This morning, the Salt Lake Tribune reported that Ensign Peak Advisors, the investment arm of the Church of Jesus Christ of Latter-day Saints, reported a total of $38.7 billion of holdings in the U.S. stock market.

Truth & Transparency first reported on this topic in May 2018 by uncovering $32 billion traded by 13 shell companies connected to the Church, and again last month when revealing the increased value of those shell companies as well as venture capital investments made by another shell company connected to the Church.

Last month, in another unprecedented move, the Church gave an exclusive interview to the Wall Street Journal discussing the portfolio, admitting to having intentionally obfuscated the paper trail with the shell companies discovered by Truth & Transparency. They feared that members would reduce their tithing donations to the Church.

Today’s story from the Tribune implies that this $38 billion is in addition to the money already reported by Truth & Transparency saying that Ensign Peak’s portfolio is “more diversified than any of those smaller funds.” However, closer analysis of the data suggests otherwise.

While it is true that Ensign Peak filed a report with the U.S. Security and Exchange Commission, none of the other 13 shell companies did, a fact the Tribune originally failed to report. This suggests that the shares were moved under the known corporate umbrella of the Church, another unprecedented and surprising move.

This hypothesis is supported by comparing the data from Ensign Peak’s most recent filing and the previous quarter’s filings from the shell companies. The number of entities the Church had invested only grew from 1,646 to 1,650 and the amount of shares traded between the two quarters is largely negligible.

Additionally, the difference in shares between the two reports could be a result of consolidating other shell companies than the ones currently known. An entity only has to file these public reports if over $100 million is held at the end of the quarter. It is completely possible that the Church has other entities under its corporate umbrella that were not trading at that threshold.

Such may be the case with Clifton Park Capital Management, an LLC known to be owned by the Church, yet one that hasn’t filed a report with the SEC since the final quarter of 2015. That does not necessarily mean that they are not still actively trading, simply that they may be doing so below $100 million.

The Church has also previously engaged in venture capital endeavors, investing in private companies before they are publicly traded. One of those companies Truth & Transparency reported on last month was the tech company Fastly. When comparing the data, the church had not reported any public shares held in Fastly until this most recent quarter in Ensign Peak’s filing. There are likely several other instances of similar activity.

This money is obviously a fraction of the $100 billion known to be controlled by the Church, as originally reported by the Washington Post, and simply the only amount discovered through public records.

While it’s likely that only a small portion of the $38 billion reported by the Salt Lake Tribune wasn’t already known, the Church is obviously making strides in becoming more financially transparent. Time will tell if the behavior is the new norm or a one-time attempt to silence critics.

The code used to perform the data analysis for this article can be found here.

In the coming days, Truth & Transparency will be publishing interactive graphs illustrating the known worth of the Mormon Church’s portfolio over time. This is a tremendous effort with many features planned. If you want to support this work, please consider making a donation today.