Middle East Christian Outreach (Australia) Inc: (updated) mini-charity review

Mini charity review of Middle East Christian Outreach (Australia) Inc (MECO) as an organisation seeking donations online. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

Is it responsive to feedback?

  • When sent a draft of this review, they…did not respond.

Is MECO registered?

  • As a charity, yes.
  • Other registrations:
    • MECO is a Victorian incorporated association (A0008890J).
    • The ACNC Register shows that it is operating in all eight states, but it does not have the required ARBN registration to allow it to operate outside Victoria.
    • It also doesn’t have a licence to fundraise in the seven states that have a licensing regime[1].
    • It uses the name MECO Australia, but has not registered it as a business name. (The company of the same name is in administration.)

What do they do?

  • The page for Australia on the MECO International site doesn’t give MECO’s mission, but the mission of the bigger body is to support Middle East Christians in sharing the love of Jesus Christ’.
  • This is how MECO’s Annual Information Statement (AIS) 2015 describes the Australian activities and outcomes:
    • Partner in mission with Middle Eastern churches and communicate, in a variety of ways, the beliefs of the Christian faith. The major activities were to – select and support workers from Australia, – support and care for workers returned from the Middle East, and – publicise and promote the work of the Association throughout Australia.
  • Although they said in the AIS 2015 that they had no intention of ‘changing the way charity (sic) pursues its purposes in the next reporting period’, in March 2016 they announced a merger with SIM International.

Do they share the Gospel?

  • If ‘the beliefs of the Christian faith’ (above) is not only about communicating to church members’, then yes.

What impact are they having?

  • Nothing found.

What do they spend outside the costs directly incurred in delivering the above impact, that is, on administration?

  • If we assume that the expense ‘Ministry Partnership’ is what was ‘directly incurred’ on the mission, then it cost $259K to send $258K.
    • That’s 50% on ‘administration’.

Can you get a tax deduction?

  • No

Is their online giving secure?

  • Given that they use PayPal, yes.

What choices do you have in how your donation is used?

  • Two: ‘’General Funds’ or ‘Specified Support’ – although the page following that may break up ‘Specified Support’.

Is their reporting up-to-date?

  • Yes. (Four and a half months after year end.)

Does their reporting comply with the regulator’s requirements?

  • AIS 2015: No
    • No outcomes reported.
    • ‘Other Income’ is incorrect.
    • No grants reported.
  • Financial Report 2015: Questionable. The ACNC would probably pass it but
    • The directors say that MECO ‘is not a reporting entity’, and therefore doesn’t have to comply with all the Accounting Standards, but they don’t say why. What they are effectively saying is that they have no users, either current or prospective, who rely on MECO’s financial statements. This for an organisation taking $481K in donations, operating in all states and having an invitation to give on the internet.
    • The Notes to the accounts are not a complete set.

What financial situation was shown in that Report?

  • The percentage of surplus to income declined from 10% to negative 4%.
  • They have continued to lend a significant amount, $161K (borrower unspecified), while at the same time continuing to borrow $77K (lender unspecified).

What did the auditor say about the last financial statements?

  • MECO, being a Medium-sized charity, took advantage of the law that allows it to have a review, rather than an audit. Still performed by an independent auditor though. This was the reviewer’s conclusion:
    • Based on our review, which is not an audit, we have no become aware of any matter that makes us believe, that the financial report…does not present a true and fair view, in all material respects… [2]
      • But note that he approved of the directors’ decision to produce the type of financial statements that require less disclosure.

If a charity, is their page on the ACNC Register complete?

  • Almost. ‘Phone’ and ‘Website’ are blank.

Who are the people controlling the organisation?

  • Not mentioned on the website.
  • From ‘Responsible Persons’ on the ACNC Register:
    • Joshua Aylward
    • Annette Cook
    • Richard Coombs
    • Lorelei Edwardes
    • John Haig
    • Peter Thomas

To whom is MECO accountable?

 

  1. The law in this area is not straightforward – is an internet invitation ‘fundraising’ for instance? – and advice varies, so check with the charity before drawing any conclusions.
  2. Even if it had been the stronger engagement, an audit, you would need to take care to take the right amount of comfort from a ‘clean’ opinion like this: see here and here.
  3. For one opinion on the strength of that accountability, see the section Activities in this review.

Melbourne School of Theology: mini charity review for donors

Mini charity review of Melbourne School of Theology (MST) as an organisation that seeks donations online. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

(To see the situation last year, read this review.)

Are they responsive to feedback?

  • When sent a draft of this review, they asked whether MST had requested the review and where it would be published. I answered the same day but 11 days later I have not heard from them again.

Is MST registered?

  • As a charity, yes.
  • Other registrations:
    • As a public company, a company limited by guarantee.
      • It is permitted to omit ‘Ltd/Limited’ at the end of its name.
      • It’s use of ‘MST’ – see, for instance, Facebook – is not registered.
    • Raises funds in its home state, Victoria, but doesn’t hold a fundraising licence there. It solicits donations via the internet, so it may be that one or more of the other six states that have a licensing regime require registration[1].

What does the group do?

  • ‘MST exists to equip God’s people with transformational theology, biblical depth, and a missional heart, to effectively communicate the Gospel of Christ to a diverse and changing world.’

Does the group share the Gospel?

  • To students, undoubtedly. But the grant of tax-deductible status to both charities suggests that the use of the money raised shouldn’t include proselytising.

What impact are they having?

  • Nothing found.

What does the group spend outside the costs directly incurred in delivering the above impact, that is, on administration?

  • The expenses are not classified to allow the calculation of the direct cost of achieving a change in the students.

Can you get a tax deduction?

  • Yes. Both MST and MSTMF are Deductible Gift Recipients.
    • As are MST’s two funds Bible College of Victoria Building Fund and Bible College of Victoria Library.
      • There is, however, nowhere in the online donation form to specify the charity or fund.

Is the group’s online giving secure?

  • PayPal is used, so yes.

Is their reporting up-to-date?

  • Yes (on the last day, six months after their year-end).
    • But if you are considering a large donation, I would ask for more up-to-date financial information – the accounts are for a year end that is now 12 months in the past.

Does their reporting comply with the regulator’s requirements?

  • AIS 2015: No
    • No outcomes, and activity not linked to purposes in question 5.
    • Questions 10 and 11 are unanswered.
    • The first part of question 13 is answered incorrectly.
    • ‘Other income’ in Question 13 is incorrect. (With a consequence that ‘All other revenue’ and ‘Total revenue’ are also incorrect.)
  • Financial Report 2015: No
    • The Report is lodged as a ‘Group Financial Report’ yet is identical to the one lodged for MST. Not a consolidated report?
      • The titles of the financial statements do not support the idea that it is a consolidated report, Note 1 says that the Report is for the ‘individual entity’, and there is no Note giving the figures for the subsidiary.
    • The directors say the company is a ‘not a reporting entity’ because ‘there are no users who are dependent on its general purpose financial reports’.
      • They are in effect saying that anybody who is interested in this company has the power to contact the company and request a report tailored to their needs. This for an organisation with hundreds of students, 38 staff and donations of $1.61 m.
      • The result of the decision is that the accounts don’t comply with all the Australian Accounting Standards, and can disclose considerably less than that required for a general purpose report, a report designed for those people who are dependent on the charity’s report for the information they need.
    • Three of the four financial statements have no prior year figures.
    • No explanation for ‘Investments’ $517K.
    • Don’t student fees have to be repaid under certain circumstances?

What financial situation was shown by that Report?

  • The surplus as a percentage of income was 24%. (No prior year figures so no comparison possible.)
  • No obvious concerns with the financial structure.

What did the auditor say about the group’s last financial statements?

  • He gave a ‘clean’ opinion[2]. But
    • He says he audited a ‘consolidated financial report’ yet none of the statements are consolidated statements.
    • In accepting the engagement, he implicitly agreed with the directors’ decision that there were no users dependent on kind of financial statements that complied with all the Accounting Standards.

If a charity, is their information on the ACNC Register complete?

  • MST: Yes
  • MSTMF: Yes

What choices do you have in how your donation is used?

  • None

Who are the people controlling the group?

  • The people shown on the website here.
  • The same list as under ‘Responsible Persons’ on the ACNC Register, except without Tim Meyers.
  • The same ten people are MSTMF’s responsible persons.

To whom is the group accountable?

  • Not claimed on the website, but MST is a member of Missions Interlink
    • Missions Interlink is an organisation that has standards with which MA must comply[3].
  • Both charities are also accountable to the ACNC.

 

 

  1. The law in this area is not straightforward and advice varies, so check with the charity before drawing any conclusions.
  2. To take the right amount of comfort from a ‘clean opinion’, please read here and here.
  3. For one opinion on the strength of this accountability, see the section Activities in this review.

International Support Aid Australia: mini charity review for donors

Mini charity review of International Support Aid Australia (ISA), as an organisation that seeks donations online. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

(To see the situation last year, read this review.)

Are they responsive to feedback?

When sent a draft of this review, they responded the same day: “Thank you for providing us with your review. I will pass this on to the Chair of our board.” I heard nothing more – but given that this 19 day period includes Christmas-New Year I will amend the review to include his/her comments should I receive them this week.

Is ISA registered?

  • As a charity, yes.
  • Other registrations:
    • As a public company, a company limited by guarantee.
      • It is permitted to omit ‘Ltd/Limited’ at the end of its name.
    • Raises funds in its home state, Victoria, but does have hold a fundraising licence there[1].
    • Business name, Care4Kids Uganda.

What does ISA do?

  • These things, in Jinja, Uganda.

Does ISA share the Gospel?

  • No

What impact are they having?

  • Nothing found.

What does ISA spend outside the costs directly incurred in delivering the above impact, that is, on administration?

  • Although ‘Grants..’ in the AIS 2016 is zero, the Income Statement shows ‘Project expenses’ $86K. If we assume that this was the money sent to Uganda, and define this money as ‘direct’ costs, then it cost them $13K to send $86K.
    • That’s 13% on administration.
    • It would be reasonable to ask them why if would not be more efficient for you to send the money direct to the destination.

Can you get a tax deduction?

  • No

Is ISA online giving secure?

  • Although the ‘Donate’ page says that you can donate by credit card online, there is no page for it. And no other online giving is offered.

Is their reporting up-to-date?

  • Yes (five months after their year-end).
    • But if you are considering a large donation, I would ask for more up-to-date financial information – the accounts are for a year end that is now nine months in the past.

Does their reporting comply with the regulator’s requirements?

  • AIS 2016: No
    • No outcomes are reported.
    • ‘Grants’ have been omitted.
    • ‘Donations’ excludes fundraising income.
  • Financial Report 2016: See below.
    • ISA’s size means that it doesn’t have to lodge a Report with the ACNC.
    • However, it lodged one anyway. This is perhaps because, as a member of Missions Interlink, ISA is required to
      • ‘have available for its members and supporters a clear and appropriate financial statement which has been approved by its auditor [Standards Statement, 4.1].
    • The Report lodged is grossly deficient (again):
      • One of the four required financial statement is missing.
      • There is no Responsible Persons Declaration.
      • There is no audit report. (Was an audit performed?)
      • There is only one Note with any information (and that’s not the all-important Note 1.)
      • The Income Statement is missing a required section.
      • The AIS 2016 says they use the cash basis, but the financial statements are not consistent with this basis.

What financial situation was shown by that Report?

  • The surplus as a percentage of income was decreased from 6% last year to negative 5% this year.
    • The increase in ‘Fundraising’ did not completely compensate for the very large fall in ‘Donations’. (The difference between the two is not explained.)
  • Nowhere is there any information about who received the money sent overseas, nor what controls there were to ensure that it was spent on the intended purpose.
  • There is no explanation for the existence of ‘Payroll expenses’ when there are no employees.
  • There is no explanation for how an office is run without any property, plant and equipment.
  • There is no explanation for how (significant) income is derived from ‘Administration’.
  • No obvious concerns with the financial structure (but see the comments under ‘Financial Report 2016’, above).

What did the auditor say about ISA’s last financial statements?

  • NA. (No audit report.)

If a charity, is their information on the ACNC Register complete?

  • Yes

What choices do you have in how your donation is used?

  • NA. (No online giving offered.)

Who are the people controlling ISA?

  • The people shown here.
  • Or with the addition of Richard Dickens, per the listing under ‘Responsible Persons’ on the ACNC Register?

To whom is ISA accountable?

  • Not claimed on the website, but ISA is a member of Missions Interlink.
    • Missions Interlink is an organisation that has standards[2] with which ISA must comply.
  • ISA is also accountable to the ACNC.

 

 

  1. The law in this area is not straightforward and advice varies, so check with the charity before drawing any conclusions.
  2. For one opinion on the strength of this accountability, see the section Activities in this review.

Hope India Mission Australia Inc.: mini charity review for donors

Mini charity review of Hope India Mission Australia Inc. (HI), as an organisation that is a member of the Australian missions umbrella organisation Mission Interlink. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

(To see the situation last year, read this review.)

Are they responsive to feedback?

  • When sent a draft of this review, they…did not respond.

Is HI registered?

  • As a charity, yes.
    • The website says that HI ‘is registered with the government of India and is governed by an executive committee in India.’
      • A return submitted to the Indian government shows an organisation called Hope India Mission and Institute receiving money from the Chairman of HI in the year ended 31 March 2015.
  • Other registrations:
    • As a WA incorporated association (A1003253C).
    • HI only operates, as least per the ACNC Register, in WA. (An ARBN registration is therefore not necessary.)
    • It does not have a fundraising licence in WA[1].
    • It has no business names, therefore must use only its full name. (Not HIM Australia Inc and HIM, for instance.)
    • Not registered for GST. (It’s turnover is below the amount when it becomes compulsory.)

What does HI do?

  • From the AIS 2015 (nothing on the website):
    • We partner with an organisation in Bangalore India called Hope India Mission that we partly fund to help them carry out the activities outlined in the previous answers’:
      • Economic, social and community development; emergency and relief, employment and training, grant-making activities, housing activities, income support and maintenance, international activities, primary and secondary education, social services.

Does HI share the Gospel?

  • No

What impact are they having?

  • Nothing found.

What does HI spend outside the costs directly incurred in delivering the above impact, that is, on administration?

  • If we define ‘direct’ as the money sent overseas, it cost them $12K to send $28K 205K.
    • That’s 30% on administration.
    • It would be reasonable to ask them why if would not be more efficient for you to send the money direct to the destination.
      • Just as the Australian Churches of Christ in Perth did in the year ended 31 March 2016.

Can you get a tax deduction?

  • No

Is HI online giving secure?

  • No online giving offered.

Is their reporting up-to-date?

  • Yes (19 days after their year-end).

Does their reporting comply with the regulator’s requirements?

  • AIS 2015: Except for the omission of outcomes, yes.
  • Financial Report 2015:
    • NA. None required (charity size), and none offered.
    • Although none are required by their constitution, the website says that “The accounts are audited annually by an independent accountant.”
    • As a member of Missions Interlink, HI is required to
      • ‘have available for its members and supporters a clear and appropriate financial statement which has been approved by its auditor [Standards Statement, 4.1].

What financial situation was shown by that Report?

  • NA
    • The ‘Financial Information’ section of the AIS 2015 shows:
      • Cash accounting is used.
        • This possibly explains the lack of balance sheet figures.
      • Receipts were $43K, which explains why HI is not registered for GST.
      • Donations was the only source of receipts.
      • The two expenses other than the money sent overseas (70% of expenses), were ‘Employee expenses/payments’ $4K and ‘Other expenses/payments’ $8K.

What did the auditor say about HI’s last financial statements?

  • NA. (See above).

If a charity, is their information on the ACNC Register complete?

  • No. ‘Phone’ and ‘Website’ are blank, and HI has yet to select a charity subtype (at least that’s what the Register says).

What choices do you have in how your donation is used?

  • No information available.

Who are the people controlling HI?

  • Not shown on the website, but see under ‘Responsible Persons’ on the ACNC Register.

To whom is HI accountable?

  • Not claimed on the website, but HI is a member of Missions Interlink.
    • Missions Interlink is an organisation that has standards[2] with which HI must comply.
  • HI is also accountable to the ACNC.

 

 

  1. The law in this area is not straightforward and advice varies, so check with the charity before drawing any conclusions.
  2. For one opinion on the strength of this accountability, see the section Activities in this review.

Anglican Board of Mission – Australia Limited: mini charity review for donors

Mini charity review of Anglican Board of Mission – Australia Limited (ABM) as an organisation that seeks donations online. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

(To see the situation last year, read this review.)

Are they responsive to feedback?

  • In response to a draft of this review, the Executive Officer, Edwin Porter, sent his comments. After I replied he chose to respond to only one comment. He then authorised the publication of his reactions plus the following general comment:
    • ‘In a robust democracy it is good for organisations to be challenged and we welcome Ted Sherwood and others asking questions about what we do. In this review I would say that in a number of places Ted’s opinions differ from ours, as might be expected, and I leave it to the reader to come to their own conclusions or contact us directly. One point in particular I must mention is that Ted’s Table of Directorships is not an accurate reflection of the facts and I have expressed my disappointment to him at its inclusion. Thank you.’

Is ABM registered?

  • As a charity, yes.
    • Not to be confused with the two charities with the name ‘Anglican Board of Mission’ but with the addition of ‘Auxiliary’ +. (See here, and here.)
    • Note 14 in the Annual Report says that ABM controls three other entities (and whose figures are included in the Financial Report 2016):
      • Anglican Board of Mission Australia Aboriginal Missions Special Purpose Trust Fund. This is an unincorporated entity that has not registered as a charity;
      • The Anglican Trust Fund for Development. This is a trading name of ABM, not a separate organisation;
        • Ministry response: The Executive Officer deleted ‘trading name of ABM’ and added ‘(a)n Overseas Aid Fund’.
          • Reviewer comment: ABM’s ABN record shows it as a trading name, and as recorded here.
      • ABM Benevolent Fund, a charity.
    • ABM has not taken advantage of the ACNC’s group reporting concessions. This means that each charity must submit an Annual Information Statement (AIS) and a Financial Report.
  • Other registrations:
    • As a public company (097 944 717), a company limited by guarantee
      • The constitution appears to contain the provisions necessary to allow ABM to omit ‘Ltd/Limited’ at the end of its name.
      • It has two members, the Anglican Church of Australia and the Primate of that Church, without the possibility of any change to this membership (see Charity’s Document, below).
    • Neither of the other two names it uses, ABM and Anglican Board of Mission, are registered as business names.
    • ABM operates throughout Australia and has a request for donations on the internet. It doesn’t have a fundraising licence in any of the seven states that have a licensing regime. In one or more of these states this may be because it believes that it is exempt due to it being an arm of the Anglican Church of Australia[1].

What does ABM do?

  • See ‘Our Programs’ half way down here.
  • How this translates into countries is shown here.

Does ABM share the Gospel?

  • No
    • Ministry response: In two parts:
      • 1. He substituted ‘Yes’ and said that ‘There is always a debate about what it means to share the gospel.’
        • Reviewer comment:
          • I don’t think there’s much debate that ‘share the Gospel’ is referring to words not deeds.  See the first page of results from Googling ‘What does “share the Gospel” mean?’  There it is most often words, sometimes words plus deeds.
      • 2. ‘ABM takes its mandate from the New Testament, in particular Luke 4 18:19. This is well established in the Anglican Communion’s Marks of Mission and reflected in our programs. (see https://www.abmission.org/pages/-abms-five-marks-of-mission-56.html) In implementing this, ABM partners with Churches in many countries as we believe that the local church is best placed to reach local people with the gospel and so works to strengthen local churches, especially through strengthening local leadership. As John Deane says in the annual report;

ABM’s Church to Church program has also enhanced its support for the work of partners in the Pacific, South East Asia and Africa. Included in the activities are a number which focus on the nurture and spiritual development of children and leadership training for both clergy and lay. These types of programs are often very difficult for ABM’s Partners to fund but vitally necessary for growing churches. The Good Friday Gift remains well supported and health related activities have been a significant focus of the recent grants from this annual collection.

The Reconciliation Action Plan (RAP) to which ABM has committed itself continues to inform and guide much of the work with Aboriginal and Torres Strait Islander peoples. This

includes support for specific activities focused on the training of indigenous leaders and assisting the work of the National Aboriginal and Torres Strait Islander Anglican Council.

There is also encouragement and mentoring provided for dioceses and parishes as they seek to implement their own RAPs

Reviewer response: This appears to be ABM helping churches help their people be in a better position to share the Gospel, not ABM itself sharing the Gospel.

What impact are they having?

  • Here is the report on the evaluations of program effectiveness performed in 2016. I’ll let you be the judge as to how well they answer the question of impact as defined by the ACNC.
  • Same with the achievements described in the Annual Report 2015-2016.

What does ABM spend outside the costs directly incurred in delivering the above impact, that is, on administration?

  • If we define ‘Funds to programs’ as the expenses ‘directly incurred…’, ABM incurred $2.82 m to invest $3.01 in beneficiaries.
    • This is ‘administration’ of 48%.
  • Ministry response: In two parts:
    • 1. ‘This analysis is incorrect by a wide margin.’
      • Reviewer comment: I have been careful to give the assumptions behind the calculation; change the assumptions, and the result will change.
    • 2. ‘If you wish to focus on programs and calculate percentages then you need the context of the development focussed ACFID format annual report from the website. (http://www.youblisher.com/p/1646288-2015-16-ABM-Annual-Report/)   Attempting to use consolidated total corporate data from the statutory accounts and not the development specific data available in the annual report will prove meaningless for that purpose. ABM is much more than just a community development organisation and works with the Indigenous Australian community, the Anglican Church communion, undertakes advocacy on relevant issues, community education, and more. I won’t include the full text here but see page 10 of the annual report as an expanded answer. I also need to point out that it is an error to include Program Support costs and Community Education as “Administration” when they are certainly not of that nature.’
      • Reviewer comment:
        • The analysis is based on the information ABM provide and the explanation of ‘administration’ given by the ACNC; ABM don’t reference the ACFID format so it is not reasonable to expect a reader to go there instead of interpret what has been presented to the ACNC.

Can you get a tax deduction?

  • The ABN record says yes.

Is ABM’s online giving secure?

  • Industry standard encryption is used, so yes.

Is their reporting up-to-date?

  • Yes (three months after their year-end – and two and a half months earlier than last year).
    • But if you are considering a large donation, I would ask for more up-to-date financial information – the accounts are for a year end that is now six months in the past.

Does their reporting comply with the regulator’s requirements?

  • AIS 2016: No
    • Ministry comment:
      • ‘Not sure how you can come to this conclusion. The ACNC would certainly advise us if we were not compliant.’
        • Reviewer response:
          • I came to this conclusion by comparing the AIS with the requirements for an AIS; the ACNC’s processes do not support the assertion that silence by the ACNC means compliance. Itconducts proportionate, risk-based monitoring of annual financial reports and Annual Information Statements as part of our compliance program.’
    • The ‘Financial Information’ is for the group, not ABM.
    • No outcomes are reported.
      • Ministry response: ‘There is a whole paragraph in the AIS of general outcomes listed and there are pages of specific outcomes in the detailed annual report.’
        • Reply sent by reviewer:
          • ABM report their purposes, not results. And the Annual Report is not included in the AIS 2016.
    • The business name is missing.
  • Financial Report 2016: Yes
    • No information on the three subsidiaries, other than their name, is disclosed.
    • ‘Employee benefits expenses’ is not disclosed.
      • From the AIS 2015 we know that it is $1.72 m.
        • If part-time is 50% and casual 10% of full-time, this total represents average annual benefits of $93K.

What financial situation was shown by that Report?

  • The surplus as a percentage of income decreased from 1% negative to 23% negative.
  • ABN holds $9.70 m of investments not expected to be sold within the next 12 months. There is no explanation for how this fits with the mission. (There are no restricted reserves.)
    • Ministry comment:
      • ‘Approx. half, or $4.6m of ABM reserves are restricted.
      • Why are reserves crucial? Reserves allow programs to be funded to fair and equitable completion should donations vary or cease for some reason. This prevents a sudden and potentially harmful cessation of program. General reserves allow investment income to offset operating costs and allow for new initiatives.’
        • Reviewer response:
          • There are no restricted reserves disclosed in the financial statements; the explanation for the level of reserves should be in the financial statements (as the ACNC has recently recommended).
  • ‘Funds to programs’ is 52% of expenses, but there is no explanation of to whom this money was sent and for what purpose.
    • Ministry comment: ‘There is a lengthy discussion of Programs and Projects in the annual report.’
      • Reviewer response: The Annual Report is neither lodged on the ACNC Register nor referenced in the financial statements.

What did the auditor say about ABM’s last financial statements?

  • He gave a ‘clean’ opinion[2].

If a charity, is their information on the ACNC Register complete?

  • Apart from a missing business name, Anglicans in Development, yes.

What choices do you have in how your donation is used?

  • An extensive range. See the list next to ‘Projects’ here.

Who are the people controlling ABM?

  • The people shown on the website here.
  • The same list as under ‘Responsible Persons’ on the ACNC Register.
  • To see all charity director positions in a particular name in Australia, search here.

Because of the possibility of two (or more) directors having the same name on the register of responsible persons, it is not possible to be definitive about the number of directorships held.

No. of charity directorships

    • Colin Bannerman 3
    • David Battrick 4
    • John Deane 3
    • Martin Drevikovsky 3
    • Claire Duffy 2
    • Stephen Harrison 6
    • Sarah MacNeil 10
    • Ian Morgan 2
    • Emma Riggs 4
    • John Roundhill 2
    • Debra Saffrey-Collins 2
    • Gregory Thompson 12
    • Garry Weatherill 3
    • Danielle Wuttke 2
  • You may reasonably question how somebody can, especially if directorship is not their full-time occupation, successfully discharge their fiduciary responsibilities to more than a handful (?) of organisations. (And the ACNC Register only includes charities; the inclusion other not-for-profits and for-profit organisations may of course increase the above numbers.)
    • Ministry comment:
      • Ted, I am really surprised to see your table (above) again this year as you know that much of the information presented is incorrect as I have previously informed you. It is a misuse of the ACNC data to enter a name into the ACNC database and then jump to the claim that all the organisations listed are related to one person, which is often nonsense. There are usually many people with the same name. When you look these names up on the ACNC to prepare your table you can see that often they are with obviously incompatible organisations and locations and yet you still include this table and then make disparaging comments about their ability to “successfully discharge fiduciary responsibilities”. If you are going to post data and make comments in the public domain then honesty is paramount and you have a very clear responsibility to ensure that you are not knowingly inaccurate, as such action could have negative implications for the people involved. The tiny footnote reference you include does nothing to offset the impression the table creates. [Editor: footnote elevated to the body] I informed you clearly last year that many of the ABM Directors listed here DO NOT have the number of personal Directorships that you list. The table is inaccurate and should not be part of your analysis.’
        • Reviewer comment:
          • The information merely reports the result of a search that the ACNC invites anybody to do.
          • I have made it clear that the ACNC search is on a name that is in the Register, and that because of the possibility of two or more directors having the same name on the Register, that it is not possible to be definitive about the number of directorships that, in this case, ABM directors have.
            • The ACNC gives no such warning.
          • I will leave it to the reader to judge what are ‘obviously incompatible organisations’ in the list produced from the ACNC search.
          • ABM, and all other charities, can easily change the name that is recorded on the Register to increase the chances that it will be unique.
          • Given the importance of the board to how a charity conducts itself, donors are entitled to question whether one of more of the charity’s directors might be overstretched.

To whom is ABM accountable?

  • The Australian Council for International Development (ACFID). This is because it is a member, claimed in the website footer. Confirmed.
  • ABM is accountable to the ACNC.

 

 

  1. The law in this area is not straightforward and advice varies, so check with the charity before drawing any conclusions.
  2. To take the right amount of comfort from a ‘clean opinion’, please read here and here.

Asia Evangelistic Fellowship International Inc.: mini charity review for donors

Mini charity review of Asia Evangelistic Fellowship International Inc. (AEFI), as an organisation that seeks donations online. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

(To see the situation last year, read this review.)

Are they responsive to feedback?

  • When sent a draft of this review, they…XXXX.

Is AEFI registered?

  • As a charity, yes.
  • Other registrations:
    • As a WA incorporated association (A1007002D).
    • Apart from its office in WA, AEFI operates, at least per the ACNC Register, in NSW and Victoria. AEFI also has an invitation to give on the internet.
      • It does not have the registration necessary, an ARBN, to operate interstate.
      • It does not have a fundraising licence in any of the seven states that have a licensing regime[1].
    • Business name, AEF International.

What does AEFI do?

  • The website says that they do evangelism, community development and ‘media ministries’.
    • There aresome 150 national missionaries in 9 Asian countries’.
    • And training schools – Asia College of Ministry (ACOM) – in four of those countries.
    • Plus, Destiny Radio.
    • But the website doesn’t make it clear to what extent it is AEFI that does this work as opposed to local AEFI organisations – or partners.
  • The AIS 2016 says that AEFI simply raises money:
    • Funding support to aid evangelism, church planting, medical assistance, schooling, orphanages, training programs.
  • The Profit & Loss Statement supports the AIS 2016 view.
  • The resolution is mostly likely in the fact that AEFI is both, without distinction in its public material,
    • the coordinating body for ‘the autonomous chartered national organisations and donor bases known as Asia Evangelistic Fellowship and other organsations started by/or affiliated with AEFI’ [the constitution, paragraph 6],
    • and the Australian Asia Evangelistic Fellowship body.
  • Ministry comment:
    • ‘The work that is carried out in the ten Asian countries is done by the people living in those countries. AEFI’s mission has always been to train Asians to reach Asian through evangelism, church planting, community development, establishing primary and secondary schools to provide education for marginalised children, and orphanages for homeless children. AEFI’s role is to set and implement the vision, identify key local leadership, establish local boards, raise the funds from our donor bases to support these projects as well as send trainers periodically  from Australia, Singapore, USA and other countries to provide the training and leadership in the various activities that are undertaken to enable these local AEF field bases to provide cost-effective outcomes.’

Does AEFI share the Gospel?

  • Yes.

What impact are they having?

  • Nothing systematic found. Some anecdotal evidence under ‘News And Events’.
  • Ministry comment:
    • ‘Typically our Annual Reports contain information about the impact of our ministry and these are made available to donors.’

What does AEFI spend outside the costs directly incurred in delivering the above impact, that is, on administration?

  • If we define ‘direct’ as the money sent overseas, it cost them $101K to send $205K.
    • That’s 33% on administration.
      • 21% of this administration ($21K) was for ‘Travel & accommodation’.
    • It would be reasonable to ask them why if would not be more efficient for you to send the money direct to the destination.
  • Ministry comment:
    • ‘AEFI gives all donors the choice of where they would like their donations to go to, some only want to give to our schools and orphanages, some want to support a worker and his family, others only want to give for training new pastors, etc. Our website states that 90% of all designated funds go to the work in our fields, in fact it is higher that 90%, the balance (less than 10%) is used to meet administrative costs of ensuring the most effective use of the donations. 

Some people are happy for AEFI to use the money wherever it is most needed, this is called the general fund. The general fund is mainly used to meet the administrative expenses of running the organisation including the salary of the office administrator which is less that $15,000 per year.Our International Director’s role includes undertaking regular visits to all 10 countries and three donor bases (this amount includes the travel costs for our Training Coordinator as well who trains our local trainers at 4 Bible colleges). Therefore, the amount is most reasonable considering the number of countries our two directors have to visit. They only travel by economy class and where possible, stay in people’s homes,  AEF properties or low budget hotels. Our International Director’s role is extensive and it is because of his regular monitoring of local leadership and projects that donors have over the years, developed confidence in AEF’s ministries.Now, our International Director’s salary is met entirely by individuals who want to support him and his family (this is clearly reflected in the financial statement as Personal support under income). Therefore, individuals and churches have elected to donate to him through AEF International because they believe in the work that is being undertaken and they know that without his role, the work in Asia would be seriously jeopardised.

Every donor to AEF International knows it is not a charity for tax deductible purposes and so it is essential that we are very good stewards of the donations that are received, I hope the above explanation shows that we are achieving this end.’

Can you get a tax deduction?

  • No

Is AEFI online giving secure?

  • Nothing said about security on the first page.
    • PayPal is one of the options, so is you use this then, yes, giving will be secure.
  • Ministry comment:
    • ‘We will check this with the website manager and put a statement there confirming that this is the case.’

Is their reporting up-to-date?

  • Yes (six months after their year-end).
    • But if you are considering a large donation, I would ask for more up-to-date financial information – the accounts are for a year end that is now six months in the past.
  • Ministry comment:
    • ‘Up to date financial information is always available to prospective donors who require it.’

Does their reporting comply with the regulator’s requirements?

  • AIS 2016: Except for the omission of outcomes, yes.
  • Financial Report 2016: No – totally inadequate. Still.
    • It is well short of what’s required by (a) AEFI’s own requirements (the constitution), (b) Mission Interlink’s standards (it is a member), and (c) the ACNC’s standards.
    • More is missing than is included:
      • Two of the four required financial statements.
      • No Responsible Persons Declaration.
      • No Notes
    • The two statements that are included do not comply with the Accounting Standards – or, in some cases, basic accounting.
      • Including no prior year figures.
    • The auditor, Ernest Painter, has produced an audit report that has almost nothing in common with the contents of one prepared per the Australian Auditing Standards.
  • Ministry comment:
    • ‘In 2017 AEFI will be reviewing its governance including a revision of its current constitution, as well ensuring that its financial reporting meets the requirements of all regulators.’

What financial situation was shown by that Report?

  • The surplus as a percentage of income was 5%. (No prior year figures for comparison.)
  • Nowhere is there any information about who received the money sent overseas, nor what controls there were to ensure that it was spent on the intended purpose.
  • ‘Employment Expenses’ are 55% of the total.
  • 15 months’ worth of income is held in cash and short-term investments.
  • No obvious concerns with the financial structure – but see the comments under ‘Financial Report 2016’, above.

What did the auditor say about AEFI’s last financial statements?

  • He said that ‘In our view the attached Financial Statements namely Balance Sheet & Profit & Loss Statement may be relied upon by the members.’ However, the fact that his audit report deviates so far from what is required by the Auditing Standards means that you would be entitled to put far less confidence in that opinion than you would normally.

If a charity, is their information on the ACNC Register complete?

  • Yes
    • But a PO Box number is not a ‘Street Address’. It’s not on the website either.

What choices do you have in how your donation is used?

  • “General’
  • ‘AEFI Futures Fund’
  • ‘Nepal Earthquake Appeal’
  • ‘Solid Rock Cambodia Hospital’
  • ‘Support the General work of AEFI’ – duplicating the first choice
  • ‘Support a Missionary Trainee’
  • ‘Support a Child
  • ‘Support a Community Project’
  • ‘Support a National Worker’
  • There is a brief description of these, except for ‘Support a Community Project’, elsewhere on the website (either here or the main menu item ‘Support Us’).

Who are the people controlling AEFI?

  • Per the listing under ‘Responsible Persons’ on the ACNC Register:
    • Gilbert Cann
    • Lindsay Casey
    • Raymond Dallin
    • Keith Ireland
    • Jonathan James
    • William Wasserman
    • Kevin Watts
    • Lorraine Wylie
  • Only Raymond Dallin is in the listing on the website.
    • Jonathan James is there too, but as the ‘International Director’, not as a board member.
    • The third person there is the ‘President’, but of what he is the president is not specified.
  • The governance required by the constitution is more complicated:
    • An International Council, a Board of Directors and an International Director shall govern the Corporation.’
      • Their membership of the International Council is not disclosed.
    • Although the members of AEFI are ‘the autonomous chartered national organisations and donor bases known as Asia Evangelistic Fellowship and other organisations…’, it is the International Council that appoints both the Board of Directors and the International Director.
      • Shouldn’t, therefore, the responsible persons on the ACNC Register be the members of the Council?
  • Ministry comment:
    • ‘All the people listed as responsible persons are board members. The President is the President and board member of AEFI. This is clearly established in the constitution. He has a non-executive role and was chosen because of his standing in the Christian community. He represents AEFI in all official functions and is also our key promoter and  deputationist. He is also part of the international leadership team and a member of the international board.
      The constitution is being reviewed in 2017 to ensure it meets our current needs and those of the regulatory bodies’

To whom is AEFI accountable?

  • Not claimed on the website, but AEFI is a member of Missions Interlink.
    • Missions Interlink is an organisation that has standards[2] with which AEFI must comply.
  • AEFI is also accountable to the ACNC.
  • Ministry comment:
    • ‘We are happy to state on our website that we are a member of Missions Interlink and also accountable to ACNC. We are accountable to our donors and we give them up to date ( monthly, quarterly and annual reports) as to the impact of our ministry  and  where their money goes.’

 

 

  1. The law in this area is not straightforward and advice varies, so check with the charity before drawing any conclusions.
  2. For one opinion on the strength of this accountability, see the section Activities in this review.

Africa Inland Mission International Australia Inc: mini charity review for donors

Mini charity review of Africa Inland Mission International Australia Inc (AIM), as an organisation that seeks donations online. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

(To see the situation last year, read this review.)

Are they responsive to feedback?

  • When sent a draft of this review, they…did not respond.

Is AIM registered?

  • As a charity, yes.
  • Other registrations:
    • As a NSW incorporated association (Y1658604).
    • AIM operates in all states. It also has an invitation to give on the internet. Plus advertises for bequests on My Bequest.
      • It does not have the registration necessary, an ARBN, to operate interstate.
      • It has a fundraising licence only in NSW. Six other states have a licensing regime[1].
    • The group uses the names Africa Inland Mission, AIM, AIM Australia, and Africa Inland Mission International – Asia-Pacific (FaceBook) in its internet presence.
      • None of these names are business names; AIM cannot therefore legally trade under any other name than its legal name.
      • At least some of this use would appear to contravene section 41(1) of its enabling legislation (the Associations Incorporation Act 2009), a section that requires the full name to be used on ‘any letter, statement, invoice, notice, publication, order for goods or services or receipt’.

What does AIM do?

  • Generally: ‘Africa Inland Mission (AIM) is a Christian mission sending agency with a heart for Africa’s peoples.’
  • More specifically, from the AIS 2016:
    • This charity mobilises people from Australia and the Asia-Pacific to ministry in Africa or our mobilising countries including Australia. Our priority is taking the good news of Jesus Christ to African people groups who have not yet heard or been reached with this message. In 2016 20 f/t workers were serving in Africa.
  • Three ministry areas.

Does AIM share the Gospel?

  • Yes.

What impact are they having?

  • Nothing systematic found. Some anecdotal evidence in the Feb-May 16 Africa News[2].

What does AIM spend outside the costs directly incurred in delivering the above impact, that is, on administration?

  • The expenses are not classified to allow a calculation of the costs of sharing the gospel, however that cost objective is defined.
    • In fact, the Income Statement does not appear to include any of the costs of employing the twenty missionaries that are working for AIM.

Can you get a tax deduction?

  • No

Is AIM online giving secure?

  • PayPal is used, so yes.

Is their reporting up-to-date?

  • Yes (three months after their year-end).
    • But if you are considering a large donation, I would ask for more up-to-date financial information – the accounts are for a year end that is now six months in the past.

Does their reporting comply with the regulator’s requirements?

  • AIS 2015: Yes
    • The absence of any expense for grants, although supported by the Financial Report, is inconsistent with their collection of money for projects.
  • Financial Report 2015: No – again
    • The Report is missing one of the four required financial statements.
    • The directors do not say why they have chosen to produce the lower-standard special purpose financial statements.
      • Their decision implies that AIM has no users, past or prospective, who are dependent on normal financial statements to make decisions about AIM. This is for an organisation that operates in all states and has 28 staff.
    • The auditor, Lawrence Green of Shedden & Green Partners, continues to produce a report that materially deviates from what is required by the Australian Auditing Standards.
    • Balance Sheet
      • Loans are misclassified. (And are therefore omitted from the AIS 2016).
      • There is no explanation why, with 28 employees, there are no ‘Employee Entitlement Provisions’.
      • ‘Investments’ do not use the classification required by the applicable Accounting Standard.
    • Income Statement
      • Donations are sought for 20 missionaries (or perhaps 28 staff) and multiple projects, and ‘Project – Balances owing’ total $590K, yet donations are only $40-42K pa.
        • This $590K includes $208K ‘resettlement amounts set aside’
      • The second largest income item, ‘Home Administration’ $63K, is unexplained.
      • Interest was paid yet there are no interest-bearing borrowings in the balance sheet.
      • Some of the terminology is incorrect.
    • Statement of Cashflows
      • All bar one of the items under ‘Cashfows in Investing Activities’ should be in one of the other two sections.
      • Two different figures are given for ‘Net cash provided by operating activities’.
    • Notes to and Forming Part of the Accounts
      • The NZ charity with a similar name that shares a website with AIM, and has two of the Australian directors on its board, is not mentioned.
        • Does AIM control this charity?
      • The ‘Related Parties’ Note does not mention the Asia-Pacific and Australia Council.
      • Note 11 says that funds are regularly remitted ‘to the field’, yet there is no obvious item for this in the expenses.
      • Many of the Notes normally included are absent.
    • The Declaration by Responsible Persons is undated.

What financial situation was shown by that Report?

  • The surplus as a percentage of income was decreased from 12% to 11% – still relatively high.
    • ‘Donations’ are only 18% of income.
      • Short Term Coordinator/Payroll Expenses’ (therefore) exceeded Donations by $7K.
      • Then another $55K was incurred for the unexplained item ‘Ministry’.
    • The second and third largest expenses are the unspecified ‘Home Office costs’ and (Ministry) ‘Other Costs’.
    • AIM, a charity with an income of $219K, owns two properties. (Or is income understated? See ‘Financial Report 2015’, above.)
  • No obvious concerns with the financial structure – but see the comments under ‘Financial Report 2015’, above.

What did the auditor say about AIM’s last financial statements?

  • He gave a ‘clean’ opinion[3]. However, confidence in the opinion is reduced by
    • His presentation of a report that does not comply with the Australian Auditing Standards.
    • His implicit acceptance of the directors’ decision to produce financial statements that don’t have to comply with all the Accounting Standards.
    • His acceptance of
      • the omission of one of the four required financial statements, and
      • multiple misclassifications in another of the statements.

If a charity, is their information on the ACNC Register complete?

  • No
    • The ACNC says, under ‘Entity Subtype’, Charity to select subtype.
    • ‘Phone’ and ‘Website’ are blank.
    • ‘Date Established’ is blank.

What choices do you have in how your donation is used?

  • The page says ‘General Donations’, ‘Worker Support’, and ‘Project Sponsorship’, but then the donation form only has the latter two.
    • Care: the form is for donations to the New Zealand charity too.
  • There is no list of either workers or projects from which to select, nor are they listed on the website.
    • It appears that anything can be written in the boxes for the name of the worker and the project name, and it will be accepted.

Who are the people controlling AIM?

  • Not shown on the website.
  • Those under ‘Responsible Persons’ on the ACNC Register.
    • John Harris and Leonard Lesleighter are also on the board of the NZ charity.
  • The AIM board is still two short of the number required by its constitution.

To whom is AIM accountable?

  • Membership of Missions Interlink is claimed by Africa Inland Mission Asia-Pacific Region in their newsletter (Africa News).
    • There is a membership in the name Africa Inland Mission International (the global organisation, but which leads to AIM’s website.
      • Missions Interlink is an organisation that has standards[4] with which AIM must comply.
  • AIM is also accountable to the ACNC.

 

 

  1. The law in this area is not straightforward and advice varies, so check with the charity before drawing any conclusions.
  2. Although said to be published three times a year, this is the latest issue.
  3. To take the right amount of comfort from a ‘clean opinion’, please read here and here.
  4. For one opinion on the strength of this accountability, see the section Activities in this review.

Mukti Australia Inc.: mini charity review for donors

Mini charity review of Mukti Australia (MA), as an organisation that seeks donations online. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

(To see the situation last year, read this review.)

Are they responsive to feedback?

  • A draft of this review was sent to MA. This prompted a discussion by email that resulted in a couple of changes and the MA comments you see below[1].

Is MA registered?

  • As a charity, yes.
  • Other registrations:
    • MA: As a Victorian incorporated association (VIC A0040914J).
    • MA: As an Australian Registered Body (ARBN 613 315 576), allowing it to trade interstate.
    • MAOAF is a discretionary investment trust[2].
    • The group has staff in Victoria and Western Australia. And other ‘area representatives’ in NSW, Queensland, Tasmania, and South Australia [Annual Report, pages 6,10]. Plus the internet invitation to give (see above).
    • The group uses the names Mukti Australia and Mukti. Neither are registered business names. Apart from the business names legislation, this would appear to contravene section 23 of its enabling legislation (the Associations Incorporation Reform Act 2012), a section that requires the full name to be used ‘in all is notices, advertisements and other official publications’.

What does the group do?

  • Not directly involved in aid and development in India as group material often suggests (for instance page 20 here and ‘Projects’ here), but supporting, primarily with money, overseas work.
    • Ministry comment:
      • ‘Yes – primarily financial support, but also hands on support through volunteers, consultants and Mukti employees who visit India during the year.  We consider this direct involvement.  We also consider assisting with the design, implementation, completion and evaluation of projects direct involvement in aid and development.   As you mention below, we pray, fund, capacity build and serve.  Most of those things don’t directly show in our financial statements. ‘
    • The AIS 2015 describes MA as a funder and supporter of work by an Indian organisation:
      • We partnered with Australians to fund and support the work and objectives of Pandita Ramabai Mukti Mission in India. Specifically, we funded development projects including…
    • And more specifically, under the ’Our Story’ tab:
      • Prayer – We pray for the work of our partners in India and Sri Lanka
      • Funding – We provide funding for development initiatives in India and Sri Lanka
      • Capacity Building – We support our partner staff in India and Sri Lanka
      • Serving – We send Australian volunteers and consultants to serve our partners in India and Sri Lanka with their time and expertise.

Does the group share the Gospel?

  • The grant of tax-deductible status by the Government suggests that the use of the money raised shouldn’t include proselytising.
  • The constitution requires MA to ‘provide aid and relief in a holistic manner’. Although many would argue that for a Christian organisation to minister holistically it would need to share the Gospel in word as well as deed, many others see no problem in excluding the spiritual component.
    • Ministry comment:
      • MA is motivated by the love of God.  We consider acts of service, love and compassion to be ways of expressing this. MA gifts are given in accordance with Australia law and therefore do not directly fund evangelism or church projects but they are administered in India in a Christian context and Australian authorities recognise this. (b) MA’s overseas partner maintains a clear Christian witness and abides by applicable Indian law.’
  • The ‘Who we are’ on the group website restricts the development activity to deeds.
    • The Indian recipient of the Australian dollars is Christian with a mission to provide “Christ centered homes where destitute women and children irrespective of their background are accepted, cared for, transformed, and empowered to be salt and light in the society.”
      • Ministry comment:
        • Our in-country partners operate as Christian organisations and carry out their work in accordance with the laws of their respective countries.  Australian tax deductible dollars are used exclusively to fund development projects consistent with our purpose to provide aid and relief to needy persons.   

What impact are they having?

  • Whether we define the mission as what the group does or what the aid and development work its partners overseas are doing, nothing systematic was found.
    • Ministry comment:
      • Our 2015 AIS indicates that we have:

partnered with Australians to fund and support the work and objectives of Pandita Ramabai Mukti Mission in India. Specifically, we funded development projects including:

– supported the holistic care of vulnerable children and women through a sponsorship program

– renovation of a home for intellectually disabled and mentally ill women

– Education Centre for children of red light district workers

– construction of a second storey in a Junior College (Years 11-12)

– construction of a high school kitchen

– supported a Creative Arts School which teachers (sic) vulnerable young women vocational skills such as sewing and jewellery making

– renovation of a kitchen for a community of blind women

– beautification of the outside are of a home for vulnerable and elderly women

– renovation of a roof of a nursery which cares for abandoned babies

– supported the staff of Pandita Ramabai Mukti Mission with funds and capacity building initiatives

– other small projects such as recreation and musical equipment for vulnerable women and children’

The lives of needy persons in India have been improved as a result of our work.  We believe this to be evidence of having an impact.

  • The Annual Report (page 19) says that ‘In 2015, Mukti fed, clothed, housed, cared for, educated and empowered over 1200 disadvantaged women and children.” The Indian partner did this, not the group – it is not uncommon for the group to mix the two organisations.
    • Ministry comment:
      • Mukti Australia provided resources (including volunteers, expertise and project management support) to help feed, clothe, house, care for, educate and empower over 1200 disadvantaged women and children.  We work closely with our Indian partner towards a common goal.  Our Indian partner does not have the internal resources to do this on its own.  The difference in so many lives would not have been possible if we had not committed our resources too.   We did this together.’  

What does the group spend outside the costs directly incurred in delivering the above impact, that is, on administration?

  • MA do not specify the impact (see above) they are seeking, so it is difficult to be definitive about what are direct costs as opposed to the costs of administration.
  • The group incurred expenses of $362K to achieve $367K of ’Overseas project distributions’. (Last year the figures were $333K and $237K.)
    • Ministry comment:
      • By that definition, at the very least the costs of volunteers serving in India (this is what our short term visitor costs are) should be considered charitable services, not administration.  So $292k to achieve $437?  40%  We haven’t applied this understanding below but it could be used to report that our administration costs are lower again.  Donors should be aware that slight changes in understanding can make big differences in this type of analysis.  
  • Under the heading ‘Local Operations’ on page 27 of the Annual Report:
    • Many of our staff costs now related (sic) to directly assisting and keeping our Indian partners accountable with the management of projects funded by our donors. In 2015 we have made accounting changes to record these costs against the larger projects and not against the Australian Office expense. We reduced the administration charge against the projects accordingly. This change in accounting treatment has led to a decrease in local office costs.
    • Presumably this has resulted in the item ‘Employee benefits expense – project management’ $109K.
    • How Australian employees are helping to manage projects in India that are funded by several Mukti International Offices is not explained.
      • Ministry comment:
        • ‘Many projects that we help to manage are funded by Australia alone but we also cooperate and work together with other international offices to help manage joint projects.’
    • If this expense is including as a direct expense, then the figures above change to $252K expenses to deliver $476K. Down to 35% of expenses.
      • Ministry comment: ‘“Project expenses” are also a direct cost – so, from the analysis above actually $154k to deliver $480k.   Down to 24%
      • But this is still well above 27% that is reported in the Annual Report for expenses other than ‘Overseas project costs’, figures that are said to have been ‘extracted from the statutory accounts’.
      • Similarly, ‘Fundraising’ is 1% of expenses in the accounts but 5% in the Annual Report, and ‘Occupancy’ 3% compared to 5%.
        • The reason appears to be that ‘Fundraising’ in the Annual Report includes ‘correspondence costs and travelling with visiting speakers’, something that is separate in the accounts.
    • Note that the 17% figure for ‘Administration’ in the Annual Report (no comparable figure in the accounts) is increased to 22% if one includes, as one commonly does, ‘Occupancy’).

Can you get a tax deduction?

  • Yes. Both MA and MAOAF are Deductible Gift Recipients.

Is the group’s online giving secure?

  • They use an (unnamed) PCI-DSS-compliant international payment gateway provider’, so yes.

Is their reporting up-to-date?

  • Yes (two weeks after the deadline, six and a half months after their year-end).
    • But if you are considering a large donation, I would ask for more up-to-date financial information – the accounts are for a year end that is now 11 months ago.

Does their reporting comply with the regulator’s requirements?

  • AIS 2015: For all intents and purposes, yes. (No answer to question 6.)
  • Financial Report 2015: Questionable
    • The group
      • has grown into an impressive network of employees, area representatives, volunteers and supporters across every state in Australia [‘Who we are’/’Our Story’]
      • in 2015 had
        • over 4000 website visitors
        • 92 new followers on Facebook [page 13, Annual Report].
        • $605K in donations, and
      • at the end of 2015 had
        • 466 ‘new contacts in our database’
        • 526 ‘Facebook Likes’ [page 13, Annual Report].
        • around 572 Australians …sponsoring women and children’ [page 19, Annual Report],
    • Yet the directors say that the group has no users, past or prospective, who are dependent on normal financial statements to make decisions about the group. (The corollary is that any group stakeholder, now and in the future, can ask the group to tailor a financial report for them.)
    • They sell things in a shop but there is still no explanation for the lack of inventory.
    • The group continues not to disclose fundraising expense and administration expense even though they are shown in the Annual Report.

What financial situation was shown by that Report?

  • The surplus as a percentage of income was decreased from 12% to a more typical 1%.
  • ‘Overseas project distributions’ were $367K. This money was sent to Pandita Ramabai Mukti Mission (Mukti Mission on the internet).
    • Pandita must report the receipt of this money to the Indian Government.
    • Two transfers from the group are reported in the year ended 31 March. Translated at the mid-year exchange rate, they totalled $574K.
    • A reconciliation is not possible because Pandita has yet to lodge its 2015-16 return.
      • The Indian organisation held $13K in the bank at 31 March 2015 (the latest disclosure).
  • No obvious concerns with the financial structure.

What did the auditor say about the group’s last financial statements?

  • He gave a ‘clean’ opinion.
    • To take the right amount of comfort from a ‘clean opinion’, please read here and here.

If a charity, is their information on the ACNC Register complete?

  • MA: Not quite:
    • India and Sri Lanka are missing under ‘Operates in (Countries)’.
      • Ministry comment: ‘Mukti Australia Inc partners with organisations in India and Sri Lanka.’
    • The ACNC says that they are overdue in selecting an entity subtype.
      • Ministry comment: ‘The ACNC does not require us to select an entity subtype beyond our current selection of “Public Benevolent Institution’
  • MAOAF: Not quite: India and Sri Lanka are missing under ‘Operates in (Countries)’.

What choices do you have in how your donation is used?

  • Donate’
    • ‘The work of Mukti in India or Sri Lanka’
    • ‘Office administration of Mukti Australia’
  • ‘Gift Catalogue’
    • ‘Gifts for India’
      • seven choices
    • ‘Gifts for Sri Lanka’
      • eight choices
  • ‘Buy Our Merchandise’
  • ‘Support A Project’
    • ‘Mooo’kti Dairy Project’
    • ‘Toilets for Families’
    • ‘Wings of Hope Project’
    • ‘The Good Harvest Project’
    • ‘Education Centre in Sangli’
  • ‘Sponsor A Woman’
  • ‘Sponsor A Child’
  • ‘Support Our People’
    • Australian staff
  • The Annual Report records that $20K was received for something that is no longer an option: ‘Indian Support Staff’.

Who are the people controlling the group?

  • The people shown on the website here.
  • And under ‘Responsible Persons’ on the ACNC Register.

To whom is the group accountable?

  • Membership of Missions Interlink claimed in the website footer. Confirmed.
    • Missions Interlink is an organisation that has standards with which MA must comply.
    • The group Annual Report claims that the charity ‘is certified as complying with the Missions Interlink Standards’.  Yes, Missions Interlink have standards[3], but members get their membership renewed if they complete a ‘Member Declaration’ – there is no positive certification.
  • Both charities are also accountable to the ACNC.

 

 

  1. This review replaces the following comment on the site: ‘This review, published on 5 December, has been temporarily withdrawn.  MA told me today (7 December) that when they sent their comments, some ‘for publication’ and others for me, their hope was that we would continue our discussion before the review was published.  Having now been told of that wish, I have reopened the discussion, and I expect to be able to republish the review within the next week.’
  2. Although MOAOF is indeed a trust, this is not the entity type that is usually selected by overseas aid funds.
  3. For one opinion on the strength of this accountability, see the section Activities in this review.

 

International Teams Ministries Australia Incorporated: mini charity review for donors

Mini charity review of International Teams Ministries Australia Incorporated (IT) as an organisation that seeks donations online. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

(To see the situation last year, read this review.)

Are they responsive to feedback?

  • When sent a draft of this review, they…did not respond.

Is IT registered?

  • As a charity, yes.
    • Not to be confused with the International Teams Ministries Australia Incorporated as the operator of a PBI. This charity was automatically created by the ACNC to recognise IT’s deductible gift recipient International Teams Australia Sydney Refugee Team.
      • Since IT has not taken advantage of the ACNC’s group reporting concessions, the second charity must submit its own AIS.
  • Other registrations:
    • As a NSW incorporated association (Y2915020).
    • IT operates in Queensland as well as its home state of NSW. It also has an invitation to give on the internet.
      • It does not have the registration necessary, an ARBN, to operate interstate.
      • It has a fundraising licence only in NSW. Six other states, including Queensland, have a licensing regime[1].
    • The name Sydney Refugee Team – on Facebook for instance – is not registered.

What does IT do?

Does IT share the Gospel?

  • Via some of its missionaries, no doubt.

What impact are they having?

  • Nothing systematic found.

What does IT spend outside the costs directly incurred in delivering the above impact, that is, on administration?

  • There is insufficient disclosure to make this calculation.

Can you get a tax deduction?

  • No
    • But the ‘Give’ section on the website incorporates the tax-deductible fund International Teams Australia Sydney Refugee Team (see ‘Is IT registered?’, above).

Is IT’s online giving secure?

  • Security is not mentioned.

Is their reporting up-to-date?

  • Yes (two weeks before the deadline, five and a half months after their year-end).
    • But if you are considering a large donation, I would ask for more up-to-date financial information – the accounts are for a year end that is now 11 months ago.

Does their reporting comply with the regulator’s requirements?

  • AIS 2015: No
    • The financial information should be for IT only, not the group.
    • No outcomes are given.
    • A business name is missing.
    • The wrong type of financial statements is given.
    • ‘Employee expenses’ only includes wages.
    • Why aren’t missionaries counted as employees?
    • ‘Donations and bequests’ doesn’t match the Income and Expenditure Statement
  • Financial Report 2015: No
    • The cover has a subheading ‘Consolidating Sydney Refugee Team’, but this is not explained anywhere.
    • The Report is still missing a statement of cash flows.
    • The statement of changes in equity is titled Income and Expenditure Statement.
    • The Income and Expenditure Statement uses a long out-of-date format, and consequently omits ‘Other Comprehensive Income’.
      • There no Notes. For instance, what is the second largest income item, the unusual ‘Global Services Funding’ ($127K).
      • $68K for two full-time and two part-time employees?
    • In the Detailed Balance Sheet –
      • Why ‘detailed’?
      • ‘Web design and development at cost’ an intangible, is misclassified.
      • The non-current ‘Provision for Web site (sic) upgrade’ is questionable as a liability.
    • The number of Notes has been increased from one to three, but this is still well short of the number required.
      • And the two added this year merely duplicate information in the financial statements.
    • The Report again includes an extra statement, again not marked as being unaudited, and again without explanation.
    • The Statement by Members of the Committee is again undated.
    • The Report is still a ‘special purpose financial report’, but the directors again don’t explain why they thought that normal financial statements are not necessary.
    • The inclusion of a Compilation Report tells us that the accounts were prepared by the auditor (reviewer). This person is again Michelle Glossop, a member of the Institute of Public Accountants, working for Parramatta Accountants & Tax Agents.
      • The Compilation Report is again unsigned.

What financial situation was shown by that Report?

  • A deficit of 1% if income was converted into a surplus of 3%.
  • No obvious concerns with the financial structure.

What did the auditor say about the last financial statements?

  • She concluded that
    • ‘Based on our review, which is not an audit, nothing has come to our attention that causes us to believe that the financial report of International Teams Ministries Australia (sic) does not satisfy the requirements of Division 60 of the Australian Charities and Not-for-Profits Commission Act 2012 including: (a) giving a true and fair view of the registered entity’s financial position as at 31 December 2015 and of its financial performance and cash flow for the year 12 months (sic) ending on that date and (b) complying with Australian Accounting Standards to the extend (sic) described in the notes; (sic) and division 60 of the ACNC Regulation 2013’
    • Re-read the information above on IT’s financial reporting and make up your own mind on the validity of her conclusion.

If a charity, is their information on the ACNC Register complete?

  • No. There is only one director under ‘Responsible Persons’, and there is one business name missing.

What choices do you have in how your donation is used?

  • ‘Where Most Needed’
  • ‘Specific Worker’
    • ‘Other Worker’ + 15 individuals/couples (including four in ‘National Office’)
  • ‘Specific Project”
    • ‘OTHER Project’
    • ‘Nea Zoi, Athens’
    • ‘RenovArte Café, Mexico’
    • ‘Rroma-Workers Network’
    • ‘StreetLight, Sydney’
    • ‘Sydney Refugee Team (tax deductible)’
    • ‘Threads of Hope, Athens’

Who are the people controlling IT?

  • The people shown on the website here.
  • It are still only showing one of these people under ‘Responsible Persons’ on the ACNC Register. And it’s still the Public Officer, a person who is not automatically on the board.

To whom are IT accountable?

  • Membership of Missions Interlink claimed on the website, for instance here. Confirmed.
    • Missions Interlink is an organisation that has standards with which IT must comply[2].
  • IT is also accountable to the ACNC.

 

 

  1. The law in this area is not straightforward and advice varies, so check with the charity before drawing any conclusions.
  2. For one opinion on the strength of this accountability, see the section Activities in this review.

Citylife Church Inc: mini charity review for donors

Mini charity review of Citylife Church Inc (CC) as an organisation that seeks donations online. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

(To see the situation last year, read this review.)

Are they responsive to feedback[1]?

  • When sent a draft of this review, they…did not respond.

Is CC registered?

  • As a charity, yes.
    • Not to be confused with the other organisations with the same name:
      • Citylife Church Incorporated, a NSW association.
      • Citylife Church (a business name of Northern Suburbs Assembly of God)
      • Citilife Church Inc (not registered as a charity)
    • Or with the one with almost the same name:
      • Citylife Church International Inc, a NSW association.
  • Other registrations:
    • As a Victorian incorporated association (A0026171A).
      • CC doesn’t have CityLife Church registered as a business name, so must use its full name. Maybe including its website and its Facebook page?
    • CC doesn’t have any fundraising licences. It is exempt in the state in which it operates. Whether it requires a licence in the other six states that have a licensing regime depends whether they think that seeking donations on the internet is ‘fundraising’.

What do they do?

  • See under ‘Connect’ and under ‘Grow’ in the main menu on the website.

Do they share the Gospel?

  • Yes

What impact are they having?

  • Nothing found.

What do they spend outside the costs directly incurred in delivering the above impact, that is, on administration?

  • The expenses are not classified to allow this calculation.

Can you get a tax deduction?

  • No
    • But under ‘Give’ in the main menu, both ‘Outreach’ and ‘Building’ options are tax-deductible giving. This is because CC is collecting for another charity.

Is their online giving secure?

  • Security is not mentioned on the first page.

Is their reporting up-to-date?

  • Yes (a little over five months after their year-end).
    • But if you are considering a large donation, I would ask for more up-to-date financial information – the accounts are for a year end that is now eleven months ago.

Does their reporting comply with the regulator’s requirements?

  • AIS 2015: Almost. No outcomes are given[2].
  • Financial Report 2015: No
    • For a very large church (Melbourne’s largest?), one on multiple sites, and with a large welfare ministry, and a large school, the directors’ claim that CC is not a reporting entity is implausible. Although they do not give any reason for this decision, a decision that results in financial statements that do not have to comply with all the Accounting Standards, what they are effectively saying is that CC has no users, past and prospective, who rely on normal financial statements to make decisions.
    • The Financial Report does not give the full picture of the CC operation. CC has three active ministries that are run via separate charities:
    • There is also Open House Christian Fellowship Inc, a Large charity that is, since 2013, being taken over by CC. Isn’t it also controlled by CC?
      • In the current reporting of this relationship, have all the financial consequences have been included?
    • Only the ‘Board of Elders’ (the committee) is mentioned under ‘Related Party Disclosure’.
    • CC discloses a contingent asset of $4.48 m. A contingent asset is one whose existence is in doubt. That’s not the situation here. Aren’t revenue and assets therefore understated by $4.48 m?
    • Kingdom Investments has lent $6.00 m to Waverley Christian College at call.
      • Why are they classified as being due beyond 12 months?
      • As a public ancillary fund, Kingdom Investments can only help deductible gift recipients. Was the loan made to Waverley’s Building Fund?
    • The presentation of income in the Statement of Income and Expenditure and Other Comprehensive Income is confusing and neither complies with the Accounting Standards nor matches what is shown in the Statement of Cash Flows.
      • CC continue to disclose ‘Revenue for General Reserves & KIF’ ($3.00 m) without explanation. It is the source of the revenue, not its destination that needs to be disclosed here.
      • CC continues to use the acronym ‘KIF’ without explanation.
      • ‘Other expenses’ $847K is broken down, but ‘Ministry expenses’ $1.06 m is unexplained.
      • ‘The unusual ‘Expense from General Reserve ($413K) is still unexplained.

What financial situation was shown by that Report?

  • With the understanding that the Report, without the inclusion of the other subsidiaries, only shows half the picture:
    • The $5.94 m received from Open House Christian Fellowship Inc last year was followed up with another $400K this year.
    • Reserves are $3.55 m less than liquid assets.
    • CC keeps at least $340K of the donations for missions unspent.
    • No obvious concerns with the financial structure.
    • ‘Tithes and offerings’ rose from $8.25 m to $8.43 m, perhaps because members of CC are required to tithe [clause 3.1, the constitution].
    • Consider the effect of the other matters mentioned under the last question.

What did the auditor say about the last financial statements?

  • He gave a ‘clean’[4] opinion. But
    • in continuing with the engagement, he again implicitly agreed with the directors’ decision to produce special purpose rather than general purpose financial statements (see above).
    • See ‘Financial Report 2015’ above.

If a charity, is their information on the ACNC Register complete?

  • Almost – the trading name is not included.

What choices do you have in how your donation is used?

  • ‘General’
    • ‘Tithes’
    • ‘General Offering’
    • ‘Church Building Fund’
    • ‘World Impact (Missions)
      • ‘Partnership in Missions’
      • ‘Other’
    • ‘Other’
  • ‘Nations’
    • ‘Partnership in Missions – Missions Worker’
      • ‘Please specify’ (no drop down menu)
    • ‘Partnership in Missions – Other’
      • ‘Please specify’ (no drop down menu)
  • ‘Outreach’
    • (‘Kingdom Investment Fund’) ‘My gift for where most needed’ (Tax-deductible)
  • ‘Building’
    • ‘The Story Building Project’ (tax-deductible)
      • This is said to be tax-deductible through the Kingdom Investment Fund. The Fund, as a public ancillary fund, can only donate to deductible gift recipients. Who is the eligible recipient?

Who are the people controlling the organisation?

  • Not shown on the website, but they listed under ‘Responsible Persons’ on the ACNC Register.

To whom are CC accountable?

  • Not mentioned on the website, but a part of CC, its ‘World Impact Dept (sic)’ is a member of Missions Interlink. (It is strange that membership continues to be in this name, the name of an entity that doesn’t even have an ABN.)
    • Missions Interlink is an organisation that has standards with which members must comply[5].
  • Plus CC is also accountable to the ACNC.

 

 

  1. Of course, accountability and proper governance is vital. Isolated authoritarian leaders cause dysfunction, often leading to abuse and hurt and …”. From a sermon by the Senior Leader of CC.
  2. Plus the trading name, but such names are of no practical effect nowadays.
  3. A third, Citylife Community Initiatives Incorporated, appears to be unrelated to CC.
  4. To take the right amount of comfort from a ‘clean opinion’, please read here and here.
  5. For one opinion on the strength of this accountability, see the section Activities in this review.