Scripture Union Queensland: mini-charity review

Mini-charity review of Scripture Union Queensland (SUQ), an organisation that seeks donations online, and is accredited with the CMA Standards Council[1]. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

Are they responsive to feedback[2]?

Is SUQ registered?

  • As a charity, yes.
    • It has a subsidiary, Body Corporate for Hope Central. No ABN could be found for this entity.
  • SUQ is a public company, a company limited by guarantee.
  • It has many business names.
    • None are disclosed on the ACNC Register.
    • Only one, School Chaplaincy A.C.T., is disclosed on Australian Business Register.
  • Although it is permitted to omit ‘Limited/Ltd’ at the end of its name, it has no licence to trade under other than Scripture Union Queensland. The website and its social media pages contravene this.
  • It has no trademarks.
  • SUQ operates in Australia, per the ACNC Register, in Queensland and the Australian Capital Territory. It seeks donations on the internet, both on its own site, and on others (Good Company, Pro Bono Australia, Everyday Hero, and others?)
    • Whether or not it uses street collectors is not disclosed.
    • It only has a fundraising licence Queensland. There are five other states that have a licensing regime applicable to charities. SUQ doesn’t explain why they have only one licence.
  • SUQ, per the ACNC Register, does not operate overseas.

What do they do?

Does SUQ share the Gospel?[4]

  • Yes – but they are not meant to in the Chaplaincy program:

  • In the three years to 2013, complaints of proselytising were few:
    • The national rate is 13 complaints of proselytising per annum (three year average). With 2,900 schools having chaplains, the rate of proselytising complaints is 0.4 per cent per annum, and has been declining year on year. In 2013, there was one complaint nationally[5].
  • SUQ is required, by its accreditation with the CMA Standards Council (Standard 1.2) to have a statement of faith. There isn’t one on the website, nor is there a ‘What we believe’ section.

What impact are they having?

  • Nothing systematic found.
  • Standard 5.6 of the CMA Standards Council standards (see above) requires that regular program evaluations must be performed. There is no mention of these on the website.

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

  • SUQ says that 84% goes to ‘Programs’. By deduction this is ‘Chaplaincy expenses’ and the undefined ‘Ministry expenses’. The Financial Report 2016 does not have a sufficient level of disclosure to say whether there is any ‘administration’ in these two expenses.

Do they pay their board members?

  • The SUQ governing document does not permit this.
  • Note 10 says that they are not paid.
  • Expenses are not disclosed at a level that allows one to check for a payment.

Can you get a tax deduction?

  • The ABN record shows that you can claim a tax deduction for a donation both to SUQ and to its fund, Scripture Union Queensland Schools Ministry Fund.
    • The ‘Choose where my gift goes’ page, however, distinguishes between those causes that are ‘tax-deductible’ and those that aren’t.

Is their online giving secure?

  • They say, below the fold on the ‘Donate’ page, that ‘Your credit card details are never stored with us. They are sent straight to our payment processor over a highly secure connection.’ The name of the provider is not given.

Is their reporting up-to-date?

  • Yes (lodged four and a half months after their year-end, two months later 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 over 12 months ago.

Does their reporting comply with the regulator’s requirements?

  • Annual Information Statement (AIS) 2016: No
    • The financial information is for the group, not SUQ.
    • It incorrectly says that there is no consolidation of entities.
    • ‘Other Income…’ and ‘Employee expenses’ are incorrect.
    • The business names are omitted.
    • Outcomes are not mentioned.
    • Is it really the case that there are exactly 500 full time and 200 part time employees?
  • Financial Report 2016[6]: Yes.
    • But SUQ is ‘transparent and accountable to its stakeholders’, so here’s some changes that would result in a clearer picture of performance and position:
      • Disclose basic information on the subsidiary, Body Corporate for Hope Central [Note 19].
      • There is no other mention of this entity in the Financial Report, nor on the website.
      • There are only two incidental mentions of ‘Hope Central’ on the website. (A Google search reveals that it is the name of the building they occupy in Brisbane.)
      • Why no ABN?
      • This entity has negative equity (Note 20)?
      • Include all the disclosures required by the Accounting Standards for the Consolidated Statement of Comprehensive Income.
      • Likewise, the Consolidated Statement of Changes in Equity.
      • Separate ‘Other income’ from ‘Revenue’.
      • Although ‘Other income’ is only 4% of revenue, it would be interesting to know what is included in this $1.41 m.
      • Disclose fundraising expenses.
      • Use one of the two expense classifications allowed by the Accounting Standards, not a mixed classification.
      • Explain the major expenses, including ‘Marketing expenses’ and ‘Ministry expenses’ (the entire charity, as a ‘Christian’ charity, is a ‘ministry’.)
      • Disclose information about related parties. (There is only a Note on ‘Controlled entities’.
      • For instance, what is the relationship between SUQ and Scripture Union Australia? (it owes $145K).
      • Distinguish between ‘Objectives’ and ‘Principal activities’ in the Directors’ Report (and report on both).
      • Give a breakup of ‘Ministry Reserves’ (so that donors + know the purpose of retaining some of the profits for the future).
      • The fact that they can ‘appropriately manage and track chaplaincy and other ministry reserves internally’ is not relevant to a decision about whether to disclose information to stakeholders – external reporting should not be a management tool for an organisation of SUQ’s size and complexity.
      • It would be helpful if we knew how many ‘key management personnel’ shared the $619K.
      • Remove ‘Workers compensation insurance’ from the figure for employee benefits [Note 3].
    • Because of the above not immaterial issues, it is arguable that the financial statements are not ‘complete and accurate’, and therefore Arrow is not complying with Standard 6.1 of the CMA Standards Council standards (see above).

What financial situation was shown by that Report?

  • Surplus as a percentage of revenue increased from negative 10% to a little over zero positive.
  • ‘Cash and cash equivalents’ represents approximately two months of revenue.
  • Employee benefits was 77% of expenses.
  • Current assets as a multiple of current liabilities (working capital) was maintained at a positive 1.8.
  • With only $744K of non-current liabilities, long-term financial structure is, based on this report, sound.

What did the auditor say about the last financial statements?

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

  • No[7]
    • It is long overdue in selecting an ‘Entity Subtype’.
    • ‘Other Name(s)’ is missing the 11 business names.

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

  • ‘Where it’s most needed’
  • Two long lists under ‘Choose where my gift goes’, one for tax deductible projects the other for non-tax-deductible projects.

Where were your (net) donations sent?

  • There is no disclosure beyond ‘Chaplaincy expenses’ ($22.70 m) and ‘Ministry expenses’ ($4.68 m).

Who are the people controlling the organisation?

  • The people shown here.
  • The ACNC Register (under ‘Responsible Persons’) has two additional names, Sally-Ann Davis and Storme Vunderink:
  • There are eight (8) charities with a Ruth Limkin as a board member. Her LinkedIn profile says that she is also a director of Christian Super and, although not shown as a responsible person, Northside Christian College. So that’s at least ten directorships.
    • Seven of them belong to Bible Society Australia. (The only member of the Bible Society Australia_ACNC Group for which she is not a board member is Centre for Public Christianity.)
    • But the register only covers charities, not all not-for-profits, and of course doesn’t include for-profit organisations.
    • Therefore, if after eliminating the charities for which SUQ’s Ruth Limkin is not a director, you are left with the total being more than a handful, it would be legitimate for you to question whether her ability to discharge her fiduciary responsibilities is threatened.
  • The quorum for a board meeting does not meet the requirements of SUQ’s accreditation with the CMA Standards Council (Standards 3.2, 3.3).
  • The Board is responsible to the membership. When last disclosed (30 June 2016, Directors’ Report), there were 94 members.

To whom are SUQ accountable?

  • As a charity, to the ACNC.
    • Its ‘Charity Tick’ is used on the website in support of you giving to them.  And rightly so, because it would be unwise to give to a charity that is unregistered.   The ‘tick’ also means SUQ’s AIS is not overdue, and the ACNC has not taken any compliance action against it.
  • SUQ has gone beyond the charity tick, and achieved accreditation with the CMA Standards Council. It is therefore entitled to display their seal – see the website footer. For this is must abide by the Council’s  Principles and Standards of Responsible Stewardship.
  • SUQ is also accountable, as a company, to ASIC.

 

 

  1. SUQ is a Foundation Partner. At the announcement of the Foundation Partners, Steve Kerr, the Executive Director of CMASC, said “Foundation Partner status is tangible recognition and reward for their efforts – these are high quality organisations.” 
  2. I agree with Randy Alcorn [Money, Possessions, & Eternity, Tyndale, 2003] when he says that ‘Any Christian leaders who resist financial accountability make themselves suspect.’ [page 425].
  3. This is a contravention of, if not the letter then certainly the spirit, Standard 8.7 of the CMA Standards Council Standards.
  4. 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.
  5. This is the footnote to that quote: ‘These are government figures supplied at the Senate estimates hearing on 4 June 2014, reported at http://www.theguardian.com/world/2014/jun/09/ complaints-about-school-chaplaincy-programme-on-the-decline-fi gures-show (accessed 14 June 2014).’
  6. I use the Pinnacle Financial Statements, respected in the profession as providing a very sound basis for producing compliant financial reports. To this I add an assessment of materiality (both quantitative and qualitative), where the users being considered are donors.
  7. This means that SUQ is contravening Standard 2.4 of the CMA Standards Council Standards.

Arrow Leadership Australia Limited: mini-charity review

Mini-charity review of Arrow Leadership Australia Limited, an organisation that seeks donations online, and is accredited with the CMA Standards Council[1]. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

Are they responsive to feedback[2]?

  • I sent them a draft of this review on 4 January, with publication scheduled for 15 January. The Executive Director, Liam Glover, responded on 11 January. This was the substantive part of his response: ‘Thank you for taking the time to alert us to your observations. We will review in due course that which you have raised below.

Is Arrow registered?

  • As a charity, yes.
  • Arrow is a public company, a company limited by guarantee.
  • It has two business names, ILG Group, and Arrow Marketplace Connections.
    • Neither is disclosed on the ACNC Register.
  • Although it is permitted to omit ‘Limited/Ltd’ at the end of its name, it has no licence to trade under other than Arrow Leadership Australia. The website and Facebook page contravene this.
  • It has no trademarks.
  • Arrow operates, per the ACNC Register, throughout Australia. It seeks donations on the internet.
    • Whether or not it uses street collectors is not disclosed.
    • It has no State fundraising licences[3].
  • Arrow, per the ACNC Register, does not operate overseas.

What do they do?

  • See the first section here.
  • These are the programs that give effect to that ‘calling’.
  • Neither ILG Group or Arrow Marketplace Connections, Arrow’s two business names, are mentioned on the website.
  • There’s no annual report this year; next year one will be required because of their accreditation with the CMA Standards Council [Standard 8.2].

Does Arrow share the Gospel?[4]

  • No (they train Christians).

What impact are they having?

  • Nothing systematic found.
  • Standard 5.6 of the CMA Standards Council standards (see above) requires that regular program evaluations must be performed. There is no mention of these on the website.

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

  • The expenses are not disclosed in a way that allows an estimate of this.

Do they pay their board members?

  • The governing document does not permit this.
  • Expenses are not disclosed at a level that allows one to check for a payment.

Can you get a tax deduction?

  • No
    • This is contradicted by the donation page. Here it says that a donation to The Brian Coombs Sponsorship Fund entitles you to a tax deduction. This is because Arrow is collecting for a third party, the charity ‘Annabel Charitable Foundation’ (actually The Annabel Charitable Foundation Ltd or Annabel Foundation).
      • Arrow implies, here and elsewhere, that The Brian Coombs Sponsorship Fund is part of Arrow. Not only is The Annabel Charitable Foundation Ltd an unrelated charity, but the Fund does not even have an ABN. Their representations are therefore contrary to Standard 9.1 of the CMA Standards Council’s standards with which they must comply.

Is their online giving secure?

  • Security is not mentioned.

Is their reporting up-to-date?

  • Yes (lodged six months after their year-end, four days before the deadline, and the same time as 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 over 12 months ago.

Does their reporting comply with the regulator’s requirements?

  • Annual Information Statement (AIS) 2016: No
    • The Annual Information Statement (AIS) 2016 does not describe 2016’s activities, as it should, but just describes what Arrow does.
    • The business names are omitted.
    • Outcomes are not mentioned.
  • Financial Report 2016[5]: Doubtful.
    • With donors and participants in events numbering enough to produce revenue of over $1m, and operations throughout Australia, it is difficult to see how the directors could reasonably conclude, effectively, that all stakeholders, both past and prospective, have the capacity to ask the company to produce financial statements tailored to their individual needs.
    • Arrow is committed to “good governance, transparency and accountability” (as recognized by their recent accreditation with the CMA Standards Council), so you might make the following additional suggestions/comments to them:
      • Disclose the arrangement with The Annabel Charitable Foundation Ltd (see above), and the effect on the accounts.
      • Disclose information about related parties.
      • Include a Note on related parties.
      • What exactly was the issue that caused the auditor to qualify the accounts this year?
      • What changes were made, if any, to avoid last year’s qualification?
      • Use one of the two expense classifications allowed by the Accounting Standards, not a mixed classification.
      • Include all the disclosures required by the Accounting Standards for the Statement of Changes in Equity.
      • What was the reason for the prior period adjustment?
      • Include intangibles in the accounting policy Note.
      • Treat ‘Other income’ consistently between the Statement of Income and Expenditure and Other Comprehensive Income and Note 2.
      • Disclose fundraising expenses.
    • Because of the above not immaterial issues, it is arguable that the financial statements are not ‘complete and accurate’, and therefore Arrow is not complying with Standard 6.1 of the CMA Standards Council standards (see above).

What financial situation was shown by that Report?

  • Surplus as a percentage of revenue increased from 2% to 6%.
  • ‘Cash and cash equivalents’ represents 2.6 months of revenue (down from 3.6 last year).
  • Employee benefits was 40% of expenses (up from 37% last year).
  • Current assets as a multiple of current liabilities (working capital) was increased from 1.2 to 1.7.
  • Although there was only 18K of long-term assets, similar liabilities only totalled $4K.

What did the auditor say about the last financial statements?

  • The auditor, Peter Shields, for Saward Dawson, issued a qualified opinion (that is, not a ‘clean’ opinion).
    • Saward Dawson did not audit the previous financial statements. They said that this meant that they were ‘not in a position to express an opinion on the comparatives for 31 December 2015 as we are uncertain as to the extent of the unidentified errors in the 2015 balances and transactions, as well as the effects on the current year’s financial statements.’
    • It appears that this qualification is in response to this requirement in the Australian Auditing Standards:
      • If the auditor concludes that the opening balances contain a misstatement that materially affects the current period’s financial report, and the effect of the misstatement is not appropriately accounted for or not adequately presented or disclosed, the auditor shall express a qualified opinion or an adverse opinion, as appropriate, in accordance with ASA 705 [ASA 501, paragraph 11, www.aasb.gov.au].
    • The previous auditor also issued a qualified opinion. This was the ‘basis’ for that opinion:
      • As is common for organisations of this type, it is not practical for Arrow Leadership Australia Ltd to maintain an effective system of internal control over the collection of donations and other fund raising (sic) activities until their initial entry in the accounting records. Accordingly, our audit in relation to fund raising (sic) was limited to amounts recorded in the accounting records.
  • Silence on a similar deficiency this year means either that Arrow introduced controls over fundraising revenue, or the current auditor has different thresholds for a qualified opinion on this deficiency [ASA 510, paragraph 9, www.aasb.gov.au].

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

  • No
    • ‘Other Name(s)’ is missing the two business names.
    • The Secretary is included as a ‘responsible person’[6].

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

  • ‘Partnership Fund – Have your gift DOUBLED to equip Christian Leaders’
  • ‘Brian Coombs Sponsorship Fund’
  • ‘Arrow Leadership International Development’

Where were your (net) donations sent?

  • Money is collected for three programs. How much is spent on each is not disclosed.

Who are the people controlling the organisation?

  • The people shown here.
  • The ACNC Register (under ‘Responsible Persons’) has one additional name, Amanda Otten:
  • For only one of the directors with a LinkedIn profile, Adam Lowe, is their Arrow role mentioned.
  • As the Secretary, Amanda Otten is not a ‘responsible person’, she should not be included on the Register.
  • There are 171 charities with an Adam Lowe as a board member, and 13 with a Christopher Edwards. But the register only covers charities, not all not-for-profits, and of course doesn’t include for-profit organisations. Therefore, if after eliminating the charities for which Arrow’s Adam Lowe is not a director, and likewise for Christopher Edwards, you are left with the total being more than a handful, it would be legitimate for you to question whether their ability to discharge their fiduciary responsibilities is threatened.
  • The Board is responsible to the membership. When last disclosed (30 June 2016, Notes to the Financial Statements), there were 23 members. Directors are required to be directors (‘Governing document’), so it is effectively 14 people holding the directors accountable.

To whom are Arrow accountable?

  • As a charity, to the ACNC.
  • Arrow was recently accredited by the CMA Standards Council. It is therefore entitled to display their seal – see the website footer. For this right it must abide by the Council’s Principles and Standards of Responsible Stewardship.
  • Arrow is also accountable, as a company, to ASIC.

 

 

 

  1. Arrow is a Foundation Partner. At the announcement of the Foundation Partners, Steve Kerr, the Executive Director of CMASC, said “Foundation Partner status is tangible recognition and reward for their efforts – these are high quality organisations.” 
  2. Arrow do not invite feedback or complaints. This is contrary to Standard 8.7 of the CMA Standards Council’s standards with which they must comply.
  3. 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.
  4. “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.
  5. I use the Pinnacle Financial Statements, respected in the profession as providing a very sound basis for producing compliant financial reports. To this I add an assessment of materiality (both quantitative and qualitative), where the users being considered are donors.
  6. Although there is no specific requirement in the CMA Standards Council standards for the Register to be complete and accurate, there are other requirements that make it an entirely reasonable expectation.

Mount Tamborine Convention: mini-charity review

Mini-charity review of Mount Tamborine Convention (MTC), an organisation that seeks donations online, and is accredited with the CMA Standards Council (CMASC)[1] (a foundation member). (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

Are they responsive to feedback?[2]

  • I sent them a draft of this review. Although they ‘value complaints and feedback as a means of identifying and understanding how we can do things better’, and although their accreditation with the CMASC (above) requires that they ‘respond in a timely and appropriate manner’ to those who submit feedback, I did not get a response.

Is MTC registered?

  • As a charity, yes.
  • MTC is an incorporated entity, incorporated under The Religious Educational and Charitable Institutions Act of 1861.
    • Both its website and the ACNC Register says that it is a ‘basic religious charity’. Although the two most common types of incorporated entities, companies and incorporated associations, are not eligible for this status (and the consequent concessions), the ACNC says that MTC’s type of incorporation does not disqualify it[3]. Is this an oversight in the legislation?
  • It has three business names: Mount Tamborine Convention Centre, Mount Tamborine Conference Centre, and The Beacon on Tamborine.
  • MTC operates, per the ACNC Register, only in Australia, and then only in Queensland. But it seeks donations via the internet. It has a fundraising licence in Queensland, but does not explain why no licence is held in the other states that have a licensing regime.

What do they do?

  • There is no description under ‘About us’ on the website, but the main menu says that they run conventions, and implies that they also offer accommodation and meeting venues for hire.
    • The camping site is only available ‘as part of organised conferences and group camp bookings’, but the chalets are available to rent. It is unclear whether other facilities are similarly available.
  • They promote, on their site, the camps of various other Christian charities. These are within the ‘MTC precinct’. Does this mean that they are on MTC land? The relationship is not explained.
    • One of these other charities is TLF (Triumphant Life Fellowship).
      • There is no such organisation on the ABN register.
      • The link given leads to a seller of domains.
      • In the annual report the CEO reported that
        • ‘In April 2016 discussions began regarding the possibility of working more closely with TLF. This has now blossomed into a symbiotic relationship where MTC now owns and maintains the land and buildings, with TLC operating as a ministry sub-committee under the umbrella of MTCC.’
        • The information disclosed in the financial statements does not support this statement.
  • Their Annual Information Statement 2016 (AIS 2016), under ‘activities and outcomes’, mentions only the conferences they held:
    • Mt (sic) Tamborine Convention held three conventions on its property at Mount Tamborine during 2016 – The Easter Convention, the Spring Holiday Convention and the Senior’s Convention.

Does MTC share the Gospel?[4]

  • Both the conferences planned so far for 2018 appear to be directed at Christians.

What impact are they having?

  • No information found.
  • MTC present, on their website, the results of some McCrindle research showing the importance of camps to the church generally.
  • The terms of MTC’s accreditation with the CMA Standards Council require it to perform regular program evaluations. There is no mention of evaluation on the website.

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

  • Although MTC have chosen not to make their financial report available on the ACNC Register (see below), it is included in their MTCC 2016 Annual Report, and that report is available on their website.
  • ‘Administration’ is not disclosed.
  • And the expenses are not classified so as to allow an estimate.

Do they pay their board members?

  • Such payments are allowed by the constitution.
    • They are, however, prohibited under the terms of MTC’s accreditation with the CMA Standards Council [Standard 3.7].
  • Whether they were made is not disclosed.

Can you get a tax deduction?

  • No

Is their online giving secure?

  • Security is not mentioned.

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

  • None

Is their reporting up-to-date?

  • Yes (six months after year end, three days before the deadline, and at the same time as last year).

What did the auditor say about the last financial statements?

  • The auditor, Rod Wallbridge FCA, gave a ‘clean’ opinion.
  • However, before you decide how much comfort to take from this opinion
    • Read the next section, and
    • Read about audit opinions here and here.

Does their reporting comply with the regulator’s requirements?

  • AIS 2016: Almost – no outcomes are reported
  • Financial Report 2016: Yes
    • Because they have a revenue of at least $25oK their size is Medium. Ordinarily this would mean that they must lodge accounts (which have been at least reviewed). However, because they are a ‘basic religious charity’, they are exempt from reporting.
    • They did produce a financial report – it is included in their annual report that is available on their website – and could have lodged this voluntarily, but chose not to.
      • This is contrary to the spirit of the CMA Standards Council’s Standards.
    • They say that the financial statements ‘satisfy the financial reporting requirements of the constitution of [MTC]’. Here’s the relevant clause:
      • ‘On behalf of the MTC Board, the treasurer must, as soon as practicable after the end date of each financial year, ensure a financial statement for its last reportable financial year is prepared’ [Clause 13.2.2].
      • They have produced ‘a financial statement’, but this falls well short of what is required by the Australian Accounting Standards.
      • The auditor, a Chartered Accountant, says that the financial report ‘is prepared, in all material respects, in accordance with applicable Australian Accounting Standards to meet the requirements of the Entity’s constituting Letters Patent.’
      • This is the only reference by MTC, either in the financial report or on the website, to ‘letters patent’.
      • A Letters Patent under the same Act, The Religious Educational and Charitable Institutions Acts, 1861 to 1959, for The Baptist Union of Queensland, has no financial reporting requirements. Nor does the Act. So perhaps we can presume that this is MTC’s situation too?
      • As a Chartered Accountant, the auditor, Rod Wallbridge, is therefore obliged to follow the Australian Auditing Standards. These in turn require him to expect MTC to produce a full set of financial statements that are compliant with the Australian Accounting Standards.
      • MTC haven’t done this, falling short by quite a distance.
        • This means that these financial statements do not meet the requirements of their partnership with the CMA Standards Council (Standard 6.1].

What financial situation was shown in the financial report?

  • Last year’s deficit of 9% of revenue was repeated. And without comment.
  • Employee benefits increased from 37% to 52% of expenses.
  • Current assets as a multiple of current liabilities (working capital) declined from 1.8 times to 1.1 times.
    • Combined with the repeated loss, this is of concern. (But it went without comment.)
  • With zero non-current liabilities and land valued at $2.07 m, the longer term financial structure is sound.

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

  • Yes

Where were your (net) donations sent?

  • NA

Who are the people controlling the organisation?

  • Not shown on the website.
  • These are the ‘Responsible Persons’ shown on the ACNC Register:
    • Duncan Drew
    • Rodney Logan
    • Peter Moody
    • Suzanne Nelson
    • Anna Roberts
    • John Sheen
    • Graham Stenton
    • William Vine
  • It appears, from the Mt Tamborine Convention Annual Report, that John Sheen has replaced Wendy Phillpotts.

To whom is MTC accountable?

  • As a charity, to the ACNC.
    • Its ‘Charity Tick’ is used on the website in support of you giving to them (and on most other pages).  And rightly so, because it would be unwise to give to a charity that is unregistered.  The ‘tick’ also means MTC’s AIS is not overdue, and the ACNC has not taken any compliance action against it.
  • MTC has gone beyond the charity tick, and achieved accreditation with the CMA Standards Council. It is therefore entitled to display their seal – you can see this on the right-hand side of most pages. For this privilege is must abide by the Council’s  Principles and Standards of Responsible Stewardship.

 

 

  1. MTC is a Foundation Partner. At the announcement of the Foundation Partners, Steve Kerr, the Executive Director of CMASC, said “Foundation Partner status is tangible recognition and reward for their efforts – these are high quality organisations.” 
  2. I agree with Randy Alcorn [Money, Possessions, & Eternity, Tyndale, 2003] when he says that ‘Any Christian leaders who resist financial accountability make themselves suspect.’ [page 425].
  3. Email from the ACNC, 8 January 2018.
  4. 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.

Perth Bible College Inc: mini-charity review

Mini-charity review of Perth Bible College Inc (PBC), an organisation that invites you, on its website, to donate to it, and is a member of Missions Interlink. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

For the previous review, see here.

Is it responsive to feedback?

  • I sent them a draft of this review. Like last year, they…did not respond.

Is PBC registered?

  • As a charity, yes[1].
  • As a WA incorporated association (A0390019Y).
  • Its website and social media sites are in the name Perth Bible College. As this is still not registered as a business name, they are still contravening both the business names legislation and their enabling legislation.
  • They do have two business names though: International Mission Teams and Centre for Biblical Counselling.
  • PBC still doesn’t have a fundraising licence in the state in which, per the ACNC Register, it operates. Nor in any of the other states that have a licensing regime applicable to charities[2].

What does PBC do?

Do they share the Gospel?[3]

  • 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 expenses are not classified to allow this calculation; for instance, personnel costs are not classified by the function of the employee.

Do they pay their board members?

  • Such payments are not prohibited by the constitution.
  • It doesn’t look as if such payments are made.

Can you get a tax deduction?

  • Yes

Is their online giving secure?

  • PayPal is used, so yes.

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

  • General College Donation’
  • ‘Library Donation’
  • ‘Student Scholarship Fund’
  • ‘International Mission Teams’

Is their reporting up-to-date?

  • Yes (four and a half months after year end, two months earlier than last year).

Does their reporting comply with the regulator’s requirements?

  • AIS 2016: Not quite.
    • Two figures in the ‘Comprehensive Income Statement summary’ are incorrect.
    • The business names are missing.
    • No outcomes are reported.
    • ‘Email address’ is blank
  • Financial Report 2016: No. Again this year
    • PBC produce special purpose financial statements, implying that any stakeholder can command PBC to prepare financial statements to suit them. As a bible college with a revenue of $1.08 m this is unlikely.
    • There is no Statement of Changes in Equity
    • The Statement of Profit or Loss is incorrect:
      • no ‘Other comprehensive income’ is shown.
      • ‘Assets written off’ have been excluded from expenses.
      • ‘Donations’ are not ‘Other Income’.
      • there is no calculation of ‘employee benefits expense’.
      • neither buildings nor the library are depreciated.
      • it uses a mixed classification for expenses.
    • The Notes to and forming part of the accounts (sic)
      • are missing many Notes.
      • do not tell us why the directors think that PBC is not a reporting entity.
      • contain a ‘Going Concern’ Note that doesn’t address the going concern assumption.
      • do not explain the relationship between PBC and the other educational institutions with which it is associated.
    • The Statement of Financial Position
      • has a confusing (non-standard) classification of current liabilities, and
      • divides, without explanation, the liabilities that are not current into ‘Non-Current Liabilities’ and ‘Long Term Liabilities’.
      • There is no evidence of a Gift Fund.
    • The Statement by the Board
      • gives a qualified opinion on the ability of PBC to pay its debts, and
      • doesn’t mention the ACNC Act.

What financial situation was shown in that Report?

  • A deficit of 10% of revenue was turned into a surplus of 4% of revenue.
  • ‘Personnel expenses’ were 68% of expenses (67% last year).
  • Working capital (current assets less current liabilities) was made positive by borrowing more money.
  • The long term financial structure, because of the land and (undepreciated) buildings they hold, is much healthier than the short-term structure.

What did the auditor say about the last financial statements?

  • The auditor, Geoffrey Carslake, for Shreeve & Carslake, gave a ‘clean’ opinion.
    • But before you decide how much comfort to take from this, have a look again at the section above, ‘Financial Report 2016’, to see what he was happy with.

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

  • Ethiopia is missing from ‘Operates in (Countries)’.
  • The board (see Responsible Persons) is, compared to the constitution, one member short.
  • ‘Email’, ‘Phone’ and ‘Website’ are blank.

Where were your (net) donations sent?

  • Although they operate in four countries other than Australia, the AIS 2016 discloses grants as zero. What do they do there?

Who are the people controlling the organisation?

To whom is PBC accountable?

  • As a charity, to the ACNC.
  • Missions Interlink, because it’s an Associate member.
    • For one opinion on the strength of that accountability, see the section Activities in this review.
  • And to the Western Australian associations regulator.

 

 

 

  1. Still with a slight mistake in the name though – there are no brackets.
  2. 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.
  3. “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.

Slavic Gospel Association Inc: mini-charity review

Mini charity review of Slavic Gospel Association Inc (SGA), an organisation that seeks donations and is a member of Missions Interlink. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

(For the situation last year, read the review here.)

Are they responsive to feedback?

  • I sent them a draft of this review. Their comments have been included below.

Is SGA registered?

  • As a charity, yes.
  • As a Victorian incorporated association (A0027142A).
    • It’s ABN record is therefore still wrong in saying that SGA is unincorporated.
    • Incorporated as The Slavic Gospel Association Inc. (emphasis mine), not as both the Australian Business Register and the ACNC continue to report.
      • Ministry comment: ‘Slavic Gospel Association Inc ( since 1993)
  • It uses the names Slavic Gospel Australia, and Slavic Gospel Association, without them being registered as business names.
    • It’s enabling legislation also requires the full name, and only the full name, to be used on all publications.
  • SGA operates – per the ACNC Register – in all states that have licensing regime for charities that are fundraisers except Tasmania. It still has no fundraising registrations[1].
  • If it’s ‘carrying on business’ outside Victoria, as it appears to be, then it still doesn’t have the required registration (an ARBN).

What do they do?

  • From the Board members’ report (in the Financial Report 2016):
    • During the financial year the principal continuing activities of the incorporated association consisted of:

● to promote the needs of the rapidly growing Church in the lands of the former Soviet Union

● raising funds to assist equipping and training Christian workers

● building Houses of Prayer for worship and outreach

● and the offering of humanitarian aid wherever possible.

  • See ‘Ministry Areas’ on the right-hand side of the home page.
  • SGA operates overseas – per the ACNC Register – in Belarus, Russian Federation, Ukraine, and Uzbekistan. The AIS 2016 says that its ‘international activities’ are ‘Transferring funds or goods overseas’, and the website confirms that this is the extent of their operations in these countries.

Do they share the Gospel?[2]

  • No
    • Ministry comment: ‘Yes’

What impact are they having?

  • Nothing systematic found. (There are stories of change in the countries to which SGA sends money in the Slavic Gospel News on the website.)

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

  • If we define ‘direct’ as ‘Designated gifts distributed’ (there were no undesignated gifts distributed), ‘administration’ is 26% of expenses.

Do they pay their board members?

  • Such payments are not prohibited by the constitution.
  • The disclosure of expenses is insufficiently detailed to allow the question to be answered.
    • Ministry comment: ‘Board members are not paid.’

Can you get a tax deduction?

  • No

Is their online giving secure?

  • Such giving is not offered.
    • Ministry comment: ‘All donations are receipted, acknowledged with a letter. Receipts not required by supporters (to save postage) are filed into their personal folders.’

Is their reporting up-to-date?

  • Yes (lodged four months after their year-end). (But again, its incomplete.)
    • 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 nearly 12 months ago.

Does their reporting comply with the regulator’s requirements?

  • AIS 2016: No
    • The description of the type of financial statements is still incorrect.
    • Most of the figures in the ‘Comprehensive Income Summary’ are incorrect.
    • There are still no outcomes reported.
  • Financial Report 2016: No.
    • There is no audit report.
    • The Board members’ declaration is unsigned.
    • There are several more minor issues.

What financial situation was shown by that Report?

  • The surplus as a percentage of revenue was reduced from 3% to negative 2%.
  • ‘Employment expenses represented 15% of expenses.
  • Current assets are 1.5 times current liabilities.
  • The long term financial structure, thanks to the ownership of unencumbered land and buildings, is sound.

What did the auditor say about the last financial statements?

  • Last year there was only an audit report; this year the Financial Report is missing an audit report.

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

  • No:
    • Their name is incorrect.
    • They still haven’t selected a subtype of charity[3].

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

  • None given on the website.

Where were your (net) donations sent?

  • This is not disclosed.

Who are the people controlling the organisation?

  • On the website, as well as on the ACNC Register (under ‘Responsible Persons’), it’s these people:
    • Douglas Brown
    • Harry Caudasko (should be ‘Chudasko’)
    • Peter Dubyna
    • Ralph Hewes
    • Larissa Porublev
      • Ministry comment: ‘Public officer’
    • Nickolai Porublev
    • Bruce Ronalds
      • Is it this Bruce Ronalds?
    • Alexander Shevchuk
  • Unless Larissa is a committee member, not just the Public Officer, she should not be in the ACNC list.
    • Ministry comment:
      • ‘Peter Dubyna – SGA Board Secretary
      • Larissa Porublev – Public Officer’
  • As the membership of SGA is limited to board members, there is no accountability there.

To whom are SGA accountable?

  • As a charity, to the ACNC.
  • As an association, to the Victorian regulator of incorporated associations.
  • Membership of Missions Interlink claimed on the website is confirmed. Missions Interlink has a general accountability regime.
    • For one opinion on the strength of this accountability, see the section Activities in this review.

 

 

  1. The law in this area is not straightforward and advice varies, so check with the charity before drawing any conclusions.
  2. 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.
  3. Their trading name is missing, but this is of little consequence nowadays; ‘Phone’ and ‘Website’ are blank, but these are not compulsory.