The Hundred-Billion-Dollar Reserve, and the Shell Compa...

This series keeps circling the same quiet fact: institutions that hold money invest it, and the largest reserves compound in near silence, whether they belong to a foundation, a university, or a state. The most striking case of all belongs to a church, and it is striking precisely because almost no one was allowed to see it. Over a few decades the Church of Jesus Christ of Latter-day Saints built an investment reserve that reputable reporting puts near $100 billion, larger than most university endowments and rivaling small sovereign wealth funds. It disclosed almost nothing about it, and when the size became public, it did so through a whistleblower and a federal enforcement action. This post reads that record, strictly from the documents.

What Ensign Peak is

The manager of the reserve is Ensign Peak Advisors, a nonprofit corporation the church created in Salt Lake City in 1997, in the Securities and Exchange Commission's words, "as an integrated auxiliary of the Church to manage the Church's investment securities" (SEC order, Release No. 96951). It has no shareholders and no members, charges the church no fees, and is governed by a board drawn from the church's Presiding Bishopric plus its own managing director, who reports to the church's First Presidency (SEC order). Its portfolio, the church calls "reserve funds," built, again in the SEC's description, from "excess tithing, income and returns generated by Ensign Peak, and the assets of other Church integrated auxiliaries" (SEC order). In plain terms, it is surplus tithing invested and reinvested rather than spent. At its founding in 1997 it managed roughly $7 billion (SEC order).

How big it grew is a genuinely open question, because the full number has never been officially confirmed. The figure that entered public consciousness, roughly $100 billion, comes from the 2019 whistleblower complaint and the Washington Post (Washington Post, December 2019); the Wall Street Journal independently estimated $80 billion to $100 billion in early 2020 (Deseret News). The church has never confirmed a specific total (Deseret News). The one officially filed number is a floor: Ensign Peak now files a Form 13F under its own name, and the most recent one disclosed about $53.7 billion in US-listed stocks as of the first quarter of 2026 (SEC EDGAR, CIK 0001454984). A 13F captures only US-listed equities above a threshold, not bonds, real estate, private funds, cash, or foreign holdings, so it is a fraction of the whole, not the whole.

The whistleblower

The size became public because a man inside the fund decided the public should know. David Nielsen, a senior portfolio manager at Ensign Peak for about nine years, resigned in 2019 and filed a whistleblower complaint with the Internal Revenue Service that November; his brother Lars helped publicize it (Washington Post). His central allegation was that the fund had amassed roughly $100 billion from tithing and had "not directly funded any religious, educational or charitable activities in 22 years"; he would later call it, on 60 Minutes, "a clandestine hedge fund" where "once the money went in, it didn't go out" (CBS News, 60 Minutes transcript). The complaint said employees were told the reserve would be used "after the Second Coming of Jesus Christ" (Washington Post).

Two specific uses of the money drew the most attention, and both are ones the church acknowledges while disputing the framing. The complaint said about $1.4 billion of fund money went into the City Creek Center, a downtown Salt Lake City shopping mall built around 2010 to 2014; the church calls that an investment, not charitable spending, one it earns returns on (Deseret News). And the complaint said roughly $600 million went to prop up the church-owned insurer Beneficial Life during the 2008 financial crisis; the church confirms the support occurred, citing about $594 million, but disputes that it was improper (CBS News).

The shell companies, and the SEC

The whistleblower's tax theory, that a charity holding an unspent fortune should lose its exemption, has not been adopted by the IRS. But a different, narrower charge stuck, and it is the part that is fully confirmed by primary documents. On February 21, 2023, the Securities and Exchange Commission announced that Ensign Peak and the church had settled charges "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" (SEC press release 2023-35). The mechanism is spelled out in the order: "From 1997 through 2019, Ensign Peak Advisors, Inc. failed to file with the Commission certain required forms (Forms 13F) that would have disclosed the size of the Church's equity portfolio. Instead, the Church and Ensign Peak created thirteen limited liability corporations (LLCs), including twelve similar LLCs (the Clone LLCs) with addresses located throughout the U.S., for the sole purpose of filing Forms 13F and preventing public disclosure" of the church's holdings (SEC order).

The scale it hid is in the order too: the Section 13(f) equity holdings grew from about $7 billion at inception to roughly $32 billion by 2018 and $37.8 billion by 2020 (SEC order). The SEC's enforcement director, Gurbir Grewal, was blunt: "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," and he added that the disclosure requirement "applies to all institutional investment managers, including non-profit and charitable organizations" (SEC press release 2023-35). Ensign Peak and the church settled without admitting or denying the findings, and paid a combined $5 million penalty. One detail cuts against the common shorthand: the larger share fell on the investment manager, not the church. Ensign Peak paid $4 million and the church $1 million (SEC order; SEC press release 2023-35).

The defense, and the question underneath

The church's own account is worth stating fairly, because it frames the whole debate. In a rare 2020 interview, the Presiding Bishopric explained the reserve as a hedge against hard times. "Because of the reserves being carefully watched over," Bishop W. Christopher Waddell said, "we won't have to stop missionary work, we won't have to stop maintaining buildings and building temples, we won't have to stop humanitarian and welfare work" (Deseret News). The church says it spends about $1.36 billion a year on charitable causes, and characterizes the City Creek mall as an investment whose returns support that work (Deseret News). And the courts have sided with it on the money question: a wave of lawsuits by former members alleging tithing was misused has been dismissed, including the Huntsman case, thrown out by the full Ninth Circuit in early 2025 (Deseret News).

The deeper question is not really about securities forms, which the settlement resolved. It is the one this whole series keeps arriving at, sharpened here to a point. A church, unlike a private foundation, faces no rule requiring it to pay out a minimum share of its assets each year; the 5 percent payout the Tax Reform Act of 1969 imposed on foundations simply does not reach it. One tax analyst framed the resulting fund as "a question of policy rather than law," since Ensign Peak is a church auxiliary with no payout obligation (Forbes). A law professor on the other side argued that "tax exempt purposes don't include investing" and that churches should file the public returns other charities do (Religion Unplugged). Both are describing the same silent structure: a tax-exempt institution, funded by its members, quietly compounding a sovereign-scale reserve it is under no legal obligation to spend or to disclose. What the SEC action changed is not the fund. It is only that, for a few years now, some of it can be seen. The rest of the lesson is the one this series keeps writing down: the largest reserves grow in the dark, and it usually takes an outside force to turn on the light.

Fact-check notes and sources

Ensign Peak Advisors (a nonprofit created by the church in 1997 as an integrated auxiliary to manage its investment securities, governed by a board from the Presiding Bishopric, holding reserves built from excess tithing, and managing about $7 billion at inception): from the SEC order, Release No. 96951. The size (the roughly $100 billion figure reported by the whistleblower and the Washington Post, the Wall Street Journal's $80 to $100 billion estimate, the church's non-confirmation, and the officially filed Form 13F of about $53.7 billion in US equities as a floor): Washington Post, Deseret News, and SEC EDGAR CIK 0001454984. The ~$100 billion total is reported and estimated, not officially confirmed; the ~$53.7 billion is officially filed but covers only US-listed equities.
The whistleblower (David Nielsen, a nine-year senior portfolio manager who filed an IRS complaint in November 2019; the "not funded any charitable activities in 22 years," "clandestine hedge fund," and "after the Second Coming" allegations; the roughly $1.4 billion City Creek mall figure the church calls an investment; and the roughly $594 to $600 million Beneficial Life support): Washington Post, CBS News 60 Minutes transcript, and Deseret News.
The February 2023 SEC settlement (the charges over failing to file Forms 13F and instead using thirteen shell LLCs, twelve of them "Clone LLCs," from 1997 through 2019; the equity holdings of about $32 billion in 2018 and $37.8 billion in 2020; the Gurbir Grewal quotations; the settlement without admitting or denying; the $5 million penalty split as $4 million for Ensign Peak and $1 million for the church; and the Section 13(f) and Rule 13f-1 basis): from the SEC press release 2023-35 and the SEC order, Release No. 96951.
The church's defense and the debate (the 2020 Presiding Bishopric interview and the Bishop Waddell quotation; the roughly $1.36 billion in annual charitable spending; the dismissal of the Huntsman tithing lawsuit by the Ninth Circuit in early 2025; and the policy-versus-law framing including that a church faces no foundation-style payout requirement): Deseret News on the 2020 interview, Deseret News on the Huntsman dismissal, Forbes, and Religion Unplugged.

This post is informational and reports strictly from the public record, including a federal settlement in which the respondents neither admitted nor denied the findings. It is not a statement about any religion's beliefs. Institutions and individuals are discussed as nominative fair use from the public record, with no affiliation implied.

The Hundred-Billion-Dollar Reserve, and the Shell Companies That Hid It: Ensign Peak