Church Finances and Transparency

Every financial claim in this section shares one habit: it takes an ambiguous data point and reads it in its most sinister possible sense — when the primary record, most of it published years before the CES Letter, resolves each one in the ordinary direction. On the one financial charge here that was ever tested in a court of law, a unanimous federal appeals panel agreed.

The Claims

In substance, the section argues:

The CES Letter’s Argument

The Church spent roughly $1.5 billion building the City Creek Center shopping mall while, over the same era, reporting only about $1.4 billion in humanitarian aid across 26 years. Members receive no detailed financial accounting. A Lorenzo Snow tithing statement was abridged in a Church manual to drop a qualifying phrase. And — as critics now press the case — Ensign Peak Advisors accumulated a reserve reported to exceed $100 billion whose full size was kept out of public view.

The Fork Jeremy Chose

At every juncture in this section, two readings of the same fact were available, and the CES Letter took the harsher one every time.

  • A capital investment that earns revenue can be read as a business asset, or as money “spent” and gone. Jeremy chose the second — then set it beside 26 years of pure charitable outflow, comparing a bank deposit to a grocery bill.
  • A federal filing exemption shared by nearly every American church can be read as standard practice, or as concealment. Jeremy chose concealment.
  • A marked ellipsis in a devotional manual can be read as ordinary abridgment, or as censorship. Jeremy chose censorship — without noticing that the very words removed demolish his own portrait of a pitiless Church.
  • A large reserve fund can be read as prudent stewardship for a global institution, or as hoarded greed. Jeremy chose greed.

The nuanced path is not merely “the faithful spin.” It is the reading supported by the on-the-record statements of Church leaders from 2003, by the published Conference Report Jeremy himself is quoting, and — on the single financial claim actually litigated — by a unanimous federal appeals court. The sections below walk each fork.

Response

1. City Creek: A Capital Asset, Not a Charity Line Item

The headline — $1.5 billion for a mall versus $1.4 billion in humanitarian aid over 26 years — only works if you never ask what kind of money each number is. City Creek Center, opened March 2012, is a capital investment: a mixed-use development built through the Church’s commercial real-estate entities and funded from investment earnings, not from tithing. A capital asset does not vanish when purchased — it earns rent, appreciates, and returns money that then funds religious and charitable work. Setting it against a charity expense is like comparing the price of a farm to a family’s grocery bill and concluding they care more about dirt than food.

The humanitarian figure is also stripped to its smallest form. The $1.4 billion counts direct disbursements and misses the rest of the welfare system entirely: in-kind donations of food, clothing, and medical supplies; tens of millions of volunteer labor hours; fast-offering funds administered congregation by congregation; bishops’ storehouses, welfare farms, and canneries; and Deseret Industries, employment services, and partner-organization relief.

This whole welfare architecture is an outgrowth of the law of consecration — the covenant ideal of a people who care for one another until there are “no poor among them” — and it never fit on a single humanitarian-aid line. The direct figure has since climbed steeply, too: the Church now publishes an annual humanitarian report documenting expenditures that in recent single years have exceeded a billion dollars — already outpacing the 26-year total the CES Letter still quotes.

The Strongest Form of the Objection — and the Court That Tested It

An honest critic can press harder than the CES Letter does. The strongest version is not “tithing built the mall” — because President Gordon B. Hinckley said the opposite, out loud, a full decade before the CES Letter appeared. In April 2003 general conference he told the whole Church: “I wish to give the entire Church the assurance that tithing funds have not and will not be used to acquire this property. Nor will they be used in developing it for commercial purposes.” He continued: “Funds for this have come and will come from those commercial entities owned by the Church. These resources, together with the earnings of invested reserve funds, will accommodate this program.” Presiding Bishop H. David Burton said the same publicly that year.

So the genuinely strong objection is narrower and sharper:

The earnings on invested reserves partly derive from decades of tithing surplus. So isn’t “earnings on tithing” still tithing? Isn’t the leaders’ careful phrasing a distinction without a difference — a shell game to fund a mall with sacred funds while denying it?

That precise theory was not left to internet argument. Former member James Huntsman sued the Church for fraud on exactly this ground, seeking the return of his donations. In January 2025 an eleven-judge en banc panel of the United States Court of Appeals for the Ninth Circuit affirmed dismissal of the suit by a vote of 11–0. Ten of the eleven judges held there had been no misrepresentation at all: because President Hinckley had openly said in 2003 that the earnings of invested reserve funds would be used, no reasonable juror could conclude the Church had concealed City Creek’s funding source.

This is worth sitting with. The one financial accusation in this section that was ever submitted to neutral, non–Latter-day Saint judges — the charge that the Church lied about where the money came from — was rejected unanimously, on the strength of a statement the Church had volunteered a decade earlier. Jeremy chose the fork that a federal appellate court, weighing the identical facts, found no reasonable juror could take.

2. “No Financial Accounting”: The Legal Norm, Not Concealment

In the United States, churches classified as 501(c)(3) religious organizations are not required to file the detailed Form 990 that other nonprofits file. That exemption is not a Latter-day Saint loophole; it applies identically to the Catholic Church, the Southern Baptist Convention, and virtually every American congregation. Declining to publish what the law does not require is the ordinary practice of American religion, not evidence of a cover-up. Where disclosure is required — the United Kingdom and Canada among others — the Church files, and those records are public.

The timeline matters for honesty, too: this point does not lean on any document from December 2013 or later. The most important transparency fact in the section — President Hinckley’s on-the-record 2003 explanation of exactly how City Creek would be funded — predates the CES Letter itself; members were told from the pulpit years in advance. Internally, a report from the independent Church Auditing Department is presented in general conference every year affirming that funds are handled according to policy. The existence of Church investments and reserves was never secret; only the aggregate figure was private — and privacy is not deception.

The CES Letter blurs two questions: whether the Church obeys the law (it does), and whether an individual member holds a governance right to line-item institutional accounts (he does not — and neither do the members of nearly any other faith). That is a fact about how religious bodies are governed, not a symptom of fraud.

3. The Lorenzo Snow “Altered” Quote — Which Cuts the Other Way

Here the fork is at its sharpest, because the “gotcha” backfires. During the drought and poverty of 1899, President Lorenzo Snow preached tithing across southern Utah. The original text, in the published Conference Report, reads:

Lorenzo Snow, 1899

“…I plead with you in the name of the Lord, and I pray that every man, woman and child who has means shall pay one-tenth of their income as a tithing…”

A later devotional manual, Teachings of Presidents of the Church: Lorenzo Snow, abridged the sentence with a visible ellipsis, trimming the phrase “who has means.” Critics call this censorship. But look at what those omitted words actually say — and then look at what Jeremy argues a few paragraphs earlier: that the Church commands the destitute to pay tithing before feeding their families.

The phrase “who has means” is the opposite of a coverup Jeremy would want. It shows President Snow himself qualifying his plea — addressing it to members who had the means to pay. The fuller, uncensored primary source undercuts the very portrait Jeremy is painting of a pitiless Church squeezing the starving. He demands the Church quote Snow in full and casts Snow as merciless — yet Snow’s full words are the merciful ones. You cannot have it both ways.

As for the abridgment: curriculum manuals routinely condense nineteenth-century sermons for length, and this one flagged the omission with an ellipsis rather than hiding it — which is precisely how a reader could compare the two texts at all. The complete address has stayed openly published in the Conference Report the entire time. There is no hidden Snow; there is a footnote-level editorial trim of a quotation whose full version helps, rather than harms, the faithful reading.

And the underlying teaching — that covenant faithfulness in hard times invites divine provision — is not a Latter-day Saint peculiarity. It is the widow of Zarephath, told by Elijah to make his bread first from her last handful of meal, whose barrel of meal did not waste (1 Kings 17:8–16). It is Malachi 3:10, inviting the Lord’s people to “prove me now herewith” and receive the windows of heaven. And it is the widow’s two mites, which Jesus praised precisely because she gave of her want (Mark 12:41–44) — two coins that bought the treasury nothing. The point was never the treasury but the giver’s faith and blessing; that is the whole logic of tithing in extremity, and why it cannot be reduced to a fundraising scheme. Latter-day Saint tithing is one expression of the older law of consecration — a covenant of stewardship, not a fee.

4. Ensign Peak: A Reserve, and a Disclosure-Form Question

Chronology first, since accuracy matters: the Ensign Peak story became public in December 2019 through a whistleblower complaint — more than six years after the CES Letter began circulating in 2013. So it is not something the CES Letter uncovered; it is a later development critics have folded backward into the older argument. We engage it because it is now part of the conversation. At full strength, the objection runs:

A former employee alleged Ensign Peak had grown past $100 billion, had made no charitable distribution in decades, and was structured to keep its size out of public view. In February 2023 the SEC announced a settlement over how the fund’s holdings were reported; the Church and Ensign Peak paid $5 million. How is asking a struggling widow for her tithing compatible with a hundred-billion-dollar fund kept out of sight?

What the reserve actually is. A hundred billion dollars is an enormous number in a headline and a modest one against the obligation it secures: sustaining tens of thousands of congregations for a worldwide membership across more than 150 nations — a footprint whose real scale is itself often misread in these very debates — through wars, depressions, and generations yet unborn. This is the endowment model, resting on the Church’s founding theology of preparedness — “if ye are prepared ye shall not fear” (D&C 38:30) — and on a practice of storing against famine that goes back to Brigham Young. A perpetual fund that lets an institution outlast the next collapse is prudence, not avarice; no one accuses Harvard of “hoarding” its endowment while it also asks alumni to give.

What the 2023 settlement actually was. The SEC order was not a finding of theft, misappropriation, or misuse of a single dollar. It concerned how the fund’s securities holdings were reported: for years Ensign Peak filed its required disclosures through a set of separate holding companies rather than under one name — an approach adopted on legal advice out of concern that revealing the fund’s full size could invite pressure and market disruption. Regulators concluded that structure did not satisfy the reporting rules; the Church updated its filing practice and resolved the matter with a combined $5 million payment, and the First Presidency affirmed a commitment to comply with the law. That is the human administration of a divine work — sincere stewards making a judgment about how to shield a sacred reserve, then adjusting when a regulator required a different approach. It is a question of paperwork and prudence, not of doctrine or integrity: the fund is real, its size is real, and the filing structure genuinely fell short of a technical standard and was put right. What does not survive is the leap to “greed,” because greed spends the money on itself — and here the money was invested, preserved, and, in recent years, drawn upon for record humanitarian outlays.

Verdict

What is resolved. The mall-versus-charity comparison is a category error — a revenue-earning capital asset set against a narrowed charity figure. City Creek’s funding was disclosed by name from the pulpit in 2003, and the fraud theory built on it was rejected 11–0 by a federal appeals court in 2025. The “no accounting” charge describes the ordinary legal posture of American churches, not concealment. The Lorenzo Snow “altered” quote is a marked, minor abridgment of an ever-public sermon whose full wording actually favors the Church. And the “$100 billion hoard” is a prudent endowment; the 2023 SEC settlement concerned the structure of a routine disclosure — not one dollar taken or misspent. On the charge that actually matters — that the Church is a greedy institution enriching itself — the evidence runs the other way.

What remains genuinely — and only mildly — open. Financial openness is a matter of prudential judgment, not doctrine: the Church could publish more voluntarily than the law requires, and members can differ on how much detail is wise. And the earlier securities-filing structure, like the editorial choice to trim “who has means” from a manual, are defensible-but-debatable judgment calls — one can wish either had been handled differently without imagining any intent to deceive. Those are questions of administration and editorial taste, not of doctrine or honesty — the small, honest kind of open question that remains once the sensational version is set aside. Reaching that sensational version required Jeremy, at every fork, to choose the reading the evidence supports least.

Further Study