- Make finances public
- Reveal Church attendance numbers
- Reveal retention numbers
(Like the Seventh-Day Adventist Church does.)
Between 1915 and 1959, annual reports of the Church’s income and expenditures were announced in general conference. These reports showed that most funds were directed to ward and stake buildings, headquarters office buildings, Church schools, missions, and welfare. After 1959, auditors presented in general conference only the results of an annual general audit, assuring the public that leaders had followed financially responsible procedures and dealt honestly in their use of Church funds. (Church Finances)
SEC investigators found the church “went to great lengths” to hide $32 billion in securities over nearly 20 years. It created 13 shell companies that were “…assigned a local phone number that would go directly to voicemail” in case regulators checked in. David Nielsen: Here they had these back-office accountants, who had never bought a bond or sold stock a day in their life, signing signatory pages for a portfolio that didn’t exist. (Sharyn Alfonsi, “Mormon who left Wall St. to work for charity blows whistle on what he says is his church’s ‘clandestine hedge fund‘,” 60 Minutes, May 14, 2023)
In 1997, the LDS Church split off its investment division and created a separate legal entity called EP. Form 13F is a quarterly report filed, per SEC regulations, by “institutional investment managers” with control over $100M in assets to the SEC, listing all equity assets under management. The purpose of the form is to provide transparency over who owns stocks.
- 1997: EP was created as a non-profit to manage LDS Church investments
- 1998: Senior leadership of the LDS Church, defined as the First Presidency and Presiding Bishopric, approved a plan to file Form 13F through a separate entity to prevent disclosure of the securities portfolio.
- 2001: The first of thirteen shell companies was created, a trust fund with separate limited liability companies (LLC) under the trust’s ownership. The LLC had an address in Glendale, Arizona, but did not conduct business out of that site. Employees of EP were assigned as managers of the trust but not granted investment discretion.
- 2003: Form 13F is first filed for the newly created shell company.
- 2005: Senior leaders of the LDS Church approve creating a second shell company based out of Wilmington, Delaware. The church created the new entity after discovering that the person signing the forms was listed as an LDS Church employee in a public directory and that the shell company could be traced back to the church.
- 2011: Five additional shell companies were approved by senior leaders after LDS Church leaders became concerned that the growing size of the investment portfolio would bring “unwanted attention.” The addresses of the five shell companies were in Delaware, but no business was conducted in that state.
- 2014: An internal LDS Church audit “highlighted the risk that the SEC might disagree with the approach” but did not recommend changes.
- 2015: An unnamed third party connected some of the shell companies with EP and brought the issue to senior leaders of the LDS Church. The senior leaders approved a plan to “gradually and carefully adapt Ensign Peak’s corporate structure to strengthen the portfolio’s confidentiality.” This included creating six more shell companies, whose managers had “common names and a limited presence on social media, and were, therefore, less likely to be publicly connected to Ensign Peak or the Church.” Selected managers were given limited information on the purpose of the shell companies.
- 2017: A second LDS Church audit again highlighted the risk of the investment approach.
- 2018: The Mormon Leaks website discovers that the 13 shell companies have web domains hosted by LDS Church servers. Mormon Leaks also connects business managers with LDS Church employees. Two of the business managers resigned out of concern with what had been asked of them. They are replaced with different managers.
- 2019: The SEC first contacts the LDS Church over its reporting structure.
- 2020: EP files a consolidated disclosure for the first time.
- 2023: On February 21, the SEC publicly announced the charges against the LDS Church and EP and the settlement. The church agrees to pay $1 million, and EP agrees to a $4 million penalty.