Exhibit 421

In the Matter of Ensign Peak Advisors, Inc. and The Church of Jesus Christ of Latter-day Saints, Exchange Act Release No. 96951, File No. 3-21306

Exhibit 421 · Administrative order

In the Matter of Ensign Peak Advisors, Inc. and The Church of Jesus Christ of Latter-day Saints, Exchange Act Release No. 96951, File No. 3-21306

the Church and Ensign Peak created thirteen limited liability corporations (“LLCs”), including twelve similar LLCs (the “Clone LLCs”) with addresses located throughout the U.S., for the sole purpose of filing Forms 13F and preventing public disclosure by Ensign Peak of the Church’s equity securities holdings.

Settled cease-and-desist order (respondents neither admitted nor denied the findings). Finds Ensign Peak failed to file Forms 13F in its own name from 1997 through 2019 and filed them under thirteen LLCs that misstated investment discretion; the Church approved the approach and caused the violations. Penalties: $4,000,000 (Ensign Peak) and $1,000,000 (Church). First consolidated Form 13F filed 14 February 2020 listing 1,659 securities worth about $37.8 billion.

Source: U.S. Securities and Exchange Commission
Date: 21 February 2023
Quoted from: Order, Part III, Summary (p. 2)
Grade: Primary record
Document: https://www.sec.gov/litigation/admin/2023/34-96951.pdf
Accessed: 2026-11-09
Cited by: Findings citing this exhibit

Cited by

Finding REL-4.3: Primary record The SEC found that from 1997 through 2019 Ensign Peak Advisors, an integrated auxiliary of The Church of Jesus Christ of Latter-day Saints, did not file Forms 13F in its own name. The Church and Ensign Peak created thirteen LLCs for the sole purpose of filing the forms and preventing public disclosure of the Church's equity holdings, and the Church's senior leadership approved the approach.
Finding REL-4.4: Primary record The SEC found that the LLCs' forms misstated that the LLCs had sole investment and voting discretion, and that the Church's audit department highlighted in 2014 and 2017 the risk that the SEC might disagree with the structure. The practice ended with a consolidated Form 13F filed on 14 February 2020 that listed 1,659 securities worth about $37.8 billion.
Finding REL-4.5: Primary record On 21 February 2023 the SEC ordered Ensign Peak Advisors to pay $4,000,000 and the Church $1,000,000 and ordered both to cease and desist, in a settlement in which neither admitted nor denied the findings. The Church's statement of the same day says Ensign Peak "received and relied upon legal counsel" and that "We affirm our commitment to comply with the law, regret mistakes made, and now consider this matter closed"; its statement of 17 December 2019 says "The Church complies with all applicable law governing our donations, investments, taxes, and reserves."