Church Missionary Society Queensland With Northern NSW: charity review

This is a charity review of Church Missionary Society Queensland With Northern NSW (CMSQN), an organisation that seeks donations and is a member of Missions Interlink[1]. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

For the previous review, see here.

Are they responsive to feedback?

  • Other than an invitation to comment on the new website, CMSQN do not seek feedback, nor complaints other than about the behaviour of its staff.
  • Accountability is not mentioned on the website.
  • I sent them a draft of this review. They…did not respond.

Is CMSQN registered?

  • As a charity, yes.
  • As a Queensland incorporated association (IA18316) (even though the usual ‘Inc’ or ‘Incorporated’ is absent).
  • CMSQN operates, per the ACNC Register, in NSW and Queensland. But it is still not registered to fundraise in either of these states. Perhaps it believes that it is exempt?
  • It is ‘carrying on business’ in NSW, but still it doesn’t have the required registration (an ARBN).
  • CMSQN does not, per the ACNC Register, overseas. What about its missionaries? Plus the fact that the AIS 2017 says that money was sent overseas?

What do they do?

  • There’s not much on this published:
    • The information under ‘What we do’ is not about CMSQN specifically, but about CMS generally (represented by the charity Church Missionary Society – Australia Limited (CMS-Australia).
    • There is one sentence in the AIS 2017:
      • We have continued to encourage churches and individuals in Queensland and Northern NSW to get involved in cross-cultural mission.
    • The Committee’s Report gives the ‘principal activities’ as ‘community and missionary services.’

Does CMSQN share the Gospel[2]?

  • No.

What impact are they having?

  • No information found.

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

  • If ‘Missionary Support to CMS Australia’ is defined as the money that goes to achieve the impact, then 68% is administration (up from 65% last year).
  • If, as CMSQN imply by the two ‘Grants and donations made…’ lines in the AIS 2016, ‘Missionary – Branch Expenses’ and ‘Missionary – Federal Expenses’ should also be included, then the figure drops to 64%.
  • Either way, it is something that deserves an explanation, especially without any information on impact.

Do they pay their board members?

  • The CMSQN governing document does not prohibit this.
  • The expenses are not classified to allow us to say one way or the other.

Can you get a tax deduction?

  • Not for a donation to CMSQN.
    • Nevertheless, the giving page that they use is, without explanation, the one belonging to CMS-Australia, nd it does offer tax-deductible giving.

Is their online giving secure?

  • Security is still not mentioned.

Is their reporting up-to-date?

  • Yes (lodged seven months after their year-end, two days before the last day allowed).
    • 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 14 months ago.

Does their reporting comply with the regulator’s requirements?

  • AIS 2017: No
    • Like last year,
      • Two of the figures in the Income Statement do not match those in Financial Report.
      • The description of ‘activities’ is, except for one sentence that is common to other branches of CMS-Australia, largely about another charity (albeit an associated one).
      • No outcomes are given.
    • No answer is given to the last two questions in ‘Reporting to state or territory regulators’.
  • Financial Report 2017: No. Like last year
    • Its relationship with CMS-Australia – the organization that collects its online donations and receives its money for missionaries – is not explained.
    • The relationship between the missionaries that it has sent overseas, employees, and CMS-Australia, is not disclosed.
    • The directors have avoided having to comply with all the Accounting Standards by saying, without giving any reason, that CMSQN is not a reporting entity. This means that they believe that there are no users, present (including donors who gave a total of $1.69 m), or prospective, who rely on a regulator to get the information they need to make decisions. For an organization that receives $1.69 m in donations, operates in two states, and has 62 staff, this is implausible.
    • Statement of Comprehensive Income
      • The reimbursements in ‘Federal Expense Reimbursement’ would be more correctly shown as a deduction from the expenses rather than as revenue.
      • ‘Bookstore Sales’ and ‘Bookstore Purchases’ are included, but where is the other component(s) of cost of goods sold?
      • Bequests are not included as donations in the Statement of Cash Flows.
    • Statement of Financial Position
      • Loans from members are usually repayable on demand. Are these any different? Unless an irrevocable authority to defer repayment beyond 12 months is held, ‘Loans from members’ should be classified as a current liability, not a non-current liability.
      • There is no explanation of the ‘Fair Value Reserve’.
      • The Note on ‘Reserves’ does not match the figure in the balance sheet.
    • Statement of Cash Flows
      • Dividends are recognised ‘when the right to receive the dividend has been established’. Why then is the cash amount identical with the revenue.
      • Similarly, with interest?
    • Notes to the Financial Statements
      • There is no information on related parties (an ACNC expectation).
      • There are several other Notes missing.

What financial situation was shown by that Report?

  • The directors continued comfort with the Financial Report in the face of the issues above and a qualified audit opinion, has tipped me over to ‘No comment’.

What did the auditor say about the last financial statements?

  • The auditor, Liam Murphy of PKF Hacketts, was unable to give CMSQN a ‘clean’ opinion. Once again, he qualified the opinion:
    • In common with similar associations, it is not practical to establish control over receipts from donations and other fundraising activities, prior to their initial entry in the accounting records…
      • So, the practices of CMSQN give us no confidence that all the money that was given to CMSQN made it into the bank account.
    • If other branches of CMS-Australia, for instance Tasmania and Victoria, can avoid such a deficiency in internal controls, why can’t CMSQN?
    • Hundreds of reviews of Christian charities like this one, performed by us, show that this inability is the exception rather than the rule.

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

  • No
    • ‘Who the Charity Benefits’ is blank.
    • The Register is blank for ‘Operates in (Countries)’. This is inconsistent with the report of $723K sent overseas (AIS 2017).

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

  • In one sense, you have no choice – it all goes to another charity, CMS-Australia.
  • Your choices at that charity are
    • General Missionary Support’
    • ‘General Tax Deductible (sic) Gift’
    • ‘A particular worker’.
      • With a dropdown listing 93 singles/couples plus ‘Other’.
        • Those working for CMSQN are not identified, but under ‘Missionaries’ on the CMSQN webpage there are 73 singles/couples.
    • Other

Where were your (net) donations sent?

  • The (net) money given for overseas work (AIS 2017) matches the figure for ‘Missionary Support to CMS-Australia’. Beyond that, we are not told. (Presumably the bulk of it goes to CMSQN’s missionaries.)
    • The description of this expense doesn’t sound as if the tax-deductible money is included. Where’s that in the expenses?
  • So, if you give on the website, you give to CMS-Australia, the money is transferred to CMSQN, and then they transfer it back to CMS-Australia. Seems clumsy.
  • The destination of the balance of the money given for local work (AIS 2017) is not disclosed.

Who are the people controlling the organisation?

  • Not shown on the webpages, but per the ACNC Register (under ‘Responsible Persons’), they are:
    • Alison Barlow
    • John Hagidimitriou
    • Martin Hawkins
    • Ronald Herbert
    • Audrey Jordan
    • Peter Kidd
    • Colin Law
    • John Menear
    • Sheila Milton
    • Joy Palmer
    • Maxine Percival
    • Angus Robinson
    • Susan Smith
    • Simon Waller
    • Selena Yen
    • There are 11 directorships recorded for the name ‘Susan Smith’. And 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 CMSQN’s Susan Smith 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.  Especially if she has a full-time job.
    • The constitution requires a minimum of 16 ‘regional delegates to the Council’ [clause 7.1]. Combining this with the other compulsory inclusions [clause 6.2], means that the Council is well short of its required number.
  • The Board is responsible to the membership. The number of members is not disclosed.

To whom are CMSQN accountable?

  • As a charity, to the ACNC.
  • And to the Queensland incorporated associations regulator.
  • Although not mentioned on their webpage, they are also accountable as a Member of Missions Interlink.
    • For one opinion on the strength of this accountability, see the section Activities in this review.

 

 

  1. The entry in the list of members leads to a ‘404 Page not found’ message.
  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. 

Northpointe Baptist Church Incorporated: charity review

This is a charity review of Northpointe Baptist Church Incorporated (NBC), an organisation that has a public invitation to give. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

Conflict of interest

I am an active participant in the community that, many years ago, chose to incorporate as NBC.  However, neither myself nor my wife are, nor do we intend to become, members of the legal entity. Some conflict of interest remains though, so I have been careful to review this charity in the same way as I have reviewed every other charity.

Is it responsive to feedback?

  • There is no invitation, on the website, to submit feedback or complaints.
  • Accountability is not mentioned on the website.
  • I sent them a draft of this review. Here is their response:
    • Thanks for performing a charity review of Northpointe.  It is extremely useful to have, and we will use it to guide is through making necessary changes to the way things are administered, recorded and reported.  The church strives to be transparent and accountable in everything that is done.
    • They also gave some feedback. This has been included below the applicable comment.

Is it registered?

  • Yes, as a charity.
  • NBC is an Australian Capital Territory (ACT) incorporated association (A 04911).
  • It operates, per the ACNC Register, in Australia only in that territory.
  • It holds no business names. It therefore should to ‘trade’ only under its full name. Not like it does on its website and on Facebook.
  • The ACNC Register says that it operates overseas only in Vietnam. But the website says otherwise:

  •  Ministry comment: ‘Regarding operating overseas, we do support missionaries overseas, but this was not included in last years (sic) report as we didn’t visit or engage in any “operational” support during the year.  Vietnam was outlined as a mission trip there (sic) was organised during the year.’
    • Reviewer response: Providing funds is an activity for ACNC purposes.
  • It has no fundraising licences. Whether or not it requires one in a state that has a licensing regime applicable to charities, depends on whether that state believes that an internet invitation to give qualifies as ‘fundraising’.

What does NBC do?

  • The usual local church things: see ‘Missions’, ‘Ministries’, and ‘Our Message’ under ‘About’, all on the home page.

Do they share the Gospel[1]?

  • Yes

What impact are they having?

  • No information found.

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

  • The expenditure is not classified to allow an estimate of this figure.

Do they pay their board members?

  • There is nothing to prohibit this in the constitution.
  • The financial disclosure doesn’t allow a check for such payments.

Can you get a tax deduction?

  • No

Is their online giving secure?

  • It is not until the fourth page of the process that security is mentioned. And then in small print.
    • Stripe is used, so your payment should be secure.

Where were the (net) donations sent?

  • For only $12K of the $41K is this disclosed: ‘Manna (Vietnam Orphanage)’.
    • How does this relate to ‘GVI’ (above) and here?

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

  • ‘General Funds’
  • ‘Missions’
  • ‘GVI’
  • ‘Building Fund’

Is their reporting up-to-date?

  • Yes (four and a half months after their year-end, three weeks later than last year).

Does their reporting comply with the regulator’s requirements?

  • Annual Information Statement (AIS) 2017: No
    • The ‘Description of charity’s activities and outcomes’
      • is not about 2017 particularly, and
      • has no outcomes.
    • The ‘Accounting method…’ does not match the one that has been used.
    • ‘Donations and bequests’ does not match the figure in the Profit & Loss Statement.
    • There are again no figures under ‘Balance Sheet Extract’.
  • Financial Report 2017: Yes
    • But only because it has been voluntarily submitted to the ACNC, and voluntarily submitted reports do not need to comply with the ACNC legislation.
      • NBC’s doesn’t comply because it deviates materially from what is required by the accounting profession.
        • For instance, there are no Notes to the accounts or Directors’ Declaration, and there is significant confusion over the reporting framework.
    • The reviewer has also deviated materially from the requirements of his profession.
    • Ministry comment: ‘The committee will work to better understand and improve accounting practices’.

What financial situation was shown in that Report?

  • 44% of the expenditure went on the one full-time employee (Annual Information Statement (AIS)2017).
  • The next highest expenditure was ‘Missions’ plus ‘Love Offering’, 28%.
    • Much more than this could have been given – NBC again has a substantial sum in the bank ($149K).
      • No explanation is given for holding such a large sum.
  • The only other figure greater than $5K was ‘Music Ministry’, $17K (11%).
    • This seems a disproportionately large amount.

What did the auditor say about the last financial statements?

  • The auditor, Doug Burgess, Chartered Accountant, of BLM Accounting Services, concluded that
    • Based on our review, which is not an audit, nothing has come to our attention that causes us to believe that the annual financial report…does not present fairly, in all material respects, the Church’s financial position as at 30th June 2017 and of its financial performance for the year ended on that date in accordance with the Australian Accounting Standards as noted in note 1 (sic).
      • There is no ‘note 1’.
      • If not an audit why this stamp on the financial statements?

      • Under ‘Scope of Review’ he says that ‘With the exception of trade creditors the statements have been prepared on a cash bais (sic)’. This basis is not one that is recognised by the Standard-setters, and there is therefore no way that the statements ‘present fairly’ as he claims.
    • This review falls so far short of the accounting profession’s requirements for a review that it is difficult to have any confidence in his opinion.

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

  • No:
    • A PO Box number is not a ‘street address’.
    • The constitution contains neither of the two clauses necessary to make NBC a not-for-profit.
    • ‘Phone’ and ‘Website’ are missing (but the ACNC says that neither are compulsory.

Who are the people controlling the organisation?

  • Per the website:

  • Which listing has little correspondence with what is shown on the ACNC Register (under ‘Responsible Persons’):
  • Ministry comments: (1) ‘The committee is looking to have the web site better maintained and will aim have any needed changes incorporated. (2) There have been changes to the leadership team over the past few months and the web site update was missed.  Thanks for outlining that.

To whom is NBC accountable?

  • As a charity, to the ACNC.
  • And to the ACT regulator of incorporated associations.

 

  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.

Cosmos Healthcare Inc: charity review

This is a charity review of Cosmos Healthcare Inc (CH) an organisation that seeks donations online, 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?

  • There is no invitation, on the website, to submit feedback or complaints.
  • Their values include accountability, openness and transparency:

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

Is CH registered?

  • As a charity, yes.
  • CH is a WA incorporated association (No. A1010684A).
  • It holds no business names yet trades under the name Cosmos Healthcare.
  • CH operates, per the ACNC Register, only in Western Australia. It has a fundraising licence there. But nowhere else.
    • Whether it needs one in the other five states that have a licensing regime for charities depends on whether those states think that inviting donations via the internet is ‘fundraising’.

What do they do?

  • They describe themselves as, ‘an intercontinental healthcare organisation’, and ‘an international health and development organisation’. Read more here.
    • The ACNC Register confirms that they operate overseas only in Zimbabwe.
  • Here’s their ‘Description of charity’s activities and outcomes’ in the AIS 2017:
    • The organization supports financially a medical centre in Zimbabwe. We also send medical teams to assist local medical staff, for treatment of local people and to train local people.
  • More balanced, and detailed, is the description on GiveNow:

Do they share the Gospel[1]?

  • No
    • Which fits the absence of (a) ‘Advancing religion’ as one of the four ‘entity subtypes’ that CH have listed on the ACNC Register, and (b) Christianity in the description of its objects in the constitution.
    • But if the plan to implement Community Health Evangelism (CHE), a plan that has existed since at least the last review, comes to pass, sharing the Gospel will be integrated in their work.
      • How will this fit with the fact that the government allows their donors a tax deduction?

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, outside ‘Donations’, what portion, if any, of the other expenses were direct to healthcare delivery in Zimbabwe?
    • There is a figure ‘Administration’ ($12K), but other administrative expenses, like ‘Property’ and ‘Insurance’ are separate items.

Do they pay their directors?

  • There is nothing to prohibit this in the constitution.
  • The financial disclosure doesn’t allow a check for such payments.

Can you get a tax deduction?

  • Yes

Is their online giving secure?

  • Security is still not mentioned on the CH giving page, and after that page redirects to GiveNow, neither do their first two pages mention it.

Where were the (net) donations sent?

  • There is no information in the Financial Report.
  • Presumably, from information on the website, the money is sent to this organization.
    • Despite one of their four values being ‘Accountability’, neither ‘financial statement’ nor ‘audit’ is mentioned on their website.

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

  • ‘Extended Care Patients’
    • There is a list of these patients on the second page under ‘Credit Card’.
  • ‘Medicine Supply Campaign’
  • ‘General Donations – 2017/18’

Is their reporting up-to-date?

  • Yes (seven months after year end, again on the last day allowed).

Does their reporting comply with the regulator’s requirements?

  • AIS 2017: No
    • Cosmos Healthcare is not disclosed as an ‘other name’.
    • The ‘Description of charity’s activities and outcomes’ is not particularly about 2017.
    • No outcomes are reported
    • The state in which they intend to fundraise in 2018 is not shown.
  • Financial Report 2017[2]: No
    • The directors have decided to produce special purpose financial statements, the type of statements that do not have to comply with all the Accounting Standards. Given that this type is only appropriate when the users, both current and prospective, do not need a regulator to help them get the financial information they need, this decision is questionable.
      • The directors do not say why they think that “the association is not a reporting entity” (and is thus qualified to produce the lower standard statements).
    • The Statement by the Committee of Management does not comply with the ACNC’s requirements.
    • Several of the usual Notes are missing.

What financial situation was shown in that Report?

  • The deficit as a percentage of revenue was increased from 1% to 2%.
  • Relatively low liabilities (all current) means that both short- and long-term financial structure are sound.

What did the auditor say about the last financial statements?

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

  • Not quite – the name they use, Cosmos Healthcare, is missing.
  • Both the website and Facebook still have a different phone number: (08) 6168 1670.
  • It is unwise to use a personal email address as a ‘Charity Address for Service’.

Who are the people controlling the organisation?

  • Those listed here on the website.
  • Which is quite different from the list (under ‘Responsible Persons’) on the ACNC Register:

To whom is CH accountable?

  • As a charity, to the ACNC.
    • CH shows the ACNC’s ‘charity tick’ in its website header.
      • Apart from saying that CH is registered with them, the ‘tick’ also means that CH’s AIS is not overdue, and the ACNC has not taken any compliance action against it.
  • Not mentioned on the website, but they are a member of Missions Interlink.
    • For one opinion of the strength of this accountability, see the section Activities in this review.
  • CH is also accountable to the Western Australian regulator of associations.

 

 

  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. 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.

EA Insurance: charity review

This is a charity review of EA Insurance (EAI), an Associate member of Missions Interlink, ‘the Australian network for global mission’.

For last year’s review, see here.

Is EAI responsive to feedback?

  • In its ‘Complaints and Disputes Policy’, EAI says that it values feedback.
  • On its website, it talks about the accountability of others, but not of itself.
  • I sent them a draft of this review. Like last year, they did not respond.

Is EAI registered?

  • Not as an entity in its own right.
  • To receive charity tax concessions from the Australian Taxation Office (ATO), a charity must register with the ACNC. The company behind the EAI name (see below) appears to satisfy the requirements for registration, yet neither the company nor its owner (see below) say why it has not registered.
  • EA Insurance is a business name belonging to EA Insurance Services Pty Ltd (the company):

  • The company’s website uses one of the names above, EA Insurance Services.
  • The company is a not-for-profit, one that is wholly-owned by a charity, EA Foundation:

    • In the accounts of the charity, the company is, without explanation, referred to as EA Insurance Project Trust. This entity does not have an ABN.
    • The company is a proprietary company, one limited by shares rather than by guarantee.
    • As a ‘small proprietary company’, it only has to lodge financial reports in limited circumstances.
      • However, their Associate membership of Missions Interlink requires them to “have available for [their] members and supporters a clear and appropriate financial statement which has been approved by its auditor.”
      • Although you will not be donating to them, by insuring with them you are supporting their Christian cause, so are eligible to ask for this ‘financial statement.’

What does EAI do?

  • From the EAI website:
    • EA Insurance Services is a specialist provider of insurance and risk management services to Faith, Charity and Not for Profit organisations throughout Australia.
  • It describes itself as a ‘Christian organisation’.

Does EAI share the Gospel?[1]

  • It appears not.

What impact are they having?

  • No information on the website.
  • Nothing in the Financial Report of its owner.

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

  • No separate financial statements are published.

Do they pay their board members?

  • Neither constitution (without paying an ASIC broker) nor accounts are available to check.

Can you get a tax deduction?

  • NA – donations are not sought.

Is their online giving secure?

  • NA

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

  • NA

Where were your (net) donations sent?

  • NA

Is their reporting up-to-date?

  • Check with their regulator, ASIC.

Does their reporting comply with the regulator’s requirements?

  • Check with their regulator, ASIC.

What financial situation was shown in that Report?

  • No Report is publicly available.

What did the auditor say about the last financial statements?

  • No audit report is available.

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

  • NA

Who are the people controlling the organisation?

  • Not disclosed.

To whom is EAI accountable?

  • To Missions Interlink, because it’s an Associate member.
  • The company is accountable to ASIC.

 

  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.

Chinese Church Support Ministries Limited: charity review

This is a charity review of Chinese Church Support Ministries Limited (CCS), an organisation that seeks donations online and is an Associate member of Missions Interlink. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

You can read last year’s review here.

Is it responsive to feedback?

  • A ‘News from CCSM Australia’ post last year invited feedback from supporters.
  • There is no mention of accountability on the website that CCS shares.
  • I sent them a draft of this review. Like last year, they did not respond.

Is CCS registered?

  • As a charity, yes.
    • But still, over fourteen months after the last review, in its old name, Antioch Missions.
    • Not to be confused with the charity Antioch Missions International Inc.
  • CCS is a public company, a company limited by guarantee.
  • It has the provisions in its constitution to allow it to omit ‘Ltd/Limited’ at the end of its name, but has not registered as business names the other names it uses, CCSM or CCMS Australia
  • CCS operates, per the ACNC Register in New South Wales (NSW) and Western Australia (WA). Its registered office as a company is an address in WA (www.asic.gov.au,) so that explains the second state. But with an Australian Capital Territory (ACT) address for its ‘Charity Street Address’, why NSW?
  • Information in it its Annual Information Statement (AIS) 2017 shows that it believes that an internet invitation does not count as fundraising, so this probably explains, given its very small donations revenue, why it has no fundraising licences.

What do they do?

  • From the AIS 2017:
    • In Australia, every month we email prayer letters to supporters living in Australia, for purposes of educating those outside of China, about its needs. A major area where our donations are directed to is our Literature ministry which sees the printing of Bibles and Christian teaching material which is distributed throughout China. Organised teams for volunteers to go into China for short trips (2 weeks) to participate in Mercy Work projects, Prayer teams and Cross-Cultural-English Teaching ran throughout 2017 and will continue to do so in 2018. This is the main way that we get people outside of China into China to participate in supporting and serving China.

Does CCS share the Gospel?[1]

  • Presumably those who go on the ‘short trips’ (see above) share the Gospel if they get the opportunity.

What impact are they having?

  • No information found.

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

  • The AIS 2017 shows that it cost them $5K to send $16K (to China).

Do they pay their board members?

  • This is prohibited by the constitution.
  • There’s insufficient financial information disclosed to check for a payment.

Can you get a tax deduction?

  • No

Is their online giving secure?

  • Security is not mentioned, but PayPal is used, so the giving should be secure.

Where were your (net) donations sent?

  • This is not disclosed.
    • $16K is shown for ‘Grants and donations made for use outside Australia’. China, per the ACNC Register is the only overseas country in which CCS operates.

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

  • No choice is given online.

Is their reporting up-to-date?

  • Yes (seven months after year end, two days after the deadline, and two weeks later than last year).

Does their reporting comply with the regulator’s requirements?

  • AIS 2017: No
    • Except for a change of the years mentioned, the ‘Description of charity’s activities and outcomes’ is identical to last year. Which means that it is not specific to 2017.
    • No outcomes are reported.
  • Financial Report 2017: Yes
    • Their size means that they are not required to lodge a Financial Report.
    • But their Associate membership of Missions Interlink requires them to “have available for [their] members and supporters a clear and appropriate financial statement (sic) which has been approved by its auditor.”
    • Assuming that they complied, they could have lodged this ‘financial statement’ voluntarily, but they chose not to.

What financial situation was shown in that Report?

  • The AIS 2017 only has to disclose totals for assets, liabilities and equity (net assets). For CCS they are $25K, $8K, and $17K.

What did the auditor say about the last financial statements?

  • There is nothing to indicate that an audit was performed.

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

  • No
    • Antioch Missions is not the ‘Legal Name’.
    • A postal address is still given instead of the street address.
    • Chinese Church Support Ministries is not an ‘other name’.
    • ‘Phone’ and ‘Website’ are still blank – but the ACNC says that they are not compulsory.

Who are the people controlling the organisation?

  • Not mentioned on the website.
  • From ‘Responsible Persons’ on the ACNC Register, the same three as last year:
    • Daniel Bao
    • Murray Cameron
    • Hercus Graham (the wrong way round?)
    • The constitution allows the company to have only three directors.

To whom is CCS accountable?

  • As a charity, to the ACNC.
  • CCS is an Associate member of Missions Interlink. Missions Interlink has an accountability regime.
    • For one opinion on the strength of this accountability, see the section Activities in this review.
  • The constitution allows the company to have only three members, so if the three directors are members, there may be no accountability from the membership.

 

 

  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.

Asia Evangelistic Fellowship International Inc.: charity review

This is a charity review of Asia Evangelistic Fellowship International Inc. (AEFI), an organisation that seeks donations online and is a member of Missions Interlink. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

To see the situation last year, read this review.

Are they responsive to feedback?

  • Neither feedback nor complaints are invited via the website.
  • I sent them a draft of this review. Unlike last year, they…did not respond.

Is AEFI registered?

  • As a charity, yes.
    • AEFI is controlled by an entity called the (AEFI) ‘International Council’. The membership is not disclosed.
  • AEFI is a Western Australian incorporated association (A1007002D).
  • It has registered, as a business name, the name it uses on the internet, AEF International.
  • Apart from its office in Western Australia, AEFI operates, per the ACNC Register, in New South Wales and Victoria. AEFI also has an invitation to give on the internet.
    • It still does not have the registration necessary, an ARBN, to operate interstate.
    • It still does explain why it has no fundraising licences.
  • There are two countries shown on the ACNC Register additional to those to which AEFI sent money in 2017: China and Malaysia.

What does AEFI do?

  • The website and the AIS 2017 give the wrong impression. They make no distinction between AEFI and the national AEF organisations:

  • AEFI is the coordinating body for ‘the autonomous chartered national organisations and donor bases known as Asia Evangelistic Fellowship and other organsations started by/or affiliated with AEFI’ [the constitution, paragraph 6],
  • There is no other Asia Evangelistic Fellowship entity with an ABN, so it appears that AEFI acts as both this coordinating body – the ‘international office’ – and the local AEF organization.
    • Otherwise, why would AEFI be soliciting donations?

Does AEFI share the Gospel?[1]

What impact are they having?

  • Nothing systematic found.

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

  • ‘Donations and bequests’ were $339K (AIS 2017). ‘Net costs’ (a list of donation destinations) totalled $251K. That’s 74% to ‘the field’. Nowhere near 90%.
    • Is the reconciliation in the definition of ‘designated’? In other words, donations to ‘General’ are excluded? But if that is the case, why assume that people who are giving to ‘General’ are not expecting their donation to go to ‘the field’? There is no explanation on the giving page that ‘General’ is for administration expenses. In fact, elsewhere, the opposite is implied:

    • Either way, the 90% claim is deceptive.
    • It would be reasonable to ask them why if would not be more efficient for you to send the money direct to the destination.

Do they pay their board members?

  • There’s nothing prohibiting this in the constitution.
  • There’s no line item in the expenses that suggests that such payments were made.

Can you get a tax deduction?

  • The ABN record says no. But they accept donations for a third party:

  • GDG is a secular organisation.

Is AEFI online giving secure?

  • Despite saying in the review last year that they would put a statement about security, there still nothing said on the first page.

Where were your (net) donations sent?

  • For 92% of the money only a country is specified.
  • 70% goes to India (8% of the Indian total goes to an organization called ‘Destiny India’).
    • If we knew the state, we could search here to see if the money had been received.

Is their reporting up-to-date?

  • Yes (seven months after their year-end, two days before the (extended) deadline, and over a month 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 nine months in the past.

Does their reporting comply with the regulator’s requirements?

  • AIS 2017: No.
    • The activities described are not just those of AEFI; they include AEF organisations overseas.
    • No outcomes are reported.
  • Financial Report 2017: No.
    • Totally inadequate, as it has been for each of the four years that Reports that have required by the ACNC.
    • This is despite saying last year that a review in 2017 would ensure ‘that its financial reporting meets the requirements of all regulators.’
    • The reporting is not only well short of what the ACNC requires and, on any reasonable definition of ‘appropriate’, non-compliant with Mission Interlink’s standards, but it is also non-compliant with its own requirements (its constitution).
    • More is missing from the Report than is included:
      • Two of the four required financial statements.
      • No Responsible Persons Declaration.
      • No Notes
    • And the two statements that are included do not comply with the Accounting Standards – including basic accounting.
      • ‘Gross profit’ is not (Donations + Book Sales) less money sent overseas.
      • The ‘Futures Fund’ is not a liability:

  • The auditor is not qualified to do the audit, and the audit that he has done does not comply with the Australian Auditing Standards.

What financial situation was shown by that Report?

  • Because of the condition of the Report, no comment.

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

  • The auditor (the third one in as many years), Peter Attwell of Attwell Partners, issued a ‘clean’ opinion. But given the state of the Financial Report (see above), I wouldn’t put much store in this.
    • Peter is not a registered company auditor (asic.gov.au) so is not qualified to do this audit.

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

  • Almost – a PO Box number is not a ‘Street Address’.
  • It is unwise to use a personal email address as the ‘Charity Address for Service.’

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

  • General’
  • ‘AEFI Futures Fund’
  • ‘Solid Rock Cambodia Hospital’
  • ‘Support the General work of AEFI’ – duplicating the first choice
  • ‘Support a Missionary Trainee’
  • ‘Support a Child
  • ‘Support a Community Project’
  • ‘Support a National Worker’
  • There is a brief description of these elsewhere on the website.
    • ‘Nepal Earthquake Appeal’ is no longer an option, and the information on ‘Solid Rock Cambodia Hospital’ is out-of-date.

Who are the people controlling AEFI?

  • This is the way it should be (from the constitution):

  • But this is how it is:

  • You can meet the incumbents of these three offices here.
  • Why no mention of the International Council?
  • The constitution goes on to say that the International Council appoints the International Director and the Board of Directors.
  • But the other members of the Board are not shown.
  • The ACNC Register (under ‘Responsible Persons’) says that the following people are on the AEFI Board:

To whom is AEFI accountable?

  • Despite saying in response to last year’s review that ‘We are happy to state on our website that we are a member of Missions Interlink and also accountable to ACNC’, ’accountability’ is still not mentioned. Nor is Missions Interlink (other than in the newsletter (see below).
  • AEFI is accountable to the ACNC.
  • And to the Western Australian regulator of incorporated associations.
  • In its newsletter it correctly claims to be an ‘accredited member’ of Missions Interlink:

    • Missions Interlink is an organisation that has standards with which AEFI must comply.
      • For one opinion on the strength of this accountability, see the section Activities in this review.

 

 

  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. Last year I did not appreciate the distinction between AEFI and the national AEF organisations.

An update on ‘The curious case of Whitley College’

Two months ago I showed why Whitley College, although a registered charity, was not on the register of registered charities.  Mystery solved.

But today it’s still not there.  Two months later.  From wondering how a Baptist college could justify having any of its information withheld from the public gaze, I move to wondering what complexities could be involved to warrant such a delay by the ACNC.