In a complaint to the IRS, David A. Nielsen alleged he saw officials with The Church of Jesus Christ of Latter-day Saints and its investment fund, Ensign Peak Advisors (EPA), take steps to keep the size of its $100 billion investment fund from the government and church members.

Lars Nielsen said he and his twin brother wrote a 74-page synopsis of the IRS complaint. Here are three excerpts:

Shutting out an apostle

Boyd K. Packer, when he was next in line to succeed then-church President Thomas S. Monson, came to [EPA President Roger] Clarke wanting to know how much Ensign Peak had amassed and the details of its structure. Mr. Clarke told Mr. Packer that he could not share such details.

“Mr. Packer said, ‘I think I should know. I’m the most senior apostle and president of the Quorum of the Twelve Apostles, and I’m a breath away from being the next prophet. I think I should be prepared.’

“Mr. Clarke reaffirmed that he had been instructed not to reveal that information to Mr. Packer, who went away perturbed and unsatisfied, as related to the whistleblower by Richard B. Willes, the head of fixed income at EPA at the time. Mr. Packer died before he could join the First Presidency and know the value of EPA.”

Fudging a BYU audit

“Because [Brigham Young University] receives federal funding, it had to be audited by an independent third party, in this case Deloitte & Touche. In order for Deloitte to verify the market value of BYU’s endowment, it needed to verify the market value of EPA’s funds.

“This was unacceptable to the [LDS Church] because the [church] did not want anyone at Deloitte to discover the true size of EPA. So, the [church] leaned on Mark Stevens, a Mormon and audit director at Deloitte, to vouch for the audit without letting any auditors see, which he did for multiple years. Eventually, Deloitte felt uncomfortable with the arrangement; it did not represent the industry’s ‘best practices’ (for obvious reasons).

“In response, EPA painstakingly stripped out all affiliate interests in all EPA funds and created separate accounts dedicated to affiliate money so that independent auditors would see no further into EPA; i.e., they would audit a cup of water instead of an entire ocean.”

Limiting broker data

“The 2001 Patriot Act requires all financial counterparties to ‘know your client’ before on-boarding (to prevent funding terrorist activities). Custodians and brokers have repeatedly requested due-diligence documentation consistent with their internal standards and written procedures, which include full financial statements. In lieu of financial statements, EPA instead provides a ‘Statement of Financial Condition.’

“Custodians and brokers who accommodate this exception go against industry best practices and their internal risk management policies. But some are not willing to forgo business with EPA. EPA simply refuses to work with a counterparty that demands EPA’s financial statements.”