Money and religion make for a volatile mix, especially when the federal government gets involved. You’ve probably seen the headlines floating around about the $5 million fine or the "secret" $100 billion fund. People call it The Church of Jesus Christ of Latter-day Saints incident, but in the world of high finance and federal regulation, it was actually a landmark SEC settlement that changed how large non-profits handle their paperwork. It wasn't about a heist or a missing pot of gold. It was about disclosure. Or, more accurately, the lack of it.
For decades, the Church managed its massive investment portfolio through an entity called Ensign Peak Advisors. Things were quiet. Then, a whistleblower and a federal investigation blew the doors off.
What actually happened with Ensign Peak?
Let's be real: most people don't find Form 13F filings exciting. But this is where the trouble started. The Securities and Exchange Commission (SEC) requires any institutional investment manager with over $100 million in qualifying assets to file these forms every quarter. It's basically a "here is what we own" list for the public to see.
The Church, acting through Ensign Peak, was worried. They didn't want the world to see exactly where their billions were parked. Why? According to the SEC's 2023 cease-and-desist order, Church leadership feared that public knowledge of the portfolio's size would lead to negative consequences. They thought members might stop paying tithing or that the public would scrutinize their market moves too closely.
To hide the scale, they created 13 separate "shell" companies.
These companies—with names like Glen Harbor Capital Management and Ashmoret Investments—were legally "separate" on paper but were all actually controlled by Ensign Peak in Salt Lake City. The SEC found that these shells filed their own 13F forms as if they were independent entities. In reality, the "business managers" for these shells were often just Church employees who were told to sign documents they didn't fully understand. It was a shell game. It worked for about 20 years.
The whistleblower that changed everything
In 2019, a former Ensign Peak investment manager named David Nielsen filed a 74-page whistleblower complaint with the IRS. He wasn't just talking about filing errors; he alleged that the fund had grown to over $100 billion and wasn't being used for charitable purposes.
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This was the spark.
While the IRS complaint dealt with tax-exempt status (which is a whole different, ongoing debate), it put a massive spotlight on the Church's financial secrecy. The SEC took notice. They started digging into how those 13F forms were being handled. What they found wasn't a crime of embezzlement—nobody was pocketing the money—but it was a systemic violation of federal transparency laws.
The $5 million fine and the fallout
By February 2023, the SEC reached a settlement. The Church agreed to pay $1 million, and Ensign Peak agreed to pay $4 million. For a fund worth $100 billion, $5 million is basically a rounding error. It's the equivalent of a normal person paying a nickel for a parking ticket.
But the reputational hit? That was massive.
The Church released a statement acknowledging they "regret the mistakes made" but emphasized they had relied on legal counsel to set up the structure. They basically said, "Our lawyers told us this was okay to protect our privacy." The SEC disagreed. They argued that the Church’s senior leadership was directly involved in the decision to use the shell companies specifically to avoid disclosure.
Why this incident matters for non-profits
This isn't just "Mormon news." It’s a huge deal for the entire non-profit sector. It set a precedent that "religious privacy" does not trump "SEC transparency."
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- Transparency is mandatory. If you manage over $100 million in the U.S. markets, the SEC doesn't care if you're a hedge fund or a church. You file the forms correctly.
- The "Reliance on Counsel" defense has limits. You can't just say "my lawyer said it's fine" if the goal is clearly to circumvent federal disclosure rules.
- Whistleblowers are powerful. One person with a stack of documents can force a multi-billion dollar organization to change its entire reporting structure.
Misconceptions about the Church's wealth
You’ll hear people say the Church is "hiding" $100 billion to avoid taxes. That’s a bit of a stretch. Under U.S. law, religious organizations are generally tax-exempt on their investment income, provided that income is eventually used for their exempt purposes. The Church argues that this money is a "rainy day fund" for the second coming or for future periods of economic collapse.
Critics, however, point out that very little of the Ensign Peak money has been used for actual charity. The most famous example of the fund being used was a roughly $1.4 billion injection into the City Creek Center—a high-end mall in Salt Lake City—and to bail out a Church-affiliated insurance company, Beneficial Life.
The Church maintains that no tithing money went into the mall, only "earnings on invested tithing." It’s a nuance that frustrates many.
The shift toward transparency
Since the SEC settlement, things have changed. If you look up the 13F filings today, you won't find Glen Harbor or Ashmoret. You’ll find one consolidated filing under Ensign Peak Advisors.
They are showing their cards now.
The portfolio includes massive stakes in Apple, Microsoft, Amazon, and Google (Alphabet). As of the last few years, the disclosed equity portion of the fund alone is worth tens of billions. And that doesn't even count the real estate, the ranches, or the private equity holdings that don't have to be reported on a 13F.
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Is the "incident" over? Legally, yes. The fines are paid. The shells are dissolved. But the conversation among the rank-and-file members of the Church is just getting started. For a long time, the finances were a black box. Now that the box has been cracked open, people are asking more questions about where their tithing goes and how much "enough" actually is for a global religion.
Actionable insights and next steps
If you are following this story or managing a large non-profit, there are a few things to keep in mind. First, total financial privacy is a thing of the past for large institutions. The SEC is increasingly aggressive about "beneficial ownership"—meaning they want to know who is actually pulling the strings, regardless of how many shell companies are in the way.
Secondly, if you are a donor or a member of any large non-profit, you have the right to look at 990 forms or 13F filings. Use tools like the SEC's EDGAR database to see what's actually happening. Knowledge is the best antidote to the "shock" of a headline.
Finally, watch for the IRS. While the SEC handled the reporting violations, the original whistleblower complaint about the Church's tax-exempt status is still a point of contention. If the IRS ever decides to challenge the "charitable" nature of a $100 billion reserve fund, the SEC incident will look like a footnote in comparison.
Keep an eye on the Senate Finance Committee as well. Senator Ron Wyden has previously expressed interest in the tax-exempt status of large investment portfolios held by religious groups. This story isn't just about one church; it's about the future of how the U.S. government treats massive piles of "religious" capital in a modern economy.