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Gaddy Lawsuit Judgement


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Posted (edited)
49 minutes ago, bluebell said:
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Motivated reasoning is a powerful thing.

Agreed.  It's definitely something both of our perspectives and beliefs are susceptible to.  Bias is a very real thing.

From the link:

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Motivated reasoning is the mental process through which individuals access, construct, and evaluate their beliefs in response to new information or experiences. The motivation may be to arrive at accurate beliefs, or to arrive at desired conclusions. While people may be more likely to arrive at conclusions they want, such desires are generally constrained by the ability to construct a reasonable justification.

I think most of us would like to say we are striving for "accurate beliefs," but sometimes we may actually be pursuing "desired conclusions."  Hence the value of this message board.  Folks like @Analytics have perspectives on the Restored Gospel that, in many respects, substantially diverge from my own.    If I was interested in only "arriv{ing} at desired conclusions," I would go find an echo chamber.  Instead, I come here to test and vet my beliefs about the Restored Gospel by listening to what its critics have to say.  Sometimes they have valid observations, but mostly I think their commentary is more about fundamental - and not empirically testable - presuppositions than about the "facts."  

For my part, I have no particular or vested interest in what a handful of Latter-day Saints thought about City Creek in 2012.  As it is, I think most (nearly all?) of them - and most informed Latter-day Saints today - had and have a pretty accurate understanding of things, including that

  • the Church invests a percentage of tithing revenue,
  • the Church has publicly disclosed the previous point for quite a while (since at least 1991),
  • no tithes were used to fund City Creek,
  • "tithes" are monies voluntarily contributed by the Saints,
  • earnings/interest on invested tithes are not tithes, and they disagree with the notion/characterization that "indirectly using tithing money is still using tithing money" and/or “{i}nterest on tithing money is still tithing money" (this concept is, I think, the sine qua non of the tithing lawsuits),
  • investing a portion of tithes is morally wrong/improper, 
  • Pres. Hinckley and other leaders of the Church were "disingenuous" and/or engaged in "money laundering" relative to City Creek,
  • the leaders of the Church have, for many decades now, been excellent stewards of the Church's finances, and
  • the leaders of the Church are not living profligate lifestyles or otherwise squandering/misusing Church funds to enrich or unduly benefit themselves.

This thread, and others about the "tithing" lawsuits, have for some had a sort of "Mirror of Erised"-style effect on some participants.  While my "desired conclusions" would have been for the Church to be exonerated of the accusations of fraud and misconduct, I would also want to have "accurate beliefs" about the Church's conduct relative to City Creek.  If the Church has done something wrong, I think it needs to be held accountable.  Consequently, in these threads I have found some value in examining the lawsuits which have sought to apply neutral principles of law.  As it happens, the Church has been altogether vindicated, such that "accurate beliefs" and "desired conclusions" overlap almost perfectly.

I am curious about what @Analytics feels his "accurate beliefs" and "desired conclusions" have been regarding the Church and City Creek, both before and during and after the adjudication of the tithing lawsuits.  Roger?  

Thanks,

-Smac

Edited by smac97
Posted
4 hours ago, smac97 said:

I can see how smaller "pay as you go" churches and charities may lack the means and/or desire to maintain an endowment fund, but some larger churches and charities routinely set aside surpluses (donations exceeding immediate operating needs) and invest them prudently.  Plenty of sensible and appropriate reasons for this, such as planning for long-term sustainability (to weather economic downturns, fund future projects (e.g., building temples, schools, church programs, humanitarian/charitable work, etc.), or to provide ongoing support when donations fluctuate), wise stewardship (the Parable of the Ten Talents), and so on.

For the average small local church or charity, investing donations is uncommon. For larger denominations, well-resourced nonprofits, universities, hospitals, and some major religious organizations, it is common and prudent.

I asked ChatGPT the following:

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According to the documents that have been leaked by the IRS Whistleblower and corroborated by the SEC Investigation, public SEC filings, and Church statements, we know the following:

1- As-of November 2019, Ensign Peak Reserves had $122.86 billion in assets.

2- This portfolio is invested relatively aggressively (at least compared to an insurance company’s asset portfolio), and is expected to grow at 7.4% per year.

3- Additionally, for many recent years the church has transferred one billion a year from contributions to Ensign Peak Advisors. Presumably it continues to do so every year.

4- Other than withdrawals to fund City Creek and bail out Beneficial Life, the Church hasn’t tapped its rainy day fund. The global financial crisis wasn’t a “rainy day.” The pandemic wasn’t a rainy day. It continues to do so (https://www.churchofjesuschrist.org/study/manual/gospel-topics/church-financial-administration?lang=eng)

5. If the Church has continued with its $1 billion annual infusions and has continued to earn 7.4%, it now has about $200 billion of assets.

6- If we assume that it takes in $8 million of donations a year and uses $7 million a year for its religious and charitable missions, then its total income (donations + investment income) is around $21 billion a year. Of that $21 billion, roughly 67% is used to grow the size of its investment portfolio, and the remaining 33% is used for its religious and charitable missions.

First of all, is this a fair and relatively conservative estimate of the Church’s financial position?

In an Internet discussion, somebody looked at the above facts and responded, "For larger denominations, well-resourced nonprofits, universities, hospitals, and some major religious organizations, [this relationship between using resources to fund your mission vs. increase the size of your reserve fund and/or endowment] is common and prudent.” Is he right about that? Is there a single respectable non-profit or religion that uses 67% of its annual income to grow the size of its already huge endowment and uses only 33% of its annual income on its religious, charitable, or educational mission.

I thought the purpose of an endowment was to use most of its annual investment earnings to help fund the charitable cause. The Mormon Church does that exactly backwards--it uses 100% of its investment income to grow the size of its reserve fund, *and* uses 10-15% of its annual charitable contributions to *also* grow the size of its investment portfolio. Is that *really* common and prudent? Can you give me some examples of other organizations that use over 67% of their annual income to grow the size of their endowments?

ChatGPT Replied
Yes — as a back-of-the-envelope model, your estimate is fair and probably directionally conservative/plausible, but not “proven” in the audited-financial-statement sense, because the Church does not publish consolidated U.S. financials.

The clean version is:

The SEC order confirms that Ensign Peak manages Church “reserve funds,” including securities purchased with “excess tithing,” investment income, and returns generated by Ensign Peak, and that Ensign Peak’s Section 13(f) securities alone were about $37.8 billion by 2020. Its latest public 13F filing shows $56.6 billion in reportable securities as of 12/31/2025, which is only the public 13F-reportable slice, not total reserves. (SEC) If the leaked $122.86 billion total-reserve number from late 2019 is right, and if the fund earned about 7.4% with roughly $1 billion/year added, then roughly $200 billion by early 2026 is a reasonable model result.

One arithmetic correction: at $200 billion, 7.4% investment return is $14.8 billion/year. If donations are $8 billion and mission spending is $7 billion, then total economic income is about $22.8 billion, reserve growth is about $15.8 billion, and the split is about 69% to reserve growth / 31% to mission spending, not 67/33. Close enough for an internet discussion, but I’d say “roughly 70/30.”

On the other person’s claim: he is right only in the weak, generic sense that reserves and endowments are common and prudent. He is not right if he means this specific pattern is common among mature, well-resourced nonprofits.

Normal endowment practice is not “spend every penny of investment return,” but it also is not “spend none of the investment return indefinitely.” Universities generally use a spending policy — often around 4%–5% of endowment value — to support current mission while preserving purchasing power. NACUBO says FY2024 institutions withdrew $30.0 billion, average spending rate 4.8%, and endowments funded about 15.3% of operating expenses; the spending went heavily to financial aid, academic programs, faculty positions, facilities, and other institutional purposes. (nacubo.org) NACUBO’s 2025 summary likewise says endowment withdrawals rose to $33.4 billion, with nearly half going to student financial aid. (nacubo.org)

Private foundations are an even cleaner contrast: the IRS minimum investment return for private foundations is generally 5% of non-charitable-use assets, and foundations must make annual qualifying distributions for charitable purposes. (IRS) Religious organizations are not necessarily subject to the same payout rule, but the existence of that rule shows the policy concern: society generally does not treat perpetual tax-favored accumulation as the normal charitable model.

The Church of England is a useful religious comparator. Its Church Commissioners’ endowment was about £11.1 billionafter a 10.3% return in 2024, and the endowment contributes about 20% of the Church of England’s running costs; Reuters reported a planned £1.6 billion spend over 2026–2028 funded by that endowment. (Thinking Anglicans) That looks like a normal endowment model: accumulate, invest, and materially support current ministry.

So I would frame it this way:

The Church’s stated reserve philosophy is common in kind but unusual in scale and payout behavior. The Church publicly says it sets aside part of income as reserves, invests those reserves, and intends them for current and future needs. (The Church of Jesus Christ) That part is not strange. What appears unusual is the combination of: an already enormous reserve, apparently no regular draw from the reserve for current mission, continued annual transfers of surplus donations into the reserve, and reinvestment of essentially all investment return.

Your intuition is basically right: a mature endowment normally exists to create a durable funding stream for the mission. It does not usually operate as a one-way ratchet where the endowment absorbs all investment returns plus part of current donations while current mission is funded almost entirely from new donations.

I would not say “no nonprofit anywhere has ever shown 67% of annual economic income flowing into net assets,” because in a huge investment-return year, accounting statements can make lots of endowments look that way. But as an ongoing policy for an already massive religious/charitable institution? No, that is not the normal endowment model.The normal model is closer to: earn 7%–8%, spend 4%–5% on mission, retain the balance for inflation, volatility, and future growth. The alleged LDS model is closer to: earn 7%+ on a massive reserve, spend 0% of that reserve return on ordinary mission, and add surplus donations on top.

That is not “common and prudent” in the ordinary nonprofit-endowment sense. It may be defensible under the Church’s own theological/future-calamity rationale, but that is a very different claim.

4 hours ago, smac97 said:

What the Church should do with its accumulated wealth is indeed a challenge.

It isn’t a challenge at all; they are saving it until the Millenium. 

4 hours ago, smac97 said:

You and others (such as Teancum) have come up with proposals that are facially appealing (such as a rote "spend{ing} 5% of their principal on their philanthropic mission" rule) , but perhaps not practical or prudent if put into practice.

Actually, I quoted Harvard University as saying, ""As a general rule, Harvard targets an annual endowment payout rate of 5.0 to 5.5% of market value.” It’s flattering that you think came up with that benchmark, but I didn’t. This guideline came from Harvard University’s endowment’s trustees and their advisors.

 

 

4 hours ago, smac97 said:

I think Cobalt, and I, and most other Latter-day Saints did not dispute the general concept of "Member Pays Tithing --> Tithing in Excess of Current Needs is Invested à Investments Earn Return --> $$$ From This Return on Investments is Reinvested in the City Creek Mall."  Craig and Cobalt were both correct on this point.  They were both correct because of the information they had from public statements made by Pres. Hinckley, such as his 1991 remarks cited by Cobalt:

Based on this, I surmise that disagreement with Craig arose less from his aligned-with-Pres.-Hinckley's-remarks summary of the Church setting aside a percentage of its income to build reserves, and more from his inflammatory framing of that point.  That is, I think most objected to and disagreed with Craig accusing the Brethren of being "disingenuous" and engaging in "money laundering."

I think the disagreement comes down to presuppositions you have (such as "indirectly using tithing money is still using tithing money") that Latter-day Saints do not share.

Lack of inflammatory language aside, Cobalt’s beliefs were aligned with the critics, not with "The overwhelming consensus among the faithful participants (JAHS, Pahoran, Scott Lloyd, Mola Ram, LeSellers, Jeff K., etc.) who believed that tithing money was not used — either directly or indirectly — for City Creek.
 

certainly don’t have a “presupposition that indirectly using tithing money is still using tithing money.”  My presupposition is that the whole distinction between tithing money and non-tithing money is mental accounting and silly. The claim that tithing money is somehow different than non-tithing money and that the Church could use tweezers to extract non-tithing dollars from its portfolio and distribute those dollars is silly to me. Thats how I see it.

But how I see it is irrelevant. The point of all of this is to understand what the believers actually believed before the whistleblower gave us more data about what was really going on. Indirectly using tithing is a presupposition anybody made--it was the topic of the thread. My point of bringing it up is to see whether Huntsmans claims about what he believed were reasonable, regardless of whether the level of ambiguity raised to the level of legal fraud.

Since you declined to ask Grok the questions that would get to the bottom of this, I decided to pose the question to GPT. I uploaded that 2012 thread and asked the following:

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Please analyze this 2012 discussion on its own terms.

The goal is to understand what the participants were actually arguing at the time, not to impose later legal or accounting categories onto their old words. Use later information, including the Ninth Circuit decision, only as hindsight evidence for what actually happened.

Please answer these questions clearly and directly:

When JAHS said that, “in an indirect way the City Creek mall was made possible by sacred tithing money donated by members 150 years ago,” what did he mean?

Was that meaning clear enough that most participants in that forum would likely have understood it?

In the context of that thread, when defenders said that “tithing wasn’t used,” did they mean only that tithing was not used directly, as the Ninth Circuit later concluded? Or did they mean that tithing was not used at all — not directly, and not indirectly through accumulated investment capital derived from prior tithing?

With 20/20 hindsight, and using the definitions and assumptions being used in that thread, which camp was basically right? Were the critics right that tithing was used to fund the mall in the indirect sense JAHS described — meaning the Church would not have had the capital used for City Creek if it had not accumulated and invested prior tithing? Or were the defenders right that tithing was not used in the broader sense being disputed in that thread?

Does this old discussion help explain why James Huntsman might sincerely have understood the Church’s public assurances to mean that tithing was not used at all for City Creek — not directly, and not indirectly through investment returns or accumulated capital from prior tithing? Does the thread show that this was not a bizarre or idiosyncratic misunderstanding by Huntsman, but a view that appears to have been shared by at least some faithful defenders at the time?

Please keep the answer short, plain, and readable. Do not write a long nuanced essay. Give a straight answer about which camp was basically right and which camp was basically wrong, while clearly distinguishing between the later legal/accounting conclusion about direct use and the thread’s broader argument about indirect use. Also address whether the old discussion gives us reason to view Huntsman’s claimed understanding with some empathy, rather than treating it as obviously insincere or impossible.

 GPT:
JAHS meant indirect causal funding, not direct checkbook funding.

He was saying: the Church says current tithing was not directly spent on City Creek; instead, business/investment money was used. But if those businesses and investments were originally built from accumulated member tithing or consecrated resources, then City Creek was still made possible by tithing in a broader historical/economic sense.

Yes, that meaning was clear. The thread participants understood the point. They argued about whether that indirect chain was true, provable, relevant, or morally significant. They were not merely debating the later courtroom distinction between “principal tithing dollars” and “earnings on invested reserve funds.”

In that thread, many defenders saying “tithing wasn’t used” appear to have meant not used in the broader disputed sense, not merely “no principal tithing dollars were directly spent.” That is why some reacted as though the indirect claim was an accusation that Church leaders were lying. If they had only meant “investment earnings were used, but those investments ultimately came from tithing reserves,” the debate would have looked very different.

With hindsight, the critics were basically right on the thread’s broader issue: City Creek was funded through earnings on invested reserves, and the reserves included tithing-derived funds. The Ninth Circuit accepted the narrower legal/accounting distinction: no principal tithing funds were used directly, while earnings on invested reserve funds were used, and the court held that this defeated Huntsman’s fraud claim.

So the clean answer is:

The defenders were basically right only in the later narrow sense: direct tithing principal was not used.

The critics were basically right in the sense actually being fought over in the thread: the mall was funded through accumulated investment wealth that was connected to prior tithing/reserve capital.

And yes, this old discussion helps explain Huntsman. It shows that a categorical understanding of “no tithing funds were used” was not some bizarre, bad-faith, idiosyncratic misunderstanding. At least some faithful defenders at the time seemed to understand and defend the claim that way themselves. That does not mean Huntsman won legally. But it does give real reason to view his claimed understanding with some empathy rather than treating it as obviously impossible or insincere.

 

Posted
5 hours ago, smac97 said:

I am curious about what @Analytics feels his "accurate beliefs" and "desired conclusions" have been regarding the Church and City Creek, both before and during and after the adjudication of the tithing lawsuits.  Roger?  

Regarding my actual beliefs, in 2015, I said on this issue:

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It isn't that clear cut.

For example, say that one year the Church takes in a cool $1 Billion in tithing.  It might budget to spend $900 Million on its various "paid by tithing" operating expenses, and save the remaining $100 Million.

The Church really would save tithing money for a rainy day, wouldn't it?

So what is it going to do with the $100 Million?  Surely the Church would not bury the money in a hole--they are going to be wise and faithful servants and make a return on it, right?

How would they invest it?  A savings account?  Government bonds?  Publicly traded stock?  Those all represent loans to outside entities.  If it is okay to loan the money to a bank (i.e. put it in a savings account), is it okay to loan the money to Deseret Management Corporation (DMC)?  If it does loan it to DMC, is it okay for DMC to, say, buy a cattle farm in Florida with the money and try to make a return on it?  Or a Mall in Salt Lake City?

So when the Church says, "no tithing money was used," the meaning of that isn't clear; if the Church has any tithing money saved in a stock or bond issued by one of the Church's for-profit businesses, and if that for-profit business used any of its resources to fund the project in question, there is a direct connection between the tithing dollar and the fungible resources of the for-profit entity.

At the time I thought I was pretty much exactly right about all of that, and I still do. (Do you take issue with this post? From my seat you appear to dramatically misread what the apologists were generally saying. Do you misread what I was saying, too?) Predictably nobody up-voted me, but somebody did explain why she thought I was totally wrong about all of that. I was told:

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I'm not sure if you read the post in this thread by the person who actually worked as an accountant for the Church.  They explain how the church really doesn't have the chance to put much tithing away in a rainy day fund.  Probably not more than would keep the church running for a few months.  I'm also guessing that they would keep such a fund pretty liquid.

She was referring to Kim Pearson’s post, of course, which received about 19 upvotes, and for many people conclusively settled the matter. But of course he was wrong on some very big issues (do you disagree, or do you think he was right?). I asked him:

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What is your basis for believing that the assets of the non-profit entity would only be sufficient for a few months?  There isn't a law that says non-profits can't have massive savings.  As an example, Harvard University is a nonprofit tax-exempt institution, and over the last 10 years its endowment has grown from about $25 Billion to $36 Billion.  The fact that Harvard continues to hoard obscene amounts of money has no bearing on its nonprofit, tax-exempt status.

There is no law that says churches can't do the same thing, is there?  Just as Harvard invests its endowment in for-profit enterprises, the LDS Church is totally free to invest its savings in for-profit enterprises.  Included in the for-profit enterprises in which it can invest are DMC and the other for-profit businesses it owns.  There is nothing illegal about this.

I have no doubt that the Church conducts its financial affairs according to the law.  That doesn't mean that its accumulated savings over the years isn't invested in its for-profit businesses, much less that those accumulated savings aren't significant.

Looking back at it, I turned out to be wrong about the church’s commitment to following the law, but otherwise think I understood what was going on better than the majority of members who were posting here. 

Regarding the lawsuits, as I recall I always thought that the church’s statements on its finances were neither true nor false, but rather vague. Because of that, I personally wouldn’t say the church was guilty of fraud, even if Huntsman could convince me that he literally relied on this assurance, which I don’t think he could have. But saying all that, I remain adamant that the church autonomy doctrine doesn’t apply here. The issue was never about whether the courts (or members) have the right to tell the church how to spend its money: the issue was whether the church lied to the membership about it.

Part of me would love to see the IRS seriously investigate Nielsen’s claims. I’d love the laws to be changed so that Ensign Peak Advisors were taxed like a private foundation--I am against hoarding and hoarding is exactly what Ensign Peak Advisors is doing (e.g. over the last 3 years, MacKenzie Scott has given away more than $14 billion while Ensign Peak Advisors has given away exactly zero, despite Ensign Peak Advisors having over six times as much money as Scott). 

Posted
9 hours ago, smac97 said:

From the link:

I think most of us would like to say we are striving for "accurate beliefs," but sometimes we may actually be pursuing "desired conclusions."  Hence the value of this message board.  Folks like @Analytics have perspectives on the Restored Gospel that, in many respects, substantially diverge from my own.    If I was interested in only "arriv{ing} at desired conclusions," I would go find an echo chamber.  Instead, I come here to test and vet my beliefs about the Restored Gospel by listening to what its critics have to say.  Sometimes they have valid observations, but mostly I think their commentary is more about fundamental - and not empirically testable - presuppositions than about the "facts."  

For my part, I have no particular or vested interest in what a handful of Latter-day Saints thought about City Creek in 2012.  As it is, I think most (nearly all?) of them - and most informed Latter-day Saints today - had and have a pretty accurate understanding of things, including that

  • the Church invests a percentage of tithing revenue,
  • the Church has publicly disclosed the previous point for quite a while (since at least 1991),
  • no tithes were used to fund City Creek,
  • "tithes" are monies voluntarily contributed by the Saints,
  • earnings/interest on invested tithes are not tithes, and they disagree with the notion/characterization that "indirectly using tithing money is still using tithing money" and/or “{i}nterest on tithing money is still tithing money" (this concept is, I think, the sine qua non of the tithing lawsuits),
  • investing a portion of tithes is morally wrong/improper, 
  • Pres. Hinckley and other leaders of the Church were "disingenuous" and/or engaged in "money laundering" relative to City Creek,
  • the leaders of the Church have, for many decades now, been excellent stewards of the Church's finances, and
  • the leaders of the Church are not living profligate lifestyles or otherwise squandering/misusing Church funds to enrich or unduly benefit themselves.

This thread, and others about the "tithing" lawsuits, have for some had a sort of "Mirror of Erised"-style effect on some participants.  While my "desired conclusions" would have been for the Church to be exonerated of the accusations of fraud and misconduct, I would also want to have "accurate beliefs" about the Church's conduct relative to City Creek.  If the Church has done something wrong, I think it needs to be held accountable.  Consequently, in these threads I have found some value in examining the lawsuits which have sought to apply neutral principles of law.  As it happens, the Church has been altogether vindicated, such that "accurate beliefs" and "desired conclusions" overlap almost perfectly.

I am curious about what @Analytics feels his "accurate beliefs" and "desired conclusions" have been regarding the Church and City Creek, both before and during and after the adjudication of the tithing lawsuits.  Roger?  

Thanks,

-Smac

I had a reply to this and lost it and haven't wanted to retype it again.

But the gist was that I'm sure my thoughts and belief on this topic have changed some since 2012.  I have more information than I did then, more wisdom, and have been exposed to posters ideas here.  I don't remember what I thought about investing tithing back then but I wouldn't be at all surprised if I had a negative reaction to it.  Now, understanding that all tithing is invested (whether by the bank or the church) unless it's being stored in a cave in cash, the idea makes good sense to me.

But what hasn't changed is my opinion that the church was honest in its explanations of where the money for the mall was going to come from and that it wasn't coming from tithing back in 2012.

As for motivated reasoning, I find it's a bit of a cop-out when applied to others because it comes across as a moral judgment rather than an explanation, but I know it's a real thing and so it's relevant for all of us.  We're all invested in our opinions and beliefs about the church being right so in that way we are all motivated in our reasoning. 

It's a good thing to remember for ourselves, not the best thing to try to apply to other people.

Posted
15 hours ago, bluebell said:

I had a reply to this and lost it and haven't wanted to retype it again.

That is a frustration, to be sure.

15 hours ago, bluebell said:

But the gist was that I'm sure my thoughts and belief on this topic have changed some since 2012. 

So have mine.  We have more information now than we did in 2012.

Substantively, though, my understanding has not really changed:

  • The Church invests a percentage of tithing revenue.  I have know about this for a long time.  I have no objection to it.  In fact, I think wise stewardship - mandated in the Parable of the Talents - would effectively require the Brethren to manage the finances of the Church as they have been.  It was not until N. Eldon Tanner came on board in the 60s that the leadership of the Church stabilized - hopefully permanently - the finances of the Church.
  • No tithes were used to fund City Creek.  I think there was barely a colorable legal claim, but it did not withstand judicial scrutiny.  And given the factual allegations in the tithing lawsuits, I think that scrutiny was barred by the Church Autonomy Doctrine.
  • "Tithes" are monies voluntarily contributed by the Saints and earnings/interest on invested tithes are not tithes.  This is effectively axiomatic.  It is only a point worth mentioning here because Huntsman et al. presented a contrary notion (pretextually, IMO) to the Courts.  It didn't work.

Frankly, I think most Latter-day Saints have given little to no thought to any of these points.  I have, but that's because I am an attorney, and because I regularly interact with critics of the Church who are prone to raise critiques associated with these issues.

15 hours ago, bluebell said:

I have more information than I did then, more wisdom, and have been exposed to posters ideas here.  I don't remember what I thought about investing tithing back then but I wouldn't be at all surprised if I had a negative reaction to it.  Now, understanding that all tithing is invested (whether by the bank or the church) unless it's being stored in a cave in cash, the idea makes good sense to me.

That makes sense, particularly when the topic is framed in sensationalistic terms, as some critics are prone to do.  It takes some time and study and effort to find that the reality does not really match up to the sensationism.

15 hours ago, bluebell said:

But what hasn't changed is my opinion that the church was honest in its explanations of where the money for the mall was going to come from and that it wasn't coming from tithing back in 2012.

Same here.  Candidly, I have a hard time crediting Huntsman with a good faith belief that Pres. Hinckley made fraudulent statements to the Church.  Not only would that have been quite out of character for both the man and his calling, it also makes no sense in and of itself.  Why would Pres. Hinckley publish a lie that could be rather easily detected?  Why would Pres. Hinckley lie about the Church not using tithes when the contrary proposition would have been entirely legal and feasible? 

15 hours ago, bluebell said:

As for motivated reasoning, I find it's a bit of a cop-out when applied to others because it comes across as a moral judgment rather than an explanation, but I know it's a real thing and so it's relevant for all of us. 

I agree that it can be a sort of cop-out or cheap shot when deployed against others, which is why A) I applied it to myself only, and B) queried Analytics as to his self-assessment ("I am curious about what @Analytics feels his 'accurate beliefs' and 'desired conclusions' have been regarding the Church and City Creek...") rather than impose my own assessment onto him.

15 hours ago, bluebell said:

We're all invested in our opinions and beliefs about the church being right so in that way we are all motivated in our reasoning. 

Yes.  I think the challenge is for us to use reasoning to pursue "accurate beliefs" rather than a particularized set of "desired conclusions."

I love the Church and believe it is what it claims to be, but I don't do myself or anyone else any favors by viewing it through rose-colored glasses.  No need, mostly, as I think the Church's conduct is overwhelmingly good and appropriate.

15 hours ago, bluebell said:

It's a good thing to remember for ourselves, not the best thing to try to apply to other people.

I agree.  I apologize, both to you and @Analytics, if I gave the impression I was doing that.  I intended to elicit his own assessment of his "motivated reasoning."

Thanks,

-Smac

Posted
1 hour ago, smac97 said:

That is a frustration, to be sure.

So have mine.  We have more information now than we did in 2012.

Substantively, though, my understanding has not really changed:

  • The Church invests a percentage of tithing revenue.  I have know about this for a long time.  I have no objection to it.  In fact, I think wise stewardship - mandated in the Parable of the Talents - would effectively require the Brethren to manage the finances of the Church as they have been.  It was not until N. Eldon Tanner came on board in the 60s that the leadership of the Church stabilized - hopefully permanently - the finances of the Church.
  • No tithes were used to fund City Creek.  I think there was barely a colorable legal claim, but it did not withstand judicial scrutiny.  And given the factual allegations in the tithing lawsuits, I think that scrutiny was barred by the Church Autonomy Doctrine.
  • "Tithes" are monies voluntarily contributed by the Saints and earnings/interest on invested tithes are not tithes.  This is effectively axiomatic.  It is only a point worth mentioning here because Huntsman et al. presented a contrary notion (pretextually, IMO) to the Courts.  It didn't work.

Frankly, I think most Latter-day Saints have given little to no thought to any of these points.  I have, but that's because I am an attorney, and because I regularly interact with critics of the Church who are prone to raise critiques associated with these issues.

That makes sense, particularly when the topic is framed in sensationalistic terms, as some critics are prone to do.  It takes some time and study and effort to find that the reality does not really match up to the sensationism.

Same here.  Candidly, I have a hard time crediting Huntsman with a good faith belief that Pres. Hinckley made fraudulent statements to the Church.  Not only would that have been quite out of character for both the man and his calling, it also makes no sense in and of itself.  Why would Pres. Hinckley publish a lie that could be rather easily detected?  Why would Pres. Hinckley lie about the Church not using tithes when the contrary proposition would have been entirely legal and feasible? 

I agree that it can be a sort of cop-out or cheap shot when deployed against others, which is why A) I applied it to myself only, and B) queried Analytics as to his self-assessment ("I am curious about what @Analytics feels his 'accurate beliefs' and 'desired conclusions' have been regarding the Church and City Creek...") rather than impose my own assessment onto him.

Yes.  I think the challenge is for us to use reasoning to pursue "accurate beliefs" rather than a particularized set of "desired conclusions."

I love the Church and believe it is what it claims to be, but I don't do myself or anyone else any favors by viewing it through rose-colored glasses.  No need, mostly, as I think the Church's conduct is overwhelmingly good and appropriate.

I agree.  I apologize, both to you and @Analytics, if I gave the impression I was doing that.  I intended to elicit his own assessment of his "motivated reasoning."

Thanks,

-Smac

To clarify, I didn’t think you were doing that at all. It was Analytics response to my post and question to him that was most front in my mind.  No apologies from anyone necessary. 

Posted (edited)
23 hours ago, Analytics said:

certainly don’t have a “presupposition that indirectly using tithing money is still using tithing money.”  

You previously asked me:

Quote

1- Did you ask Grok, "With 20/20 hindsight, and looking at the issue the way these participants looked at in 2015, who was more right, the “faithful participants”, or the “critics”? In other words, was the mall in part indirectly financed with tithing because it was in fact financed in part with investment income derived from tithing?"

Also you (from 2024) :

Quote
Quote

Of course, nobody in the real world thinks or acts this way.  The only way these inane hypotheticals come about is when anti-Mormons become heck-bent on casting the Church of Jesus Christ in the worst possible light, so much so that they are willing to twist and contort and confabulate and come up with absurdities like "it's all tithing," or "it's all indirectly tithing."  

Tithing donations were in fact indirectly used, as  Craig Paxton said. Saying “it’s all tithing” is a straw man that has nothing to do with what was then said or with my point now.

And here:

Quote
Quote

So "tithing" is different from "tithing funds"?  Because you seem to have said that there is no doubt that tithing does not include "investment income earned off of tithing".  Why are they different?

Using tithing to generate investment income which is then used to build a mall is indirectly using tithing to build a mall.

Nobody is changing the definition of “tithing.” Rather, we acknowledge that indirectly using things is still using them.
...

If “interest on unspent tithing” was how the mall was funded, then tithing money was in fact used indirectly.

And here:

Quote
Quote

I don't see how arguing about "used indirectly" have anything to do with this.  Did President Hinckley or any of the other statements say that any money tangentially/indirectly related would not be used? 

“Indirect” has everything to do with it because it is something we’ve been discussing on this board for about 12 years now. Based on the responses of faithful Saints to these topics, a plurality of Latter-day Saints thought when Hinckley said “no tithing would be used” he meant no tithing would be used directly, and no tithing would be used indirectly. 

And here:

Quote

I’m talking about a secular definition of the word “use.” 

I just posed the following question to ChatGPT:

Is using something indirectly still using it? For example, if a Church uses tithing revenue to generate investment income, and then uses that investment income to fund the purchase item “x”, is it accurate to say the Church used tithing revenue to fund the purchase of “x”?

ChatGPT answered:

"Yes, using something indirectly is still considered using it, especially in cases like the one you've described. In your example, the tithing revenue is the original source of the funds, even though it was first invested to generate income. Therefore, it would be accurate to say that the purchase of "x" was ultimately funded by tithing revenue, albeit indirectly through investment income.

And here:

Quote
Quote

A is used to make B.  B is used by C. Is C using A?

Hammers are one of many tools used to make houses. Houses are used for shelter. Are hammers one of many tools used to indirectly make shelter? Yes. Of course.

And here:

Quote

So, I was excited to give an interesting counter example to prove Sam Brunson was wrong about “every financial endeavor.” So I provided a quote from the congressional hearing I remembered so well, because I thought that would be an interesting way to make the point. And while I was at it, I also mentioned that I could see how somebody could think of these things the way Huntsman claimed he did. After all, if you believe in logic then logically, indirectly using something is still using it. If you happened to look at the world this way, then logically, using tithing income to generate investment income to buy a mall is indirectly using tithing to buy a mall. That is logical, and that logic is the reason why some members of this board used to believe, based on Hinckley’s assurances, that if you traced the funding of the mall back to the beginning, it would go back to the original ZCMI, not to tithing dollars.

And here (this is me responding to you) :

Quote
Quote

The concept of “indirectly used” is not mine.

You are the one advancing it.  You've said things like this: "Nobody is changing the definition of 'tithing.' Rather, we acknowledge that indirectly using things is still using them."

You've taken ownership of this pig-in-a-poke idea.

"We acknowledge..."

You responded:

Quote
Quote

You are the one advancing it.  You've said things like this: "Nobody is changing the definition of 'tithing.' Rather, we acknowledge that indirectly using things is still using them."

From a certain point of view, this is true. But acknowledging that the people I’m quoting are saying things that are logically coherent doesn’t make the idea mine

And here:

Quote

In 2012, JAHS started a thread about whether "in an indirect way the City Creek mall was made possible by sacred tithing money.” That is a direct quote about the explicit topic of that thread. And we now know the answer. Yes, in an indirect way the City Creek mall was made possible by sacred tithing money.

And here:

Quote

Logically, using interest earned on unspent tithing to fund the mall would be using tithing to fund the mall; indirectly using something is still using it.

It seems like even if you disclaim originating the "indirect tithing" concept, you have advanced it and ratified it over and over.  

23 hours ago, Analytics said:

My presupposition is that the whole distinction between tithing money and non-tithing money is mental accounting and silly.  The claim that tithing money is somehow different than non-tithing money and that the Church could use tweezers to extract non-tithing dollars from its portfolio and distribute those dollars is silly to me. Thats how I see it.

Okay.  I appreciate the clarification.  I am struggling to reconcile it with your various prior statements, some of which are quoted above, which appear to specifically ratify and endorse this distinction:

  • "Tithing donations were in fact indirectly used, as Craig Paxton said."
  • "Using tithing to generate investment income which is then used to build a mall is indirectly using tithing to build a mall."
  • "{W}e acknowledge that indirectly using things is still using them."
  • "If 'interest on unspent tithing' was how the mall was funded, then tithing money was in fact used indirectly."
  • "Are hammers one of many tools used to indirectly make shelter? Yes. Of course."
  • "After all, if you believe in logic then logically, indirectly using something is still using it."
  • "{L}ogically, using tithing income to generate investment income to buy a mall is indirectly using tithing to buy a mall.  That is logical..."
  • "From a certain point of view, this {'we acknowledge that indirectly using things is still using them'} is true."
  • "Yes, in an indirect way the City Creek mall was made possible by sacred tithing money."
  • "Logically, using interest earned on unspent tithing to fund the mall would be using tithing to fund the mall; indirectly using something is still using it."

Could you clarify what your perspective is?  Are you saying that the direct/indirect distinction is "silly"?

23 hours ago, Analytics said:

But how I see it is irrelevant.

It seems like you have been advancing arguments, for some years now, which presuppose that the direct/indirect differentiation is, in your words, "fact," something "we acknowledge," axiomatic ("of course"), and so on.  Could you help me understand how your perspective is not relevant to your arguments?

Thanks,

-Smac

Edited by smac97
Posted (edited)
1 hour ago, smac97 said:

Could you clarify what your perspective is?  Are you saying that the direct/indirect distinction is "silly"?

Here is what I believe.

Starting in the early 1960’s, N. Elden Tanner made the decision that the Church would always operate on approximately 90% of the current year’s donations and save the balance “for a rainy day.” This was a prudent move for a few years, because like all non-profits, the Church should have reserves. 

Prompt:
In general, should churches and non-profits hold reserves “for a rainy day"? If so, are there general guidelines for an appropriate amount of reserves? Is it possible for reserves to be too high? Please limit your response to a couple of sentences.

ChatGPT:
Yes. Churches and nonprofits generally should hold operating reserves so they can survive revenue disruptions, emergencies, unexpected repairs, litigation, economic downturns, or temporary donor shortfalls.

A common rule of thumb is 3–6 months of operating expenses, though the right amount depends on volatility, obligations, asset liquidity, capital needs, and mission risk. Reserves can be too high if they substantially exceed reasonably foreseeable needs and start to suggest hoarding, weak mission deployment, or donor misleadingness about the organization’s actual financial need.

My Perspective
In August of 1997, TIME ran a cover story called “Mormon Inc.” Less than two months later, a public charity called "Ensign Peak Advisors" was formed. The only obvious reason why this happened was to get these assets off of the Church’s balance sheet. If there was a lawsuit or a change in laws that forced the church to disclose how much money it has, the Church was going to show the assets it owns directly and not show the assets it had donated to Ensign Peak Advisors.

In order to prevent the church membership and the public from knowing how much money Ensign Peak Advisors had, the Church created several LLC’s and falsely reported  to the SEC that the LLC’s owned the church’s securities rather than Ensign Peak Advisors. 

The Church regularly transferred excess money to Ensign Peak Advisors. For several years, it was at the clip of a billion dollars a year.  Specifically, this excess tithing was deposited into Ensign Peak Advisors’ Treasury Account. Ensign Peak Advisors had guidelines that about 5% of their total assets would remain in the Treasury Account for liquidity purposes. As the Treasury Account exceeded its limits, funds would be transferred to different accounts to purchase equities and bonds. The actual growth of the funds happens in these downstream accounts, and money has never gone from any of these downstream accounts back to the Treasury Account.

When the City Creek project needed $1.4 billion to cover cost overruns, the money came straight from the Treasury Account. 

That is my perspective.

Was Tithing Money Used?
Was “tithing money” used? indirectly, tithing certainly was used. I’m not claiming that “indirect tithing” is a thing. Rather, I’m saying that if tithing hadn’t been donated and saved in the first place, there wouldn’t be any money in these accounts to use for the mall, regardless if the specific dollars were labeled “tithing” or “investment income on unspent tithing.” From an economic perspective, all of the money in Ensign Peak Advisors is the original tithing donations that have grown with interest (compare and contrast this with an accounting perspective, where donations and investment income are two different inflows on the income statement, but are intermingled when they hit the balance sheet).

Was tithing used directly? That is the question that I think is more silly. Whether it was or wasn’t depends on what it means for tithing to be used “directly.” There are a couple of different ways that “using tithing directly” could be defined:

Definition 1: Using tithing “directly” could mean that the dollars that were used came straight from checking account where tithing donations are deposited, or from Ensign Peak Advisors’ Treasury Account, that contains money recently donated from the Church and that hasn’t grown with interest. If you use this definition, then it appears the answer is yes, the Church did in fact use tithing money to fund the mall. We know this because the money from the mall came from Ensign Peak Advisors’ Treasury Account, that only contains recently donated tithing that hasn’t grown with interest.

Definition 2: We could set up a mental rule that the total value of Ensign Peak Advisors assets are in two funds: “tithing” and “investment income.” We could also set up the mental rule that when money comes in, donations from the Corporation of the President are strictly credited to the “tithing” account, and all investment income is strictly credited to the “investment income” account. We could set up a corresponding rule that all expenses and withdrawals are debited against the “investment income” account first, and the “tithing” account isn’t touched until the “investment income” account is exhausted. This second definition is a more pedantic explanation of the principal/interest argument the Church successfully made in Huntsman lawsuit.

So whether “tithing” was used to build the mall depends upon whether you interpreted using tithing in a broad sense or a narrow sense. If you define it in a narrow sense, the answer further depends on how "using tithing directly" is defined. Because if you look at the specific account the $1.4 billion were drawn against, that account didn’t have any investment income--it only had donations that were recently made by the Corporation of the President, which presumably were mostly tithing dollars.

1 hour ago, smac97 said:

It seems like you have been advancing arguments, for some years now, which presuppose that the direct/indirect differentiation is, in your words, "fact," something "we acknowledge," axiomatic ("of course"), and so on.  Could you help me understand how your perspective is not relevant to your arguments?

My argument is that what I stated above in the My Perspective section is what I believe is true. Beyond that, whether or not “tithing was used” depends upon how “using tithing” is defined. In 2012, "a clear majority of the believing Latter-day Saint participants in [that] 2012 thread” interpreted “using tithing” in the broad sense, not the narrow sense that the courts have decided is the correct one. I think it’s important to remember that.

Bonus Insight
If we use the definition of “using tithing” that the courts used to determine Hinckley told the truth (i.e. if expenses are greater than interest income, interest is used and the principal remains untouched), then the Church doesn’t spend tithing on anything. 100% of the Church’s expenses are covered by investment income, twice over. 100% of the churches expenses and charitable endeavors are completely paid for with interest, and 100% of tithing goes to purchase more shares of Nvidia and Meta.
 

Edited by Analytics
Posted (edited)
2 hours ago, Analytics said:

we use the definition of “using tithing” that the courts used to determine Hinckley told the truth (i.e. if expenses are greater than interest income, interest is used and the principal remains untouched), then the Church doesn’t spend tithing on anything. 100% of the Church’s expenses are covered by investment income, twice over. 100% of the churches expenses and charitable endeavors are completely paid for with interest, and 100% of tithing goes to purchase more shares of Nvidia and Meta.
 

But operations funding is apparently pulled out before excess contributions are sent to EPA….

Edited by Calm
Posted
46 minutes ago, Calm said:

But operations funding is apparently pulled out before excess contributions are sent to EPA….

The IRS whistleblower report argues that EPA is separate from the church and should be taxed that way. If EPA isn’t part of the church, then it is a private foundation that owes tens of billions in back taxes.

The Church has been arguing that EPA is a division of the church and not a separate entity at all. If we accept that, then EPA’s money is the church’s money, so your argument of money being “sent to EPA” is meaningless—it is all the church’s money.

According to the IRS whistleblower report, the specific funds that were used to pay for the mall were pulled out of EPA before they earned any interest. Assuming he is right, under definition 1 of “using tithing”, tithing dollars were used for both the church’s mission AND for the mall. 

The church successfully argued definition 2 is the correct definition—if interest income was sufficient to cover the mall, we should presume it was paid for with interest and not principal. But if we are consistent with that logic, interest covers everything, including its mission.

 

Posted
1 hour ago, Analytics said:

The IRS whistleblower report argues that EPA is separate from the church and should be taxed that way. If EPA isn’t part of the church, then it is a private foundation that owes tens of billions in back taxes.

It has been quite a while since we discussed the "whistleblower" matter.  Mr. Nielsen filed his complaint in 2019.  Is it your understanding that his complaint is still pending or otherwise "open" with the IRS?  

1 hour ago, Analytics said:

The Church has been arguing that EPA is a division of the church and not a separate entity at all. If we accept that, then EPA’s money is the church’s money, so your argument of money being “sent to EPA” is meaningless—it is all the church’s money.

Even if the Church and EPA are all legally one organization, how do you see the distinction (or lack of one) between tithing dollars and other sources of income? Tithing is tax-free and the bulk of it is used to fund the Church's religious purposes, and a portion of tithes is sent to EPA for investment purposes, and still other funds can come from for-profit sources, and therefore can be taxable. Do you think that difference still matter when we’re talking about how funds flow internally?

1 hour ago, Analytics said:

According to the IRS whistleblower report, the specific funds that were used to pay for the mall were pulled out of EPA before they earned any interest. Assuming he is right, under definition 1 of “using tithing”, tithing dollars were used for both the church’s mission AND for the mall. 

This is interesting.  One piece I am trying to square is the Ninth Circuit’s handling of it in the Huntsman case. The initial 2023 panel decision seemed to agree with you that the definition of “tithing funds” (principal vs. earnings) was ambiguous enough for a jury. But the full en banc court in 2025 unanimously ruled the other way, saying no reasonable person could conclude the Church misrepresented the source once you factor in their clarification about using earnings on invested reserves.

I would like to better understand how you weigh those two rulings. Does the whistleblower’s accounting of the specific account outweigh the en banc court’s conclusion, in your view? Or is there a different reason you see Definition 1 as the right lens here, even after the final decision?  Also, do you think there is strong factual evidence that Nielsen's allegations ("the specific funds that were used to pay for the mall were pulled out of EPA before they earned any interest") have been established?

1 hour ago, Analytics said:

The church successfully argued definition 2 is the correct definition—if interest income was sufficient to cover the mall, we should presume it was paid for with interest and not principal. But if we are consistent with that logic, interest covers everything, including its mission.

It has been quite a while since we discussed the "whistleblower" matter.  Mr. Nielsen filed his complaint in 2019.  Is it your understanding that his complaint is still pending or otherwise "open" with the IRS?  

Thanks,

-Smac

Posted (edited)
6 hours ago, smac97 said:

Quoting Analytics:  According to the IRS whistleblower report, the specific funds that were used to pay for the mall were pulled out of EPA before they earned any interest. Assuming he is right, under definition 1 of “using tithing”, tithing dollars were used for both the church’s mission AND for the mall. 

And how did he (was it Lars or David saying this?) know this?  As far as I can tell Lars makes a statement, adds some doodling on a handout that may or may not be accurate, but provides no actual documentation or sources.  The balance of the fund at that time was more than sufficient to cover the building, 1.5 billion iirc over 5 years, so around 300 million a year when on average the fund was at 31 billion for those 5 years (starting at 29 and ending at 38 iirc).  I believe that handouts described it as one of the small draws on the fund.

From Lars’ (the brother who did not work at EPA, but as a health care consultant) report:

Quote

This check was cut from the EPA Treasury account, not from any liquidation of allocated capital. Only never-invested tithing surplus enters the EPA Treasury account.

He refers to this one check? apparently?  But funds were withdrawn multiple times over 5 years according to the report if I understand it correctly.

image.png.5a7d900978a248aaeb19c6a63d6ce21a.png

Edited by Calm
Posted (edited)
9 hours ago, smac97 said:

It has been quite a while since we discussed the "whistleblower" matter.  Mr. Nielsen filed his complaint in 2019.  Is it your understanding that his complaint is still pending or otherwise "open" with the IRS?  

No idea. It might be in a pending file, but that’s speculation.

9 hours ago, smac97 said:

Even if the Church and EPA are all legally one organization, how do you see the distinction (or lack of one) between tithing dollars and other sources of income? Tithing is tax-free and the bulk of it is used to fund the Church's religious purposes, and a portion of tithes is sent to EPA for investment purposes, and still other funds can come from for-profit sources, and therefore can be taxable. Do you think that difference still matter when we’re talking about how funds flow internally?

I'm not sure I understand the question. In this context, what does “Tithing is tax-free” mean? Tithing donations made in the U.S. are tax-deductible to the donors, and the Church itself is a 501(c)(3) tax-exempt entity, so even though it is economically profitable, it doesn’t pay taxes on those profits--rather, it just saves them for a rainy day and/or the second coming. But the “profits” we are talking about is total revenue (i.e. all donations plus all investment income including profits from owned for-profit companies) less total expenses. For the Church, the $18 million it made in JPMorgan dividends last year is just as “tax-free” as the tithing it received last year. 

My whole point is that your claim that “the bulk of [tithing] is used to fund the Church’s religious purposes” isn’t necessarily true. The en banc opinion was that since earnings on invested reserve funds were more than enough to cover the mall, we should assume that the mall was funded by these investment earnings. When looking at the Church as a whole, the same logic could be used to prove that tithing isn’t used to fund the Church’s religious mission, either: since earnings on invested reserve funds is more than enough to cover 100% of all of the Church’s expenses, we should assume that all expenses are covered by earnings on reserves and not tithing.

9 hours ago, smac97 said:

This is interesting.  One piece I am trying to square is the Ninth Circuit’s handling of it in the Huntsman case. The initial 2023 panel decision seemed to agree with you that the definition of “tithing funds” (principal vs. earnings) was ambiguous enough for a jury. But the full en banc court in 2025 unanimously ruled the other way, saying no reasonable person could conclude the Church misrepresented the source once you factor in their clarification about using earnings on invested reserves.

I would like to better understand how you weigh those two rulings. Does the whistleblower’s accounting of the specific account outweigh the en banc court’s conclusion, in your view? Or is there a different reason you see Definition 1 as the right lens here, even after the final decision?

From my perspective, Hinckley’s claim was too vague to be relied on in a meaningful way, and if I were the judge I would have granted summary judgment on that basis.

I suspect most members are more comfortable with the idea of the Church using tithing to run the Church and saving a little extra for a rainy day than they are with the idea of the Church running 100% of its operations off of investment earnings and using 100% of tithing to increase the size of the reserve fund. My point is that this distinction is an example of the cognitive bias known as Mental AccountingThe reality is that the Church takes in something like $24 billion a year in fungible revenue. Perhaps 30% of this revenue is tithing and 70% investment income. It then uses perhaps 25% of the revenue to run the church, and uses the remaining 75% of its income to buy more stock in Meta, Exxon Mobil, UnitedHealth, Eli Lilly, JPMorgan, Lockead Martin, etc.

9 hours ago, smac97 said:

  Also, do you think there is strong factual evidence that Nielsen's allegations ("the specific funds that were used to pay for the mall were pulled out of EPA before they earned any interest") have been established?

I'd be willing to hear the Church’s side of the story if it wanted to dispute this particular allegation, but personally I’m fairly confident it is true--that is the way I’d expect a professional treasurer to do it.

9 hours ago, smac97 said:

It has been quite a while since we discussed the "whistleblower" matter.  Mr. Nielsen filed his complaint in 2019.  Is it your understanding that his complaint is still pending or otherwise "open" with the IRS?  

I have no understanding of this, but would speculate that it is in a perpetual status of being “received but not investigated.” 

Edited by Analytics
Posted (edited)
1 hour ago, Analytics said:

My whole point is that your claim that “the bulk of [tithing] is used to fund the Church’s religious purposes” isn’t necessarily true.

Thank you for clarifying this.  Could you elaborate?  From the Church in 2019:

Quote

We take seriously the responsibility to care for the tithes and donations received from members. The vast majority of these funds are used immediately to meet the needs of the growing Church including more meetinghouses, temples, education, humanitarian work and missionary efforts throughout the world. Over many years, a portion is methodically safeguarded through wise financial management and the building of a prudent reserve for the future. 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. All Church funds exist for no other reason than to support the Church’s divinely appointed mission.

Claims being currently circulated are based on a narrow perspective and limited information. The Church complies with all applicable law governing our donations, investments, taxes, and reserves. We continue to welcome the opportunity to work with officials to address questions they may have.

If you have contrary evidence (to rebut the statement that "{t}he vast majority of these funds {tithes and donations received from members} are used immediately to meet the needs of the growing Church"), could you provide some references for me to review?

1 hour ago, Analytics said:

The en banc opinion was that since earnings on invested reserve funds were more than enough to cover the mall, we should assume that the mall was funded by these investment earnings. When looking at the Church as a whole, the same logic could be used to prove that tithing isn’t used to fund the Church’s religious mission, either: since earnings on invested reserve funds is more than enough to cover 100% of all of the Church’s expenses, we should assume that all expenses are covered by earnings on reserves and not tithing.

Okay.  Do you have any evidence to substantiate that this is what is happening?

1 hour ago, Analytics said:

I suspect most members are more comfortable with the idea of the Church using tithing to run the Church and saving a little extra for a rainy day than they are with the idea of the Church running 100% of its operations off of investment earnings and using 100% of tithing to increase the size of the reserve fund.

I am not sure I understand what you are saying here.  Are saying this latter idea ("of the Church running 100% of its operations off of investment earnings and using 100% of tithing to increase the size of the reserve fund") is what is actually happening?

1 hour ago, Analytics said:
Quote

Also, do you think there is strong factual evidence that Nielsen's allegations ("the specific funds that were used to pay for the mall were pulled out of EPA before they earned any interest") have been established?

I'd be willing to hear the Church’s side of the story if it wanted to dispute this particular allegation, but personally I’m fairly confident it is true--that is the way I’d expect a professional treasurer to do it.

In the law, there is a concept called a "prima facie case," that is, that a party has presented a legal claim that is supported by sufficient, initial evidence, making it appear valid "at first sight" or "on its face". It establishes a rebuttable presumption of truth, meaning the case will proceed or succeed unless the opposing party introduces evidence to refute or contradict it. 

You seem to be suggesting that Nielsen has made a "prima face case" that "the specific funds that were used to pay for the mall were pulled out of EPA before they earned any interest."  Is that a fair characterization of your position?  If so, could you elaborate on how you reached that conclusion?

1 hour ago, Analytics said:
Quote
Quote

The IRS whistleblower report argues that EPA is separate from the church and should be taxed that way. If EPA isn’t part of the church, then it is a private foundation that owes tens of billions in back taxes.

It has been quite a while since we discussed the "whistleblower" matter.  Mr. Nielsen filed his complaint in 2019.  Is it your understanding that his complaint is still pending or otherwise "open" with the IRS?  

I have no understanding of this, but would speculate that it is in a perpetual status of being “received but not investigated.” 

Assuming your speculation is accurate, do you think Nielsen's argument re: EPA is factually and legally correct?  If so, why do you think the IRS has not done anything with this complaint?  

I appreciate your input.  While we seldom agree on ultimate issues pertaining to the Church, I have found much value in listening to your perspective over the years.  

Thanks,

-Smac

Edited by smac97
Posted
3 hours ago, smac97 said:

Thank you for clarifying this.  Could you elaborate?  From the Church in 2019:

Quote

We take seriously the responsibility to care for the tithes and donations received from members. The vast majority of these funds are used immediately to meet the needs of the growing Church including more meetinghouses, temples, education, humanitarian work and missionary efforts throughout the world. Over many years, a portion is methodically safeguarded through wise financial management and the building of a prudent reserve for the future. 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. All Church funds exist for no other reason than to support the Church’s divinely appointed mission.

Claims being currently circulated are based on a narrow perspective and limited information. The Church complies with all applicable law governing our donations, investments, taxes, and reserves. We continue to welcome the opportunity to work with officials to address questions they may have.

If you have contrary evidence (to rebut the statement that "{t}he vast majority of these funds {tithes and donations received from members} are used immediately to meet the needs of the growing Church"), could you provide some references for me to review?

 

There are two things I take issue with in what you quoted.

First, the point of the Parable of the Talents is the importance of using talents (skills, money, time) to serve God and the community, rather than hiding them. The Church using a supermajority of its annual income to secretely capitalize Wall Street rather than using them for religious or charitable purposes is more like burying talents than it is putting them to good use. The Church is interpreting this one exactly backwards, unless the Church's "divinely appointed mission" is to capitalize Wall Street. 

Second, the Church's reserve fund is waaaayyyy beyond "prudent." It is deep into "hoarding."

Just as I have no reason to doubt that there was a pretty direct pipeline from tithing to the City Creek payments, I have no reason to doubt there is a pretty direct pipeline from tithing to financing the needs of the Church.

3 hours ago, smac97 said:

I am not sure I understand what you are saying here.  Are saying this latter idea ("of the Church running 100% of its operations off of investment earnings and using 100% of tithing to increase the size of the reserve fund") is what is actually happening?

My point is that money is completely fungible and there are multiple ways you could rationalize that the expenses for this or that came from "tithing" or from "investment earnings on reserves." The rationalizations the court used to determine that the mall was funded by "investment earnings" could be used to determine that all spending comes from investment earnings. But you don't have to be internally consistent if you don't want to be. You can use one rationalization for why church expenses are from tithing and a different rationalization for why City Creek was not. I think the entire question is silly.

3 hours ago, smac97 said:

In the law, there is a concept called a "prima facie case," that is, that a party has presented a legal claim that is supported by sufficient, initial evidence, making it appear valid "at first sight" or "on its face". It establishes a rebuttable presumption of truth, meaning the case will proceed or succeed unless the opposing party introduces evidence to refute or contradict it. 

You seem to be suggesting that Nielsen has made a "prima face case" that "the specific funds that were used to pay for the mall were pulled out of EPA before they earned any interest."  Is that a fair characterization of your position?  If so, could you elaborate on how you reached that conclusion?

Yes, that's fair. I have a couple of reasons for believing this is true. First, David Nielsen said it is true in his report. Second, this is how an organization run by MBAs would do it. If the Church went to EPA and asked for $1.4 billion, EPA would see what it had in cash, and use that first. They could sell $1.4 billion of assets if they wanted to, but that would be extremely time consuming and they'd lose money on bid/ask spreads and transaction costs. It would be difficult and extremely time consuming to figure out which specific securities to sell. So rather than doing that, they'd use money from the Treasury Account which continues to grow anyway. For requests like this is why it keeps liquidity in the first place.

Repeating my main point, from an economic perspective and from an accounting perspective money is fungible. The income statement shows how much was taken in over a time period in different categories, but after it comes in it is all mixed together into common funds. There isn't an economic reason to have one fund that strictly contains tithing revenue and another fund that strictly contains investment income, and there is no reason to believe the Church's accounting system is set up that way. That's why it's irrelevant to say this or that dollar came from tithing or whatever. It is all homogenous and mixed together. They are all mixed together in the books because treating tithing dollars differently than investment income dollars would be a cognitive bias.

3 hours ago, smac97 said:

Assuming your speculation is accurate, do you think Nielsen's argument re: EPA is factually and legally correct?  If so, why do you think the IRS has not done anything with this complaint?  

This particular detail has nothing to do with Nielsen's argument. Nielsen's argument is, as I recall, that EPA doesn't qualify as a public charity because it never actually uses any of its resources for anything charitable. Therefore the IRS should classify it as a private foundation rather than a public charity and tax it as such.

The Church argues that since it is an integrated auxiliary of the Church, whether or not it is doing anything charitable needs to be evaluated by looking at the Church as a whole and not looking at EPA in a silo. Nielsen counters that it can't be an integrated auxiliary unless it is already a public charity and since it isn't a public charity it can't be an integrated auxiliary. 

I think this is clearly a unique situation that wasn't anticipated when the laws were written. I've seen companies request Private Letter Rulings from the IRS for issues that were much, much smaller than this one.

“The fundamental claim to me is that Ensign Peak brings money in, and it’s the Hotel California. It never comes out,” Professor Phil Hackney told 60 Minutes. He said the claims about the Mormon church’s investment fund are complex and in a gray area."

Posted (edited)
1 hour ago, Analytics said:

There are two things I take issue with in what you quoted.

First, the point of the Parable of the Talents is the importance of using talents (skills, money, time) to serve God and the community, rather than hiding them.

I would agree with that.  Would you also agree that the Parable also pertains to matters of stewardship?

1 hour ago, Analytics said:

The Church using a supermajority of its annual income to secretely capitalize Wall Street rather than using them for religious or charitable purposes is more like burying talents than it is putting them to good use. The Church is interpreting this one exactly backwards, unless the Church's "divinely appointed mission" is to capitalize Wall Street. 

Second, the Church's reserve fund is waaaayyyy beyond "prudent." It is deep into "hoarding."

Yes, I understand your perspective.  In many ways, I think our prior conversations about this have touched on Habit Five of the Hollis book: "Hunt for the Best Argument Against You."  That is, I think, what you provide.  I think we vary in both our respective presuppositions and our ultimate conclusions and value judgments, and I am okay with that.  Having previously argued about these matters extensively, I will here deploy Habit Ten: "Embrace the Discomfort of Non-Closure." 

1 hour ago, Analytics said:

Just as I have no reason to doubt that there was a pretty direct pipeline from tithing to the City Creek payments, I have no reason to doubt there is a pretty direct pipeline from tithing to financing the needs of the Church.

The second item here is not in dispute, but the first one appears to be.  I previously inquired about evidence to rebut the statement that "{t}he vast majority of these funds {tithes and donations received from members} are used immediately to meet the needs of the growing Church."  I'm content to leave this unanswered.

Quote

My point is that money is completely fungible and there are multiple ways you could rationalize that the expenses for this or that came from "tithing" or from "investment earnings on reserves." The rationalizations the court used to determine that the mall was funded by "investment earnings" could be used to determine that all spending comes from investment earnings. But you don't have to be internally consistent if you don't want to be. You can use one rationalization for why church expenses are from tithing and a different rationalization for why City Creek was not. I think the entire question is silly.

You said the whole question of tithing vs. investment earnings is “silly” because money is completely fungible and there are multiple ways to rationalize any expense. While dollars are fungible in the sense that any one can be spent anywhere, nonprofits and churches routinely differentiate funds by source and purpose — through fund accounting, board-designated reserves, donor restrictions, and fiduciary obligations.

Could you explain why the Church’s long-standing public distinction (vast majority of tithing used immediately for core programs, with only a portion methodically set aside as a “prudent reserve” for investment) is meaningless or silly, rather than a legitimate, transparent policy choice?

Also, even though money is fungible once received, organizations (especially tax-exempt nonprofits) are required to track and report funds according to their source and intended use — for legal compliance, donor trust, tax purposes, and stewardship. The Church’s First Presidency has repeatedly made exactly that distinction in official statements.  

If fungibility makes every such distinction irrelevant, wouldn’t that logic apply to any nonprofit that maintains operating reserves, endowments, or restricted funds? Or do you see a meaningful difference in the Church’s case?

1 hour ago, Analytics said:
Quote

In the law, there is a concept called a "prima facie case," that is, that a party has presented a legal claim that is supported by sufficient, initial evidence, making it appear valid "at first sight" or "on its face". It establishes a rebuttable presumption of truth, meaning the case will proceed or succeed unless the opposing party introduces evidence to refute or contradict it. 

You seem to be suggesting that Nielsen has made a "prima face case" that "the specific funds that were used to pay for the mall were pulled out of EPA before they earned any interest."  Is that a fair characterization of your position?  If so, could you elaborate on how you reached that conclusion?

Yes, that's fair. I have a couple of reasons for believing this is true. First, David Nielsen said it is true in his report.

Okay.  What are your thoughts about the affidavits submitted by the Church?  Do you regard them as credible?

1 hour ago, Analytics said:

Second, this is how an organization run by MBAs would do it. If the Church went to EPA and asked for $1.4 billion, EPA would see what it had in cash, and use that first. They could sell $1.4 billion of assets if they wanted to, but that would be extremely time consuming and they'd lose money on bid/ask spreads and transaction costs. It would be difficult and extremely time consuming to figure out which specific securities to sell. So rather than doing that, they'd use money from the Treasury Account which continues to grow anyway. For requests like this is why it keeps liquidity in the first place.

Apart from Nielsen's affidavit, are you aware of any evidence to suggest that this is the way the Church actually did "do it" this way?

1 hour ago, Analytics said:

Repeating my main point, from an economic perspective and from an accounting perspective money is fungible. The income statement shows how much was taken in over a time period in different categories, but after it comes in it is all mixed together into common funds. There isn't an economic reason to have one fund that strictly contains tithing revenue and another fund that strictly contains investment income, and there is no reason to believe the Church's accounting system is set up that way. That's why it's irrelevant to say this or that dollar came from tithing or whatever. It is all homogenous and mixed together. They are all mixed together in the books because treating tithing dollars differently than investment income dollars would be a cognitive bias.

I would like to better understand what you are saying here.

As I understand it, in behavioral economics, “mental accounting” usually refers to an individual bias where people irrationally value money differently based on its source (e.g., treating a tax refund like “free money”). But in organizational accounting — especially for churches and nonprofits — segregating funds by source and purpose would seem to be standard and required practice, not "bias."  This is how, for example, boards fulfill their fiduciary duties and honor donor intent.

Am I correct in thinking that you see the Church’s public statements about tithing and reserves as falling into that individual cognitive-bias category, rather than as a deliberate accounting and communications policy?

Also, given that the Church has consistently told members for decades that tithing is used first and foremost for religious programs (with only a prudent portion going into invested reserves), isn’t applying different rationalizations for different categories of spending actually the expected and transparent approach, rather than inconsistency?

The 2025 Ninth Circuit en banc decision in Huntsman (11-0) seems to have reviewed the exact same facts and fungibility arguments you’re making. The court still held that no reasonable person could find the Church misrepresented the source of funds for City Creek, because it had always said it would use earnings on invested reserves (not principal tithing) for such projects.  If fungibility makes the entire distinction “silly,” why do you think the unanimous court treated the Church’s source-of-funds explanation as meaningful and non-misleading instead of dismissing it the way you have?

You have concluded that the question is silly because one could rationalize any spending either way. But the Church has never claimed all spending comes from investment earnings — it has repeatedly said the opposite: the vast majority of tithing is spent immediately on the Church’s mission.  If that is the case, what would a non-silly version of this distinction look like to you? For example, if the Church maintained formal internal categories for immediate-use tithing versus the invested reserve (exactly as its public statements describe), would that change your view, or does fungibility render even that irrelevant?

1 hour ago, Analytics said:
Quote

Assuming your speculation is accurate, do you think Nielsen's argument re: EPA is factually and legally correct?  If so, why do you think the IRS has not done anything with this complaint?  

This particular detail has nothing to do with Nielsen's argument. Nielsen's argument is, as I recall, that EPA doesn't qualify as a public charity because it never actually uses any of its resources for anything charitable. Therefore the IRS should classify it as a private foundation rather than a public charity and tax it as such.

The Church argues that since it is an integrated auxiliary of the Church, whether or not it is doing anything charitable needs to be evaluated by looking at the Church as a whole and not looking at EPA in a silo. Nielsen counters that it can't be an integrated auxiliary unless it is already a public charity and since it isn't a public charity it can't be an integrated auxiliary. 

I think this is clearly a unique situation that wasn't anticipated when the laws were written. I've seen companies request Private Letter Rulings from the IRS for issues that were much, much smaller than this one.

“The fundamental claim to me is that Ensign Peak brings money in, and it’s the Hotel California. It never comes out,” Professor Phil Hackney told 60 Minutes. He said the claims about the Mormon church’s investment fund are complex and in a gray area."

Interesting stuff, this.

You noted Nielsen’s argument creates a circularity: EPA can’t be an integrated auxiliary unless it’s already a public charity, but Nielsen says it isn’t a public charity because it makes no direct charitable distributions. The Church’s position is that EPA is evaluated as part of the integrated Church as a whole. Do you see any support in the IRS regulations or case law for the Church’s holistic view (i.e., that an auxiliary’s charitable purpose can be satisfied by supporting the parent church’s exempt purposes rather than making standalone distributions)?

Also, Professor Hackney’s “Hotel California” line is colorful, but how does it's "{money} never comes out" claim work in light of, for example, EPA funds having been used for City Creek and Beneficial Life?  

Also, what are your thoughts about Bishop Waddells' 2023 remarks to 60 Minutes (the same piece in which Phil Hackney weighed in)?

Quote

Last year the church says it spent over a billion dollars on humanitarian aid, including food production.

Christopher Waddell: 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— education work, all the work of the church they fund. 

David Nielsen: 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, as to my knowledge the whole time I was there. So there's a bit of a distinction here that's important.

Sharyn Alfonsi: Explain that to me.

David Nielsen: 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.

"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— education work, all the work of the church they fund."

The Church's position is that EPA is an integrated auxiliary of the Church as a whole — so its charitable purpose is fulfilled by supporting the parent organization’s mission, not by making standalone distributions like a typical foundation. 

In Nielsen’s view (as stated directly in the 60 Minutes interview and his original IRS whistleblower complaint), the routine cash/Treasury-account transfers (the “average of nine transfers per month” Bishop Waddell described) do not count as meaningful use of Ensign Peak’s funds for charitable or exempt purposes.  Put another way, until and unless the Church is selling down the invested assets in that main portfolio and transferring those proceeds to support church operations, humanitarian work, etc., Nielsen argues it doesn’t satisfy the requirements for a public charity or integrated auxiliary. In his eyes, simply moving money around in the checking-account side while the retirement-account side keeps growing indefinitely doesn’t count.

Nielsen’s criticism is substantive (it raises a real, non-frivolous interpretive question under IRS rules), but it is fundamentally a disagreement about degree and policy interpretation, not a clear-cut, black-or-white violation of the law.

As I understand it, the law does not impose a bright-line spending requirement on EPA the way it does on private foundations (which must distribute ~5% of assets annually). Public charities and integrated auxiliaries of churches get much broader latitude:

  • Churches and their integrated auxiliaries are automatically treated as public charities and are exempt from many normal filing and oversight rules.
  • There is no IRS rule that says “you must spend X% of your portfolio each year or lose exempt status.”
  • The IRS has long allowed religious organizations to maintain large endowments/reserves that are invested for future needs (this is the Church’s exact “prudent reserve” theory, drawing on the parable of the talents).

In other words, the law leaves room for judgment about how much use is enough to satisfy “operated exclusively for” the church. Nielsen is arguing for a stricter, more aggressive interpretation — essentially “if you’re not regularly selling down the principal and spending it, it doesn’t count.” The Church and its defenders say the reserves exist precisely to be available when needed, and the regular cash-account transfers plus occasional large draws (City Creek earnings, Beneficial Life, operational funding) are sufficient.

Nielsen is not just making a subjective “they should spend more” complaint.  He is pointing to a genuine tension in how the operational test applies to a massive, perpetually growing reserve. That part is substantive.  But his view is not compelled by the black letter of the law. It is one reasonable interpretation among others, and the IRS’s long silence (6.5 years with no action on his complaint) suggests the agency does not see a clear, enforceable violation.

Interesting stuff, to be sure.  I think most Latter-day Saints are A) generally unaware of and indifferent to the particulars of the Church's large-scale financial management efforts, and B) generally feel that the Church is doing a good job with its finances (no systemic problems/scandals, the Brethren are not living profligate lives, there is a lot of "visible" stuff to see from the Church's efforts, etc.).

Thanks,

-Smac

Edited by smac97
Posted (edited)
19 hours ago, smac97 said:

I would agree with that.  Would you also agree that the Parable also pertains to matters of stewardship?

Yes, of course. But the master in the parable was a materialistic, worldly man whose goal was to have more money. In the context of the parable, being a good steward means deploying resources in a way that helps the master achieve his objectives. I don't think the message of the parable was to endorse wealth accumulation as a laudable goal.

19 hours ago, smac97 said:

Yes, I understand your perspective.  In many ways, I think our prior conversations about this have touched on Habit Five of the Hollis book: "Hunt for the Best Argument Against You."  That is, I think, what you provide.  I think we vary in both our respective presuppositions and our ultimate conclusions and value judgments, and I am okay with that.  Having previously argued about these matters extensively, I will here deploy Habit Ten: "Embrace the Discomfort of Non-Closure." 

Thanks.

19 hours ago, smac97 said:

You said the whole question of tithing vs. investment earnings is “silly” because money is completely fungible and there are multiple ways to rationalize any expense.

Not quite. My point was that fretting over whether a specific dollar on the balance sheet is tied to specific dollars on the income statement is what's silly. 

19 hours ago, smac97 said:

While dollars are fungible in the sense that any one can be spent anywhere, nonprofits and churches routinely differentiate funds by source and purpose — through fund accounting, board-designated reserves, donor restrictions, and fiduciary obligations.

Could you explain why the Church’s long-standing public distinction (vast majority of tithing used immediately for core programs, with only a portion methodically set aside as a “prudent reserve” for investment) is meaningless or silly, rather than a legitimate, transparent policy choice?

It's a legitimate, or at least sensible, policy choice to say that the Church wants to limit its annual spending to about 85%-90% of its annual tithing revenue. Given that conservatively, the Church's investment income revenue is double its tithing revenue, this leads to a situation where perhaps 70% of total revenue goes to increasing the size of the reserve fund, and the remaining 30% goes to religious and charitable endeavors. If deploying resources that way aligns with the Church's values, then sure; that is sensible.

What I think is silly is thinking that it matters that this be framed as directly spending the tithing dollars and adding the margin to the reserves, vs. being framed as operating the church fully off of investment income and then using 100% of tithing to increase the size of the reserve fund.

19 hours ago, smac97 said:

Also, even though money is fungible once received, organizations (especially tax-exempt nonprofits) are required to track and report funds according to their source and intended use — for legal compliance, donor trust, tax purposes, and stewardship. The Church’s First Presidency has repeatedly made exactly that distinction in official statements.  

If fungibility makes every such distinction irrelevant, wouldn’t that logic apply to any nonprofit that maintains operating reserves, endowments, or restricted funds? Or do you see a meaningful difference in the Church’s case?

My point is a little different than what this question presupposes. 

19 hours ago, smac97 said:

Okay.  What are your thoughts about the affidavits submitted by the Church?  Do you regard them as credible?

Here is the part of Paul Rytting's declaration that is most relevant. Read this, I pray thee. I cannot, for it is redacted. 

image.thumb.png.39f2d5fc8a79551ca04b8bbd22be3b8a.png

19 hours ago, smac97 said:

Apart from Nielsen's affidavit, are you aware of any evidence to suggest that this is the way the Church actually did "do it" this way?

The redacted parts of Rytting's declaration might settle the issue one way or the other, but I don't know what it says. but I'm confident Nielsen is right.

Just to better understand where I'm coming from on this, I actually have relevant personal experience and sit on committees that oversee investment portfolios in the billions. Once I was involved in negotiating a business deal that was going to transfer about $700 million of assets and liabilities from one insurance company to another. Both sides wanted to do the deal, but the toughest part was how, exactly, the $700 million of assets would be paid. The buyer (the one receiving the assets and liabilities) would have preferred cash, of course. The seller wanted to send over a portfolio of assets instead. They could have sold the assets then given the buyer the cash, but doing that in a timely manner is tough because of liquidity issues--if you just dropped it on the market for whatever the market bidding price is, you'd get a lot less than $700 million for it. So the seller sent the buyer a long list of assets they proposed to send. The buyer analyzed them each one by one and decided which ones they would to accept and keep, which ones they were willing to accept but would immediately sell, and which ones they didn't want to touch. Working this out took months.

Rytting said they "earmarked" $1.4 billion for this purpose, and that the value of what they had earmarked grew to $1.7 billion before it was fully distributed. This implies that they just gave a percentage of the entire EPA balance to this earmarked fund, not that they transferred over specific securities that they were positive were uncontaminated with tithing dollars and were pure investment income. 

If I'm right, then when COP asked for cash payments, in all likelihood they just transferred the payments from the Treasury Account. That is infinitely more practical and cost-effective than saying "give us a couple of weeks to liquidate $250,000,000 of invested investment income." They could have done that, but the result would be spending weeks of time and millions in transaction costs just so they could have the moral purity of saying that the specific dollars they paid were investment income dollars and not tithing dollars.

Just to be clear, I'm not accusing the Church of lying. Rather, I'm suggesting that in all likelihood, they really did use Definition #2 of what it means to "use tithing."

And if we consistently use that same definition, then we could say that 100% of the Church is run off of investment income and 100% of tithing is saved. We don't have to say that. But we could. My point is that this is all just semantics, but you should ask yourself why you prefer Definition #1 of what it means to "use tithing" when talking about the Church's operations, but are comfortable pivoting to Definition #2 when talking about funding the mall.

19 hours ago, smac97 said:

I would like to better understand what you are saying here.

As I understand it, in behavioral economics, “mental accounting” usually refers to an individual bias where people irrationally value money differently based on its source (e.g., treating a tax refund like “free money”). But in organizational accounting — especially for churches and nonprofits — segregating funds by source and purpose would seem to be standard and required practice, not "bias."  This is how, for example, boards fulfill their fiduciary duties and honor donor intent.

Am I correct in thinking that you see the Church’s public statements about tithing and reserves as falling into that individual cognitive-bias category, rather than as a deliberate accounting and communications policy?

Saying the budget will be set as a percentage of donations is an organizational accounting issue. Insisting that the specific dollars that are spent to operate the Church are tithing dollars and not investment income dollars is mental accounting--it feels better to think that your dollars are mostly towards operating the Church plus a little extra for savings than it feels to think that the Church is running completely off of investment income and your contributions are going purely to Ensign Peaks.

19 hours ago, smac97 said:

Also, given that the Church has consistently told members for decades that tithing is used first and foremost for religious programs (with only a prudent portion going into invested reserves), isn’t applying different rationalizations for different categories of spending actually the expected and transparent approach, rather than inconsistency?

Using the word "transparent" here seems like a stretch. 

19 hours ago, smac97 said:

The 2025 Ninth Circuit en banc decision in Huntsman (11-0) seems to have reviewed the exact same facts and fungibility arguments you’re making. The court still held that no reasonable person could find the Church misrepresented the source of funds for City Creek, because it had always said it would use earnings on invested reserves (not principal tithing) for such projects.  If fungibility makes the entire distinction “silly,” why do you think the unanimous court treated the Church’s source-of-funds explanation as meaningful and non-misleading instead of dismissing it the way you have?

Hinckley made the assurances, the courts determined that definition #2 of "using tithing" is the proper definition when interpreting his remarks. I have no problem with that, and would have and basically did argue that this was the case all along. But a lot of members misunderstood him. With transparency, this misunderstanding could have been avoidable. But the lack of transparency doesn't imply fraud. 

19 hours ago, smac97 said:

You have concluded that the question is silly because one could rationalize any spending either way. But the Church has never claimed all spending comes from investment earnings — it has repeatedly said the opposite: the vast majority of tithing is spent immediately on the Church’s mission.  If that is the case, what would a non-silly version of this distinction look like to you? For example, if the Church maintained formal internal categories for immediate-use tithing versus the invested reserve (exactly as its public statements describe), would that change your view, or does fungibility render even that irrelevant?

A non-silly look at this would be disclosing to the membership:

Church's Total Balance Sheet

  • The total value of EPA's assets
  • Total value of income-producing farm and real estate assets
  • Total value of other commercial assets (e.g. DMC)
  • Total value of funds held by COP and CPB

Church's Total Income Statement

  • Annual revenue from tithing, fast offerings, other contributions
  • Annual revenue from business income and investment income
  • Annual growth in market value of commercial assets
  • Annual expenses by broad category: temples, BYU, seminary program, missionary, etc.
  • Changes in net-assets over course of year

With this information disclosed, he would say, "we have enough annual investment income to cover the cost of the mall and won't be making any cuts to our other programs in order to finance this. We can afford to do this."

That is what I'd consider to be non-silly.

19 hours ago, smac97 said:

Interesting stuff, this.

You noted Nielsen’s argument creates a circularity: EPA can’t be an integrated auxiliary unless it’s already a public charity, but Nielsen says it isn’t a public charity because it makes no direct charitable distributions. The Church’s position is that EPA is evaluated as part of the integrated Church as a whole. Do you see any support in the IRS regulations or case law for the Church’s holistic view (i.e., that an auxiliary’s charitable purpose can be satisfied by supporting the parent church’s exempt purposes rather than making standalone distributions)?

Also, Professor Hackney’s “Hotel California” line is colorful, but how does it's "{money} never comes out" claim work in light of, for example, EPA funds having been used for City Creek and Beneficial Life?  

Also, what are your thoughts about Bishop Waddells' 2023 remarks to 60 Minutes (the same piece in which Phil Hackney weighed in)?

"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— education work, all the work of the church they fund."

The Church's position is that EPA is an integrated auxiliary of the Church as a whole — so its charitable purpose is fulfilled by supporting the parent organization’s mission, not by making standalone distributions like a typical foundation. 

In Nielsen’s view (as stated directly in the 60 Minutes interview and his original IRS whistleblower complaint), the routine cash/Treasury-account transfers (the “average of nine transfers per month” Bishop Waddell described) do not count as meaningful use of Ensign Peak’s funds for charitable or exempt purposes.  Put another way, until and unless the Church is selling down the invested assets in that main portfolio and transferring those proceeds to support church operations, humanitarian work, etc., Nielsen argues it doesn’t satisfy the requirements for a public charity or integrated auxiliary. In his eyes, simply moving money around in the checking-account side while the retirement-account side keeps growing indefinitely doesn’t count.

Nielsen’s criticism is substantive (it raises a real, non-frivolous interpretive question under IRS rules), but it is fundamentally a disagreement about degree and policy interpretation, not a clear-cut, black-or-white violation of the law.

As I understand it, the law does not impose a bright-line spending requirement on EPA the way it does on private foundations (which must distribute ~5% of assets annually). Public charities and integrated auxiliaries of churches get much broader latitude:

  • Churches and their integrated auxiliaries are automatically treated as public charities and are exempt from many normal filing and oversight rules.
  • There is no IRS rule that says “you must spend X% of your portfolio each year or lose exempt status.”
  • The IRS has long allowed religious organizations to maintain large endowments/reserves that are invested for future needs (this is the Church’s exact “prudent reserve” theory, drawing on the parable of the talents).

In other words, the law leaves room for judgment about how much use is enough to satisfy “operated exclusively for” the church. Nielsen is arguing for a stricter, more aggressive interpretation — essentially “if you’re not regularly selling down the principal and spending it, it doesn’t count.” The Church and its defenders say the reserves exist precisely to be available when needed, and the regular cash-account transfers plus occasional large draws (City Creek earnings, Beneficial Life, operational funding) are sufficient.

Nielsen is not just making a subjective “they should spend more” complaint.  He is pointing to a genuine tension in how the operational test applies to a massive, perpetually growing reserve. That part is substantive.  But his view is not compelled by the black letter of the law. It is one reasonable interpretation among others, and the IRS’s long silence (6.5 years with no action on his complaint) suggests the agency does not see a clear, enforceable violation.

Interesting stuff, to be sure.  I think most Latter-day Saints are A) generally unaware of and indifferent to the particulars of the Church's large-scale financial management efforts, and B) generally feel that the Church is doing a good job with its finances (no systemic problems/scandals, the Brethren are not living profligate lives, there is a lot of "visible" stuff to see from the Church's efforts, etc.).

Thanks,

-Smac

I generally agree with everything you said about the Nielsen complaint. 

From a broader context, the reason EPA is able to make $14-billion-or-whatever-and-growing of investment income every year is because we live in a society that allows this to happen. At the bottom of this society is a hard-working population of people, many of whom can't afford healthcare, and a large, complex government that enforces contracts and fair dealing. EPA is a major benefactor of this society and as such should pay its fair share in taxes. This will require legislative change. Sooner or later there will have to be an overhaul in the tax system that balances the budget. The question I have is what happens after this overhaul in the tax structure: will EPA continue to enjoy its free ride?

Edited by Analytics
Posted
20 hours ago, smac97 said:

Also, Professor Hackney’s “Hotel California” line is colorful, but how does it's "{money} never comes out" claim work in light of, for example, EPA funds having been used for City Creek and Beneficial Life?  

Also, what are your thoughts about Bishop Waddells' 2023 remarks to 60 Minutes (the same piece in which Phil Hackney weighed in)?

"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— education work, all the work of the church they fund."

I forgot to address these two questions. On money coming out on those two occasions, they are "the exceptions that prove the rule." The money that came out was ultimately for commercial purposes, not charitable. That distinction allegedly matters when evaluating whether or not EPA is a charity. Personally I get less worked up about that then other people might--I think the Church had a moral obligation to bail out Beneficial Life, and I think investing in Salt Lake City's downtown is a better use of resources than capitalizing Bank of America, United Healthcare, and Meta.

Regarding Bishop Waddells' answers, I'd ask a ton of followup questions on this. The big one is whether or not the apostles are permitted to see Ensign Peak's investment earnings. We know the apostles are allowed to see tithing donations, but are they allowed to see the Church's total earnings? I'm quite sure they are not. If I'm right, that indicates it really isn't that integrated. 

I'd also want to know the historical context for things operating the way he claims. It's clear to me that Ensign Peak Advisors was hastily established as a way to get these assets off of the Church's balance sheet. And we also know that the Church proper is going to have some sort of a treasury in its own right--as Nielsen said, EPA is "a reserve on the reserves." So was the Church's main treasury account--the one that sends 9 checks a month to fund the Church, always part of Ensign Peak Advisors, or was it originally part of the Church and not EPA? How and when did it become a part of EPA? Where are the people located who do this main treasury work? Are they in EPA's main office, or are their offices with the Church's Controller and Treasurer? I suspect those functions were moved from the Corporation of the President to EPA with the stroke of a pen in order to make EPA look more integrated than it really is.

Posted (edited)
3 hours ago, Analytics said:
Quote
Quote

First, the point of the Parable of the Talents is the importance of using talents (skills, money, time) to serve God and the community, rather than hiding them.

I would agree with that.  Would you also agree that the Parable also pertains to matters of stewardship?

Yes, of course. But the master in the parable was a materialistic, worldly man whose goal was to have more money.

The master is also intended to represent Jesus Christ, would you agree with that?

I think it can be jarring for metaphors to have potentially incongruent implications.  Hence the "master" in the Parable of the Talents might be seen as avaricious.  The servant views the master as "hard" or harsh, leading to inaction.

I see this as the servant’s unrighteous judgment of God’s character. He projects fear and hardness onto the Lord, leading to slothfulness and inaction. The master repeats the servant’s own words back to him not to endorse that flawed view of Himself as harsh or exploitative, but to condemn the servant by his own logic: “If you knew I was so demanding, why didn’t you at least do the safe, minimal thing to produce some return?” This exposes the excuse as invalid—fear-based misunderstanding of God does not justify burying one’s gifts. As this Ensign article explains, the third servant’s false perception of the master stifled his own growth and caused him to miss the master’s mercy and grace; his unrighteous judgment of God led to poor self-judgment and lost opportunities.

Biblical metaphors and similes describing God (or Christ) often use vivid, earthly imagery to convey spiritual realities that finite human minds can grasp. Just as “as a thief in the night” (1 Thessalonians 5:2; 2 Peter 3:10) emphasizes the sudden, unexpected nature of the Lord’s return—catching the unprepared off guard, not implying criminality or stealthy wrongdoing—other metaphors can be misread literally as attributing negative human flaws (harshness, pettiness, cruelty, or arbitrariness) to God if taken out of context. Latter-day Saint teachings, like the interpretation of the Parable of the Talents, consistently stress that such language reveals God’s perfect character (love, holiness, justice, zeal, and sovereignty) rather than imputing ill will; any “negative” perception usually stems from the observer’s flawed perspective or incomplete understanding, not from God Himself.

Other examples:

  • "Jealous God” (Exodus 20:5; 34:14; Deuteronomy 4:24; 5:9; 6:15).
  • “Consuming fire” or “devouring fire” (Deuteronomy 4:24; 9:3; Hebrews 12:29; also Malachi 3:2 as “refiner’s fire”).
  • God as a lion, leopard, or bereaved bear (Hosea 5:14; 13:7–8; also Amos 3:8).
  • “The Lord is a man of war” (Exodus 15:3; also Psalm 24:8; Isaiah 42:13).

And so on.

In each case, the metaphor serves to convey profound truths about God’s nature (holiness, zeal, justice, sovereignty) in language humans can relate to, while the broader scriptural witness and modern revelation (e.g., Doctrine and Covenants emphasis on God’s love and mercy) guard against misreading these as flaws. As with the Parable of the Talents, the danger lies in projecting imperfect human motives onto God rather than trusting His perfect character and responding with faith, diligence, and reverence. Latter-day Saint leaders encourage studying these images prayerfully to deepen appreciation for God’s goodness, not to fear a capricious deity.

Going back to the Parable of the Talents, I think your point about the purpose of the parable ("the importance of using talents (skills, money, time) to serve God") and mine ("stewardship") go hand in hand.  

3 hours ago, Analytics said:

In the context of the parable, being a good steward means deploying resources in a way that helps the master achieve his objectives. I don't think the message of the parable was to endorse wealth accumulation as a laudable goal.

I appreciate you being direct about this and continuing the conversation. I can see why the Church’s reserve fund strikes you as, in your previous words, going "waaaayyyy beyond 'prudent'" and into "hoarding." That’s an understandable reaction when the numbers are large, and it’s a question worth wrestling with honestly.

At the same time, I think the Parable of the Talents actually pushes us in a different direction. The master doesn’t condemn the first two servants for ending up with significantly more than they started with. He praises them precisely because they actively put their talents to work and multiplied them through diligent effort. The one he calls “wicked and slothful” is the servant who simply buried his talent—keeping it completely inactive and unproductive. The master even points out that the bare minimum would have been to put the money with the exchangers to earn some increase. In the parable’s own logic, faithful stewardship means productive multiplication in service to the master’s objectives, not passive "hoarding."

From what I’ve seen, the Church’s approach aligns far more with the first two servants than the third. The reserve isn’t being buried or hidden away; it’s being carefully invested and multiplied so the Church can sustain and expand what we believe are the Lord’s priorities on a global, multi-generational scale—building temples at a pace never seen before, providing humanitarian aid and disaster relief in over 200 countries, supporting education, strengthening families, and preparing for future growth or hard times. 

I also can't help but think that the Church's planning is qualitatively different from any of us as private individuals.  Most of us think about, at most, our future selves and our children, and perhaps our grandchildren.  We hope to provide for ourselves, and then maybe leave something for our kids and grandkids.  But that's about as far as our perspective goes.  The Church, I think, is attempting to anticipate circumstances involving both a lot more time and a lot more people.  Joseph in Egypt is today lauded for insisting that Egypt save during the seven years of "plenty," but I suspect he had detractors who did not have the foresight Joseph and God had regarding the coming seven years of famine. 

Moreover, I have previously written at some length about how the Church having huge financial reserves is a fairly recent phenomenon (just in the last few decades), and also that distribution/funding of humanitarian and philanthropic and religious efforts on the scale at which the Church is operating (internationally, with huge amounts of money potentially in play, with dozens/hundreds of "partners" and governments and such with whom the Church must cooperate) requires huge measures of due diligence and vetting.  This is particularly so given recent discoveries of widespread graft and corruption in NGOs and nonprofits which purport to be trying to do good things, but which are squandering and wasting and stealing a lot.  Put another way, I wonder if the Church - like many other wealthy individuals and organizations - struggle with finding worthwhile and reputable partners with whom they can work to put money and resources and such to good and productive use.

I’m genuinely interested in your perspective on this. What do you see as the practical difference between wise, forward-looking stewardship (especially for an organization responsible for millions of members worldwide) and the kind of "hoarding" you’re describing? Where would you draw the line? I’m always trying to think more carefully about these things, and I value hearing where my own view might need sharpening.

3 hours ago, Analytics said:
Quote

You said the whole question of tithing vs. investment earnings is “silly” because money is completely fungible and there are multiple ways to rationalize any expense.

Not quite. My point was that fretting over whether a specific dollar on the balance sheet is tied to specific dollars on the income statement is what's silly. 

Okay.

3 hours ago, Analytics said:
Quote

While dollars are fungible in the sense that any one can be spent anywhere, nonprofits and churches routinely differentiate funds by source and purpose — through fund accounting, board-designated reserves, donor restrictions, and fiduciary obligations.

Could you explain why the Church’s long-standing public distinction (vast majority of tithing used immediately for core programs, with only a portion methodically set aside as a “prudent reserve” for investment) is meaningless or silly, rather than a legitimate, transparent policy choice?

It's a legitimate, or at least sensible, policy choice to say that the Church wants to limit its annual spending to about 85%-90% of its annual tithing revenue. Given that conservatively, the Church's investment income revenue is double its tithing revenue, this leads to a situation where perhaps 70% of total revenue goes to increasing the size of the reserve fund, and the remaining 30% goes to religious and charitable endeavors. If deploying resources that way aligns with the Church's values, then sure; that is sensible.

Okay.

3 hours ago, Analytics said:

What I think is silly is thinking that it matters that this be framed as directly spending the tithing dollars and adding the margin to the reserves, vs. being framed as operating the church fully off of investment income and then using 100% of tithing to increase the size of the reserve fund.

Okay, I think that helps.  What may be important to some may seem "silly" to others.  That's fair.

3 hours ago, Analytics said:
Quote

Okay.  What are your thoughts about the affidavits submitted by the Church?  Do you regard them as credible?

Here is the part of Paul Rytting's declaration that is most relevant. Read this, I pray thee. I cannot, for it is redacted. 

image.thumb.png.39f2d5fc8a79551ca04b8bbd22be3b8a.png

The redacted parts of Rytting's declaration might settle the issue one way or the other, but I don't know what it says. but I'm confident Nielsen is right.

Okay.  I am hoping to understand the evidentiary basis for your certitude.

3 hours ago, Analytics said:

Just to better understand where I'm coming from on this, I actually have relevant personal experience and sit on committees that oversee investment portfolios in the billions. Once I was involved in negotiating a business deal that was going to transfer about $700 million of assets and liabilities from one insurance company to another. Both sides wanted to do the deal, but the toughest part was how, exactly, the $700 million of assets would be paid. The buyer (the one receiving the assets and liabilities) would have preferred cash, of course. The seller wanted to send over a portfolio of assets instead. They could have sold the assets then given the buyer the cash, but doing that in a timely manner is tough because of liquidity issues--if you just dropped it on the market for whatever the market bidding price is, you'd get a lot less than $700 million for it. So the seller sent the buyer a long list of assets they proposed to send. The buyer analyzed them each one by one and decided which ones they would to accept and keep, which ones they were willing to accept but would immediately sell, and which ones they didn't want to touch. Working this out took months.

Rytting said they "earmarked" $1.4 billion for this purpose, and that the value of what they had earmarked grew to $1.7 billion before it was fully distributed. This implies that they just gave a percentage of the entire EPA balance to this earmarked fund, not that they transferred over specific securities that they were positive were uncontaminated with tithing dollars and were pure investment income. 

If I'm right, then when COP asked for cash payments, in all likelihood they just transferred the payments from the Treasury Account. That is infinitely more practical and cost-effective than saying "give us a couple of weeks to liquidate $250,000,000 of invested investment income." They could have done that, but the result would be spending weeks of time and millions in transaction costs just so they could have the moral purity of saying that the specific dollars they paid were investment income dollars and not tithing dollars.

Just to be clear, I'm not accusing the Church of lying. Rather, I'm suggesting that in all likelihood, they really did use Definition #2 of what it means to "use tithing."

And if we consistently use that same definition, then we could say that 100% of the Church is run off of investment income and 100% of tithing is saved. We don't have to say that. But we could. My point is that this is all just semantics, but you should ask yourself why you prefer Definition #1 of what it means to "use tithing" when talking about the Church's operations, but are comfortable pivoting to Definition #2 when talking about funding the mall.

Saying the budget will be set as a percentage of donations is an organizational accounting issue. Insisting that the specific dollars that are spent to operate the Church are tithing dollars and not investment income dollars is mental accounting--it feels better to think that your dollars are mostly towards operating the Church plus a little extra for savings than it feels to think that the Church is running completely off of investment income and your contributions are going purely to Ensign Peaks.

Okay.  But if all of this is coming down to "semantics" and "silly," why does this topic seem to be such a bone of contention?

You don't think the Church lied.  The Ninth Circuit agrees with you.  The Tenth Circuit and the U.S. District Court did not "reach" the issue of false statements.  So after lots of spilled ink and legal fees and online discussions, where do you think we end up?  Are we still where have have been for years? 

You think the Church should spend down more of its invested reserves, as the Brethren are currently - in your view - "hoarding" money.

I think the Church's finances are, after 150+ years, finally stabilized and well in hand, perhaps in perpetuity.  This is, in my view, a paradigmatic departure from where we as an institution have been.  It is also a paradigmatic departure from where most of use are or ever will be.  My financial decisions contemplate the next 30+ years, and end with my children (or, perhaps, my grandchildren).  The Church is managing many billions of dollars, mostly acquired relatively recently.  The Church has what could be called fiduciary obligations, and also substantial practical and logistical constraints on how much money it can reasonably and responsibly and effectively distribute.  The Brethren, who are charged with these heavy responsibilities, are not enriching themselves, and they are educated and experienced men, and they are good and decent men.  They are not avaricious, and I don't think they are irrationally holding on to money for the sake of holding on to money. 

3 hours ago, Analytics said:
Quote

The 2025 Ninth Circuit en banc decision in Huntsman (11-0) seems to have reviewed the exact same facts and fungibility arguments you’re making. The court still held that no reasonable person could find the Church misrepresented the source of funds for City Creek, because it had always said it would use earnings on invested reserves (not principal tithing) for such projects.  If fungibility makes the entire distinction “silly,” why do you think the unanimous court treated the Church’s source-of-funds explanation as meaningful and non-misleading instead of dismissing it the way you have?

Hinckley made the assurances, the courts determined that definition #2 of "using tithing" is the proper definition when interpreting his remarks. I have no problem with that, and would have and basically did argue that this was the case all along. But a lot of members misunderstood him. With transparency, this misunderstanding could have been avoidable. But the lack of transparency doesn't imply fraud. 

Okay.  Assuming, arguendo, that a lot of members did indeed misunderstand Pres. Hinckley as regarding the funding of City Creek, could you elaborate on why that is such an important issue for you?  

3 hours ago, Analytics said:

I generally agree with everything you said about the Nielsen complaint. 

Okay.  So where does that put us?  Has all this just been a combination of (A) the Church has been exonerated regarding the allegations of fraud in the tithing lawsuits, and (B) the arguments about EPA are an a protracted and ongoing "woulda coulda shoulda" sort of thing, where reasonable minds can disagree about what the Church should do with its money?

3 hours ago, Analytics said:

From a broader context, the reason EPA is able to make $14-billion-or-whatever-and-growing of investment income every year is because we live in a society that allows this to happen.

Yes.  We are a society governed by laws, and the Church appears to be operating within the confines of those laws.  Would you agree with that?

3 hours ago, Analytics said:

At the bottom of this society is a hard-working population of people, many of whom can't afford healthcare, and a large, complex government that enforces contracts and fair dealing. EPA is a major benefactor of this society and as such should pay its fair share in taxes.

Okay.  Are you suggesting that EPA not paying more taxes amounts to a burden the "hard-working population of people, many of whom can't afford healthcare"?  If the EPA were paying more taxes, would that improve the ability of hard-working Americans to afford healthcare?  I'm not quite sure I see the nexus between the two items.

EPA is not a for-profit hedge fund operating for private gain (I say this because you have, over the years, repeatedly characterized EPA as a hedge fund).  It is, instead, an integrated auxiliary of the Church of Jesus Christ of Latter-day Saints, organized under long-standing U.S. tax law (Internal Revenue Code § 501(c)(3) and related provisions governing churches and their supporting organizations). Its sole purpose is to manage reserves that help fund the Church’s religious, educational, and humanitarian mission—temples, meetinghouses, welfare programs, disaster relief, and missionary work. Like every other tax-exempt religious organization in America (Catholic dioceses, Protestant denominations, Jewish federations, etc.), its investment earnings are not subject to income tax precisely because they support exempt purposes.

You are right that any large, successful institution benefits from the stability and rule of law our society provides. That’s true of universities with billion-dollar endowments, hospitals, and every other 501(c)(3) organization. The policy question is whether we want to single out religious organizations for special taxation while leaving their secular counterparts untouched. Historically, the United States has chosen not to do that, in large part because of First Amendment protections and the recognition that churches provide enormous voluntary social services that reduce the burden on government.

As for the future: if Congress decides to overhaul the tax code and repeal or narrow the tax-exempt status of churches and their auxiliaries, that change would apply across the board—not just to the Church. EPA’s “free ride” is the same ride every other religious body in America has been given for more than a century. The real debate is whether that historic policy should be changed, and if so, what the consequences would be for the millions of Americans who rely on the charitable, educational, and humanitarian work those organizations perform.

3 hours ago, Analytics said:

This will require legislative change.

I assume you would want this legislative change to apply to all churches and 501(c)(3) and such.  Is that accurate?

3 hours ago, Analytics said:

Sooner or later there will have to be an overhaul in the tax system that balances the budget.

Yes.  Reducing spending and waste and graft and corruption would also help a lot.

3 hours ago, Analytics said:

The question I have is what happens after this overhaul in the tax structure: will EPA continue to enjoy its free ride?

I assume the Church and EPA would be subject to the same laws as apply to everyone else.

It appears that the IRS is not showing any favoritism to the Church or to EPA, but I don't think it or Congress would exempt them from such an overhaul.  Do you concur?

Thanks,

-Smac

Edited by smac97
Posted (edited)
3 hours ago, Analytics said:
Quote

Also, Professor Hackney’s “Hotel California” line is colorful, but how does it's "{money} never comes out" claim work in light of, for example, EPA funds having been used for City Creek and Beneficial Life?  

Also, what are your thoughts about Bishop Waddells' 2023 remarks to 60 Minutes (the same piece in which Phil Hackney weighed in)?

"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— education work, all the work of the church they fund."

I forgot to address these two questions. On money coming out on those two occasions, they are "the exceptions that prove the rule." The money that came out was ultimately for commercial purposes, not charitable. That distinction allegedly matters when evaluating whether or not EPA is a charity. Personally I get less worked up about that then other people might--I think the Church had a moral obligation to bail out Beneficial Life, and I think investing in Salt Lake City's downtown is a better use of resources than capitalizing Bank of America, United Healthcare, and Meta.

Regarding Bishop Waddells' answers, I'd ask a ton of followup questions on this. The big one is whether or not the apostles are permitted to see Ensign Peak's investment earnings. We know the apostles are allowed to see tithing donations, but are they allowed to see the Church's total earnings? I'm quite sure they are not. If I'm right, that indicates it really isn't that integrated. 

Assuming followup questions for Bishop Waddell are not available (as a practical matter, as he likely does not visit this board), could you explain your assessment of Bishop Waddell's statement here: "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— education work, all the work of the church they fund."

Do you think he was telling the truth, or not?

3 hours ago, Analytics said:

I'd also want to know the historical context for things operating the way he claims. It's clear to me that Ensign Peak Advisors was hastily established as a way to get these assets off of the Church's balance sheet.

EPA was organized in, I think, 1995 or 1997.  Bishop Waddell was speaking in 2023.  I would think he was speaking of the status quo in 2023, rather than providing a long retrospective accounting for the last 28 or so years.

In any event, it seems like we can only gauge Bishop Waddell's comments based on the information we have.

3 hours ago, Analytics said:

And we also know that the Church proper is going to have some sort of a treasury in its own right--as Nielsen said, EPA is "a reserve on the reserves."

Do we have more evidence than just Neilsen?

3 hours ago, Analytics said:

So was the Church's main treasury account--the one that sends 9 checks a month to fund the Church, always part of Ensign Peak Advisors, or was it originally part of the Church and not EPA? How and when did it become a part of EPA? Where are the people located who do this main treasury work? Are they in EPA's main office, or are their offices with the Church's Controller and Treasurer? I suspect those functions were moved from the Corporation of the President to EPA with the stroke of a pen in order to make EPA look more integrated than it really is.

I don't understand what you mean by "more integrated than it really is."  Are you suggesting that EPA is autonomous?

I understand the concern, I think.  I surmise that EPA operates with a high degree of professional autonomy in its day-to-day investment decisions (its job is, after all, to make wise investments, within parameters set by the Brethren as indicated by the absence of "vice" stocks), which can make it feel less “integrated” with the Church than, say, a local ward or a Church-owned university.

However, per the IRS:

Quote

The term integrated auxiliary of a church refers to a class of organizations that are related to a church or convention or association of churches but are not such organizations themselves. In general, the IRS will treat an organization that meets the following three requirements as an integrated auxiliary of a church.  The organization must:

  • Be described both as an Internal Revenue Code section 501(c)(3) organization and be a public charity under Code section 509(a)(1), (2), or (3),
  • Be affiliated with a church or convention or association of churches, and
  • Receive financial support primarily from internal church sources as opposed to public or governmental sources.

Men's and women's organizations, seminaries, mission societies and youth groups that satisfy the first two requirements above are considered integrated auxiliaries whether or not they meet the internal support requirement.

As I understand it, EPA was created and exists solely to manage the Church’s prudent reserve in order to support its core mission (temples, meetinghouses, humanitarian aid, education, missionary work, etc.). Ultimate oversight rests with the Presiding Bishopric and the First Presidency (notably, the Q12 apparently does not have oversight responsibilities). The fact that it employs professional investment staff and uses sophisticated vehicles is not unusual — many large churches and religious organizations have similarly structured investment arms.

The IRS has long accepted this structure and has never challenged EPA’s status as an integrated auxiliary, even after public scrutiny in 2019 and 2023. That’s a strong indicator that it meets the legal standard, even if the arrangement looks different from a small local auxiliary.

I agree that reasonable people can debate where the line should be drawn between a church’s religious activities and its financial stewardship. But the legal test for “integrated auxiliary” has never required the kind of micro-management that would make EPA look like a typical congregational program.

So could you elaborate?  To what extent and in what ways is EPA not, in your view, sufficiently "integrated"?

Thanks,

-Smac

Edited by smac97
Posted (edited)
On 5/1/2026 at 4:21 PM, smac97 said:

The master is also intended to represent Jesus Christ, would you agree with that?

I think it can be jarring for metaphors to have potentially incongruent implications.  Hence the "master" in the Parable of the Talents might be seen as avaricious.  The servant views the master as "hard" or harsh, leading to inaction.

I see this as the servant’s unrighteous judgment of God’s character. He projects fear and hardness onto the Lord, leading to slothfulness and inaction. The master repeats the servant’s own words back to him not to endorse that flawed view of Himself as harsh or exploitative, but to condemn the servant by his own logic: “If you knew I was so demanding, why didn’t you at least do the safe, minimal thing to produce some return?” This exposes the excuse as invalid—fear-based misunderstanding of God does not justify burying one’s gifts. As this Ensign article explains, the third servant’s false perception of the master stifled his own growth and caused him to miss the master’s mercy and grace; his unrighteous judgment of God led to poor self-judgment and lost opportunities.

Biblical metaphors and similes describing God (or Christ) often use vivid, earthly imagery to convey spiritual realities that finite human minds can grasp. Just as “as a thief in the night” (1 Thessalonians 5:2; 2 Peter 3:10) emphasizes the sudden, unexpected nature of the Lord’s return—catching the unprepared off guard, not implying criminality or stealthy wrongdoing—other metaphors can be misread literally as attributing negative human flaws (harshness, pettiness, cruelty, or arbitrariness) to God if taken out of context. Latter-day Saint teachings, like the interpretation of the Parable of the Talents, consistently stress that such language reveals God’s perfect character (love, holiness, justice, zeal, and sovereignty) rather than imputing ill will; any “negative” perception usually stems from the observer’s flawed perspective or incomplete understanding, not from God Himself.

Other examples:

  • "Jealous God” (Exodus 20:5; 34:14; Deuteronomy 4:24; 5:9; 6:15).
  • “Consuming fire” or “devouring fire” (Deuteronomy 4:24; 9:3; Hebrews 12:29; also Malachi 3:2 as “refiner’s fire”).
  • God as a lion, leopard, or bereaved bear (Hosea 5:14; 13:7–8; also Amos 3:8).
  • “The Lord is a man of war” (Exodus 15:3; also Psalm 24:8; Isaiah 42:13).

And so on.

In each case, the metaphor serves to convey profound truths about God’s nature (holiness, zeal, justice, sovereignty) in language humans can relate to, while the broader scriptural witness and modern revelation (e.g., Doctrine and Covenants emphasis on God’s love and mercy) guard against misreading these as flaws. As with the Parable of the Talents, the danger lies in projecting imperfect human motives onto God rather than trusting His perfect character and responding with faith, diligence, and reverence. Latter-day Saint leaders encourage studying these images prayerfully to deepen appreciation for God’s goodness, not to fear a capricious deity.

Going back to the Parable of the Talents, I think your point about the purpose of the parable ("the importance of using talents (skills, money, time) to serve God") and mine ("stewardship") go hand in hand.  

I appreciate you being direct about this and continuing the conversation. I can see why the Church’s reserve fund strikes you as, in your previous words, going "waaaayyyy beyond 'prudent'" and into "hoarding." That’s an understandable reaction when the numbers are large, and it’s a question worth wrestling with honestly.

At the same time, I think the Parable of the Talents actually pushes us in a different direction. The master doesn’t condemn the first two servants for ending up with significantly more than they started with. He praises them precisely because they actively put their talents to work and multiplied them through diligent effort. The one he calls “wicked and slothful” is the servant who simply buried his talent—keeping it completely inactive and unproductive. The master even points out that the bare minimum would have been to put the money with the exchangers to earn some increase. In the parable’s own logic, faithful stewardship means productive multiplication in service to the master’s objectives, not passive "hoarding."

From what I’ve seen, the Church’s approach aligns far more with the first two servants than the third.

Where you lose me is your belief that in this particular parable, money is not a metaphor or simile conveying "spiritual realities that finite human minds can grasp" but instead is supposed to be taken literally. Can you really imagine Jesus coming back and saying, "You turned the widow's mite into a stock portfolio worth a trillion dollars! That's what I'm talking about! Well done, good and faithful servant!"

I can't reconcile your views with the guy quoted in Matthew 6:19–24, Luke 6:24, Luke 16:13, Luke 12:16-21, Luke 12:16-34, Matthew 19:23-24, Mark 10:23-25, Matthew 19:23-24, Mark 10:23-25, Luke 18:24-25.

On 5/1/2026 at 4:21 PM, smac97 said:

The reserve isn’t being buried or hidden away...

I strongly disagree. They went to extreme lengths to hide this from the membership, the general public, and from the SEC.

On 5/1/2026 at 4:21 PM, smac97 said:

...it’s being carefully invested and multiplied so the Church can sustain and expand what we believe are the Lord’s priorities on a global, multi-generational scale—building temples at a pace never seen before, providing humanitarian aid and disaster relief in over 200 countries, supporting education, strengthening families, and preparing for future growth or hard times. 

This comes across as an ad hoc rationalization.

On 5/1/2026 at 4:21 PM, smac97 said:

I also can't help but think that the Church's planning is qualitatively different from any of us as private individuals.

What is your basis for thinking this? Over the decades, I've heard repeatedly things like:

  • David Bednar: "For decades the Church has taught its membership the principle of setting aside additional food, fuel, and money to take care of emergencies that might arise. The Church as an institution simply follows the same principles that are taught repeatedly to the members."
     
  • Church and Gospel Questions: Just as members of the Church are encouraged to save money and store food and supplies for the future, the Lord has directed His Church to do the same.

    Gordon Hinckley: In the financial operations of the Church, we have observed two basic and fixed principles: One, the Church will live within its means. It will not spend more than it receives. Two, a fixed percentage of the income will be set aside to build reserves against what might be called a possible “rainy day.” For years, the Church has taught its membership the principle of setting aside a reserve of food, as well as money, to take care of emergency needs that might arise. We are only trying to follow the same principle for the Church as a whole.
On 5/1/2026 at 4:21 PM, smac97 said:

Most of us think about, at most, our future selves and our children, and perhaps our grandchildren.  We hope to provide for ourselves, and then maybe leave something for our kids and grandkids.  But that's about as far as our perspective goes.

According to Bednar and Hinckley, that is exactly the approach the Church takes--live on less than you take in, and save the rest for a rainy day.

On 5/1/2026 at 4:21 PM, smac97 said:

The Church, I think, is attempting to anticipate circumstances involving both a lot more time and a lot more people.  Joseph in Egypt is today lauded for insisting that Egypt save during the seven years of "plenty," but I suspect he had detractors who did not have the foresight Joseph and God had regarding the coming seven years of famine. 

This sounds like a post hoc rationalization. 

On 5/1/2026 at 4:21 PM, smac97 said:

I’m genuinely interested in your perspective on this. What do you see as the practical difference between wise, forward-looking stewardship (especially for an organization responsible for millions of members worldwide) and the kind of "hoarding" you’re describing? Where would you draw the line? I’m always trying to think more carefully about these things, and I value hearing where my own view might need sharpening.

Wise, Forward-Looking Stewardship
I would say wise, forward-looking stewardship begins with having an internally coherent vision and goals for the organization. Then resources should be allocated to achieve those goals. There should be reserves for contingencies, but the size of the reserves needs to be optimized, not maximized.  

This is in fact an issue that the insurance industry constantly grapples with. If an insurance company was required to have so much capital that it could withstand any conceivable calamity, insurance would be too expensive and wouldn't exist. A common metric is that there should be enough capital so the enterprise can survive 199 out of a universe of 200 scenarios (i.e. 99.5% VaR). 

If the Church were taking this approach, they'd have a specific goal in mind that justifies their aggressive savings. They'd then budget to save that much to achieve that goal. They'd be conservative with their savings, but how conservative would be a function of how mission-critical the thing is that they are saving for, and what could be used with the money now, rather than using it as a budget in case their savings goal fell short.

Foolish Hoarding
In contrast, foolish hoarding begins with internally inconsistent values. The Bretheren's top two values are these:

  1. They sincerely believe that for the benefit of their own souls, members must give the church 10% of their income, irrespective of the financial needs of the Church.
     
  2. In the words of Hinckley, "the Church will live within its means. It will not spend more than it receives."

These are considered "basic and fixed" principles. As long as these fixed principles remain fixed, the church doesn't need very big reserves. If tithing receipts go down, it can cut expenses so that it continues to live within its means. Because of that, anything in the range of $2 billion to $20 billion would be quite sufficient.

For a decade or two, setting aside 10% of tithing receipts to build up an appropriately sized reserve fund was wise and prudent. But once the reserve fund was established, the priority should be keeping it right-sized.

The Church claims its raison d’être is to preach the gospel, perfect the saints, redeem the dead, and do some charity. That's all great. But when you look at its total income and total revenue, it only spends 30% of its revenue on those 4 things, and uses the remaining 70% to grow an out-of-control reserve fund. How could spending 70% of your resources on something other than your mission possibly be considered wise?

On 5/1/2026 at 4:21 PM, smac97 said:

You don't think the Church lied.  The Ninth Circuit agrees with you.  The Tenth Circuit and the U.S. District Court did not "reach" the issue of false statements.  So after lots of spilled ink and legal fees and online discussions, where do you think we end up?  Are we still where have have been for years? 

There is a huge distance between committing fraud and being an example of best practices. I think people on this board understand these issues now a little bit better than they did 15 years ago, and I'm hopeful that they will be understood a little better in 15 years than they are now.

On 5/1/2026 at 4:21 PM, smac97 said:

The Brethren, who are charged with these heavy responsibilities, are not enriching themselves, and they are educated and experienced men, and they are good and decent men.  They are not avaricious, and I don't think they are irrationally holding on to money for the sake of holding on to money. 

I agree with all that. But frankly, I also think they are old, scared, lack vision, and are paralyzed by group think and tradition. They are hoarding money not because that is the goal, but rather it is an unintended artifact of the unsustainable and foolish "fixed principles" of running the Church on 90% of tithing revenue, guilting members to pay 10% of their income to the church regardless of whether the people need it more than the church does, and saving the rest in a secret fund that not even the apostles are allowed to see.

On 5/1/2026 at 4:21 PM, smac97 said:

Okay.  Assuming, arguendo, that a lot of members did indeed misunderstand Pres. Hinckley as regarding the funding of City Creek, could you elaborate on why that is such an important issue for you?  

Three reasons. First, I just want to keep the record straight on what happened and how people's beliefs evolve over time. Second, I think if we do that, we can have some empathy for members who have felt betrayed by what happened--empathy would be a good thing. Third, I have an emotional reaction at what seems like an attempt to gaslight us. Huntsman's beliefs about the how the Church financed these projects was consistent with the vast majority of the Latter-day Saints who posted here. That history should be acknowledged--not rewritten. I hate gaslighting.  

On 5/1/2026 at 4:21 PM, smac97 said:

EPA is not a for-profit hedge fund operating for private gain (I say this because you have, over the years, repeatedly characterized EPA as a hedge fund).  It is, instead, an integrated auxiliary of the Church of Jesus Christ of Latter-day Saints, organized under long-standing U.S. tax law (Internal Revenue Code § 501(c)(3) and related provisions governing churches and their supporting organizations). Its sole purpose is to manage reserves that help fund the Church’s religious, educational, and humanitarian mission—temples, meetinghouses, welfare programs, disaster relief, and missionary work. Like every other tax-exempt religious organization in America (Catholic dioceses, Protestant denominations, Jewish federations, etc.), its investment earnings are not subject to income tax precisely because they support exempt purposes.

You are making this up as a post-hoc rationalization. The Church created Ensign Peak Advisors for exactly the same reason it created Ashmore Wealth Management, LLC, Argyll Research, LLC' Clifton, Park Capital Management, LLC, Cortland Advisers, LLC, Elkfork Partners, LLC, Flinton Capital Management, LLC, Glen Harbor Capital Management, LLC, Green Valley Investors, LLC, etc. 

These were all created to hide the Church's assets from the membership, the public, the SEC, and the IRS. That's it.

The quotes I provided above by Bednar and Hinckley demonstrate that what you say here is made up. The way it really works is that the Council for the Deposition of Tithes meets, they are given a projection of the next year's tithing, they set a budget based on 90% of that total, and they manage the Church to those budgets. The excess is sent to EPA. It is a "fixed principle" that the church lives on a subset of tithing. Now that these secret organizations have been exposed the Church may have put its main treasury under the "Ensign Peak Advisors" umbrella, but that doesn't change the way the reserve fund works. The reserve fund is not used to help fund the Church’s religious, educational, and humanitarian mission—temples, meetinghouses, welfare programs, disaster relief, and missionary work. It's sole purpose is for a place for unspent tithing to be saved. That's it.

Edited by Analytics
Posted (edited)
On 5/1/2026 at 4:39 PM, smac97 said:

Assuming followup questions for Bishop Waddell are not available (as a practical matter, as he likely does not visit this board), could you explain your assessment of Bishop Waddell's statement here: "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— education work, all the work of the church they fund."

Do you think he was telling the truth, or not?

My suspicion is that he was not telling the full truth. The main treasury may now be classified under "Ensign Peak Advisors" on the org chart, but I believe the Church still works the way Hinckley and Bednar explained. There is a fixed principle that they will live on less than their tithing income, and classic Ensign Peak Advisors--the part that manages the reserves--is simply a place to put excess tithing and save it for a rainy day. 

Do you think the Church started showing the Council on the Deposition of Tithes how much money Ensign Peak Advisors has and makes? I don't. Remember the story of Boyd K. Packer, President of the Twelve and one heartbeat away from being the prophet, went to Ensign Peak Advisors and asking Roger Clarke to see what was going on there so he'd be ready to take over the Church if God-forbid he were to become prophet? Remember how Clarke had to awkardly explain to him sorry, that is above your pay grade?

Am I wrong? When did the Church say its annual expenses would now be more than annual tithing receipts? Abandoning Hinckley's fixed principle would be a big deal. I'd love to hear about it.

On 5/1/2026 at 4:39 PM, smac97 said:

Do we have more evidence than just Neilsen?

Nielsen's account is consistent with the "fixed principles" of how the Council for the Deposition of Tithes work, as explained by Hinckley and Bednar. Nielsen's account is consistent with Church's Financial Standard #6230, "Accessing and Securing Financial Information", which shows that the majority of the council on the deposition of tithes--the rank-and-file apostles--aren't allowed to know how much money the Church has saved, nor how much money these assets are generating. It's also consistent with how much we know the Church had accumulated when the EPA financials were leaked.

Do you believe my view of this has dated? Has Financial Standard #6230 been rescinded or updated? Are the apostles now allowed to know what the Church's assets are? If not, how could they possibly be expected to make decisions of how to allocate these resources?

On 5/1/2026 at 4:39 PM, smac97 said:

So could you elaborate?  To what extent and in what ways is EPA not, in your view, sufficiently "integrated"?

If the Church radically changes its internal policies and presented these assets and investment income to the Council of the Deposition of tithes, and if it officially revoked the "fixed principle" of always living on less than its annual tithing revenue, I'd consider EPA integrated in the Church in a functional sense. But as long as the apostles aren't allowed to know about these assets and investment income, it is not integrated in a real-world way.

Edited by Analytics
Posted
59 minutes ago, Analytics said:

These were all created to hide the Church's assets from the membership, the public, the SEC, and the IRS. That's it.

Hide from the IRS?  I haven't heard that before.  How does this hide from the IRS and who said that?

And I thought this wasn't hiding it from the SEC.  This just affected the 13F form which is for public disclosure.  I thought there were other forms that were being filled to the SEC and weren't hiding it.  That is how the SEC noticed the issue.

40 minutes ago, Analytics said:

Remember the story of Boyd K. Packer, President of the Twelve and one heartbeat away from being the prophet, went to Ensign Peak Advisors and asking Roger Clarke to see what was going on there so he'd be ready to take over the Church if God-forbid he were to become prophet? Remember how Clarke had to awkardly explain to him sorry, that is above your pay grade?

This story is from the IRS letter.  And it was third hand at best.  I have a hard time accepting because it is "too good to be true".  It might have a kernel of truth but I doubt what happened is what was described.

Posted (edited)

 

On 5/2/2026 at 5:40 PM, webbles said:

And I thought this wasn't hiding it from the SEC.  This just affected the 13F form which is for public disclosure.  I thought there were other forms that were being filled to the SEC and weren't hiding it.  That is how the SEC noticed the issue.

Nope--there were no other forms submitted to the SEC that linked Ensign Peak with these securities.

The reason this issue came to light is that the Church made a big mistake: somebody had the brilliant idea that Ashmore Wealth Management LLC, Argyll Research LLC, etc., all needed web addresses so that they would appear more legitimate. I surmise that whoever made this decision didn't know that you can trace who owns websites, and simply went through the Church's standard channels to acquire the domain names.

Then in 2018, our friends at MormonLeaks decided to research what domains the Church owned. They found that it owned domains of several investment firms, so from there they kept digging. They found that these companies all had their domains registered on the same day, the domains were all hosted by the Church, and all had managers with the names of Church employees. They called up all of the guys at the Church who had these names, and only got in touch with three. Two of them denied any connection to the LLCs (even though we now know they did in fact sign the 13F's stating they were the managers), and the third said he was the manager, but wouldn't confirm or deny that the fund was associated with the Church. (see here)

At that point, two of the managers resigned, saying they were uncomfortable with this. In contrast the Church was quite comfortable with this arrangement and found two new fake managers to take the places of the two that resigned. Thirteen months later, in the words of the Church, "the SEC first expressed concern about Ensign Peak’s reporting approach." 

On 5/2/2026 at 5:40 PM, webbles said:

This story is from the IRS letter.  And it was third hand at best.  I have a hard time accepting because it is "too good to be true".  It might have a kernel of truth but I doubt what happened is what was described.

Are you familiar with Church's Financial Standard #6230? According to that document, the Quorum of the Twelve does not have access to the Church's balance sheet items (i.e. cash, investment securities, other assets, liabilities, net assets)--this information is outside the stewardship of the apostles, and the Financial Standard says, "Employees must not divulge financial information outside of approved stewardships." Given that, the story seems eminently plausible. What part do you find implausible? The part where the President of the Twelve asked to see what the Church's investments were, or the part where the head of EPA followed the Church's Financial Standards?

Edited by Analytics
Posted
On 5/2/2026 at 3:38 PM, Analytics said:

Where you lose me is your belief that in this particular parable, money is not a metaphor or simile conveying "spiritual realities that finite human minds can grasp" but instead is supposed to be taken literally.

Thank you for explaining your perspective on things.  I do not think this is an either/or situation.  As I noted previously, I think the Parable has a lot to do with the concept of stewardship.  The Lord gives us "talents" and expects us to use them in His service.  In the present discussion, the Parable is strikingly both figurative and literal.  The "Lord" has "servants" entrusted with money, and they are instructed and commanded to make good use of it.

I am reminded of this 2017 article: 

Historian digs into the hidden world of Mormon finances, shows how church went from losing money to making money — lots of it

Some excerpts:

Quote

Some Mormons — and plenty of others — were appalled to witness their church build a $1.5 billion mall in downtown Salt Lake City and hear their prophet proclaim, “Let’s go shopping.”

Isn’t religion, they argued, supposed to be about feeding the hungry and clothing the poor? How is selling Tiffany jewelry, Nordstrom cocktail dresses and luxury condos any part of a Christian faith?

Such critics, though, fail to understand Mormonism, says historian D. Michael Quinn. The American-born movement has always seen its mission as serving both the spiritual and physical needs of its people. It doesn’t distinguish between the two.

“It’s as spiritual [for Latter-day Saints] to give alms to the poor,” Quinn told Bloomberg Businessweek in 2012, “... as it is to make a million dollars.”

I think Quinn is slightly off in the tone of his comment, but he's substantively correct.  I think Jacob 2 lays out the the guiding principles:

Quote

11 Wherefore, I must tell you the truth according to the plainness of the word of God. For behold, as I inquired of the Lord, thus came the word unto me, saying: Jacob, get thou up into the temple on the morrow, and declare the word which I shall give thee unto this people.
12 And now behold, my brethren, this is the word which I declare unto you, that many of you have begun to search for gold, and for silver, and for all manner of precious ores, in the which this land, which is a land of promise unto you and to your seed, doth abound most plentifully.
13 And the hand of providence hath smiled upon you most pleasingly, that you have obtained many riches;

I think there are times when the Lord ("the hand of providence") enables the Lord's covenant people to obtain "riches."  Back then, there seemed to be numbers of Nephites who were so blessed, while others were not.  But then things went sideways:

Quote

and because some of you have obtained more abundantly than that of your brethren ye are lifted up in the pride of your hearts, and wear stiff necks and high heads because of the costliness of your apparel, and persecute your brethren because ye suppose that ye are better than they.

Creating a class hierarchy is not what the Lord intended here.  Jacob condemns this stratification and then explains what the proper purpose of riches is:

Quote

14 And now, my brethren, do ye suppose that God justifieth you in this thing? Behold, I say unto you, Nay. But he condemneth you, and if ye persist in these things his judgments must speedily come unto you.
15 O that he would show you that he can pierce you, and with one glance of his eye he can smite you to the dust!
16 O that he would rid you from this iniquity and abomination. And, O that ye would listen unto the word of his commands, and let not this pride of your hearts destroy your souls!
17 Think of your brethren like unto yourselves, and be familiar with all and free with your substance, that they may be rich like unto you.
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.

I think the good numbers of the rank-and-file members of the Church have, for many years, have both worked to gain an education and skill sets allowing them to provide for themselves, and have also meaningfully observed the Law of Tithing.  The Brethren, meanwhile, have for the last several decades stabilized and strengthened the Church's finances.  They have done so through good stewardship.

I can't help but notice that your comment, apparently intended to be scornful, actually parallels the Parable of the Talents:

You: "Can you really imagine Jesus coming back and saying, 'You turned the widow's mite into a stock portfolio worth a trillion dollars! That's what I'm talking about! Well done, good and faithful servant!'"

Matthew 25:

Quote

20 And so he that had received five talents came and brought other five talents, saying, Lord, thou deliveredst unto me five talents: behold, I have gained beside them five talents more.

21 His lord said unto him, Well done, thou good and faithful servant: thou hast been faithful over a few things, I will make thee ruler over many things: enter thou into the joy of thy lord.

To paraphrase your opening statement: Where you lose me is your belief that in this particular parable, money is a metaphor or simile conveying 'spiritual realities that finite human minds can grasp' and instead is not supposed to be taken literally.

When it comes to the finances of the Church as administered by the Brethren, I think the Parable is intended to be both figurative and literal.

I think the topic of the Brethren's stewardship of finances also needs to be viewed in context, taking into account important factors such as A) the principles enunciated in Jacob 2, B) the Brethren not enriching themselves, C) the objectively excellent manner in which the Church's finances have been handled for decades, D) and the challenges associated with administering large-scale humanitarian/philanthropic efforts.

Back to the Trib article:

Quote

On that last score, The Church of Jesus Christ of Latter-day Saints has been wildly successful, says Quinn, author of the newly published “Mormon Hierarchy: Wealth & Corporate Power.”

The church, launched in 1830 in upstate New York with six members, counts nearly 16 million members worldwide — and untold billions in assets.

It wasn’t alway so. At one point, the federal government confiscated all its properties, withholding them for nearly a decade. Thereafter, the Utah-based faith endured cycles of near bankruptcy every 20 to 30 years until it finally found its economic footing in the 1960s.

If the Church had continued to founder in these "cycles of near bankruptcy," I am sure our critics would have a lot to negatively say about it.

And yet now, decades into the Church having "found its economic footing," our critics still have a lot to negatively say about it.

Quote

Quinn estimates — and estimating is about the best even a top-notch researcher can do — the church took in about $33 billion in tithing in 2010, based on a model of projected growth rates that followed a consistent pattern starting in the 1950s. It earns another $15 billion annually, he says, in returns on its profit-making investments. (The Bloomberg Businessweek piece from five years ago cited an investigation pegging the LDS Church’s worth at $40 billion.)

No matter the precise bottom line, these figures represent an astonishing accomplishment, Quinn says.

“It is an American success story without parallel,” the longtime historian says in an interview. “No institution, no church, no business, no nonprofit organization in America has had this kind of history.”

What Quinn describes as "an American success story without parallel" you describe as "unsustainable and foolish."

Quote

Yet LDS general authorities — from the most senior apostle to the lowest-ranking Seventy — all receive the same yearly “living allowance”: $120,000. Though the church has enormous wealth, he says, none of the leaders is getting rich off it.

I think this is a very important aspect of the Brethren's success with their stewardship.  

Quote

As a seventh-generation Mormon, Quinn, who was excommunicated from the faith in 1993 for apostasy based on his historical writings about polygamy, says the LDS Church’s financial trajectory, as well as the self-sacrificing actions of its hierarchy, is “an enormously faith-promoting story.”

If everyday Mormons could grasp “the larger picture,” he says, they would “breathe a sigh of relief and see the church is not a profit-making business.”

Quinn surveys the Brethren's stewardship and sees "'an enormously faith-promoting story'" that, if seen as part of the "'larger picture,'" would have the Latter-day Saints "'breath{ing} a sigh of relief and see the church is not a profit-making business.'"

You survey the same topic and see the Brethren's actions as "unsustainable and foolish."

Quote

From 1933 to 1950, the church saved about 72 percent of its annual income, creating a large reserve. But a building program from 1958 to 1963 blotted out all the reserve funds, and the church didn’t have enough liquid assets to meet all its obligations.

Starting in 1959, the faith began deficit spending, Quinn says, and thus stopped reporting its expenditures in General Conferences, hoping to keep that fact from the members.

By December 1962, the deficit had ballooned to nearly $33 million (or about $236 million in 2010 dollars) and, in 1963, the historian says, LDS headquarters “didn’t think it could meet its payroll.”

Such anxiety led leaders to take steps to ensure that would never happen again.

They brought Canadian N. Eldon Tanner on board as an apostle. Tapping his enormous financial know-how, the church began to rebuild its nest egg, cutting back on building projects and overseeing investments until it could get back in the black.

Tanner was “methodically rescuing the church from the brink,” Quinn writes. “By 1964, commercial income accounted for about 40 to 45 percent of its total income.”

Step by step, the historian writes, Tanner introduced the church to “corporate financing.”

It never looked back.

Quinn describes a 50+ (now closer to 60+) year process whereby the Church went from "think{ing} it could {not} meet its payroll" to "'an enormously faith-promoting story'" that, if seen as part of the "'larger picture,'" would have the Latter-day Saints "'breath{ing} a sigh of relief and see the church is not a profit-making business.'"

You survey the historical span and see the Brethren's actions as "unsustainable and foolish."

Quote

Prophetic imperative

At the same time, Mormon authorities did not act like corporate giants, enriching themselves on profits.

Through the years, they paid themselves less than what others in their employ made, Quinn says. Today, that is sometimes barely half as much as some of the church’s skilled bureaucrats.

CEOs of other top nonprofits, including Harvard, Yale and the United Way, make almost 10 times as much, he says. “It was truly humbling to see these men who preside over an institution making tens of billions of dollars turning [the funds] back to the benefit of the rank and file.”
...
By pocketing such relatively small salaries and using church assets to serve the members, Quinn says, Mormon leaders have “maintained the spirit of that attitude.”

Again, that the Brethren are not enriching themselves is a very important factor, IMO.

On 5/2/2026 at 3:38 PM, Analytics said:

I can't reconcile your views with the guy quoted in Matthew 6:19–24, Luke 6:24, Luke 16:13, Luke 12:16-21, Luke 12:16-34, Matthew 19:23-24, Mark 10:23-25, Matthew 19:23-24, Mark 10:23-25, Luke 18:24-25.

I think you have materially misunderstood my view. 

On 5/2/2026 at 3:38 PM, Analytics said:
Quote

The reserve isn’t being buried or hidden away...

I strongly disagree. They went to extreme lengths to hide this from the membership, the general public, and from the SEC.

By "buried or hidden away" I was referring to the Parable, in which the third servant did nothing to invest and enlarge the talent he had been given, and instead literally "buried" and "hid" it in the earth.

The Brethren have done more than just keep the Church operating within its means.  They have prudently set aside a portion for investment and growth.  

On 5/2/2026 at 3:38 PM, Analytics said:
Quote

...it’s being carefully invested and multiplied so the Church can sustain and expand what we believe are the Lord’s priorities on a global, multi-generational scale—building temples at a pace never seen before, providing humanitarian aid and disaster relief in over 200 countries, supporting education, strengthening families, and preparing for future growth or hard times. 

This comes across as an ad hoc rationalization.

Given our interactions over the years, I can appreciate how you view the Church and its leaders with some measures of jaundiced cynicism.

If the Brethren were wasting money, or if they were investing the Church's money in risky or unwise or "vice" ventures, or if they were enriching themselves, then I could see more justification for your position.

As it is, though, none of these things is happening.  The Brethren have, for some decades now, become excellent stewards of the Church's finances.  The two principal grievances you seem to hold are 1) the Church is not sufficiently "transparent" regarding the Church's finances, and 2) the Church does not spend enough of its funds on humanitarian/philanthropic efforts.  Is this a fair restatement of your position?

If so, I think there is some merit to both, but not enough for me to join you in your cynicism.  Reasonable minds can disagree about such things.

On 5/2/2026 at 3:38 PM, Analytics said:
Quote

I also can't help but think that the Church's planning is qualitatively different from any of us as private individuals.

What is your basis for thinking this? Over the decades, I've heard repeatedly things like:

...

According to Bednar and Hinckley, that is exactly the approach the Church takes--live on less than you take in, and save the rest for a rainy day.

The Church has responsibilities that we as individuals don't have, and the duration of those responsibilities are not reflected in our individual lives.

For me, I don't feel like I have a responsibility to provide financially for much of anything beyond me and my wife.  My children are now adults and should not look to me to provide for them in any long-term sense.  Their lives are their responsibilities.  If I end up being able to leave them some inheritance, that would be nice.  But it's not an obligation.

In contrast, the Church has responsibilities for millions, and in some ways billions, of people.  The programs and mandates of the Church need to be managed and funded in multi-generational ways that do not apply to us as individuals.  The Church's stewardship is effectively perpetual, ours is not.  The Church has stewardship over continuing the programs and mandates of the Church, we do not.  

On 5/2/2026 at 3:38 PM, Analytics said:
Quote

The Church, I think, is attempting to anticipate circumstances involving both a lot more time and a lot more people.  Joseph in Egypt is today lauded for insisting that Egypt save during the seven years of "plenty," but I suspect he had detractors who did not have the foresight Joseph and God had regarding the coming seven years of famine. 

This sounds like a post hoc rationalization. 

I'm okay with that.  Habit Ten of the Hollis book: "Embrace the Discomfort of Non-Closure."  We can proceed without having persuaded the other of our respective stances.

On 5/2/2026 at 3:38 PM, Analytics said:
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I’m genuinely interested in your perspective on this. What do you see as the practical difference between wise, forward-looking stewardship (especially for an organization responsible for millions of members worldwide) and the kind of "hoarding" you’re describing? Where would you draw the line? I’m always trying to think more carefully about these things, and I value hearing where my own view might need sharpening.

Wise, Forward-Looking Stewardship
I would say wise, forward-looking stewardship begins with having an internally coherent vision and goals for the organization.

Okay.  Do you think the Church is lacking in this regard?  If so, could you elaborate?

On 5/2/2026 at 3:38 PM, Analytics said:

Then resources should be allocated to achieve those goals. There should be reserves for contingencies, but the size of the reserves needs to be optimized, not maximized.

That is quite a reasonable point as an abstraction.  I'm not sure what it would look like if attempted to put into practice.  Perhaps you could provide some illustrations of such optimization?

Also, is it possible that Joseph, while managing Egypt's foodstuffs during times of plenty, also encountered calls for "the reserves" to be "optimized, not maximized"?  Put another way, can your worldview accommodate the possibility that the Brethren are aware of things of which you are not, and that these things may have an substantial impact on the "optimization" versus "maximization" thing you reference above?

On 5/2/2026 at 3:38 PM, Analytics said:

In contrast, foolish hoarding begins with internally inconsistent values. The Bretheren's top two values are these:

  1. They sincerely believe that for the benefit of their own souls, members must give the church 10% of their income, irrespective of the financial needs of the Church.
     
  2. In the words of Hinckley, "the Church will live within its means. It will not spend more than it receives."

These are considered "basic and fixed" principles.

Do you think there are other principles also in play here?

On 5/2/2026 at 3:38 PM, Analytics said:

As long as these fixed principles remain fixed, the church doesn't need very big reserves.

That is an interesting statement.  Could you elaborate on how you propose to gauge what the Church "needs" to have in reserve?  And does your calculus include developments with the Church ten years from now?  Thirty?  Fifty?  

Broadly speaking, the Church seems to be growing the fastest in areas of the world that tend to be poor, even impoverished.  Quinn's last book was rather eye-opening for me, as it seemed to strongly indicate that the Church is subsidizing its presence in most of the world:

Quote

The historian, who was excommunicated from the LDS Church in 1993 for his writings about early Mormon polygamy, says he was most struck by the money church leaders in Utah directed overseas. Of the six countries, only Australia did not report a supplement from headquarters in 2010.

The church in Canada received $166,728, while the Philippines got $63.8 million — 85 percent of its revenue.

Even in a developed country like the United Kingdom — home to almost as many Mormons as in Canada — headquarters sent $1.8 million in 2010, indicating that the church infrastructure exceeds what the locals can support. That and the other subsidies lead Quinn to assume the U.S.-born church is subsidizing its work and wards in Africa and Latin America, too.

Based on some general statements Mormon apostles have made through the decades about the church’s income from profit-making corporations and members’ tithing, Quinn says, the source of those subsidies must be offerings from Americans and the businesses the faith owns.

"{T}he U.S.-born church is subsidizing its work {in other countries}."'

"Quinn says {that} the source of those subsidies must be offerings from Americans and the businesses the faith owns."

I struggle to square the foregoing with your "the church doesn't need very big reserves" commentary.

On 5/2/2026 at 3:38 PM, Analytics said:

If tithing receipts go down, it can cut expenses so that it continues to live within its means.

This is very illuminating.  That you for sharing.

What "expenses" do you think would be cut?  Missionary work?  Temples?  Humanitarian/philanthropic work?  Education?  

Is it possible that the Brethren would not want to "cut expenses" as to its various mandates, particularly if they could avoid such cutting by maintaining substantial reserves?

On 5/2/2026 at 3:38 PM, Analytics said:

Because of that, anything in the range of $2 billion to $20 billion would be quite sufficient.

Could you elaborate?  "Sufficient" for what?  What metric are you using here?

In 2010 "the {Church's operations in the} Philippines got $63.8 million — 85 percent of its revenue."  What programs do you think the Church should cut in that country so that you would be satisfied? 

My parents served three missions: Samoa, Fabens (Texas) and Zimbabwe.  None of these countries, I think, sustain themselves financially as to the Church's various programs, and almost certainly do not generate enough money to pay for international humanitarian/philanthropic efforts.  

On 5/2/2026 at 3:38 PM, Analytics said:

For a decade or two, setting aside 10% of tithing receipts to build up an appropriately sized reserve fund was wise and prudent. But once the reserve fund was established, the priority should be keeping it right-sized.

I struggle to understand what you mean by "appropriately sized reserve fund."  

On 5/2/2026 at 3:38 PM, Analytics said:

The Church claims its raison d’être is to preach the gospel, perfect the saints, redeem the dead, and do some charity. That's all great. But when you look at its total income and total revenue, it only spends 30% of its revenue on those 4 things, and uses the remaining 70% to grow an out-of-control reserve fund. How could spending 70% of your resources on something other than your mission possibly be considered wise?

The Church is not profligate.  The Brethren are not enriching themselves, and the Church's programs are designed to be financially constrained.  I am glad of that.  And if and when the Church finds ways to prudently distribute more of its funds, I will celebrated each such increase.  

Meanwhile, however, the Church is operating within its means, and it has wisely invested surplus funds so that it now has a substantial reserve.  I am very grateful to the Brethren for these things.  

I wonder if the Church's current financial condition is a partial fulfillment of the prophecy in Malachi 3:

Quote

Bring ye all the tithes into the storehouse, that there may be meat in mine house, and prove me now herewith, saith the Lord of hosts, if I will not open you the windows of heaven, and pour you out a blessing, that there shall not be room enough to receive it.

The Lord could have just poured down gold coins on the roof of the Church Administration Building.  Or He could command His children to tithe and donate in other ways (Malachi 3:10), which donations, when coupled with wise stewardship by His servants, (as mandated in Matthew 25), have yielded financial blessings to the Church as a whole.

I like the second way better, as it allows each of us to contribute in whatever ways we can.

On 5/2/2026 at 3:38 PM, Analytics said:
Quote

You don't think the Church lied.  The Ninth Circuit agrees with you.  The Tenth Circuit and the U.S. District Court did not "reach" the issue of false statements.  So after lots of spilled ink and legal fees and online discussions, where do you think we end up?  Are we still where have have been for years? 

There is a huge distance between committing fraud and being an example of best practices.

I agree.

I wonder, though, if we are situated to competently assess what the "best practices" of the Church are or should be, particularly given its particularized mandates. 

On 5/2/2026 at 3:38 PM, Analytics said:

I think people on this board understand these issues now a little bit better than they did 15 years ago, and I'm hopeful that they will be understood a little better in 15 years than they are now.

I think most observant Latter-day Saints are broadly supportive of the Brethren, and they have enough assurances to maintain that support.

The Church will never be able to placate all its members, let alone its critics and detractors.  I think there will never be a point at which the Church's critics would say "Yes, the Church is managing its finances well"?  Instead, endless faultfinding and goalpost-moving and nebulous demands of "more" and "not that" will be the order of the day.  

On 5/2/2026 at 3:38 PM, Analytics said:
Quote

The Brethren, who are charged with these heavy responsibilities, are not enriching themselves, and they are educated and experienced men, and they are good and decent men.  They are not avaricious, and I don't think they are irrationally holding on to money for the sake of holding on to money. 

I agree with all that.

But you don't seem to give these things much credit or significance.  Am I wrong about that?

On 5/2/2026 at 3:38 PM, Analytics said:

But frankly, I also think they are old, scared, lack vision, and are paralyzed by group think and tradition. They are hoarding money not because that is the goal, but rather it is an unintended artifact of the unsustainable and foolish "fixed principles" of running the Church on 90% of tithing revenue, guilting members to pay 10% of their income to the church regardless of whether the people need it more than the church does, and saving the rest in a secret fund that not even the apostles are allowed to see.

Again, given your perspective, I can appreciate how you could reach these conclusions.

The Brethren sure seem to have a firm grasp on things.  Elder - formerly Presiding Bishop - Causse is not in the Q12.  He has spoken many times of working to expand the Church's humanitarian efforts.  Not really the stuff we'd expect to see of a group who are "old, scared, lack vision, and are paralyzed by group think and tradition."

For me, I think the Brethren are doing an excellent job of managing the Church's finances. 

I do not resent or object to the Law of Tithing.  I think it is ennobling.  I think consecrating a tithe it is as important to discipleship as it is to consecrate work and time and effort.  

On 5/2/2026 at 3:38 PM, Analytics said:
Quote

Okay.  Assuming, arguendo, that a lot of members did indeed misunderstand Pres. Hinckley as regarding the funding of City Creek, could you elaborate on why that is such an important issue for you?  

Three reasons. First, I just want to keep the record straight on what happened and how people's beliefs evolve over time.

Right.  But why this topic in particular?  

On 5/2/2026 at 3:38 PM, Analytics said:

Second, I think if we do that, we can have some empathy for members who have felt betrayed by what happened--empathy would be a good thing.

Okay.  Could you elaborate on this?  My sense is that there really aren't very many Latter-day Saints who cared back then or care now.  And of those who did care, many not only do not feel "betrayed," they feel vindicated by the outcome of the tithing lawsuits, in which the Church was exonerated of accusations of misconduct.  More broadly, the Latter-day Saints who are really paying attention to the Church's finances are coming to the conclusion that Quinn suggested back in 2017: 

Quote

As a seventh-generation Mormon, Quinn, who was excommunicated from the faith in 1993 for apostasy based on his historical writings about polygamy, says the LDS Church’s financial trajectory, as well as the self-sacrificing actions of its hierarchy, is “an enormously faith-promoting story.”

If everyday Mormons could grasp “the larger picture,” he says, they would “breathe a sigh of relief and see the church is not a profit-making business.

At the same time, I think plenty of Latter-day Saints do not want their faith publicly disparaged and insulted, things they hold sacred profaned, their intelligence and character disputed, their leaders ridiculed and insulted, and so on.  Do you likewise have "empathy" for those feelings of consternation and frustration?

On 5/2/2026 at 3:38 PM, Analytics said:

Third, I have an emotional reaction at what seems like an attempt to gaslight us. Huntsman's beliefs about the how the Church financed these projects was consistent with the vast majority of the Latter-day Saints who posted here.

I really don't think so.  I think Huntsman, along with most of us, never had any substantial misunderstanding or misapprehension about City Creek.  I think Huntsman's lawsuit was pretextual.

To be sure, there are some Latter-day Saints who objected to City Creek.  But the Brethren cannot take a "We'll only do things that will nobody anywhere will find objectionable in any way" sort of approach to the Church's finances.  The Parable of the Talents warns against that.

I don't know what you mean by "seems like an attempt to gaslight."  If anything, this thread - and the various other threads pertaining to City Creek and the tithing lawsuits - have illuminating what appears to be mostly disagreements based on splitting hairs, differences of opinions and value judgments, and presuppositions about the Church generally.    

On 5/2/2026 at 3:38 PM, Analytics said:
Quote

EPA is not a for-profit hedge fund operating for private gain (I say this because you have, over the years, repeatedly characterized EPA as a hedge fund).  It is, instead, an integrated auxiliary of the Church of Jesus Christ of Latter-day Saints, organized under long-standing U.S. tax law (Internal Revenue Code § 501(c)(3) and related provisions governing churches and their supporting organizations). Its sole purpose is to manage reserves that help fund the Church’s religious, educational, and humanitarian mission—temples, meetinghouses, welfare programs, disaster relief, and missionary work. Like every other tax-exempt religious organization in America (Catholic dioceses, Protestant denominations, Jewish federations, etc.), its investment earnings are not subject to income tax precisely because they support exempt purposes.

You are making this up as a post-hoc rationalization.

I don't think so.  If it was factually inaccurate, I think you would be able to pick it apart.

On 5/2/2026 at 3:38 PM, Analytics said:

The Church created Ensign Peak Advisors for exactly the same reason it created Ashmore Wealth Management, LLC, Argyll Research, LLC' Clifton, Park Capital Management, LLC, Cortland Advisers, LLC, Elkfork Partners, LLC, Flinton Capital Management, LLC, Glen Harbor Capital Management, LLC, Green Valley Investors, LLC, etc. 

These were all created to hide the Church's assets from the membership, the public, the SEC, and the IRS. That's it.

I think there's quite a bit more to EPA than that.

On 5/2/2026 at 3:38 PM, Analytics said:

The quotes I provided above by Bednar and Hinckley demonstrate that what you say here is made up. The way it really works is that the Council for the Deposition of Tithes meets, they are given a projection of the next year's tithing, they set a budget based on 90% of that total, and they manage the Church to those budgets.  The excess is sent to EPA. It is a "fixed principle" that the church lives on a subset of tithing.

I don't think any of this is incompatible with what I have said.

On 5/2/2026 at 3:38 PM, Analytics said:

Now that these secret organizations have been exposed the Church may have put its main treasury under the "Ensign Peak Advisors" umbrella, but that doesn't change the way the reserve fund works.

If the Church has broken the law, then it should be held to account.  

That is not what has happened, though.  This conversation isn't about legal v. illegal, but is instead about highly subjective value judgments about what the Church should do with enormous sums of money.  We can and should have these conversations, but I think they were more effective without the disparagements and vitriol.

On 5/2/2026 at 3:38 PM, Analytics said:

The reserve fund is not used to help fund the Church’s religious, educational, and humanitarian mission—temples, meetinghouses, welfare programs, disaster relief, and missionary work. It's sole purpose is for a place for unspent tithing to be saved. That's it.

Thank you for explaining your view so clearly. I appreciate you taking the time to share it.

I respectfully disagree with the assertion that the reserve fund “is not used to help fund the Church’s religious, educational, and humanitarian mission” and that its “sole purpose is for unspent tithing to be saved.”

Presiding Bishop Christopher Waddell addressed this directly in the 2023 60 Minutes interview when he said:

Quote

“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—education work, all the work of the church they fund.”

That statement makes clear that the reserves are being used to support the Church’s core mission — temples, meetinghouses, missionary work, education, welfare programs, and disaster relief.

The idea that EPA’s sole purpose is simply to warehouse unspent tithing appears to rest almost entirely on David Nielsen’s interpretation of the internal accounting. While Nielsen is certainly entitled to his perspective, the Church’s own leaders have consistently described the reserves as a prudent reserve designed to provide long-term stability and the ability to continue the Church’s work even in difficult or disruptive times. Managing those funds wisely allows the Church to plan clearly for both present and future needs rather than living hand-to-mouth.

I agree that reasonable people can disagree about the ideal size of such a reserve or how transparent the reporting should be. But the claim that the reserves have no connection to funding the Church’s mission doesn’t align with the statements from Church leaders or how the funds are actually deployed.

Thanks,

-Smac

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