Should DMBA File as 13F Forms Prior to 2020?

A large proportion of DMBA's 9.23 billion is in mutual funds and ETFs, but are they directly held? Widows might have to look into that as well. None of those assets that DMBA has that they've outsourced requires any 13F filing. And so I don't think this is justification enough to allege that the church was doing anything wrong by itself. What chances are that DMBA barely hit the $100 million threshold for DMBA to be required to file a 13F?"