "Letter to an IRS Director."
[147]↩︎
In 2018, in the Church Newsroom and in a talk by Presiding Bishop Gérald Caussé, Church investments are described as available and accessible for various needs. Caussé said:
These invested funds can be accessed in times of hardship to ensure the ongoing, uninterrupted work of the Church’s mission, programs, and operations and to meet emergency financial needs. The funds can also be used to provide additional financial resources as needed to support Church growth as prophecy is fulfilled that the gospel of Jesus Christ will be taught and the Church established throughout the world.
Additionally, as described in the Newsroom, "some investments serve a dual purpose"—like how investing in "good farms" can produce food "to feed people should there come a time of need" or how "investment in City Creek . . . enhanced the environs of Temple Square and underscored a commitment to Salt Lake City" while increasing economic activity in the city during a financial downturn.
[148]↩︎
David and Lars Nielsen's whistleblowing complaint describes "the overall liquidity of EPA’s portfolio is uncharacteristically high."
In what is allegedly an internal EPA presentation slide labeled "March 2013, New Staff Orientation Deck" as "Exhibit G" in David and Lars' Nielsen's "Letter to an IRS Director," in a section labeled "Role of Ensign Peak Advisors" and amongst other directives is the internal goal to:
• Maintain adequate liquidity for Church operations and investment flexibility
- The text of Lars Nielsen's "Letter to an IRS Director."
[149]↩︎
Included as "Exhibit R" of "Letter to an IRS Director," allegedly internal EPA slides describe a portfolio designed for ease of liquidation:
- "Liquidity (liquidation within 3-months) 75%+" from "September 2013, 'EPA Policy Book.'"
- "Cash-flow: More than $7bn could accumulate within 6 months with the roll-off of our cash-like investments" from allegedly "March 2013, 'Framework and Exposures.'"
- "Liquidity: The vast majority of the portfolio is in liquid instruments. Within 3 months, we could potentially liquidate close to 85% of the portfolio" from allegedly "March 2013, 'Framework and Exposures.'"
- "It was also approved that the portfolio should maintain a minimum liquidity level of 75% or more that would be available within a 90-day window." from allegedly "September 2013, 'EPA Policy Book.'"
- The text of Lars Nielsen's "Letter to an IRS Director."
[150]↩︎
As defined by the National Council of Nonprofits and Investopedia, an endowment is usually invested assets owned by an organization that are grown over time and produce interest that is then used to subsidize the organization's expenses.
As the National Council of Nonprofits makes clear, "Endowments are not the same as reserve funds."
Investopedia defines a reserve fund as "a savings account or other highly liquid asset set aside by an individual or business to meet any future costs or financial obligations, especially those arising unexpectedly."
[151]↩︎
The Wall Street Journal in 2020 summarized how EPA funds were different than an endowment:
"Whereas university endowments generally subsidize operating costs with investment income, Ensign Peak does the opposite. Annual donations from the church’s members more than covers the church’s budget. The surplus goes to Ensign Peak."
The question of "money going out" of EPA was a central issue in an episode of 60 Minutes. First Counselor in the Presiding Bishopric Christopher Waddell reported that in a given month "an average of nine transfers" routed money from EPA back to the Church "to fund all church operations." But whistleblower David Nielsen claimed a distinction between EPA's long-term investments and their "cash accounts," with those investments and their returns being held in reserve with few exceptions.
- Wall Street Journal's coverage of Church's $100 billion fund.
- Transcription of CBS's "60 Minutes" coverage of the whistleblower report.
[152]↩︎
For example, Jacob 2:18-19 instructs:
18 But before ye seek for riches, seek ye for the kingdom of God. 19 And after ye have obtained a hope in Christ ye shall obtain riches, if ye seek them; and ye will seek them for the intent to do good—to clothe the naked, and to feed the hungry, and to liberate the captive, and administer relief to the sick and the afflicted.
- Jacob warns against pursuing wealth before the kingdom of God.
[153]↩︎
For example, 1 Timothy 6:10 states:
For the love of money is the root of all evil: which while some coveted after, they have erred from the faith, and pierced themselves through with many sorrows.
- Paul says that the root of all evil is the love of money.
[154]↩︎
The National Council of Nonprofits, in defining "Endowments," wrote:
Endowments are commonly used by large institutions, such as universities and hospitals, but also may play a role in any charitable nonprofit’s financial management and/or revenue strategy.
- National Council of Nonprofits Website discusses what an "endowment" is.
- Tim Smith discusses what an Endowment is on Investopedia Website.
[155]↩︎
In The Washington Post in 2022, Danielle Douglas-Gabriel described a movement for wealthy schools to pay more, and included a ranking of universities by endowment size. A sampling of the top five with fund values:
- Harvard University, $51.9 billion
- University of Texas System, $42.9 billion
- Yale University $42.2 billion
- Stanford University, $37.8 billion
- Princeton University $37.6 billion
- The Washington Post reports that Harvard University's endowment is $51.9 billion, followed by the University of Texas System with $42.9 billion.
[156]↩︎
The Sovereign Wealth Fund Institute hosts a "Largest Healthcare Foundation Rankings by Total Assets," the top five of which are summarized:
- Kaiser Foundation Health Plan, $76.4 billion
- CommonSpirit Health, $49.4 billion
- Mayo Clinic, $27.7 billion
- Trinity Health Corporation, $27 billion
- Howard Hughes Medical Institute $22.5 billion
- Sovereign Wealth Fund Institute list the top 43 healthcare foundations; their total wealth is $464,232,997,754.
[157]↩︎
For instance, the Sri Padmanabhaswamy Temple in Kerala, India has an estimated $20 billion in treasure including "sacks full of diamonds, gold coins and jewellery," according to the BBC.
Or in another instance, the German newspaper Handelsblatt conducted an investigation that claimed the Catholic Church in Germany collected $7.1 billion in tax in a year and has assets of around $31.2 billion, made up of "financial investments" and “equities or real estate, particularly in western Germany, donated by former nobility,” Handelsblatt reports.
[158]↩︎
The most noticeable financial difference between the Church and other religious organizations is the sizeable, centralized Church reserves managed by EPA. It has been argued that other religious organizations, like the Catholic Church, have greater assets, but the Church has a seemingly unique reserve in its dedicated purpose and accounting.
Another difference between the Church and many religious organizations appears to be the rarity of deficit spending, debt, or financial crises in the modern Church.
Comparing the Church's reserve to charitable (secular) nonprofits is most clearly distinguished by its function—these charitable organizations often utilize their funds as endowments and to feed into an operating budget, where the Church almost exclusively deposits into their reserve.
- The text of Lars Nielsen's "Letter to an IRS Director."
- During General Conference, N. Eldon Tanner describes his philosophy for financial "constancies."
[159]↩︎
Harvard University is a private research university in Cambridge, Massachusetts. It's partially funded by an endowment.
The National Center for Education Statistics lists Harvard as the top US college for endowment fund size.
- National Center for Education Statistics reports that Yale University's endowment at the end of 2021 was $31,201,686.
- Harvard University Website discusses Harvard's endowment for 2022.
[160]↩︎
According to Harvard's "Financial Report for Fiscal Year 2022," the value of Harvard's endowment was $50.9 billion at the end of 2022.
- Harvard's financial report for 2022, including endowment details and annual expenses.
[161]↩︎
Harvard's "Financial Report for Fiscal Year 2022" gives $5.4 billion in "total operating expenses" for the year 2022.
- Harvard's financial report for 2022, including endowment details and annual expenses.
[162]↩︎
In 2025, Harvard's 'About' page reports 24,596 undergraduate and graduate students, 20,667 faculty and staff, and over 400,000 alumni.
Dividing the endowment fund of $50.9 billion by 445,263 constituents results in $114,314.46 per constituent.
- Total Harvard Students, Faculty, and Alumni in 2025.
[163]↩︎
Yale University is a private research university in New Haven, Connecticut, and is partially funded by an endowment.
The National Center for Education Statistics lists Yale as the second-highest US college for endowment fund size.
- The "About Yale" page on the Yale University Website; notes it was founded in 1701.
- National Center for Education Statistics reports that Yale University's endowment at the end of 2021 was $31,201,686.
[164]↩︎
The Yale University Financial Report for 2021-2022 reports a value of $41.122 billion in the endowment, with total assets for the university reported at $54.72 billion.
The Yale Endowment 2021 report reports a market value of $42,28 billion for the endowment.
- Yale University reports an endowment worth $42,282,900,000 at the end of 2021.
- The Yale University Financial Report for 2021-2022 reports a value of $41.122 billion in the endowment, with total assets for the university reported at $54.72 billion.
[165]↩︎
The Yale University Financial Report for 2021-2022 reports total operating expenses of $4.651 billion for 2022.
Dividing the total endowment by this annual cost gives an approximation of year's worth of reserve, or 8.838 years.
- The Yale University Financial Report for 2021-2022 reports a value of $41.122 billion in the endowment, with total assets for the university reported at $54.72 billion.
[166]↩︎
Yale's Fall 2022 Fact Sheet lists 14,806 total students, 5,259 faculty, and 10,891 staff. In 2010, Yale Magazine listed 130,000 as a figure for total living alumni, which might serve as an approximation. Totaling these gives an estimated 160,956 constituents. Dividing the total endowment by this number gives an approximation of $255,349.29 per constituent.
- Yale University's Fact Sheet lists 14,806 total students, 5,259 faculty, and 10,891 staff.
- Yale Alumni Magazine reports that Yale University has 130,000 alumni as of May/June 2010.
[167]↩︎
Novo Nordisk Foundation is an international medical enterprise foundation started in Denmark. Its family of related organizations includes the pharmaceutical company Novo Nordisk, biotech company Novozymes, and its subsidiary that manages investments, Novo Holdings.
Novo Nordisk Foundation supports the life sciences industry and distributes grants to biomedicine, biotechnology, and other medical applications. Wikipedia reports that Novo Nordisk Foundation is the wealthiest charitable organization in the world by endowment value.
[168]↩︎
The 2022 Novo Holdings Annual Report (Novo Holdings is the controlling shareholder and investment manager for Novo Nordisk Foundation) reported "Total Investment Assets" of $805 billion Danish Krone, or $108 billion Euros.
Using the average Krone to dollar exchange rate for 2022 (7.0763 DKK to 1.0 USD), the investment assets equal $113.76 billion USD.
[169]↩︎
2022 expenses for the Novo Nordisk Foundation, its parent Novo Holdings, and a sister company Novozymes equaled around $174.4 million DKK, or about $24.65 million USD by 2022 average exchange rate.
Novo Nordisk Foundation gave out grants totaling 7.5 billion DKK, or $1.06 billion USD in 2022. They also gave 5.2 billion DKK in payouts, or about $735 million USD in 2022.
Adding expenses, grants, and payouts equals around $26.45 billion USD.
[170]↩︎
The Novo Nordisk Foundation, in its 2022 report, described the areas for its grant activities: "people’s health, the sustainability of society and the planet, and boosting the life science ecosystem." Though they describe their area of stewardship is global, representing their constituency as every person on the planet might be an unhelpful metric.
If you were to divide their reserve by the 7.97 billion world population in 2022, an approximate dollar per constituent of $14.95 USD could be given.
If calculating constituents by just employees, the Novo group family has a dollar per constituent of about $1.53 million USD.
The 2022 Annual Report for the Novo Nordisk Foundation lists a total of 74,196 employees for the Novo Nordisk Foundation Group, which includes Novo Nordisk and Novozymes. Novo Holdings employed 152 employees in 2022 for a total of 74,348 employees.
Neither world population nor employees make for a reasonable dollar per constituent, so "N/A" fills this table cell.
[171]↩︎
The Bill and Melinda Gates Foundation is a private foundation and reportedly the second-largest charitable organization in the world, as stated on Wikipedia or reported in Fortune. The foundation's goals include improving health, "giving [people] the chance to lift themselves out of hunger and extreme poverty," and promoting education, according to the foundation's fact sheet.
- Fortune reports that the Bill & Melinda Gates Foundation is the second-largest charitable organization in the world by assets with an endowment worth nearly $70 billion.
- The Bill & Melinda Gates Foundation Fact Sheet reports a total for its endowment as $67.3 billion as of December 31, 2022.
[172]↩︎
The audited Consolidated Financial Sheets for the Bill and Melinda Gates Foundation for 2022 lists total assets of $69.023 billion.
The Bill and Melinda Gates Foundation Fact Sheet (accessed August 1, 2023) reports a total for its endowment:
Foundation Trust Endowment as of December 31, 2022: $67.3 billion
- The Bill & Melinda Gates Foundation Fact Sheet reports a total for its endowment as $67.3 billion as of December 31, 2022.
- The audited Consolidated Financial report for the Bill & Melinda Gates Foundation for 2022 lists total asserts of $69.023 billion.
[173]↩︎
The audited Consolidated Financial Sheets for the Bill and Melinda Gates Foundation for 2022 lists total expenses, including charitable programs and operational costs, of $7,424,542,000.
Dividing the total foundation assets by the annual expense for 2022, an approximation of 9.299 years' worth of reserve operating costs can be given.
However, a stated purpose of the Foundation is to spend all of its reserves eventually:
Because Bill and Melinda believe the right approach is to focus the foundation’s work in the 21st century, we will spend all of our resources within 20 years after Bill's and Melinda's deaths.
- The audited Consolidated Financial report for the Bill & Melinda Gates Foundation for 2022 lists total asserts of $69.023 billion.
[174]↩︎
The Bill and Melinda Gates foundation embraces a global mission. As such, representing their constituency as every person on the planet might be an unhelpful metric,
If you were to divide their reserve by the 7.97 billion world population in 2022, an approximate dollar per constituent of $8.65 USD could be given.
If calculating constituents by just people employed by the foundation (1,818), the dollar per constituent would be $37.95 million USD.
Neither world population nor employees make for a reasonable dollar per constituent, so "N/A" fills this table cell.
- The Bill & Melinda Gates Foundation Fact Sheet reports a total for its endowment as $67.3 billion as of December 31, 2022.
[175]↩︎
The Sri Venkateswara Swamy Temple is a Hindu temple in the town of Tirumala in the Tirupati district in the state of Andhra Pradesh, India. The temple is managed by a trust called Tirumala Tirupati Devasthanams, which is controlled by the Andhra Pradesh government.
Sri Venkateswara Swamy is reportedly "the world's richest Hindu temple" according to Business Standard in 2023 with "almost double the estimated number of people visiting Vatican City" according to NDTV in 2007. The "richest Hindu temple" is contested.
[176]↩︎
The Economic Times reports the Sri Venkateswara Swami temple has about "Rs 2.5 lakh crore (about USD 30 billion)" in net worth.
The Times describes this worth in assets:
"Its assets include 10.25 tonnes of gold deposits in banks, 2.5 tonnes of gold jewellery, about Rs 16,000 crore of deposits in banks, and 960 properties across India. All these total to over Rs 2.5 lakh crore."
The Quint repeats the claim of "Rs 2.5 lakh crore" and describes its assets as "land parcels, buildings, cash, and gold deposits in the banks, given as offerings to the temple by devotees."
- The Economic Times reports on the Hindu temple in Tirupati, India: the Lord Venkateswara temple; reports it is worth $30 billion.
- Madhusree Goswami reports that the Lord Venkateswara temple is worth RS 2.5 lakh crore ($30 million approx).
[177]↩︎
In 2023, Business Standard lists a few expenses from the yearly budget for Tirumala Tirupati Devasthanam, the managing trust for the Sri Venkateswara Swami Temple. Though these expenses are probably not comprehensive, Business Standard lists them in descending order from "highest expenditure."
Totaled, these expenses are Rs 2,451.95 crore or 24,519,500,000 rupees.
On average in 2023, the Indian Rupee was worth 0.0122 US Dollars. At this rate, the Sri Venkateswara Swami Temple's annual expenses listed in Business Standard are about 297,779,519.70 USD.
By dividing the total reserve of $30 billion by that annual expense, an estimation of 100.75 years' worth of reserve fund can be given.
- Business Standard reports on the budget for the Tirumala Tirupati Devasthanam Hindu Temple in India.
- The average conversion rate for Indian Rupees to US Dollars in 2023, according to ExchangeRates.org.uk.
[178]↩︎
Sri Venkateswara Swami Temple is located in the southern coastal state of Andhra Pradesh in India.
According to the 2011 Indian Census, Andhra Pradesh has a population of 49,577,103, 90.87% of which are of the Hindu religion, meaning about 45,050,713 Hindus in the state containing the Sri Venkateswara Swami Temple.
By dividing the Temple's reserve funds by the number of Hindu people in its state, an approximation of dollars per constituents can be made of $665.92 USD.
- World Population Review notes that there are 1,093,780,000 Hindus in India.
- The 2011 India Census lists population by religious community.
[179]↩︎
The Sri Padmanabha Swamy Temple is a Hindu temple in Thiruvananthapuram, the capital of the state of Kerala, in India. The temple is managed by the Sri Padmanabha Swamy Temple Trust, instituted by the Travancore royal family.
In 2011, the Guinness Book of World Records attached to the temple the distinction of "Richest Hindu temple," though this is contested.
- Home page of the Website for the Sree Padmanabhaswamy Temple Trust.
- Guinness World Records reports that the richest Hindu Temple is the Sree Padmanabha Swanmi Temple in India; it is worth approx. $18 billion.
[180]↩︎
It's unclear the full value of assets associated with the Sri Padmanabha Swamy Temple, as the value of $20 billion is associated with the treasure in one vault.
In 2020, BBC reported that "one of the temple's vaults" of Sri Padmanabhaswamy was opened in 2011, and "it was found to contain riches worth more than $20bn."
2011 coverage from Indian news site NDTV described "vaults" plural containing "gold, jewels and statues worth an estimated $22 billion."
However, other sources like Forbes in 2015 claimed that when considering "recent treasure findings in several other vaults, the researchers are estimating could total over $1 trillion."
[181]↩︎
Business Standard in 2022 reported on a financial crisis for the Sri Padmanabha Swamy Temple. The temple is managed by the Travancore royal family and an anonymous "top person in the family" served as an informant for the article. That informant is quoted:
"Approximately the temple has a monthly expenses of around Rs one crore."
One crore, or ten million, Indian rupees at an average rate for 2023 is equal to about $121,445.00 USD. Multiplying that monthly expense by 12 gives annual expenses for the temple of around 1,457,340 USD.
Dividing the full fund size by that annual expense gives an estimation of 13,723.63 years' worth of expenses in reserve.
- Business Standards reports on the Sri Padmanabhaswamy temple's expenses; each month, its expenses is R. one crore or 10,000,000 rupees (approx. $120,000).
- The average conversion rate for Indian Rupees to US Dollars in 2023, according to ExchangeRates.org.uk.
[182]↩︎
There are approximately 19.16 million Hindi people in the Indian state of Kerala.
[183]↩︎
The Catholic Church in Germany is part of the global Catholic Church led by the Pope. The governing body for German Catholicism is the German Bishop's Conference. There are 29 dioceses in Germany.
In Germany, 8% to 9% of the income of registered church members is deducted automatically by the government as a tax.
[184]↩︎
International German business news site Handelsblatt conducted an investigation in 2018, saying:
According to calculations by Handelsblatt, Germany’s 27 dioceses are sitting on a fortune of at least €26 billion, likely making it Europe’s wealthiest Catholic institution aside from the Vatican itself. . . . More than €15 billion is tied up in financial investments and €20 billion is marked as fixed assets and invested in equities or real estate,
At an average exchange rate of 1 Euro to 1.1811 USD in 2018, this $26 billion Euros equals approximately $30.7 billion USD.
[185]↩︎
In 2021, Europe-based Catholic news site LA CROIX international reported:
The VDD has an annual budget of around €120 million ($146 million) which represents around 2% of the total resources of Germany's 27 Catholic dioceses and is overseen by the bishops' conference president.
VDD stands for "Federation of Dioceses of Germany," which LA CROIX defines as "the umbrella body coordinating the German Church's activities at federal level."
The full expenses of the Catholic Church in Germany are not publicly reported and unknown.
By diving the reported $30.7 billion by this reported annual budget, an estimation for 210 operating years in reserve can be given.
- La Croix International reports that the German Catholic Bishops' Conference (VDD) has an annual budget of around $146 million, which is around 2% of the total resources of Germany's 27 dioceses.
- La Croix International reports on the German Bishop's Conference budget being cut in 2017; for 2017, its budget was €127 million.
[186]↩︎
National Catholic Register reported in 2023 that there were 20.94 million Catholics in Germany. This number followed a record number of departures, down from a peak number of 28.3 million in 1990.
By dividing the reported $30.7 billion in assets by the number of Catholics in 2023, an approximation of dollars per constituent can be given of $1,466.09.
- National Catholic Register reports on number of Catholics in Germany; in 1990, there were 28.3 million, and in 2023, there were 20.94 million.
[187]↩︎
The Catholic Church in Australia is part of the global Catholic Church led by the Pope. The Catholic Church there is governed by the Australian Bishop's Conference. There are 33 Australian dioceses.
- GCatholic.org Website gives an overview of the Catholic dioceses in Australia.
- On the Catholic Australia Website, we learn that the Catholic Church there is governed by the Australian Bishop's Conference; there are 33 dioceses.
[188]↩︎
The Sydney Morning Herald conducted a six-month investigation and reported in 2018:
" . . . across 36 municipalities - including nearly all of metropolitan Melbourne - the church had land and buildings worth almost $7 billion in 2016. Extrapolated nationally, using conservative assumptions, the church owns property worth more than $30 billion Australia-wide."
ABC News repeated the findings of the investigation and included discussion of the church's tax exempt status.
- The Sydney Morning Herald reports that the Catholic Church in Australia has funds of up to $30 billion.
- ABC News Australia reports on an investigation showing that the Catholic Church in Australia has an estimated wealth of $30 billion.
[189]↩︎
The Catholic Church in Australia does not disclose total financial earnings. Since the Catholic Church manages finances at a diocese level, each of the 33 individual dioceses in Australia is managed as a Basic Religious Charity under Australian law, meaning they aren't legally required to disclose any financial reports.
- Secular group in Australia comments on the lack of financial transparency of the Catholic Church.
[190]↩︎
According to data from the 2021 Australian Census there were 5,075,907 Australian Catholics, representing approximately 19.9% of the national population. This number was down from 2016, when there were 5,291,817 Australian Catholics.
By dividing the reported $30 billion in assets by the number of Catholics in 2021, an approximation of dollars per constituent can be given of $5,190.27.
- Catholic Australia reports on the number of Catholics in Australia in 2021.
[191]↩︎
The Church of England is a protestant Christian church that is the established state church in England. It began in 1534, after a schism with the Catholic Church due to a conflict regarding King Henry VIII's desire to annul a marriage with his wife Catherine of Aragon. Members of the Church of England are commonly referred to as Anglicans. There are 42 dioceses of the Church of England located throughout England.
- Key facts about the Church of England.
[192]↩︎
The Church of England reports that they manage an investment fund worth approximately 10.4 billion British pounds. At May 2025 exchange rates, £10.4 billion is worth approximately $14,007,111,352.
- The Church of England official webpage explains their investments.
[193]↩︎
In 2023, according to the non-profit organization Save the Parish, The Church of England totaled £980 million in expenditures, which is approximately $1.32 billion.
- Report detailing the expenditures and income of The Church of England.
[194]↩︎
La Croix International reported that in 2022 there were "about 20 million baptized" members of The Church of England residing in England. However, it stipulated that only "just under one million" regularly attended worship services.
By dividing the reported $14 billion in assets by the number of members of The Church of England, an approximation of dollar per constituent can be given of $700.
- La Croix International reports that the Church of England has approximately 20 million baptized members, of which just under a million regularly attend worship, based on 2022 data.
- The Church of England official webpage explains their investments.
[195]↩︎
In 2012, University of Tampa sociologist Ryan Cragun and Reuters performed estimates based on countries where the Church is required to disclose donations, like Canada, and estimated the Church collected about $7 billion annually.
And the Widow's Mite Report estimated about 6.7 billion in donations for 2022, divided into three categories:
- ~$0.8 billion in "Fast Offerings and Humanitarian Aid"
- ~$5.6 billion in "Tithing and Other Donations"
- ~$0.3 billion in "Missionary Donations"
- Widows Mite Report Website produces an estimation of Church inflows and outflows for 2022.
- Reuters and Ryan Cragun estimate that the Church is worth $40 billion.
[196]↩︎
Churches are not required to disclose the donations they receive, as supported by documents like IRS Publication 1771 and IRS Publication 1828.
- IRS discusses charitable contributions; churches are not required to disclose the donations they receive.
- IRS publishes a tax guide for Churches and Religious organizations.
[197]↩︎
The Church is required to file annual financial statements, including of all income in that country, in Australia, Canada, and the UK.
[198]↩︎
For example, Canada can serve as an adequate proxy for tithing behavior in the United States, the most member-populous country by a large margin. The ratio of members to tithing for Canada can be used to estimate the tithing from US members, and then a guess can be made for how much of global tithing is accounted for by these four countries.
This general approach was taken by University of Tampa sociologist Ryan Cragun and Reuters in 2012, when they performed estimates based on countries where the Church is required to disclose donations and estimated the Church collected about $7 billion annually.
By working backward from external estimates of $7 billion in tithing collected annually (from those like Cragun or as repeated on 60 Minutes), a broad approximation of tithing from the global population minus these four countries can be given.
It should be noted that this since Australia, Canada, and the UK are not representative of the entire Church membership, estimates are just that - estimates.
[199]↩︎
In 1985, Gordon B. Hinckley said in General Conference:
We have a few income-producing business properties, but the return from these would keep the Church going only for a very short time. Tithing is the Lord’s law of finance. There is no other financial law like it.
David Nielsen's 2019 whistleblower report points out that Church investments probably produce more annually than tithing income, though it appears this increase in value is almost never realized in gained income.
In an estimation of "Church Inflows and Outflows" by the Widow's Mite Report, Church expenses are reportedly covered by income from donations, with excess moved to reserves for investment.
[200]↩︎
The 2021 Australian Census reported a total of 57,868 people who self-identified as Latter-day Saints, representing about 0.23% of the Australian population.
In 2021, the Church Newsroom reported 154,595 members in Australia.
For the purposes of this table, the census number is used, as it is assumed to correlate more closely with tithe-paying members (the Church Newsroom figure includes members of varying activity, while the census might be a better gauge of members actively identifying as Latter-day Saint.)
[201]↩︎
Both "THE CHURCH OF JESUS CHRIST OF LATTER-DAY SAINTS AUSTRALIA" and "THE CHURCH OF JESUS CHRIST OF LATTER-DAY SAINTS" are listed on the Charity Register of the Australian Charities and Not-for-Profits Commission. While the latter is not required to post Financial Reports, the Church in Australia has statements since 2014.
In 2023, Donations for the Church in Australia equaled $45,201,903 Australian dollars.
At an average 2023 exchange rate for Australian dollars to US Dollars, this equals about $30,036,664.54 USD.
- The Church's financial statement for 2023 as required in Australia.
- The average conversion rate for Australian to US Dollars in 2023, according to ExchangeRates.org.uk.
[202]↩︎
The 2021 Canadian Census counted 87,725 people who self-identified as Latter-day Saints.
In 2021, the Church Newsroom reported 199,054 total Church membership in Canada.
For the purposes of this table, the census number is used, as it is assumed to correlate more closely with tithe-paying members (the Church Newsroom figure includes members of varying activity, while the census might be a better gauge of members actively identifying as Latter-day Saint.)
- The 2021 Canadian Census lists 87,725 people who self-identify as Latter-day Saints.
- Church Newsroom reports that there were 199,054 Church members in Canada in 2021.
[203]↩︎
"The Church of Jesus Christ of Latter-Day Saints in Canada" is a registered charity with the Canada Revenue Agency, registration number 826344632 RR 0001.
For 2023, "Receipted Donations" were $190,208,626 Canadian dollars.
At an average 2023 exchange rate for Canadian to US dollars, this would equal about $140,906,550 USD.
- Text of the Church's finance report for 2023 in Canada.
- The average conversion rate for Canadian to US Dollars in 2021, according to ExchangeRates.org.uk.
[204]↩︎
The 2021 UK Census did not count Latter-day Saints as a distinct category and instead counted them in the "Christian" group. As such, there is no census count for Latter-day Saints in the UK.
In 2021, the Church Newsroom reported 188,187 total Church membership in the UK.
For the purposes of this table, the census number is used, as it is assumed to correlate more closely with tithe-paying members (the Church Newsroom figure includes members of varying activity, while the census might be a better gauge of members actively identifying as Latter-day Saint.)
[205]↩︎
The Church can be found as "The Church of Jesus Christ of Latter-day Saints (Great Britain)" on the Scottish Charity Regulator and the Charity Commission for England and Wales. No Church entity is listed on the Charity Commission for Northern Ireland.
Both the Scottish Charity Regulator and the England and Wales Charity Commission describe "The Church of Jesus Christ of Latter-day Saints (Great Britain)" as a cross-border entity concerned with the religious work of the Church across the United Kingdom.
Though it appears Northern Ireland is omitted, the financial information for this "(Great Britain)" entity might serve as a reasonable proxy for the Church in the UK.
The total "Donations and Legacies" income for this entity in 2023 was £64.3 million. At an average exchange between British pound sterling and US dollars in 2023, this would equal $79,982,770 million dollars.
[206]↩︎
In 2021, the Church Newsroom reported 6,721,032 total Church membership in the US.
The US Census doesn't ask Americans about their religious affiliation. The 2021 Census of American Religion and the American Values Atlas put on by the Public Religion Research Institute conducted a survey of 40,000 Americans and found that 1.5% self-identified as Latter-Day Saint.
Applying this percentage to the US population at the end of 2021 (estimated at 332,403,650 people by the US Census Bureau), an approximation of 4,986,055 Latter-day Saints in the US can be given.
[207]↩︎
This estimation is achieved by using Canada as a proxy (this assumes Canada is a useful analog for living conditions, wealth, tithing habits, and Church membership.)
Canada's 199,054 members produced $151.4 million dollars in tithing in 2021, or about $761 per member. Applying this same ratio to the US member population produces about $5.1 billion dollars (5,112,000,809 dollars).
This figure appears to be a reasonable approximation. Adding up the three known tithing values from countries where disclosure is required (Australia, Canada, and the UK) and combining that sum with this US estimation gives a total of about $5.3 billion dollars. If we assume the estimation is correct that the Church makes around $7 billion in donations a year, then every country excluding Australia, Canada, the UK, and the US would produce around $1.7 billion in tithing for the Church.
[208]↩︎
In 2021, the Church Newsroom reported a global church member population of 16,565,036.
By subtracting the above four countries' member population (Australia, Canada, UK, and US), a representation of the all other countries' member populations can be given. This estimation is 9,302,168 members.
- The Church reports its global member count for 2021.
[209]↩︎
If the commonly-estimated figure of $7 billion for total annual donations collected by the Church is assumed correct, then a rough approximation of total tithing excluding Australia, Canada, UK, and US can be given. This figure is found by subtracting the total estimated tithing from these countries from a total of $7 billion, for a remainder of $1.7 billion.
[210]↩︎
Comprising "EXHIBIT D" on page 44 in the whistleblowing complaint from David and Lars Nielsen titled "Letter to an IRS Director," reportedly a "slide from EPA’s IPC preparation deck" from March 2013, “Framework and Exposures” summarizes the internally-understood purpose of EPA and its reserve funds.
The full paragraph reads:
"The draw on the the investment reserves has been relatively small due the conservative nature of Church finances—i.e. a balanced budget. This is a very strong fist line of defense. Furthermore, over the past several years, approximately $1bn has been granted to EPA on an annual basis."
- The text of Lars Nielsen's "Letter to an IRS Director."
[211]↩︎
While the budget for the Church or EPA is not public information, there are many estimates. Estimates indicate that the Church spends less than it earns.
As far as estimates go, in whistleblower David Nielsen's "Letter to an IRS Director" on page 20, David cites an unnamed EPA leader:
"The COP is famously tight lipped about what its total tithes and donations are, but one EPA senior leader suspected in 2019 that they are $6–$7 billion annually with maybe $5–$6 billion in expenses."
Widow's Mite Report estimated "Church inflows and outflows" for 2022 and estimated an income of about $6.7 billion, with about "~1.1-1.2B" put into reserve funds "in recent years" with their current estimate supporting "~$1B saved."
- The text of Lars Nielsen's "Letter to an IRS Director."
- Widows Mite Report Website produces an estimation of Church inflows and outflows for 2022.
[212]↩︎
In 1963, N. Eldon Tanner was called as Second Counselor to President McKay. In the First Presidency, Elder Tanner implemented financial policies to strictly control the budget and build a surplus. In administration and to the members, Tanner advocated for "living on less than you earn." While previous church leaders had attempted to build a reserve fund, Tanner probably marks the successful implementation of modern Church financial policy.
[213]↩︎
In the whistleblowing complaint "Letter to an IRS Director," David and Lars Nielsen described the process by which the Church reserve fund grew:
"It was just a matter of time before the combination of the above three policy changes and the power of compounded interest would produce unmitigated, run-away wealth (~7% investment growth times $124 billion = $8.7 billion annually, which is greater than the highest internal estimate for total annual tithing, which is $7 billion). 'It’s a miracle,' reportedly remarked Mr. Davies of the CPB on multiple occasions. The journal entries make plain that nothing supernatural has occurred: austere operations, milked membership, compounded interest, tax breaks and time."
- The text of Lars Nielsen's "Letter to an IRS Director."
[214]↩︎
In 1985, Gordon B. Hinckley said in General Conference:
We have a few income-producing business properties, but the return from these would keep the Church going only for a very short time. Tithing is the Lord’s law of finance. There is no other financial law like it.
In a document titled "2022 Estimated Church Inflows and Outflows" by the Widow's Mite Report, estimated Church expenses are reportedly covered by income from donations.
- Hinckley Questions and answers "is the church wealthy".
- Widows Mite Report Website produces an estimation of Church inflows and outflows for 2022.
[215]↩︎
The concept of tithing as a commandment is most distinctly found in scripture in the Doctrine and Covenants and the Bible, especially the Old Testament.
The modern commandment to tithe is understood by modern revelation and guidance from church leaders.
[216]↩︎
In 1982, Gordon B. Hinckley described tithing as an "obligation" that came with the "marvelous promise" of temporal and spiritual blessings. Then in 1991 and 1995, Hinckley discussed church finances including the reserve fund and on each occasion described tithing as an exercise of faith tied to blessings.
Other examples of church leaders on tithing include Robert D. Hales in 2002, who said "Tithing is a test of faith with eternal blessings" or in 2013 when David A. Bednar promised that "the law of tithing" results in "spiritual and temporal blessings."
[217]↩︎
For instance, Mormon Literature writer James Goldberg, in discussion of tithing and the Church's investments, wrote in 2019:
"I've paid tithing faithfully all my life . . . I don't see myself as a stockholder in the corporation of the Church. I don't see myself as a donor to a charity . . . I don't pay tithing for the Church. I pay tithing, like Jacob in Genesis 28, as a spiritual practice. I pay because I believe it's good for me to mark my relationship with God by giving away a tenth of all I'm given . . . If it came to it, I believe it would have spiritual value--and yes, I've thought about this before--to pile one tenth of my income on a stone altar and burn it . . . I would watch the smoke rise heavenward."
- James Goldberg notes that paying tithing is not only a financial transaction but it also a demonstration of faith.
[218]↩︎
Writer and English and Comparative Literature scholar Natalie Brown wrote in 2022:
". . . The question of how tithes should be spent is, for me, distinct from the question of whether I should pay them. God will hold those in charge of administering funds accountable . . . But, for me, tithing is not a mere charitable donation. It’s not about efficiency. It’s not about exercising my power to determine where money can promote my values. It’s a commandment—and a faith test—designed to help us 'prove' or know God. It’s an exercise in letting go of our resources and power in exchange for aligning our will with God and in so doing knowing Him."
- Natalie Brown, on the By Common Consent blog, states that she pays tithing because "it’s a commandment—and a faith test—designed to help us 'prove' or know God."
[219]↩︎
In a article entitled 'Church Financial Administration', published in 2025, the Church reaffirmed that tithing is a commandment of the Lord.
The law of tithing is a commandment from the Lord, and continued tithes from Church members help the Church fulfill its divine mission as the Church grows throughout the world. Tithing is about more than money; by giving the law of tithing to the members of His restored Church, the Lord invites them to exercise faith and receive promised blessings.
- Church issues article about Church finances and how they are administered.
[220]↩︎
D&C 119 reads that "the tithing of my people" is required by the Lord as "a standing law unto them forever," where "one-tenth of all their interest annually" is to be "put into the hands of the bishop of my church in Zion."
The General Handbook describes tithing with an emphasis that it is paid to the Church:
Tithing is the donation of one-tenth of one’s income to God’s Church (see Doctrine and Covenants 119:3–4; interest is understood to mean income). All members who have income should pay tithing.
The handbook also says that the "Church normally discourages making in-kind contributions" and that donations are to be paid to the Church "monetarily" by default.
- Pamphlet published by the Church discusses what tithing it.
- D&C 119 teaches that "the tithing of my people" is required by God as "a standing law unto them forever."
[221]↩︎
Some Church members, including Religion News Service columnist Jana Riess, have decided to donate to charities in lieu of paying tithing to the Church over concerns about the Church's wealth and finances. In 2020, she wrote that "while I am still a full tithe-payer, I have not paid a dime of it to the Church in 2020." This decision was informed by whistleblower information about the Church's sizeable reserve fund. In 2022, Riess reflected on her tithing position:
Tithing, in other words, can’t be reduced to checking a box that says you support an insanely wealthy institution with yet more wealth and are suddenly right with the Lord because of it. It’s not just the act of financial sacrifice that makes tithing holy, although sacrifice is part of it. It’s how that money helps God’s children, many of whom are in great need. I’m not saying the church does not engage in any charitable activities. It absolutely does . . . Such efforts are beautiful and important — and not nearly enough.
- Jana Riess publishes her decision to stop paying tithing to the Church in response to news of Church reserves.
- Jana Riess argues that the Church does not give enough in charity in light of its $100 billion fund.

Non-profit Entity	Endowment or Fund Size	Annual expense compared to reserve in years	Dollar per constituent
The Church of Jesus Christ of Latter-day Saints	~$100 billion	$6 billion, about 17 years.	$5,882
Harvard University[159]	$50.9 billion[160]	$5.4 billion, about 9 years.[161]	$114,314[162]
Yale University[163]	$41.1 billion[164]	$4.65 billion, about 9 years.[165]	$255,349[166]
Novo Nordisk Foundation[167]	$113.8 billion[168]	$26.45 billion, about 4 years.[169]	N/A[170]
The Bill and Melinda Gates Foundation[171]	$69.0 billion[172]	7.42 billion, about 9 years.[173]	N/A[174]
Sri Venkateswara Swamy Temple[175]	$30 billion - alleged[176]	$297.78 million, about 100 years.[177]	$666[178]
Sri Padmanabha Swamy Temple[179]	$20 billion - alleged[180]	$1.46 million, about 13,724 years.[181]	$1,148[182]
Catholic Church in Germany[183]	$30.7 billion - alleged[184]	Unknown.[185]	$1,466[186]
Catholic Church in Australia[187]	$30 billion - alleged[188]	Unknown.[189]	$5,910[190]
The Church of England[191]	$14 billion (£10.4 billion)[192]	$1.32 billion (£980 million), about 11 years.[193]	$700[194]

Country (membership numbers)	*Tithing Amount and date (estimated)**
Australia (154,595 members in 2021)[200]	$30 million USD in 2023.[201]
Canada (199,054 members in 2021)[202]	$140.9 million USD in 2023. [203]
United Kingdom (188,187 members in 2021)[204]	$79.98 million USD in 2023.[205]
United States (6,721,032 members in 2021)[206]	$5.1 billion USD in 2021.*[207]
Every other country (9,302,168 members in 2021)[208]	$1.7 billion USD in 2021.*[209]