Options for Financial Transparency

DSCF3468

In today’s Deseret News, Boyd and Chapman then acknowledge:

Of course, it’s fair game to question whether the reserves are adequate or excessive, or whether specific actions with funds are proper, as the Post article and the whistleblower does.  Vast assets require controls and nonprofit reserve investments can be controversial.

I agree wholeheartedly: let’s start asking questions about Church finances.  But first, we need Church financial disclosures.

As Sam Brunson laid out on the blog earlier today,

As for whether $100 billion is too much for the church to have sitting, unspent: it’s an important thing to think about.  It’s a question that the church needs to seriously engage.  It’s a question that we, as members of the church and as tithepayers, need to seriously engage.  And the question of how large an endowment tax-exempt organizations (including, but not limited to, churches) should have is an important question we, as society and the voting public, need to engage with.

I’ve written before about mapping the Church’s finances onto it’s institutional priorities.  But a serious limitation of my analysis is my guesswork about the underlying finances.  Frankly, we as Church members are not well-equipped to engage these ethical and prudential questions about spending.  At least not until we obtain basic, accurate financial information from the Church.

The reason the Washington Post story is newsworthy is because we don’t have insight into the financial picture.  Why not?  Because federal tax law exempts all churches from filing both taxes and the standard nonprofit financial disclosure form, the IRS Form 990.

This is a fixable problem.  One solution is to lobby the Government to change the reporting requirements for all nonprofits, including churches.  After all, the appropriate scope of charitable holdings and financial disclosures is a common controversial topic in society at large.  But change from a legal route would be years away, and the details uncertain.

Alternatively, we could ask the Church to voluntarily publish its financial reports.

Such financial reports could take many forms.  I propose four options below.  All of them should reflect information already in the Church’s possession, and the publication of any would immediately provide us with more information than currently known.

Option 1:  Voluntarily publish an IRS Form 990

Here’s a blank IRS Form 990.  This is the form most other 501(c)(3) nonprofits are required to publicly disclose each year.  If the Church was required to disclose it, we would quickly learn:

  • Total revenue, and the breakdown of sources of that revenue
  • Total expenditures, and major categories of expenditures
  • Total grants to other charitable organizations
  • Senior employee and board member salaries
  • Travel and housing stipends for church officials
  • Description and scope of any political lobbying or campaign activities
  • Summary of foreign financial grants

The comparison points the Washington Post uses for its story appear to have come from IRS Form 990 data and other public disclosures by other nonprofits.  With the same type of information, we could more accurately compare the Church and its subsidiary institutions to its peers in the fields of education, welfare, refugee assistance, disaster relief, public media, etc.

Option 2:  Publish equivalent information to what the Church already discloses abroad.

Before the Washington Post story, much that was known about the Church’s finances was gleaned or extrapolated from foreign financial disclosures the Church already makes.  The United Kingdom, Canada, and Australia, for example, all require public accountings.

Publishing the same information in the United States would help reveal:

  • Total revenues
  • Total expenditures
  • Employee salaries and compensation
  • Building costs
  • Subsidies from Salt Lake City to fund the global church

Analyses of these public filings informed much of D. Michael Quinn‘s 2017 book on Church finances, which Sam Brunson reviewed with caveats here at BCC.

Option 3:  Publish the full audit already conducted each year.

In a statement released today, the First Presidency reiterated that “The Church complies with all applicable law governing our donations, investments, taxes, and reserves.”  (The statement also downplayed the whistleblower report as based on “limited information.”)

I believe this.  I believe the Church strictly complies with tax law.  (This is one of the reasons Kirton McConkie exists.)  I believe there’s no reason to think the Church broke the law.  I believe the annual Church Auditing Report in General Conference reflects an enormous amount of honest and diligent financial effort by trained professionals.  I have seen how seriously the Church responds to any whiff of money misuse or embezzlement by local leaders.

But I do not believe that “trust us, we’re in authority” is an adequate substitute for actual financial disclosures.  When missionaries ask us to pray for a testimony of the Book of Mormon, at least we have the published Book of Mormon to read.  I wish the same was true of our financial statements.

So publish the full annual audit.  Presumably this audit contains the four basic financial statements taught in Accounting 101, plus some of the supplemental disclosures required by public entity SEC statements.

This audit would help reveal:

  • A year-end balance sheet reflecting the total financial picture of all Church assets and liabilities
  • A statement of annual revenues and expenses
  • A statement of cash flows
  • A complete list of all Church-owned or Church-affiliated entities
  • A list of worldwide regulatory investigations, criminal investigations, and/or civil litigation matters which could significantly affect Church finances
  • A summary of the Church’s view of the global financial picture and its contingency plans in case of crisis.

Notably, the Church used to publish similar information, but stopped in 1959 as it careened into debt.

Option 4:  Publish a reader-friendly graphical summary.

Last fall, my now-husband and I sat waiting in a Catholic parish lobby for a wedding planning meeting with a Priest.  Among the papers and magazines on the coffee table was a complete diocesan annual report.  I picked it up out of curiosity, and then surprised myself by devouring its contents.

Much of the report is similar in tone to The World Report published between sessions of General Conference.  An opening statement!  Candid photos!  New buildings!  New ordinations!  New baptisms!  Youth Mission Trips!  Welfare service projects!  Yay religion!

…and then on page four a huge call-out box discusses ecclesiastical abuse.  It includes a hotline number, disclosure of financial settlements and therapy costs for victims, and a link to more information.  The link includes a public statement of credible accusations against specific clergy members in diocesan history.

Wow.  Ok.  Its tragic that it took decades of scandals for the Catholic Church to frankly acknowledge its sex abuse troubles, but I can appreciate the transparency now.  That’s different than what I’ve seen out of all the other religious-affiliated institutions I’ve interacted with. [fn1]

Turning to page five, the diocese begins to provide detailed financial information.  Including:

  • Revenues from contributions, grants, tuition, and investments
  • Expenditures for buildings, salaries, schools, scholarships, and outward donations
  • Expenditures on specific programs
  • Links to full financial reports
  • Links to affiliated financial reports (such as for Catholic Charities)

Here’s a sample of just part of one page.

Sample Page

I’ve since learned that the Diocese of Arlington is not unique — I’ve started hunting for annual reports in the literature stacks at every Catholic Church we visit when travelling.  More often than not, I can find them.

* * *

Publishing comparable information at the area-wide or Church-wide level would be groundbreaking.

As a member of the Church, I would read any published financial statements cover-to-cover.  I would line them up with the Church’s statements of priorities.  I would compare our assets and expenditures to peer institutions, particularly for universities and disaster relief.  I would evaluate what a reasonable nest egg might look like in the event of the next global financial crisis.  I would engage complex theological questions about whether the Church has a moral responsibility to tithe 10% of its income to outside charitable endeavors.

And then I would start to ask the truly hard questions.  Like, when can we hire janitors for all our buildings again?

END

*Pictured, my photo of my Aunt’s handmade piggybank pottery she sells at Pike Place Market in Seattle.

[fn1]  Almost every corporation, nonprofit, and religious institution I know of has stories of gross mismanagement, including failures to appropriately address red flags surrounding squandered finances and physical abuse.  Organizations are made up of humans.  Humans do greedy, power-hungry, violent and abusive things.  In my opinion, those organizations should be judged by the transparency of their processes and the adequacy of their responses for addressing these human ills, not their skill in hiding them.

 

Comments

  1. Kevin Barney says:

    I sort of imagine that the Church never restarted the annual financial reporting after the ship was righted out of a worry that people would see these huge numbers and not fully appreciate how much it takes to run the Church. I personally would favor some sort of financial reporting to the membership. But if the Church isn’t doing it for the reason I suggest, I think the best option would be to publish the full audit. This would have the virtue of providing the most substantive information to those who can read a financial statement, whereas those who can’t read a financial statement would take comfort from the mere existence of so substantial a document.

  2. Amen. Culturally people are starting to expect much more transparency from organizations they donate to or work for – “trust, but verify” – and as the church gets further and further from what we expect of institutions people will be much less likely to continue to donate. I think it’s a matter of survival. People will walk with their dollars. Perhaps until now the greater risk was that people would see the numbers and be disappointed and disaffected but I think the tide is shifting to where more disaffection will result from secrecy.

  3. If the church saw an increase in retention, when it stopped making financials public (perhaps due to less bickering over “fair” distribution) I doubt that the church would change in this manner.
    On the other hand, if the church sees higher retention in countries where there are public financials, I’d be surprised that the church wouldn’t make it a world wide practice.

  4. Thanks Carolyn. You bring up an important point: while the church isn’t required to make financial disclosure by law, it’s also not prohibited from making them. It can disclose as much as it wants.

    I really like the ethic of the ECFA, but ultimately I’m mostly indifferent as to the form of the disclosures. At this point, though, for both the church’s sale and the reassurance of its various stakeholders, I think disclosure is a critical move.

  5. “Alternatively, we could ask the Church to voluntarily publish its financial reports”

    Sign me up! Oh wait…what would this look like and honestly what are the odds it would actually happen?

  6. josh harrison says:

    Ever since 2013, when the Church began publishing the Gospel Topic Essays, I’ve been on a major transparency kick. My governing philosophy is that the coverup is worse than the crime (thank you Nixon). I feel strongly that most members can deal with controversy if the Church is transparent about it. And that should include Church finances. I think most members can process any information they encounter about these finances as long as they come from official sources. What many can’t handle is information from external sources that cause doubts and questions because they are unanswered or unaddressed by the Church. Many of us trust, but we want to verify (thank you Reagan).

  7. It’s nice to know, but so the f what? EVERY church has the same ‘issue’. And I, for one and perhaps the only one, don’t care. It’s none of my business. It’s a question of faith in my opinion. Tithing got the number up to that figure IF it’s accurate. If one starts giving in to the purulent interest in things that didn’t constitute ‘news’ three decades ago, then one, in my opinion, is questioning their own faith and the honesty of the Leadership. I don’t know how honest those men are, but I have FAITH they are. Transparency is fine, if the motivation of the asker is pure.

  8. No, Melanie, every church does not have the same issue. Most Protestant and Catholic parishes will print and distribute annual reports to their members with detailed budget items, such as how much was spent on salaries and office supplies and liturgical supplies and whatnot.

  9. Ditto what Melanie said.

  10. How does a member agitate effectively for transparency?

  11. Personally, I want some additional transparency, but only at a very high level. I want a summary of expenditures and revenues, but I don’t want a summary of asset. In fact, I don’t think I even necessarily need to see dollar figures attached to anything. My ideal financial report would report percentages. X% of revenues came from tithing, Y% from for-profit businesses, etc. A% was spend on facilities, B% on ward budgets, C% on missionary efforts, etc. Then I would like some parameter for reserves that is the Church’s target. For example, the Church could state that its goal is to have liquid reserves that equal between 4 and 10 years of last year’s expenditures, and simply report whether it is within that range. I’d even like to see a third party auditor verify the Church’s report. But I don’t want dollar figures, because if there’s one thing that the past few days has taught me, it’s that people don’t have a really good grasp on budgets for large organizations.

  12. By writing blog posts you know are read by employees at the Church Office Building, for starters.

    More seriously, I think the best thing you can do is faithfully raise your concerns with your bishops and stake presidents. Grassroots work doesn’t percolate up as well as I would like it to in this Church, but leadership do discuss common concerns with each other.

  13. In response to Melanie, perhaps you don’t think it is any of your business, but many faithful members do think it is or should be their business. We are not customers of the church purchasing a product. We are MEMBERS; we freely donate our time, talents, and money. We are all in this together. If it is Christ’s church, and we are all members of the body of Christ, then we have a very strong vested interested in the health, status, position, policies, programs, etc. of the church. Is is not Joseph Smith’s church, Brigham Young’s church, Hinckley’s church, Monson’s church, or Nelson’s church (legal status of the COFP aside). It is Christ’s church, and we are MEMBERS. Does Christ have anything to hide from us? Does he think we can’t handle the truth? Does he think we don’t deserve to know fully the workings of his church which we have covenanted to serve? Given how integral the church is to so many of our lives, I think it is only respectful and decent to share further light and knowledge with us. Faith doesn’t mean we should be blind. If we are to fully participate and lead in the church we should all be fully involved. Nelson, the FP, and the Q12 all exist to serve us. They are called to serve. They are not our overlords or masters, we don’t bow to them. They should be accountable to us. That is not about questioning their authority, that is about accountability.

  14. Bro. Jones says:

    I’m not smart enough to write the blog post that would go with it, but: what would a poorer church look like? Let’s imagine a world where for some reason, this $100b fund vaporizes overnight. Does it mean that the pace of temple building slows, or that they are less grand when built? That the cost of attending BYU or serving a full-time mission increases? Maybe it means that members are asked to host non-Sunday activities outside of church facilities, in order to conserve resources. These are all challenges, to be sure, but none of them have me imagining the Savior returning and unleashing wrath upon church personnel.

    I’m not saying we need to return to the model and financial status of the mid-20th century, but we seemed to get by with fewer temples and a smaller economic footprint.

  15. I’m not sure the Nielsens quite did their homework before releasing Letter to an IRS Director. The title alone makes them look like embittered agenda-pushers with an ax to grind. The content even more so. They really should have consulted attorneys before moving forward and had the attorneys write the letter.

    If anything, however, it shows that the church is probably worth about $100 billion. This isn’t necessarily a criminally large amount. The church has expensive operational costs and a rainy day fund should be in the billions.

    Still, I think given the church’s large savings it should be fully transparent with its finances in the way other churches are. It should also ease up on tithing collection. Do away with tithing settlement and don’t ask about tithing payment to obtain a temple recommend. They can still ask people to pay tithing, of course. Maybe also give more specifics on what portion of income tithing is to be paid on (gross, net, surplus after necessary expenses?).

  16. Nate GT: “If anything, however, it shows that the church is probably worth about $100 billion.”

    Now, is the church “worth” $100 billion, or does it have $100 in cash?
    This is a question I have and how this whole story is being understood by many.

  17. Good post, Carolyn. I see few downsides to releasing the full audit, and would prefer that. But like Sam, I care less about the form of disclosure than the fact of it. As long as we don’t disclose, people will continue to be suspicious and assume the worst, resulting in an unnecessary PR blackeye.

    I think there are still hard questions about what’s the proper size of a cash reserve and what’s the proper humanitarian expenditure percentages for an organization like the church, and I can understand why the church may be hesitant to disclose big numbers that, if not understood in the proper context, can look like hoarding, but ultimately, if we believe our choices are defensible, then we should be able to own them. And besides, if we release it ourselves, we can put it in all the context we think it needs. Otherwise, it gets out in leaks that may not be reliable, and over which we have no control.

  18. senkyoshi, the allegation is essentially that the church has $100 billion in a portfolio of various securities, many, but not all, of which are fairly liquid. That wouldn’t count the value of the church’s real estate holdings and for-profit businesses; the $100 billion is (mostly) just passive investments.

  19. Nate GT: you misspoke when you said “I’m not sure the Nielsens quite did their homework..” That should not be Nielsens plural. If you read the WaPo report you will see that David Nielsen (the one who actually worked at Ensign) did NOT consent to the release of his report. He wrote it to be sent to the IRS as a confidential whistleblower. Whistleblowers don’t write for public dissemination, they write for government agencies with the intent/hope to spur an investigation and get a reward. The report was released by the brother, who clearly has an agenda.

  20. In response to Meg’s post above about what it would look like to ask the Church to voluntarily publish its financial reports, the simple answer involves a quick look at this blog’s doppelgänger bycommonconsent.org and the petition there. John Oliver has shown how grassroots movements can help change US legislation. Perhaps a similar grassroots movement might work with the Church, especially if a significant number of tithe-payers are involved.

  21. I agree with Jared Cook. My own best guess is that the church has divided opinions about what to do with the money, and that’s partly because when you have been through a depression, you reuse the same tin foil over and over for years rather than buying new “just in case.” I’m sure that’s one faction among leadership. Another issue is that distributing charity requires infrastructure and oversight and sound management. Those things exist to some extent, but in other cases have to be created in a way that is not wasteful and that is sustainable over time. The most sustainable things are the ones that kick start local capability to manage and build from within, not those that require ongoing charity.

    If I were in charge of this stash of cash, I would start by building apartments for the homeless (not homeless shelters, but actual apartments with private baths and kitchens and building security and nearby public transit) in major cities around the world where the government was willing to take over and partner to maintain the buildings and procedures to admit individuals in need of free housing.

  22. Geoff - Aus says:

    This appears to be the Australian statement https://www.acnc.gov.au/charity/bce55328f97e59a1c1531b687c07dbaa#financials-documents
    To an untrained individual it doesn’t appear to show any wages, or accumulated savings, or charitable donations outside members. The total income appears to be exactly 40,000 x 87000 the average wage.
    The Pacific office was moved to New Zealand some years ago so prrhaps the wages show up there. https://www.register.charities.govt.nz/Charity/CC31692
    Couldn’t find wages but they claim to make 10 million profit in NZ.
    It would be good to have transparency from SLC.

  23. The church certainly isn’t wasting much time trying to respond.
    https://newsroom.churchofjesuschrist.org/article/church-of-jesus-christ-finances
    The problem is still the spin. Some parts are demonstrably misleading. For example:
    “The Church’s Seminaries and Institutes program provides daily religious instruction to some 400,000 high school students and 300,000 university students each year.”
    Unless you’re in an area with high Mormon population density, seminary is taught in a member’s home, by a volunteer teacher. To suggest that all 400,000 seminary students are a tithing-supported activity is a stretch. (Yes, tithing pays for the teacher’s manual, and the regional CES employee, and the committee time spent making the manual, I get it).
    Transparency, not spin or “trust us”, is needed.

  24. “We could ask the church to….” in this sentence multitudes. Someone (or seven) will be excommunicated or disciplined for organizing an effective, coordinated campaign to ask for fuller disclosure. Another crowd will be pushed out as pariahs or just weary. More sermons on “steadying the ark”. Then it will happen and be hailed as in no way related to these efforts and as coming down from Mount Sinai. That all just sound a little wearying. Let them play with their money in the dark and save us all a lot of trouble.

  25. “If you read the WaPo report you will see that David Nielsen (the one who actually worked at Ensign) did NOT consent to the release of his report”

    Sigh, you don’t get to blame someone else you blabbered to for a reason why you violated your NDA. His brother had no right to know what he was told. In fact, he signed a specific agreement stating he wouldn’t share that info with anyone.

    So let’s be clear. If you work at an investment firm, you don’t get to use, “I told my brother instead of the police/IRS that I believed something illegal was going on”.

    You don’t get to tell someone else and then ask them to help you tell the IRS.

    But what you would likely do, if you’re a liar and looking to embarrass the target and claim deniability afterwards is concoct this dumb story that the person you violated your NDA in talking to, violated your non existence nda between the two of you by talking to someone else.

    At least half the people opining on this are being played like a fiddle.

  26. I imagine the church is not interested in disclosing it’s financials because of ideas expressed in the OP. Why would they want all kinds of people who are not charged with administering the affairs of the church demanding this or that regarding how the church handles the money?

    I am certainly open to being persuaded otherwise, but my current position is that these leaders are accountable to God in how they handle things, including finances. They are not accountable to me, and if I ever felt that way, I could choose to not pay tithes and offerings and donate to organizations that will be transparent to my personal satisfaction. I feel I have been commanded to pay tithing with no strings attached (e.g., I only need to pay it if I feel it’s being managed wisely, etc.).

    I am not saying people shouldn’t wonder or ask questions. I am saying that in discussions such as this there seems to be an assumption that church leaders are clueless about finances, about the serious nature of their stewardship, etc. Or worse, implicitly entertaining the thought that they are corrupt.

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