In December 2019, a former Ensign Peak Advisors employee filed a whistleblower complaint with the IRS that made public what many had suspected: the LDS Church's investment arm manages roughly $100 billion in assets. The story broke in the Washington Post and spread from there. It was one of the biggest revelations about LDS finance in modern history. Let me walk through what we actually know, what remains unclear, and what it means for ordinary members and investors.

The Whistleblower Complaint

David Nielsen, a former portfolio manager at Ensign Peak Advisors (EPA), filed a whistleblower complaint with the IRS in late 2019 alleging that EPA held approximately $100 billion in assets and that these assets had never been used for the charitable purposes that would justify the church's tax-exempt status. Nielsen's complaint was published by the Washington Post in December 2019, making the existence and scale of EPA widely known for the first time.

Before the whistleblower complaint, EPA was not well understood outside of senior church leadership. The entity existed and was known to some observers, but the scale of assets was not generally appreciated. The $100 billion figure was larger than most educated guesses.

The whistleblower's central claim was that EPA was acting as an investment fund that wasn't distributing assets to charitable purposes, which he argued violated the terms of the church's tax-exempt status. The IRS has not publicly confirmed any action on the complaint, though the SEC did later impose a $5 million fine on Ensign Peak Advisors in 2023 for securities reporting violations (specifically, for using shell companies to obscure holdings in SEC 13F filings).

What Ensign Peak Advisors Is

Ensign Peak Advisors is a registered investment advisor based in Salt Lake City. It's named after Ensign Peak, the hill near Salt Lake City where Brigham Young reportedly surveyed the Salt Lake Valley soon after arrival and identified the site for the eventual Salt Lake Temple.

EPA was organized in the mid-1990s. Its official role is to manage the church's long-term financial reserves. Unlike DMBA (which manages employee benefits) or Beneficial Financial (which services insurance policies), EPA manages investment assets that serve as a long-term reserve for the church's operations and future needs.

EPA is an investment manager, not a bank, not a holding company for church businesses, and not a pension fund. It's more like a university endowment or sovereign wealth fund in structure. It receives assets and invests them in a diversified portfolio.

What We Know About the Portfolio

EPA files 13F forms with the SEC because it manages over $100 million in US equity securities, which triggers the reporting requirement. 13F filings disclose long positions in US equities but don't include bonds, international stocks, private investments, real estate, or short positions. So 13F filings are a partial picture.

Based on the most recent 13F filings (as of Q4 2025), EPA holds positions in hundreds of US-listed companies. The holdings generally track a broad US equity index, with the largest positions in mega-cap names you'd expect:

Apple (AAPL)
Microsoft (MSFT)
Alphabet (GOOGL, GOOG)
Amazon (AMZN)
Meta Platforms (META)
Nvidia (NVDA)
Berkshire Hathaway (BRK.B)
JPMorgan Chase (JPM)
Visa (V)
Mastercard (MA)
Johnson & Johnson (JNJ)
Procter & Gamble (PG)
Eli Lilly (LLY)
UnitedHealth Group (UNH)
Exxon Mobil (XOM)
And hundreds more

The US equity portion of EPA's portfolio is consistent with a broad market allocation. It's not significantly tilted toward any particular sector or style. It looks a lot like what you'd get if you bought the S&P 500 or the Russell 1000.

This is worth noting because it tells us something important: EPA applies relatively limited values-based screening to its equity holdings. The fund holds many companies that would fail a strict LDS values screen, including:

Starbucks (SBUX): coffee
Nike (NKE): historically controversial for various reasons
Many media companies with content considerations

EPA does not appear to hold the major tobacco companies (Altria, Philip Morris International) based on 13F disclosures. This suggests at least some values-based screening is applied, likely for the most clear-cut exclusions like tobacco and possibly alcohol.

The absence of tobacco holdings is notable. It matches what you'd expect from an LDS-affiliated investment fund. The presence of Starbucks and some other coffee-adjacent names suggests that EPA does not apply the strictest version of Word of Wisdom screening to its portfolio. The church's official position, as mentioned in earlier posts, has generally been that member investment choices are personal and don't require specific exclusions.

What the Fund Doesn't Tell Us

The 13F filings don't cover:
- International equity holdings
- Fixed income (government and corporate bonds)
- Private equity and alternatives
- Real estate holdings
- Cash and money market positions
- Derivatives or hedging positions

A fund managing $100+ billion would almost certainly have substantial holdings in these other categories. The 13F filings probably capture somewhere between 50-70% of EPA's total assets, though this is speculation.

EPA does not publish an annual report, audited financial statements, or portfolio updates. The church's overall financial disclosure is limited compared to most large nonprofits. This has been a source of criticism and occasional controversy.

The Controversy

The existence of a $100 billion reserve fund has generated mixed reactions within the LDS community and outside it.

Criticisms:
- The fund is large relative to the church's charitable spending
- Members' tithing contributions accumulate in the fund rather than flowing to charitable work
- The lack of transparency makes it hard to evaluate stewardship
- The 2023 SEC fine suggested that EPA had been obscuring its holdings to avoid public scrutiny
- Some members feel the scale is inconsistent with church teachings about helping the poor

Defenses:
- A reserve fund provides long-term stability for the church through economic cycles
- Large institutions need diversified asset bases to weather disruptions
- The church does substantial charitable work, welfare, and humanitarian aid, most of which isn't publicly accounted for
- Religious organizations have legitimate reasons for financial privacy
- The fund is consistent with principles of prudent stewardship and long-term preparation

Both sides have legitimate points. The tension between "save for the future" and "give to the present" is a real theological and practical question that doesn't have an obvious answer.

What This Means for Members

For active LDS members, the EPA revelations have not fundamentally changed tithing practice or church participation. The church's guidance on tithing remains unchanged: pay one tenth of your increase, as a matter of faith and obedience, without worrying about how the church uses the funds.

Some members have raised questions about whether to adjust their tithing practice in light of the fund's size. The church's response has generally been that tithing is a principle of obedience and gratitude, not a transactional decision based on institutional financial status. A member who pays tithing based on faith is responding to a commandment, regardless of how the church's finances look.

For investors specifically, the EPA portfolio is sometimes cited as an implicit endorsement of particular investment approaches. Because EPA holds a broad US equity portfolio that doesn't apply every LDS values screen, some members have argued that stricter screening by individuals isn't required if the church itself doesn't apply it.

This reasoning is imperfect. The church has never said members shouldn't apply values-based screening to their investments. The church's institutional investment decisions are made by professional staff balancing return, diversification, and basic screening, not by prophetic revelation about which stocks to own. Individual members are free to apply stricter screens based on personal conviction, and many do.

Comparison to Other Religious Endowments

Context helps here. Other major religious institutions also maintain substantial reserve funds.

Catholic Church assets: Estimates vary widely, but the Vatican's direct investments plus Catholic institutional wealth (dioceses, orders, universities, hospitals) likely total several hundred billion dollars globally. The Vatican Bank (Istituto per le Opere di Religione) manages a smaller direct portfolio of roughly $5-6 billion.

Harvard University: The Harvard endowment is roughly $50 billion. Harvard is a university rather than a church, but it's a comparable nonprofit institution with similar long-term reserve management.

Yale University: Similar scale to Harvard, around $40 billion.

Bill and Melinda Gates Foundation: Roughly $60 billion in assets. A charitable foundation rather than a religious institution.

Wellcome Trust: UK charitable foundation, roughly $50 billion in assets.

In this context, a $100 billion church reserve fund is large but not unprecedented. It's in the range of major university endowments and charitable foundations. For a worldwide church with 17 million members and a 200-year history, the scale is substantial but not absurd relative to peer institutions.

What Members Should Do

For ordinary LDS members and investors, the practical takeaways are:

Continue paying tithing as a matter of faith. The scriptural basis is clear, the practice is unchanged, and your relationship with the Lord doesn't depend on the church's balance sheet.
Apply values-based screening to your own investments based on personal conviction. You can apply stricter standards than EPA does if you choose. Many LDS members do.
Take practical lessons from institutional management. EPA's broad diversified approach is consistent with modern portfolio theory. The professional management, long time horizon, and values-based exclusions (particularly tobacco) match what most LDS financial advisors recommend for individual investors.
Maintain perspective about financial transparency. Religious institutions have legitimate reasons for privacy. You can be thoughtful about supporting institutions whose stewardship you trust without demanding full disclosure.
Remember the spiritual framework. Tithing, investing, and managing money are all ultimately in service of spiritual goals and family welfare. The financial details matter but shouldn't become the center of your religious life.

Bottom Line

The Church of Jesus Christ reserve fund, managed by Ensign Peak Advisors, is estimated at over $100 billion based on the 2019 whistleblower complaint and subsequent reporting. The fund invests in a broad US equity portfolio along with likely substantial international, fixed income, and alternative holdings. The fund applies limited values-based screening, excluding tobacco and probably some other categories, but holds many mainstream names that individual LDS investors might choose to exclude.

The existence and scale of the fund have generated both criticism and defense within the LDS community. For individual members, the practical implications are limited: tithing practice continues, personal investment choices remain personal, and the broader framework of financial stewardship stays rooted in scriptural principles and prophetic counsel.

For stock investors using FaithScreener or similar tools, the EPA example is informative: even at the institutional level, LDS investing combines broad market exposure with selective screening. Individual investors can go stricter or more permissive, depending on their convictions and circumstances. The goal isn't to match the institutional portfolio but to build a personal investment approach that honors your values, provides for your family, and aligns with your understanding of what faithful stewardship looks like in 2026.

The Church of Jesus Christ Reserve Fund ($100B+): What We Know