Crossway Baptist Church Inc.: mini-charity review

Mini-charity review of Crossway Baptist Church Inc. (CBC), an organisation that

  1. is connected, through its director John Peberdy, to the CMA Standards C0uncil, Christian Management Australia’smajor new initiative, accrediting Christian organisations against a set of standards of good governance, financial oversight, and fundraising ethics.’
  2. seeks donations online.

Is it responsive to feedback?

  • When sent, on 24 April 2017, a draft of the review written before they lodged their 2016 Annual Information Statement 2016 (AIS 2016), they…did not respond.

Is it registered?

  • Yes, as a charity.
  • CBC is a Victorian incorporated association (A0045459U).
  • It controls three other charities:
  • CBC has not registered the name it uses, Crossway.
  • As a religious body that has authority to marry people, it does not need a fundraising licence in Victoria, the only state in which it operates.

What does CBC do?

  • There isn’t one page that gives this on the website, but the ‘Senior Pastor’s Report’ in the 2016 Annual Report will give you a good idea of what CBC and its controlled entities does.

Do they share the Gospel[1]?

  • Yes

What impact are they having?

  • Nothing systematic found.
  • CBC’s mission is ‘Loving God, Loving People, Disciples that Multiply’. The 2016 Annual Report, a report on CBC and its arms, reports
    • ‘502 first time commitments’
    • ‘145 baptisms’
    • ‘Net increase in lifegroups 23’
    • ‘3 new missional community (sic)’
    • 300 pre-Christians discipled through Discovery Bible Study’
    • ’79 New Disciplers’
    • ‘794 people struggling in our community were transformed through hope, healing and care’

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

  • Although there is an item ‘Administration & Facility expenses’ in the profit and loss statement, ‘Depreciation’ is shown separately, and the composition of the program expenses is not given.
    • The 2016 Annual Report says that it is 23%.

Can you get a tax deduction?

  • Not to CBC itself.
  • But you could if CBC sought donations for its two funds, Crossway Baptist Fellowship Fund, and Crossway CRE Fund, but it doesn’t.
  • It does however offer, on its website, tax-deductible donations to two of its charities, Crossway Kingdom Fund, and Crossway Lifecare Ltd.

Is their online giving secure?

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

  • If you give online:
    • ‘Crossway Tithes and Offerings’
    • ‘Crossway Kingdom Fund (Tax Deductible)
    • ‘Crossway Lifecare (Tax Deductible)’
  • If you give by direct debit:
    • The last two above, plus
    • ‘General Fund (Tithes/Missions)’
    • ‘Crossway Property Fund (Refurbishment)

Is their reporting up-to-date?

  • Yes (four months after their year-end)

Does their reporting comply with the regulator’s requirements?

  • Annual Information Statement 2016 (AIS 2016): No
    • Over half the figures in the ‘Comprehensive Income Statement summary’ are incorrect.
    • The activities do not relate specifically to 2016.
    • No outcomes are reported.
    • Zero for ‘Grants and donations made…’ does not match the Financial Report information.
  • Financial Report 2016: No
    • The Report excludes the entities that CBC controls. It is difficult to see how this gives a true and fair view.
    • It stretches credulity to say, as the directors do, that an organisation with $7.46 m of income and 82 employees [AIS 2016], and 1881 members and 1669 volunteers [2016 Annual Report], has ‘no users dependent on its general purpose financial statements.’ This allows them to produce the lower standard special purpose statements.
    • No explanation is given for why all the figures in the last year column for expenses are different from what was shown last year.

What financial situation was shown in that Report?

  • With the understanding that the Report only covers part of the church’s operations,
    • The surplus as a percentage of income has decreased from 1% to negative 8%.
    • Short-term cash assets are equal to about five months’ income.
    • Both short-term and long-term financial structure appear sound.

What did the auditor say about the last financial statements?

  • He gave a ‘clean’ opinion[2].
    • But he agreed with CBC excluding the entities they control, and he agreed with them saying, effectively, that anybody needing financial information about CBC would be able to get a report tailored to their needs.

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

  • ‘Phone’ and ‘Email’ are blank, but this is not compulsory information.

Who are the people controlling the organisation?

  • Not shown on the website.
  • On the ACNC Register (under ‘Responsible Persons’):
    • Mark Churchward
    • Edward Harrison
    • Francis Hoe
    • Kok Looi
    • Scott Pilgrim
    • Margaret Spicer
    • Dale Stephenson
    • Beth Strybosch
    • Timothy Wilson
    • John Peberdy
      • John is a director of Christian Management Advancement Ltd, an organisation that believes that
        • Christian organisations should be the standard-setters in terms of impeccable corporate behaviour.
          • The mission of their committee, the CMA Standards Council, is to ‘help build faith and trust in Christian organisations’, including by allowing organisations who are compliant with a set of standards, formed by the Council, to display the Council’s seal of approval.
    • There are 14 directorships recorded for the name ‘John Peberdy’, and 8 for ‘Timothy Wilson’.  And the register only covers charities, not all not-for-profits, and no for-profit organisations.  Therefore, if after eliminating the charities that don’t belong to the CBC director, you are left with their total being more than a handful, it would be legitimate for you to question whether their ability to discharge his fiduciary responsibilities is threatened.

To whom is CBC accountable?

  • To the ACNC.
  • And to the Victorian associations regulator.

 

 

  1. Good living and social concern are important [to the cause of evangelism], but they are not uniquely Christian graces…I’ve met a lot of fine Hindus, Muslims and atheists. Just living the life is not going to bring someone to Christ. There is much more to it than that. We must help people, certainly, but we must also share with them why we are motivated to do so. We must stand against injustice, poverty and need, but we must at the same time point to the One who brings justice and who can meet the deepest need. Until they know our reasons, how can they come to know our Lord?” [Dan Armstrong, the Fifth Gospel: The Gospel According to You, Anzea Books, pp. 13-14.
  2. To take the right amount of comfort from a ‘clean opinion’, please read here and here.

City Bible Forum Incorporated: mini-charity review for donors

Mini charity review of City Bible Forum Incorporated (CBF), as an organisation that seeks donations online. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

Are they responsive to feedback?

  • When sent a draft of this review, they did not respond[1].

Is CBF registered?

  • As a charity, yes.
  • Other registrations:
    • As a NSW incorporated association (Y2770511)[2].
    • As an Australian Registered Body (ARBN: 105 231 089), allowing it to trade interstate.
    • The website says that CBF has offices in all states except ACT, Tasmania and the Northern Territory. Canberra, i.e. the ACT, is in the drop-down menu, and although it shows Sydney as its office, it is listed on the ACNC Register.
      • Apart from the fundraising via the internet (see above), do any of these offices fundraise? All the states in which it operates have a licensing regime for fundraisers: it is exempt in NSW, but is not licensed in the other five[3].
    • CBF does not have any name registered other than its legal name (above). Therefore, it must, under its enabling legislation (section 41(1)),
      • ‘not issue any letter, statement, invoice, notice, publication, order for goods or services or receipt in connection with its activities unless the association’s name appears in legible characters on the document.’
      • It is arguable that, nowadays, this includes at least some of what is published on CBF’s social and other media pages, pages that are in the name City Bible Forum.

What does CBF do?

  • Generally: what they describe here.
  • More specifically: the activities here. (Less than this is said in the Annual Information Statement (AIS) 2015).

Does CBF share the Gospel?

  • Although not required by its constitution – there is actually no purpose or objects written there– it is assumed that at least some of CBF’s activities (see ‘What does CBF do?’, above), include the proclamation of the Gospel.

What impact are they having?

  • Nothing found.

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

  • CBF do not make the impact they are seeking explicit. But even if they did, there is likely insufficient disclosure in the Statement of Comprehensive Income to calculate the cost of administration.

Can you get a tax deduction?

  • Not to CBF. But you can to its fund, City Bible Forum Public Library.
    • Where is the library?

Is CBF’s online giving secure?

  • They use eway, so yes.

Is their reporting up-to-date?

  • Yes (three days before the deadline, seven 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 over 16 months ago.

Does their reporting comply with the regulator’s requirements?

  • AIS 2015: No
    • No outcomes are given.
    • The type of financial statements said to be produced is incorrect.
    • The figures for ‘All other revenue’ and ‘Other income’ do not match those in the financial statements.
  • Financial Report 2015: Questionable
    • Special purpose financial statements: CBF has offices in five states, at least 27 employees, and receives $1.68 m in donations. Yet the directors say that CBF has no users, past or prospective, who are dependent on normal financial statements to make decisions about the charity. (The corollary is that any stakeholder, now and in the future, can ask CBF to tailor a financial report for them.)
    • How can an organization that has offices in five states have no non-current assets, for instance, office equipment?
    • Why is the library not included in the balance sheet?
    • In the audited accounts:
      • Almost the entire expenses total, $1.81 m, is included merely as ‘Other expenses…’
      • Employee benefits expense is not disclosed.
        • ‘Employee expenses’ in the AIS 2015 is $1.44 m, 79% of the total.
          • The number of employees is reported as 14 full-time and 28 part-time in AIS 2015, considerably different from the 28 shown on the website.
      • No explanation is given for the inclusion of a liability, Provision for Long Serve Leave, in the Statement of Comprehensive Income…, or for it being a negative expense.
      • ‘Ministry activities’ ($141K) is not explained.

What financial situation was shown by that Report?

  • The surplus as a percentage of income was decreased marginally from 2.2% to 2.0%.
    • The surplus is overstated by the amount of any depreciation that should have been charged.
  • They borrowed once for working capital (rather than capital assets). Will they have to do it again?
  • Liabilities exceed assets by $29K (down from $64K). This means that if CBF closed at 31 December 2015, it would owe people outside CBF at least this amount.
  • Only $3K of the $104K loan is shown as a current (short-term) liability. The term of the loan is not given, but the directors’ comment that ‘The creditor has given a written undertaking not to call on the debt until the association has eliminated the deficiency of funds’, implies that it is repayable on demand. Such an undertaking, because it is not an unconditional right to defer settlement, does not qualify the loan to be classified as non-current [AASB 101.69, www.aasb.gov.au].
  • This means that the working capital (current assets less current liabilities) is not the positive 1.2 times that is currently shown, but slightly negative.
  • The administrative burden is increased by the use of a very large number of bank accounts.

What did the auditor say about the last financial statements?

  • He gave a ‘clean’[4] opinion. But
    • Silence by the directors on the challenge to the going concern assumption, plus their misclassification of the loan, suggests that a ‘clean opinion’ might not have been appropriate.
    • By accepting the engagement, the auditor implicitly agreed with the directors’ choice of special purpose financial statements over normal statements.
    • It appears that he signed before the directors signed their declaration.
    • And see the comments under ‘Financial Report 2015’, above.

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

  • Yes

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

  • Infinite: ‘Please tell us if your donation has a special purpose’
    • There is no mention of the tax deductibility (see ‘Can you get a tax deduction?’, above).
    • Melbourne office is seeking money separately, and says that ‘We are able to make contributions of $2000 and more tax deductible (only a portion of our budget is tax deductible). This information does not match that shown on CBF’s ABN record (see above).

Who are the people controlling the CBF?

  • Not shown on the website.
  • The following people (from ‘Responsible Persons’ on the ACNC Register).
    • David Barnsdall
    • Andrew Charleston
    • Darryl Cross
    • Mark Daly (who is also a director of The Spiritual Assembly of the Baha’Is of Warringah Limited).
    • Mark Genning
    • Jacqueline Hodges
    • Peter Kaldor
    • Michael Raiter
    • Craig Shilson-Josling
  • These directors are on more than three charity boards:
    • Peter Kaldor: seven
      • If it is the same Peter Kaldor for all seven charities, and knowing that this number does not include directorships of non-charity not-for-profits or businesses, you may reasonably question how somebody who is the managing director of a national charity with 28 staff can successfully discharge their fiduciary responsibilities to all these organisations.
    • Michael Raiter: four (including SparkLit and Familyvoice Australia Incorporated)

To whom is CBF accountable?

  • To the ACNC.
  • And to the New South Wales associations regulator.

 

 

  1. Review sent 17 April 2107; published 1 May 2017.
  2. Not, as their ABN record says, an ‘Other Unincorporated Entity’.
  3. The law in this area is not straightforward and advice varies, so check with the charity before drawing any conclusions.
  4. To take the right amount of comfort from a ‘clean opinion’, please read here and here.

The Trustee For Rosenheim Trust: mini-charity review

Mini-charity review of The Trustee For Rosenheim Trust (Rosenheim), an organisation that is connected, by the directorship of Robert Rawson, to the CMA Standards C0uncil, Christian Management Australia’smajor new initiative, accrediting Christian organisations against a set of standards of good governance, financial oversight, and fundraising ethics.’

Is it responsive to feedback?

  • When sent a draft of this review, on 20 April 2017, they responded the next day – but nothing for publication.

Is it registered?

  • Yes, as a charity.
  • Rosenheim is a trust, an unincorporated body.
  • No information was found to indicate that Rosenheim seeks donations from the public.

What does Rosenheim do?

  • It donates money consistent with its ‘purpose of sustaining, advancing and promoting evangelical Christian ministries’.
    • Because they say on the ACNC Register than they operate only in Queensland, perhaps the recipients were all in that State?

Do they share the Gospel?

  • No

What impact are they having?

  • Nothing found.
    • No outcomes are reported in the Annual Information Statement 2016 (AIS 2016).

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

  • Nil – ‘Grants and donations made…for use in Australia’ are 100% of expenses.

Can you get a tax deduction?

  • No

Is their online giving secure?

  • NA – there is no website.

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

  • NA

Is their reporting up-to-date?

  • Yes (three months after their year-end)

Does their reporting comply with the regulator’s requirements?

  • Annual Information Statement 2016 (AIS 2016): Not quite – no outcomes are reported.
  • Financial Report 2016: Yes – because of its size, none is required.

What financial situation was shown in that Report?

  • NA. But from the AIS 2016:
    • Income was 100% ‘Other revenue/receipts’, $42K.
    • No employees.
    • No expenses other than what they donated, $36K.

What did the auditor say about the last financial statements?

  • NA. Not required by the ACNC, and not required by the trust deed.

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

  • Not quite – there is only one trustee listed. The Trust Deed requires a minimum of two.

Who are the people controlling the organisation?

  • Per the ACNC Register (under ‘Responsible Persons’), just one, Robert Rawson.
    • Robert is a director of Christian Ministry Advancement Ltd, an organisation that believes that
        • Christian organisations should be the standard-setters in terms of impeccable corporate behaviour.
          • The mission of their committee, the CMA Standards Council, is to ‘help build faith and trust in Christian organisations’, including by allowing organisations who are compliant with a set of standards, formed by the Council, to display the Council’s seal of approval.
  • Per the Trust Deed:
    • ‘Initial’
      • Robert James Rawson
      • Dorothy Joy Rawson
    • ‘Substituted’
      • Wendy Gaye Webb
      • Julie Ann Iveson
      • Nicole Joy Orr

To whom is Rosenheim accountable?

Global Aid Network Incorporated: mini-charity review

Mini-charity review of Global Aid Network Incorporated (GAN) an organisation that invites the public to donate to it, and that is connected, through Robert Rawson, to the CMA Standards C0uncil, Christian Management Australia’smajor new initiative, accrediting Christian organisations against a set of standards of good governance, financial oversight, and fundraising ethics.’

(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, on 1 April 2017, the ACNC contact responded the same day to say that what I had written wasn’t true, and requested that publication be deferred until he returned to the office in three weeks. Upon his return he said that there was nothing that needed changing and declined the opportunity to submit a comment for publication.

Is it registered?

  • Yes, as a charity.
  • Other registrations:
    • GAN is a New South Wales incorporated association (NSW INC9880886).
      • It doesn’t appear to be connected with the private ancillary fund Global Aid Foundation and its trustee Global Aid Foundation Pty Ltd. Or these entities that are not charities: Global Aid Warehouse Pty Ltd and Global Aid Zone Incorporated.
    • GAN trades under the name GAIN, but this is not a business name. And unavailable – ASIC says that it is identical to two names that are already registered.
    • GAN operates, per the ACNC Register, in New South Wales. It also raises money on the internet. It has a fundraising licences in NSW, but not any of the other six states that have a licensing regime[1].

What does GAN do?

Do they share the Gospel?

  • Although not being included under ‘About us’, it appears, from this newsletter, and this description of what humanitarian aid means to them, that they do share the Gospel.

What impact are they having?

  • Nothing systematic found.

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

  • No financial statements have been lodged – it is voluntary for GAN – but the financial information in the AIS 2016 shows that $87K was spent to give $35K in grants.

Can you get a tax deduction?

  • No

Is their online giving secure?

  • If security is mentioned, it is after you enter your personal details.

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

  • ‘Join a Medical Mission Team in 2016 (sic) – $3000’
  • ‘Sponsor a Medical Mission Team member – $1000’
  • ‘Provide solar lighting for one house in Bihar, India – $500’
  • ‘Purchase medicine for Medical Missions – $200’
  • ‘Contribute to rebuilding in the Philippines following Typhoon Haiyan _ $100’
  • ‘Donate a different amount’

Is their reporting up-to-date?

  • Yes (four and a half months after their year-end).

Does their reporting comply with the regulator’s requirements?

  • Annual Information Statement 2016 (AIS 2016): Almost – no outcomes are reported.
  • Financial Report 2016: Yes
    • As a Small charity, no Financial Report is required, and GAN has not chosen to lodge one voluntarily.

What financial situation was shown in that Report?

  • No Report, but from the AIS 2016:
    • ‘Other revenue/receipts’ are 75% of income, ‘Donations and bequests’ the other 25%
    • ‘Other expenses/payments’ are 2.5 times ‘Grants and donations made…’ (all overseas).
    • Surplus as a percentage of revenue was 7%.
    • Assets are 2.9 times liabilities.

What did the auditor say about the last financial statements?

  • NA

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

  • Yes.
    • But Global Aid Network is neither a trading name or a business name, and the other name they list, (GAIN) Australia is not a business name (and not quite the trading name either).

Who are the people controlling the organisation?

  • Not shown on the website.
  • ‘Responsible Persons’ on the ACNC Register:
    • Taciano Bantatua
      • Is it this Taciano Bantatua?
    • Phillip Anthony Cuming
      • Is it this Phillip Cuming?
    • Allan Drew
      • Is it this Allan Drew?
    • William John Hodgson
      • Is it this William Hodgson?
    • John Joseph
    • Jiji Skariah
    • Robert Rawson
    • Robert is a director of Christian Ministry Advancement Ltd, the organisation that is introducing a set of standards for Christian organisations, compliance with which will allow display of the CMA Standards Council seal.

To whom is GAN accountable?

  • To the ACNC.
  • And to the New South Wales regulator of associations.
  1. Opinions vary on whether an internet invitation qualifies as ‘fundraising’.

Prison Fellowship Australia: mini-charity review

Mini-charity review of Prison Fellowship Australia (PFA), an organisation that invites the public to donate to it, and that is connected, through a director, John Peberdy, to the organisation that is planning to accredit ‘Christian organisations against a set of standards of good governance, financial oversight, and fundraising ethics.’

(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.

Is it responsive to feedback?

  • I sent a draft of the review on 5 April 2017. They did not respond.

Is it registered?

  • Yes, as a charity.
  • PFA is a public company, a company limited by guarantee.
    • It is entitled to omit ‘Limited/’Ltd’ from the end of its name.
  • It operates, per the ACNC Register, in all eight states of Australia. It has offices in six states. It also fundraises via the internet. However, it has a fundraising licence in only two of the seven states that have a licensing regime[1].

What does PFA do?

  • ‘Across Australia there are over 1000 volunteer men and women visiting prisoners, running programs in prisons, organising camps and providing Christmas presents for prisoners’ children, supporting ex- prisoners when they are released, playing sports, running in-prison Bible studies, and providing many other services.’ [https://prisonfellowship.org.au/prison-fellowship-australia/].

Do they share the Gospel?

  • The PFA mission is ‘To share the Gospel of Jesus Christ with prisoners, ex-offenders, and their families.’

What impact are they having?

  • Nothing systematic found.
    • The website has only two references to impact.

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?

  • It says so on their ABN record, but there is no mention of it on their website.

Is their online giving secure?

  • If security is mentioned it is after you have entered your personal information.

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

  • Prison Visiting’
  • ‘Angel Tree’
  • ‘The Prisoners (sic) Journey’
  • ‘Sycamore Tree Project’
  • ‘SLAM’
  • ‘Change On The Inside’
  • ‘Camp for Kids’
  • ‘Darwin’
  • ‘Where Most Needed’

Is their reporting up-to-date?

  • Yes (six months after their year-end).

Does their reporting comply with the regulator’s requirements?

  • Annual Information Statement 2015 (AIS 2015): No
    • The description of activities is not particularly about 2015.
    • No outcomes are reported.
    • Their business name is missing.
  • Financial Report 2015: No.
    • The directors have again adopted the lower standard special purpose financial statements.
      • It stretches credulity to suggest, as the PFA directors do, that an organisation with $1.70 m turnover, 15 employees, 1075 volunteers, and that has offices in six states[2], had ‘no users who are dependent on general purpose financial statements’.
    • Note 1 first says that the financial statements cover PFA ‘as an individual entity’ then, two paragraphs later, says that ‘the report covers (PFA) as a consolidated entity, made up by the following entities:
      • Prison Fellowship Queensland
      • Prison Fellowship National (sic) Territory
      • Prison Fellowship Western Australia
      • Prison Fellowship New South Wales
      • Prison Fellowship Tasmania
      • Prison Fellowship South Australia
      • Prison Fellowship National Office
      • Prison Fellowship Victoria
        • All these entities have an ABN except for ‘National Office’.
        • Four of them are in the former name of PFA, Prison Fellowship of Australia (emphasis added).
    • Consolidation fits with the fact that the Articles of Association [clause 60A], require ‘Each State Council’ to produce “a balance sheet and profit and loss account’ for their AGM.
    • But
      • There is no mention of Councils on the PFA website.
      • There are seven state entities above but only six ‘State contacts’.

What financial situation was shown in that Report?

  • A 16% decline in revenue was more than compensated for by a 37% reduction in ‘Employee benefits expense’. This helped to turn a negative 3% return on revenue into a positive 4%.
  • The ratio of current assets to current liabilities was increased significantly (from 1.9 to 2.8).
  • Long-term financial structure appears sound.

What did the auditor say about the last financial statements?

  • Although he gave a ‘clean’ opinion, the auditor, Matthew Hung of rdl.accountants,
    • agreed with the directors’ decision that there are no users (present or prospective) who are dependent on general purpose financial statements (see ‘Financial Report’, above), and
    • left in the accounts the confusion over the connection between PFA and its state bodies.

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

  • Almost – their business name is missing.
    • The governing document is still missing the Memorandum of Association though.

Who are the people controlling the organisation?

  • The nine people shown here on the website.
  • Who are also shown under ‘Responsible Persons’ on the ACNC Register:
    • David Cormack
    • Shane Ellery
    • Peter Hall
    • David Maxwell
    • Daryl Myatt
    • Steven Nicholson
    • Vera Ou-Young
    • Michael Wood
    • John Peberdy
      • John is a director of Christian Ministry Advancement Ltd, the organization that is introducing a ‘major new initiative, accrediting Christian organisations against a set of standards of good governance, financial oversight, and fundraising ethics.’
    • There are 14 directorships recorded for the name ‘John Peberdy’, and 11 for ‘Peter Hall’. And the register only covers charities, not all not-for-profits, and no for-profit organisations. Therefore, if after eliminating the charities that don’t belong to the PFA director, you are left with their total being more than a handful, it would be legitimate for you to question whether their ability to discharge his fiduciary responsibilities is threatened.

To whom is PFA accountable?

  • To the ACNC.
  • And, as a company, to ASIC.

 

 

  1. The licence in NSW is in the name Prison Fellowship of Australia, a NSW entity. The licence in Queensland is in the name Prison Fellowship of Australia Queensland Council; 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. AIS 2915.

Access Ministries: mini-charity review

Mini-charity review of The Council for Christian Education in Schools trading as Access Ministries (Access), an organisation that invites the public to donate to it, and that is connected, through John Peberdy, to Christian Ministry Advancement Ltd’s ‘major new initiative, accrediting Christian organisations against a set of standards of good governance, financial oversight, and fundraising ethics.’

(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.

Is it responsive to feedback?

  • They were sent a draft of the review on 4 April 2017. They did not respond.

Is it registered?

  • Yes, as a charity.
  • Access is a public company, a company limited by guarantee.
    • It is entitled to omit ‘Limited/’Ltd’ from the end of its name.
  • The main name under which it trades Access Ministries, is a (registered) business name.
  • It operates, per the ACNC Register, only in Victoria. It is licensed to fundraise there.
    • It also fundraises via the internet. It does not have a licence outside Victoria[1].

What does Access do?

  • See the description here.

Do they share the Gospel?

What impact are they having?

  • Nothing systematic found.
  • There is a 2009 study on the impact of chaplains in schools, and some anecdotal reports of impact in the Annual Review 2015, and elsewhere.

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.
  • The Annual Review 2015 reports in an infographic that 27% of the expenses were indirect (page 10).

Can you get a tax deduction?

  • Yes

Is their online giving secure?

  • There is no mention of security.

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

  • Donate to our current appeal’
  • ‘General Donations’
    • ‘Gift for Christian programs in schools’
    • ‘Other’
  • ‘Chaplaincy Donations’
  • ‘SRI Partnerships’

Is their reporting up-to-date?

  • Yes (five months after their year-end).

Does their reporting comply with the regulator’s requirements?

  • Annual Information Statement 2015 (AIS 2015): No
    • The description of activities is not particularly about 2015.
    • No outcomes are reported.
    • Three business names are missing.
    • The figure for ‘Interest’ is wrong.
  • Financial Report 2015: No.
    • The directors have again adopted the lower standard special purpose financial statements.
      • It stretches credulity to suggest, as the Access directors do, that an organisation with a $11.00 m turnover, more than 200 staff, 1000 volunteer instructors, and 1900 donors[2], had ‘no users who are dependent on general purpose financial statements’.
    • Note 1 (p) says that
      • Funds held by local Chaplaincy Support Groups are not shown in the company’s assets, nor is the income and expenditure of the Support Groups consolidated into the parent company. The activities of the Support Groups are controlled by local governance committees. There were 54 Support Groups at 31 December 2015 with net assets totally $3,150,638 (2014: $3.399,322).
        • Despite these Chaplaincy and Wellbeing Support Groups being an integral part of Access’s operation, the acknowledgement of the parent-subsidiary relationship, and the collection of donations by Access for the Groups, the directors again give no reason for this decision.
        • Inclusion of these net assets would increase Access’s equity by 213%.

What financial situation was shown in that Report?

What did the auditor say about the last financial statements?

  • Although he gave a ‘clean’ opinion, the auditor, M.A. Cunningham of Grant Thornton, agreed with the directors’ decision that
    • there are no users (present or prospective) who are dependent on general purpose financial statements, and
    • the transactions and balances of the 54 Chaplaincy and Wellbeing Groups need not be consolidated.

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

  • Almost – there are three business names missing.

Who are the people controlling the organisation?

  • Not shown on the website.
  • Per the ACNC Register:
    • Elida Brereton
    • Stephen Dickins
      • Is it this Stephen Dickins?
    • James Hall
    • Grant Lawry
    • Lisa McDonald
    • Peter Rawlings
    • Jorg Selhorst
    • John Peberdy
      • John is a director of Christian Ministry Advancement Ltd, the organization that is introducing a ‘major new initiative, accrediting Christian organisations against a set of standards of good governance, financial oversight, and fundraising ethics.’
    • There are 14 directorships recorded for the name ‘John Peberdy’, and 10 for ‘Elida Brereton’. And the register only covers charities, not all not-for-profits, and no for-profit organisations. Therefore, if after eliminating the charities that don’t belong to the Access director, you are left with their total being more than a handful, it would be legitimate for you to question whether their ability to discharge his fiduciary responsibilities is threatened.
    • Access is still non-compliant with its own requirement to have a minimum of ten directors.

To whom is Access accountable?

  • To the ACNC.
  • And, as a company, to ASIC.

 

 

  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. Sources, in turn: Financial Report, AIS 2015, Annual Review 2015, Annual Review 2015.

Youth With A Mission (Perth) Incorporated: mini-charity review

Mini-charity review of Youth With A Mission (Perth) Incorporated (YWAMP) an organisation that invites the public to donate to it, and that is a member of Missions Interlink, ‘the Australian network for global mission’.

(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.

Is it responsive to feedback?

  • When sent a draft of this review, on 3 April 2017, they…did not respond.

Is it registered?

  • Yes, as a charity.
  • It also controls another charity, Youth With A Mission (Perth) Incorporated As the operator of a PBI (YWAMPBI)
    • Here’s the ACNC’s explanation:
      • Organisations that are the operators of a Public Benevolent Institution (PBI) or Health Promotion Charity (HPC) were provided with a new ABN to make clear which part of the organisation is a registered charity and which part is a PBI or HPC. As both are registered entities with the ACNC, they have their own reporting obligations. You can choose to lodge separate annual reports via the ACNC Charity Portal or you can apply to group report by submitting Form 4B: Request group reporting.
        • Distinguishing PBIs (and HPCs) from charities does not fit with what the ATO says.
      • YWAMP has not taken advantage of group reporting.
      • There is no mention of ‘public benevolent institution’ or ‘PBI’ on the YWAMP website.
  • Other registrations:
    • As a Western Australian incorporated association (A0822268A).
    • YWAMP uses the names Youth With A Mission Perth and YWAM Perth. It has neither registered as business names.
      • YWAM has a trademark for the first name.
    • It operates, per the ACNC Register, in Western Australia. It also raises money on the internet. It has no fundraising licences[1].

What does YWAMP do?

  • Described here.
  • The ACNC Register says that YWAMP operates in ten overseas countries. It made no overseas grants, but perhaps these are the countries to which ‘mission trips’ were made?
  • YWAMPBI: I can find no information on the PBI.
    • Its Annual Information Statement 2015 (AIS 2015) has the same description of activities as YWAMP’s.

Do they share the Gospel?

  • Yes. See the section just above.
  • YWAMPBI: Being a PBI, I suspect not.

What impact are they having?

  • Nothing systematic found.
  • YWAMPBI: Nothing found.

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

  • The financial statements that were lodged have been withheld from the Register by the ACNC at YWAMP’s request.
    • There is no reason given for the suppression, and the reason is not available to the public. This just leads us to speculate as to the nature of the information that has caused the ACNC to decide that the harm that may be caused by its publication ‘outweighs the public interest in publishing the information’.
    • The loss of transparency is mitigated by the fact that the statement withheld relates to a year-end that is now over two years ago.
    • Their membership of Missions Interlink requires them 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]. So just ask.
  • YWAMPBI:
    • The ‘Financial Information’ section in the AIS 2015 has all zeros.
    • The Financial Report is YWAMP’s Financial Report.

Can you get a tax deduction?

  • Yes, both for YWMP as an organisation (since 22.09.2016), and for a donation to its fund, Youth With A Mission Western (Perth) Inc School Building and Maintenance Fund (since 1.07.2000).
    • How did such an overtly evangelising organisation like YWAMP get endorsement as a Deductible Gift Recipient?
    • How was the DGR status granted when YWAMP doesn’t have the required revocation clause in its constitution?
    • There is no mention of the Fund on the website.
  • YWAMPBI: Yes, if you give to its fund, Youth With A Mission (Perth) Inc Donation Account.

Is their online giving secure?

  • Security is not mentioned.
  • YWAMPBI: NA – no separate website, and no option on YWAMP’s website to give to the PBI.

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

  • ‘Donation or Gift’
  • ‘Student’
  • ‘Staff’
  • ‘Other’
  • YWAMPBI: NA

Is their reporting up-to-date?

  • Yes
    • But three months late.
    • And, at the request of the ACNC, for the year-ended 31 March 2015, not 2016 as is normal for other charities.
  • YWAMPBI: Yes
    • But three months late.
    • And, at the request of the ACNC, for the year-ended 31 March 2015, not 2016 as is normal for other charities.

Does their reporting comply with the regulator’s requirements?

  • Annual Information Statement 2015 (AIS 2015): No
    • Three important figures in the ‘Financial Information’ section do not match those in the financial statements.
    • The activities are not specific to 2015.
    • No outcomes are reported.
  • Financial Report 2016: No[2]
    • It stretches credulity for the directors of a charity with a turnover of $6.15 m, multiple training courses, a large staff, 6K followers on Facebook, and a public invitation to give, to conclude that there are no stakeholders, either present or prospective, who are dependent on general purpose financial statements to make decisions about the organisation.
  • YWAMPBI:
    • Annual Information Statement 2015 (AIS 2015): No
      • The activities are not specifically those of the PBI
      • No outcomes are reported.
      • Their fund is not an ‘Other name’.
      • The financial statements that are attached are not those of the PBI.
      • The ‘Financial Information’ does not match what is shown in the financial statements.
    • Financial Report 2016: No – it is YWAMP’s Financial Report.

What financial situation was shown in that Report?

  • No Report is available via YWAMP’s Register entry – the Report was received but the ACNC, at YWAMP’s request, have withheld the information.
  • However, there is a Financial Report for YWAMP on the PBI’s entry:
    • Income: $6.15 m.
      • Donations 408K
      • Over a million dollars:
        • ‘Outreach Fees’ $1.84 m
        • ‘Tuition Fees’ $1.54 m
        • ‘Staff Fees’ $1.34 m
    • Expenses: $5.09 m
      • Zero ‘Employee expenses’. Elsewhere in the AIS they report zero employees. How does YWAMP do what it does?
      • No ‘Grants and donations…’.
      • Over a million dollars:
        • ‘Outreach Expenses’ $1.67 m
        • ‘Rent’ $1.46 m
    • Assets $19.56 m
      • ‘Cash’ $2.00 m
      • ‘Property, Plant & Equipment’ $17.48 m
        • ‘Land & Buildings at cost’ $15.94 m: why so much rent then?
    • Liabilities $5.87 m
      • ‘Interest Bearing Liabilities’ (due beyond 12 months): $4.49 m
  • YWAMPBI: The report that has been lodged is that of YWAMP.

What did the auditor say about the last financial statements?

  • He gave a qualified opinion, that is, not a ‘clean’ opinion.
    • The qualification is because the directors of YWAMP have ‘determined that it is impracticable to establish control over the collection of cash donations prior to entry into its financial records’.
      • If most other charities can establish these controls, what stops YWAMP?
  • He also implicitly agreed with the directors’ decision that YWAMP is not a reporting entity, thus allowing them to produce the lower standard special purpose financial statements.
  • YWAMPBI: NA

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

  • Yes
  • YWAMPBI: Yes

Who are the people controlling the organisation?

  • Not shown on the website.
  • The ACNC Register says that YWAMP has a board of one, Caleb Brownhill. However, as he is the Public Officer, it is possible that he is not a responsible person, and therefore should not be listed here.
    • The constitution[3] requires a minimum of three officers.
  • YWAMPBI: Caleb is again the only one listed.

To whom is YWAMP accountable?

  • To the ACNC.
  • And to the Western Australian regulator of associations.
  • YWAMPBI: to the ACNC.

 

 

  1. Opinions vary on whether an internet invitation qualifies as ‘fundraising’.
  2. Submitted but not available to the public because they applied, and the ACNC agreed, to withhold the Report. Their Financial Report is available on the Register entry for YWAMPBI.
  3. Marked ‘Information withheld’ on the Register, but available on YWAMPBI’s Register entry.

Citylife Community Care Inc: mini-charity review

Mini-charity review of Citylife Community Care Inc (CCC) an organisation that invites the public to donate to it. (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, on 30 March 2017, they…did not respond.

Is it registered?

What does CCC do?

Do they share the Gospel?

  • No.
    • It describes itself as a ‘faith-based organisation’, not Christian, or Christ-centred.
      • It does say, though, that ‘Our counsellors are competent in using various trusted and proven therapeutic approaches informed by Christian principles.

What impact are they having?

  • Nothing systematic found.

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

  • The way the expenses are classified does not allow this calculation.

Can you get a tax deduction?

  • Yes

Is their online giving secure?

  • If security is mentioned, it is after you enter your personal details.

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

  • None.

Is their reporting up-to-date?

  • Yes (five and a half months after their year-end).

Does their reporting comply with the regulator’s requirements?

  • Annual Information Statement 2015 (AIS 2015): Almost – no outcomes are reported.
  • Financial Report 2015: Only if
    • You agree with the directors that CCC has no users, present or prospective who need general purpose financial statements for their decisions about CCC.
      • The directors don’t give a reason for saying that CCC is not a reporting entity, and therefore able to produce the lower standard special purpose financial statements.
    • There is no Note on related parties (an ACNC expectation).

What financial situation was shown in that Report?

  • Surplus as a percentage of revenue declined from 2% to 1%.
  • Working capital declined marginally, but is still strongly positive (440%).
  • Long term capital structure is sound.

What did the auditor say about the last financial statements?

  • He gave a ‘clean’ opinion[2].

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

  • Yes

Who are the people controlling the organisation?

  • Not shown on the website.
  • ‘Responsible Persons’ on the ACNC Register:
  • Assuming the ‘Position’ shown is correct, this number of directors is two short by the constitution.

To whom is CCC accountable?

  • To the ACNC.
  • And to the Victorian regulator of associations.
  • To Citylife Church (as a wholly-owned subsidiary).
  1. Opinions vary on whether an internet invitation qualifies as ‘fundraising’.
  2. To take the right amount of comfort from a ‘clean opinion’, please read here and here.

NSW Service for the Treatment and Rehabilitation of Torture and Trauma Survivors (STARTTS): mini-charity review

Mini-charity review of NSW Service for the Treatment and Rehabilitation of Torture and Trauma Survivors (STARTTS), an organisation that invites the public to donate to it, and that is connected, through Richard Menteith, to the CMA Standards C0uncil, Christian Management Australia’smajor new initiative, accrediting Christian organisations against a set of standards of good governance, financial oversight, and fundraising ethics.’

(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, on 30 March 2017, they…did not respond.

Is it registered?

  • Yes, as a charity.
  • STARTTS is a public company, a company limited by guarantee.
    • Not, as its ABN record shows, an ‘Other Incorporated Entity’.
  • There are three other charities with STARTTS in their name:
    • South Sudan STARTTS (should have ‘Limited’/’Ltd’ on the end)
      • It operates from the same address as STARTTS.
    • Friends of STARTTS Inc. (Y 10372-04 Associations) (shouln’t have the last part)
      • Donations to STARTTS go to this charity, not STARTTS, it operates from STARTTS’ premises, and the ‘Charity Address for Service’ is the email of one of the directors of STARTTS.
    • STARTTS Clinical and Facilities Trust
      • It operates from the same address as STARTTS, the ‘Charity Address for Service’ is the (work) email of one of the directors of STARTTS, and it shares two directors with STARTTS.
    • The financial statements are only for STARTTS, and although the Notes says that there are related parties, they are not identified. But does STARTTS control at least the last two charities?
  • STARTTS trades under the name ‘STARTTS’, but they have not registered the name.
  • STARTTS raises money on the internet. It has no fundraising licences[1].

What does STARTTS do?

Do they share the Gospel?

  • No.

What impact are they having?

  • Nothing systematic found.

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

  • The way the expenses are classified does not allow this calculation. (The information it too out-of-date anyway.)

Can you get a tax deduction?

  • Yes

Is their online giving secure?

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

  • None. It all goes, without explanation, to another charity, Friends of STARTTS Inc.

Is their reporting up-to-date?

  • No (two and a half months overdue; last year they reported six months late).

Does their reporting comply with the regulator’s requirements?

  • Annual Information Statement 2015 (AIS 2015): No
    • Most of the figures in the ‘Income Statement’ do not match those in the Financial Report.
    • No outcomes are reported.
    • ‘NSW STARTTS’ is not an ‘Other name’.
  • Financial Report 2015: Yes (except that it is well out-of-date).

What financial situation was shown in that Report?

  • Too out-of-date to be relevant.

What did the auditor say about the last financial statements?

  • Too out-of-date to be relevant.

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

  • Yes. But
    • ‘NSW Startts’ is neither a trading name nor a business name.
    • ‘Responsible Persons’ is incomplete.

Who are the people controlling the organisation?

  • The 11 people here:
  • None of whom are the (two only) responsible persons shown on the ACNC Register:
    • Lachlan Murdoch
    • Richard Menteith
      • Richard is a director of Christian Management Advancement Ltd, the organisation that is introducing a set of standards for Christian organisations, compliance with which will allow display of the CMA Standards Council seal.
    • The constitution requires a minimum of eight directors.

To whom is STARTTS accountable?

  • To the ACNC.
  • And, as a company, to ASIC.

 

 

  1. Opinions vary on whether an internet invitation qualifies as ‘fundraising’.

Reventure Limited: mini-charity review

Mini-charity review of Reventure Limited (Reventure), an organisation that is connected, by the directorship of Jame Lewis, to the CMA Standards Council, Christian Management Australia’smajor new initiative, accrediting Christian organisations against a set of standards of good governance, financial oversight, and fundraising ethics.’

Is it responsive to feedback?

  • When sent a draft of this review, on 28 March 2017, they…did not respond.

Is it registered?

  • Yes, as a charity.
  • Reventure is a public company, a company limited by guarantee.
    • It does not have the necessary provisions in its constitution to allow it to omit ‘Limited’/’Ltd’ at the end of its name.
  • Reventure has a fully-owned subsidiary, Converge International Pty Ltd (Converge) a private company.
    • Converge has not registered the name it uses, Converge International.
  • No information was found to indicate that Reventure seeks donations from the public.

What does Reventure do?

  • In its own right: here.
  • Via its subsidiary: here.

Do they share the Gospel?

  • Although Reventure has a statement of faith in its constitution (although not on its website), it appears that it doesn’t share the Gospel – ‘Gospel’, ‘Jesus’, and ‘Christ’ do not appear on either website.

What impact are they having?

  • Nothing found, for either entity.

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

  • The information is not presented to allow this calculation – for either entity.

Can you get a tax deduction?

  • No

Is their online giving secure?

  • NA

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

  • NA

Is their reporting up-to-date?

  • Yes (two weeks late, seven and a half months after their year-end)

Does their reporting comply with the regulator’s requirements?

  • Annual Information Statement 2016 (AIS 2016): No
    • Most of the figures in the ‘Comprehensive Income Statement summary’ do not match those in the financial statements.
    • No outcomes are reported.
    • ‘Reventure Limited’ is not an ‘Other Name’.
  • Financial Report 2016: Yes. Consolidated financial statements, Reventure and its wholly-owned subsidiary Converge.

What financial situation was shown in that Report?

  • Profit as a percentage of revenue declined markedly, from 7% to 0.2%.
  • Working capital (current assets less current liabilities) improved slightly, but is still negative at 0.84.
  • Goodwill is 81% of the non-current assets.

What did the auditor say about the last financial statements?

  • He gave a ‘clean’ opinion[1].

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

  • ‘Phone’ is blank – but this is not compulsory information.
  • ‘Website’ is blank, but they don’t have to disclose it to the ACNC if they don’t want to.
  • ‘Reventure Limited’ is not an ‘Other Name’.

Who are the people controlling the organisation?

To whom is Reventure accountable?

  • To the ACNC.
  • And, as a company, to ASIC.
  • Converge: to ASIC.

 

 

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