Second Wind Network: mini-charity review

Mini-review of Second Wind Network (SW), a member of Missions Interlink, an organisation that, among other things, gives members income tax exemption even though they do not meet the “in Australia” test and do not have deductible gift recipient status.

See here for last year’s review.

Is it responsive to feedback?

  • When sent a draft of this review, on 19 June, they…did not respond.

Is SW registered?

  • As a charity, yes.
  • SW is an unincorporated entity.
  • It is not registered for GST, so its gross income should be less than $150K.
  • It has its name registered as a business name.
  • It operates (per the ACNC Register) in Queensland. It does not appear to fundraise, so needs no fundraising licences.

What do they do?

  • See here.
  • SW were looking for new ‘National Directors’ from at least early 2014. I don’t think they found them.
  • What they did in 2016 (from the Annual Information Statement (AIS) 2016):
    • Conducted an elective seminar at a church Missions expo to promote the Second Wind concept. Continued to maintain the website as a portal for enquirers looking for opportunities in mission.
  • The ‘portal’, the Mission Matching Service they established, was handed over to Missions Interlink last year.

Do they share the Gospel?

  • No.
  • Although the ‘primary objects’ in the constitution make no mention of Christianity, let alone spreading the Gospel, the ‘primary requirement’ for new board members does:
    • ‘members will have a passionate heart for God and world mission and a belief that people in their 40s and upwards have a significant contribution to make to the completion of the Great Commission [Constitution, clause 3.2].

What impact are they having?

  • No information found.

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

  • The financial information in the AIS 2016 does not allow this calculation. (But minimal trade means that the question is largely academic.)

Can you get a tax deduction?

  • No

Is their online giving secure?

  • NA (SW no longer calls for donations on its website.)

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

  • NA

Is their reporting up-to-date?

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

Does their reporting comply with the regulator’s requirements?

  • AIS 2016: Almost – no outcomes are reported
  • Financial Report 2016: NA
    • As a ‘Small’ charity, SW does not have to lodge a Financial Report.
    • SW could have voluntarily lodged their report with the ACNC, but they chose not to.
    • There is no ‘financial statement’ on the website.
      • As a member of Missions Interlink, SW must ‘have available for its members and supporters a clear and appropriate financial statement which has been approved by its auditor [Standards Statement, 4.1].

What financial situation was shown in that Report?

  • NA
    • In the AIS 2016: $150 revenue, $2,130 expenses, $4,768 assets (no liabilities).

What did the auditor say about the last financial statements?

  • NA

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

  • Almost – their business name is missing.
  • “Phone” and “Website” are blank, but neither are compulsory.

Who are the people controlling the organisation?

  • Not shown on the website.
  • Per the ACNC Register (‘Responsible persons’):

To whom is SW accountable?

Bridgeway Publishing Foundation Trust: mini-charity review

Mini-review of Bridgeway Publishing Foundation Trust (BP) as 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.)

See here for last year’s review.

Is it responsive to feedback?

  • When sent a draft of this review, on 19 June 2017, they one correction. Additional information was added as a result.

Is BP registered?

  • As a charity, yes.
  • BP is an unincorporated entity.  It is a trust, governed by a trust deed.
  • It operates (per the ACNC Register) in NSW, Queensland and Victoria. It asks for donations on the internet.  It has no fundraising licences[1][i].
  • BP trades under the name ‘Bridgeway Publications’. Although an ASIC search shows this name as being owned by three of the five directors, this appears to be a limitation of the ASIC system – BP have shown that it is owned by all five.

What do they do?

  • See here.
  • They included this comment in last year’s review:

How Bridgeway works

The way Bridgeway works is that volunteer couples pack and post books and handle the correspondence with those who receive the books and those who sponsor them, but also encourage Christians here in Australia to pay for them. We have no staff, no office, no vehicles, no equipment, no independent funds. We all work from our homes, yet over the years we have been able to send over a million books to people all over Africa and Asia.

From time to time we get some additional gifts of money that we can pass on. Out of the thousands of people who’ve received Bridgeway books, we have over the years been gradually forming a group of people and ministries (more than seventy in number, and spread around more than twenty countries of Africa and Asia) who to us are special in some way and to whom we may send a gift of money every now and then. Nothing regular. This money comes from a variety of people, some anonymous, some who give to Bridgeway.

Do they share the Gospel?

  • No.  The trust deed says the fund is to help those who are already Christians:
    • The Founder wishes to establish a non-profit fund exclusively for the purposes of providing money, literature, property and/or benefits to or for Christians, Christian Churches and Christian organisations in developing countries and nations.

What impact are they having?

  • No information found.

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

  • No financial information is published.  (No Financial Report is required due to BP size; no financial information is required in the Annual Information Statement because BP is a basic religious charity.

Can you get a tax deduction?

  • No

Is their online giving secure?

  • NA

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

  • None

Is their reporting up-to-date?

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

Does their reporting comply with the regulator’s requirements?

  • AIS 2016: Almost – no outcomes are reported
    • The description of activities is the same as for 2014 and 2015.  Last year BP said that this was because the activities do remain the same year to year.
    • The usual financial information is absent because, as a Basic Religious Charity (see below), BP is exempt from supplying any such information (and chose not to submit it voluntarily).
  • Financial Report 2016: NA
    • Even if they weren’t a Small charity, and therefore exempt from lodging a Financial Report, they would still be exempt because of their status as a Basic Religious Charity.
    • BP could have voluntarily lodged their report with the ACNC, but they chose not to.
      • The trust deed requires an annual audit, and because the fund is a ‘non-profit public fund’ that solicits donations from the public, it seems reasonable that the public have access to the result.
      • Although not mentioned by it on its website, BP is a member of Missions Interlink. One of their requirements is that members ‘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 again public access would seem to be reasonable.
        • Last year BP commented that We have no issue with fulfilling Mission Interlink’s requirements and have provided appropriate financial information on supporter’s requests in times past.”

What financial situation was shown in that Report?

  • NA

What did the auditor say about the last financial statements?

  • NA

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

  • Yes
    • Even though BP supplies ‘money, literature, property and/or benefits’ to multiple overseas countries, it has decided that, for the ACNC’s purposes, it does not operate overseas.
    • Last year they said ‘We understand the need to be listed as medium size charity as a result of increased support in the last 2 financial years.”  They have yet to make the change.

Who are the people controlling the organisation?

  • Not shown on the website.
  • Per the ACNC Register (‘Responsible persons’):
    • Michael Conolly
    • Gordon Cowell
    • Donald Fleming
    • Ian Fletcher
    • Stephen Stathis

To whom is BP accountable?

 

 

  1. The law in this area is not straightforward – is an internet invitation ‘fundraising’ for instance? – and advice varies, so check with the charity before drawing any conclusions.

The Trustee for Crossway Kingdom Fund: mini-charity review

Mini-charity review of The Trustee for Crossway Kingdom Fund (CKF), an organisation that is connected, through the cross directorship of John Peberdy, to the CMA Standards C0uncil, Christian Ministry Advancement Ltd‘s  ‘major 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 18 June 2017, they…did not respond.

Is it registered?

  • Yes, as a charity.
    • The trustee is Crossway Baptist Church (CBC)
      • For some unexplained reason, the trustee does not consolidate the affairs of the Fund, and has not taken advantage of the ACNC’s ‘Group reporting’ concessions.
  • CKF is a public ancillary fund, a fund that collects tax deductible donations and gives them to funds who have Deductible Gift Recipient status[1].

What does CKF do?

  • The only information available, including on the CBC website, is OKF’s ‘Description of charity’s activities and outcomes’ in their Annual Information Statement (AIS) 2016:
    • Crossway Kingdom Fund distributed funds in the 2016 year to eligible entities for the purposes of supporting – building project for a DGR charity – missionary work – ACCESS Ministries.
      • The ‘DGR charity’ was Crossway Lifecare Ltd, another charity controlled by CBC. It received 96% of CKF’s distributions.
      • Given that ACCESS Ministries has DGR status, that status means that it shouldn’t be doing ‘missionary work’.

Do they share the Gospel[2]?

  • No – and nor should the recipients of their grants.

What impact are they having?

  • No information is available.

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

  • There is no mention of impact in CBC’s publications.
    • Expenses other than ‘Distributions’ were less than one percent of expenses.
      • But ‘Employee expenses’ were zero.

Can you get a tax deduction?

  • Yes

Is their online giving secure?

  • CKF has no website. (Giving to CKF is one of the options on the CBC website. Giving there is secure.)

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

  • NA (and none when giving via the CBC website).

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: Not quite
    • No outcomes are reported
    • ‘Interest’ is reported as ‘Other income’.
  • Financial Report 2016:
    • Only if you believe that the decision, by the directors of a ‘Large’ public ancillary fund, to produce the lower-standard financial statements, is correct. (The decision implies that all users, both present and prospective, can command the preparation of a financial report tailored to their needs.)
    • The Report is shy a few of the Notes that are expected.

What financial situation was shown in that Report?

  • The surplus as a percentage of revenue declined from a high 31% to a more typical 9%.
  • Minimal short-term and no long-term liabilities.

What did the auditor say about the last financial statements?

  • He gave a ‘clean’ opinion.

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

  • Almost: No ‘Entity Subtype’ is given.
  • ‘Email’ and ‘Website’ are blank, but neither are compulsory.

Who are the people controlling the organisation?

  • Given that CBC is the trustee I would have thought that its directors would be the directors of CKF. But it’s not quite the same set. From the ACNC Register (under ‘Responsible Persons’):
    • Matthew Buntsma
    • David Caldera
    • Mark Churchward
    • Edward Harrison
    • Francis Hoe
    • Kok Looi
    • Scott Pilgrim
    • Margaret Spicer
    • Dale Stephenson
    • Beth Strybosch
    • Timothy Wilson
    • Michael Yap
    • 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’ (there are 12 but five are for the same charity).  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 CKF 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 CKF accountable?

  • To the ACNC.
  • As a public ancillary fund, to the ATO.

 

 

  1. The ‘Entity type’ they have selected on their ABN record, ‘Discretionary Investment Trust’, is therefore, even though one of the choices recommended by the ACNC, perhaps not the most appropriate one.
  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.] 

Baptist Union of Victoria: mini-charity review

Mini-review of Baptist Union of Victoria (BUV) as an organisation that seeks donations online for their Grow-Give-Go campaign. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

BUV is also an organisation that is connected, by the cross-directorship of Jame Lewis, to Christian Ministry Advancement Ltd, the organization that is responsible for the CMA Standards Council’s ‘major 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 15 June 2017, they…did not respond.

Is BUV registered?

What do they do?

Do they share the Gospel?

  • No. (Not their mission.)

What impact are they having?

  • Despite promoting a book with the subtitle The Six Practices of High-Impact Nonprofits, there is no indication that BUV are even assessing their impact.

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

  • From the classification of expenses used by BUV there is no clear way to even estimate this percentage.

Can you get a tax deduction?

  • Only if you give to its Fund, the Refugee Airfare Loan Scheme.

Is their online giving secure?

  • Grow-Give-Go: If it is, it’s not mentioned until after you have entered your information on the first page.
  • Refugee Airfare Loan Scheme: donations are invited but no facility provided.

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

  • None

Is their reporting up-to-date?

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

Does their reporting comply with the regulator’s requirements?

  • AIS 2016: No
    • No outcomes are reported.
      • And ‘Empowered the leaders of Victorian Baptist Churches for mission.’ is not very helpful as a description of 2016’s activities.
    • Two business names are missing.
    • No explanation is given for the omission of ‘Other comprehensive income’.
  • Financial Report 2016: No
    • The directors give no explanation for their decision that ‘the Union is not a reporting entity’, that is, they have no users dependent on general purpose financial statements to make their decisions about BUV.
    • The decision allows them to produce the lower standard special purpose financial statements. This is only the correct decision if any of BUV’s users, either present or prospective, can request BUV to tailor a financial report to their needs. With a paid staff of 36, ‘constituents’ collectively paying $1.00 m for membership, and control of six significant charities, this is not plausible.
    • The Councillors’ Report (in the Financial Report 2016) says that ‘Insurance reserves totalling $539,321 were written back and taken up as revenue in 2016’. To do so is contrary to basic accounting, there is no ‘insurance reserve’ shown in the accounts, and there is no such movement in reserves.
    • The division of equity between ‘Unrestricted Fund’ and ‘Reserves’ implies that the amounts in the latter are restricted. However, well over half of the total are ‘restricted’ only by ‘internal rules and charters’, that is, are free to be used by BUV at their discretion.
    • The ‘Related Parties’ Note does not mention either Global Interaction (page two of the Financial Report) or Now and Not Yet Inc (also page two).
    • ‘Other’ under Revenue is 16% of the total. A bit large to be unexplained.
    • $431 K was paid in interest yet there are no loans.
    • Why is the increase in trust funds included as a financial activity in the Statement of Cash Flows?
    • The classification of the $38.95 m of investments does not follow that required in the Accounting Standards.

What financial situation was shown in that Report?

  • Remembering that the Report, due to the omission of controlled agencies, falls far short of showing the true position of BUV…
    • A negative return on revenue (-5%) was reversed (3%).
    • ‘Remuneration’ – presumably ‘employee benefits expense’ – declined from 56% of expenses to 49%.
    • Working capital (current assets less current liabilities) remained slightly positive at 120%.
    • Long-term liabilities are minimal compared to long-term assets.

What did the auditor say about the last financial statements?

  • He gave a ‘clean’ opinion.
    • But he agrees with the directors’ decisions not to consolidate and to produce that the lower standard special purpose financial statements are appropriate (see ‘Does their reporting..’, above).

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

  • Almost. It is missing information under ‘Other Name(s)’.
  • ‘Phone’ and ‘Website’ are blank, but neither are compulsory.

Who are the people controlling the organisation?

  • There is an organisation chart on the website, and a page on governance, but neither include the members of the board (Council).
  • Per the ACNC Register (‘Responsible persons’), it is currently these people who control BUV:
    • Jo-anne Bradshaw
    • Mark Browning
    • Daniel Bullock
    • Allan Demond
    • Fiona Hall
    • Darryl Kilker
    • Michael Turnbull
    • Debbie Uy
    • Jame Lewis
      • Jame 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 eight directorships recorded for the name ‘Allan Demond’. And the register only covers charities, not all not-for-profits, and no for-profit organisations. Therefore, if after eliminating the charities for which Allan is not a director, you are left with the total being more than a handful, it would be legitimate for you to question whether his ability to discharge his fiduciary responsibilities is threatened.

To whom is BUV accountable?

 

 

  1. A Financial Report normally identifies the organisation’s enabling legislation; the directors do not mention it in the 2016 Report.
  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.

Christian Ministry Advancement Ltd: mini-charity review

Mini-charity review of Christian Ministry Advancement Ltd (CMA), as an organisation that seeks donations on the internet. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

CMA is also the organisation that is, via the CMA Standards Council, giving a seal of approval to Christian organisations who meeta set of standards of good governance, financial oversight, and fundraising ethics.”[1]

Is it responsive to feedback?

  • When sent a draft of this review, on 12 June 2017, they…did not respond.

Is it registered?

  • Yes, as a charity.
  • CMA has several business names, but the one that it uses most, ‘CMA’ is not registered. (And ASIC says that it is not available.)
  • CMA is a member of the EA Foundation ‘family’, an affiliate.
    • The EA Foundation was originally the Evangelical Alliance; Australian Evangelical Alliance Inc is a separate charity trading as Missions Interlink (which is also one of the EA Foundation’s affiliates).
  • CMS is a public company, a company limited by guarantee.
    • It appears to have the provisions in its constitution to enable it to omit ‘Ltd/Limited’ at the end of its name.
  • The ACNC Register says that CMS operates throughout Australia, ‘Grants and donations’ is easily its largest source of revenue, and it seeks donations via its website. But it doesn’t have a fundraising licence in any of the seven states with a licensing regime[2].

What does CMA do?

Do they share the Gospel[3]?

  • No (Not part of their mission.)

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.

Can you get a tax deduction?

  • No

Is their online giving secure?

  • Yes

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

  • None

Is their reporting up-to-date?

  • Yes (nearly six months after their year-end, 10 days before the final due date)

Does their reporting comply with the regulator’s requirements?

  • Annual Information Statement 2016 (AIS 2016): Almost
    • ‘Outcomes’ are not reported.
    • One business name is missing
  • Financial Report 2016[4]: Questionable
    • The directors say that ‘there are no users dependent on general purpose financial statements’, implying that any of CMA’s stakeholders, both present and prospective, who require financial information to make a decision, are able to command the preparation of statements tailored to their needs. With a professional management, operations in all states, hundreds of subscribers, others who attend events who are not subscribers, a public invitation to donate, and a high-profile initiative to give a seal of approval to Christian organisations that meet a set of standards, this is questionable.

What financial situation was shown in that Report?

  • Revenue increased 24%.
    • Within this, ‘Grants and donations’ increased 148%.
  • The surplus as a percentage of income increased from less than 1% to 4%.
  • ‘Employee benefits expense’ increased 54% – something to do with the CMA Standards Council?
  • ‘Professional fees’ of $16K presumably include the (undisclosed) audit fee.
  • There are no non-current liabilities, so how did the ‘’Finance costs’ arise?
    • And where are they in the Statement of Cash Flows?
  • Working capital (current assets less current liabilities) dropped marginally, from 134% to 129%.
  • It appears that a grant was received for the CMA Standards Council that doesn’t yet qualify as revenue, and is therefore included as a liability ($85K).
  • There are no long-term liabilities.

What did the auditor say about the last financial statements?

  • He gave a ‘clean’ opinion[5].
    • To do this he had to agree with the directors that there are no users, past or prospective, who are dependent on the type of accounts that are produced when users are not able to command the preparation of statements tailored to their needs.

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

  • Yes

Who are the people controlling the organisation?

  • On the website here.
  • Which matches ‘Responsible Persons’ on the website:
    • Jame Lewis
    • Richard Menteith
    • Karen Naylor
    • Robert Rawson
    • John Peberdy
      • There are 14 directorships recorded for the name ‘John Peberdy’. And the register only covers charities, not all not-for-profits, and no for-profit organisations. Therefore, if after eliminating the charities for which John is not a director, you are left with his total being more than a handful, it would be legitimate for you to question whether his ability to discharge their fiduciary responsibilities is threatened.

To whom is CMA accountable?

  • To the ACNC as a charity, and to ASIC as a company.

 

 

  1. Here are the first three organisations accredited. See www.tedsherwood.com for a review of each.
  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.
  4. Although far from an uncommon practice, I have always wondered about the appropriateness of featuring the logo of the auditor on the cover of a report that is the responsibility of the charity.
  5. To take the right amount of comfort from a ‘clean opinion’, please read here and here.

The Trustee for The Overseas Council Fund: mini-charity review

Mini-charity review of The Trustee for The Overseas Council Fund (OCF), an organisation that is connected, through Stephen Kerr, to the CMA Standards Council, Christian Ministry Advancement Ltd‘s  ‘major 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 7 June 2017, they…didn’t respond.

Is it registered?

  • Yes, as a charity.
    • Its trustee is Overseas Council Australia.
      • For some unexplained reason, the trustee does not consolidate the affairs of the Fund, and has not taken advantage of the ACNC’s ‘Group reporting’ concessions.
  • OCF is a public ancillary fund, a fund that collects tax deductible donations and gives them to funds who have Deductible Gift Recipient status[1].

What does OCF do?

  • The only information available, including on the OCA website, is OCF’s ‘Description of charity’s activities and outcomes’ in their Annual Information Statement (AIS) 2016:
    • Raising funds to assist partner colleges to improve leadership in developing countries.

Do they share the Gospel[2]?

  • From the little information about the Fund that is available, it is not possible to say. However, its Deductible Gift Recipient status means that it shouldn’t.

What impact are they having?

  • No information is available.

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

  • Expenses other than ‘Grants and donations made…for use in Australia’ are 25% of the total.
    • But there is only $450 outside ‘Exployee expenses/ payments’, so it appears that they are not bearing all their own costs.

Can you get a tax deduction?

  • Yes

Is their online giving secure?

  • The Fund has no website, and even though OCF ‘maintains separate accounting and bank accounts, and provides tax deductible receipts to donors’, there is no mention of giving to the Fund on the trustee’s website.

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

  • NA

Is their reporting up-to-date?

  • Yes (eight months after their year-end, one day after the maximum period allowed).
    • Why did the ACNC allow a month more than other charities – and that when they had all been given an extra month?

Does their reporting comply with the regulator’s requirements?

  • Yes
    • The Financial Report 2016 is a single blank page. But a report is not required.

What financial situation was shown in that Report?

  • No Report is available, but from the financial information in the AIS 2016:
    • 75% of the expenses were sent overseas as ‘Grants and donations’.
    • They made a proportionally large loss (28% of revenue).
    • Three full-time and four part-time employees somehow only cost them $54K.
    • They have no liabilities.

What did the auditor say about the last financial statements?

  • NA

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

  • Yes

Who are the people controlling the organisation?

  • The people under ‘Responsible Persons’ on the ACNC Register:
  • There are 29 directorships recorded for the name ‘John Anderson’, 20 for ‘David Brown’, and eight for ‘Kenneth Chapman’. 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 OCF director, you are left with his total being more than a handful, it would be legitimate for you to question whether hiability to discharge his fiduciary responsibilities is threatened.
  • The above people are also the directors of OCA.
    • Even though OCA says that OCF ‘has trustees nominated from the OCA Board’, OCF’s responsible persons, because OCA is the trustee, are automatically the same people as those who are the directors of OCA.

To whom is OCF accountable?

  • To the ACNC.
  • As a public ancillary fund, to the ATO.

 

 

  1. The ‘Entity type’ they have selected on their ABN record, ‘Discretionary Investment Trust’ is therefore, although given as an option by the ACNC, not the most appropriate one.
  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.

Service Fellowship International Inc: mini-charity review

Mini-charity review of Service Fellowship International Inc (SFI), an organisation that is connected, by the cross-directorship of John Peberdy, to Christian Ministry Advancement Ltd, the organization that is responsible for the CMA Standards Council’s ‘major new initiative, accrediting Christian organisations against a set of standards of good governance, financial oversight, and fundraising ethics.’

Is it responsive to feedback?

  • They were sent a draft of the (pre AIS 2016) review on 6 June 2017. They…did not respond.

Is it registered?

  • Yes, as a charity.
    • SFI is a member of an ACNC ‘Reporting group’. The group has one other member, S F I Overseas Aid Fund (SFIOAF).
      • SFIOAF has, with the addition of Wayne Belcher, the same directors as SFI.
    • SFI also has the same directors as Global Interaction Inc. (GI), both SFI’s and GI’s names are on the building at the SFI ACNC address, and GI’s Andrew Streets is the contact for SFI and SFIOAF. But
      • GI is not a member of the SFI Reporting group, nor has it established one of its own. No reason could be found for this.
      • The only reference to SFI on the GI website is in their ‘Introduction to Global Interaction’ document:
          • Security In order to ensure the safety of cross-cultural workers and local believers in some countries, we limit the publication of people group names and exact locations. Cross-cultural workers in these regions are seconded to Service Fellowship International (SFI) for development and humanitarian work.
      • There is no explanation of the connection between SFI and GI in either of their Financial Reports. Which means no financial consolidation.
    • GI is an ‘affiliated body’ of the Baptist Union of Australia. Although, as an affiliate, GI has its own board, the members are appointed by Union organisations. So it is effectively controlled by the Union. There is no mention of SFI on the Union site though.
  • SFI is a Victorian incorporated association (VIC A0002168H).
  • SFIOAF is an unincorporated entity (not an ‘Other Incorporated Entity’ as SFIOAF says on its ABN record).
    • SFIOAF has lodged SFI’s constitution as its ‘Governing document’ with the ACNC, not its own, so we can’t be any more precise.
  • SFI operates, per the ACNC Register, in all states bar the ACT, SFOAF in all eight. Given that the two charities raised $2.78 m in ‘Donations and gifts’ – how did they do that without a website? –the lack of a fundraising licence, in either name, in any of the seven states, does not seem right.

What does SFI/SFIOAF do?

  • Neither charity has a website, and all we know from the GI website is that SFI does ‘humanitarian and development work’ (see above).
  • There’s a little more in the SFI ‘Financial Report’:
    • The principal activities of Service Fellowship International during the financial year were to facilitate sending staff to the field, and to receive and distribute funds for aid and development purposes [page 2].
  • The ‘Group Reporting (Joint basis) 2016 Annual Information Statement’ said that this is how the ‘group’s activities and outcomes helped achieve the members of [the group’s]…reporting group’s charitable purpose (sic):
    • Aid and Development. Providing English teachers to a University in Central Asia (sic) Supporting an Education Foundation(sic) in South East Asia (sic) Supporting a sheep loan program in Central Asia to provide income generation for families. Providing Health Education (sic) in South East Asia. Supporting Income (sic) generation projects in South Asia
      • This is identical to 2015.

Do they share the Gospel?

  • From the little information that is available about each charity, I’d say not. (Which would be consistent with their status as Deductible Gift Recipients.)

What impact are they having?

  • Nothing found.

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

  • If we define ‘direct’ as ‘Funds to international programs’, administration was 29% of expenses.
    • But where does the $1.24 m of ‘Cross-cultural staff and management services provided by Global Interaction’, shown in the Group Financial Report, fit in?

Can you get a tax deduction?

  • Yes, to both charities.

Is their online giving secure?

  • NA

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

  • NA

Is their reporting (i.e. the Group reporting) up-to-date?

  • Yes (five months after their year-end)
    • The ACNC Register shows them being six months late in lodging the 2016 accounts, but this is because the ‘Financial Year End’ date on the ACNC Register is incorrect).

Does their reporting comply with the regulator’s requirements?

  • Group Reporting (Joint basis) 2016 Annual Information Statement (AIS 2016): No
    • Zero for ‘Grants and donations…for use outside Australia’ does not fit with the $1.86 m ‘Funds to international programs’ in the financial statements.
    • They have an employee yet no ‘Employee expenses’.
      • Employees have, without explanation, declined from 18 to one.
    • No outcomes mentioned.
  • Group Financial Report 2016: No
    • The Report is not a group report, but a report on SFI only. There is no consolidation of the other member of the Group.
    • The directors give no explanation for their decision that ‘the association’ is not a reporting entity, that is, they have no users dependent on general purpose financial statements to make their decisions about SFI/SFIOAF.
    • The decision allows them to produce the lower standard special purpose financial statements. This is only the correct decision if any of the Group’s users, either present or prospective, can request SFI/SFIOAF to tailor a financial report to their needs. With a professional staff separate to the members, operations in all states, $2.78 m in ‘Donations and gifts’, this is not plausible.
    • There is no explanation of the relationship between the Group and GI.
    • There is no explanation of how a multi-million-dollar charity can operate without ‘Property, plant and equipment’.
    • There is no explanation for how a charity with employees has no provisions for employee benefits.
    • The Notes to the Financial Statements are missing a number of Notes that one would normally expect to find for a true and fair view.
    • The figure in the 2015 Financial Statements for ‘Cross-cultural staff and management services provided by Global Interaction’, $848K, has been changed this year, without explanation, to $1.20 m.

What financial situation was shown in that Report?

  • Subject to the unknown effect of the relationship with GI,
    • The surplus as a percentage of revenue dropped dramatically (from 24% to 6%).
    • No government grants have been received for the last two years.
    • Current assets compared to current liabilities (working capital) increased from 12 to 1 to 24 to 1.
    • There are no long-term liabilities, so the long-term financial structure is sound.

What did the auditor say about the last financial statements?

  • He gave a ‘clean’ opinion.
  • The auditor, Saward/Dawson (Jeffrey Tulk),
    • agreed with the directors’ decision that there are no users (present or prospective) who are dependent on general purpose financial statements, and
    • agreed with the directors’ decision not to consolidate SFIOAF.

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

  • SFI: ‘Website’ is blank, but it appears that they don’t have one.
  • Group: Not incomplete but incorrect: The year-end is 31 December, not 30 June.
  • SFIOAF: There is a ‘Governing document’, but it SFI’s, not SFIOAF’s.

Who are the people controlling the organisation?

  • SFI, per the ACNC Register:
    • David Bird
    • Kenneth Clendinning
    • Heather Coleman
    • Murray Crabb
    • Kay Hunter
    • Beth Jackson
    • David Moyes
    • Surette Southwood
    • John Peberdy
      • John Peberdy 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 nine for ‘Surette Southwood’. And the register only covers charities, not all not-for-profits, and no for-profit organisations. Therefore, if after eliminating the charities for which SFI/SFIOAF’s John and Surette are not directors, you are left with their number being more than a handful, it would be legitimate for you to question whether their ability to discharge their fiduciary responsibilities is threatened.
  • SFIOAF: the same as above, except plus Wayne Belcher.

To whom is SFI/SFIOAF accountable?

  • SFI: To the ACNC and the Victorian regulator of incorporated associations.
  • SFIOAF: To the ACFID – it is ‘Full’ member.

MMM Australia: mini-charity review

Mini-review of MMM Australia (MMM) as an organisation that seeks donations from the public. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

MMM is also an organisation that is connected, by the cross-directorship of John Peberdy, to Christian Ministry Advancement Ltd, the organization that is responsible for the CMA Standards Council’s ‘major new initiative, accrediting Christian organisations against a set of standards of good governance, financial oversight, and fundraising ethics.’

(For last year’s review, see here.)

Is it responsive to feedback?

  • When sent a draft of this review, on 31 May 2017, they…did not respond.

Is MMM registered?

  • As a charity, yes.
    • MMM is one of two members of an ANCN ‘reporting group’. The other MMM Build Pty Ltd (which is winding down).
    • They report as part of an ACNC ‘Joint’ reporting group (along with MMM Build Pty Ltd).
  • Other registrations:
    • As a public company (a company limited by guarantee).
    • MMM operates (per the ACNC Register) in five of the seven states that have a fundraising licence regime. It is not licensed in any of them. It is licensed in only its home state.  [Amended 24.06.17] (Even if exempt, it may be that a prominent website request for donations may also, for some or all states, be an argument for being licensed.)

What do they do?

  • ‘MMM is a mission organisation operating throughout Australia and our neighbouring countries. We support Christian ministries by providing building, maintenance and other practical services…We do this work through 4 legs of ministry:

Do they share the Gospel?

  • No.

What impact are they having?

  • There is no indication that they are even assessing their impact. (I searched for ‘outcomes’ too.)

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

  • From the classification of expenses used by MMM there is no clear way to even estimate this percentage.

Can you get a tax deduction?

  • No.
    • The ‘Donate’ page on the website says that
      • tax-deductible gifts can be made for special approved overseas projects through MMM International Development Inc and the MMM International Development Fund.’ However, this association was deregistered in January 2017.

Is their online giving secure?

  • PayPal is used, so yes.

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

  • Two are given:
    • the ongoing work of MMM’, and
    • MMM Fundraiser Development Projects’.
      • However, the ‘Donate’ button for his one leads to PayPal’s home page.

Is their reporting up-to-date?

  • Yes (three months after their 31 August year-end).
    • They report as part of an ACNC ‘Joint’ reporting group (along with MMM Build Pty Ltd).
      • The ‘Financial Year End’ is incorrect on the Register entry for the Group.
    • 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 in the past.

Does their reporting comply with the regulator’s requirements?

  • AIS 2016 (for the Group): Not quite. No outcomes are reported.
  • Financial Report 2016 (for the Group): Questionable:
    • Do the directors realise that, by saying that “there are no users who are dependent on its general purpose financial statements”, they are also effectively saying that all current and prospective donors, staff and suppliers can command the preparation of a report tailored to their needs?
    • Earmarking funds for a future use (‘Special projects, Note 1(o)) does not meet the definition of a liability (‘Other current liabilities’ $24K).
    • Not recognising the surplus or deficit on the projects completed by ‘work parties’ in the ‘statement of comprehensive income’ is not consistent with the Accounting Standards (Note 1(p)).
    • The expected loss on a contract is questionable as a liability (‘Provision of onerous costs’ $61K, Note 1(q)).

What financial situation was shown in that Report?

  • The Group’s deficit as a percentage of revenue increased markedly, from 8% to 56%.
  • Financial structure, both short-term (working capital) and long term (debt versus assets) appears to be sound.

What did the auditor say about the last financial statements?

  • He gave a ‘clean’ opinion. To take the right amount of comfort for this finding, please read here and here.
    • But he agrees with the directors’ decision – see ‘Does their reporting..’, above – that the lower standard special purpose financial statements are appropriate.

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

  • Almost. It is missing information under ‘Other Name(s)’.

Who are the people controlling the organisation?

  • Per the website, these people:
    • Roderick McGarvie
    • Melanie McGrice
    • John Peberdy
    • Shane Prior
    • Matthew Smith
    • Dale Richardson
    • Which probably means that they are well overdue in amending the listing on the ACNC Register (‘Responsible Persons’) to include Dale.
    • John Peberdy 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 the register only covers charities, not all not-for-profits, and no for-profit organisations. Therefore, if after eliminating the charities for which John is not a director, you are left with the total being more than a handful, it would be legitimate for you to question whether his ability to discharge his fiduciary responsibilities is threatened.

To whom is MMM accountable?

  • Although they make no mention of it, they are, apart from the ACNC, accountable because of their membership of Missions Interlink.

Great Commission Foundation: mini-charity review

Mini-charity review of Great Commission Foundation (GCF), an organisation that is connected, by the cross directorship of Robert Rawson, to Christian Management Australia, the body 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 29 May 2017, they…did not respond.

Is it registered?

  • Yes, as a charity.
  • GCF is a public company, a company limited by guarantee.
    • It is entitled to omit ‘Ltd/Limited’ at the end of its name.
  • GCF has not said on the ACNC Register where it operates, but its office is in Victoria. It doesn’t have a fundraising licence, but this may be because it still hasn’t traded, or intends to raise less than $10K p.a[1].

What does GCF do?

  • Its Annual Information Statement (AIS) 2016 says that it didn’t operate from its inception on 28 April 2016 to 31 December 2016 (its year-end).
  • Its constitution says that

The company’s object is to pursue the promotion of Christianity and Christian mission throughout the world in partnership with Power to Change[link mine].

  • Under ‘Will the charity change or introduce any activities in the 2017 period? in its AIS 2016, GCF reports ‘Changes planned bequests’ (sic).

Do they share the Gospel[2]?

  • Given its object (see above), an ACNC ‘Entity subtype of ‘Advancing Religion’, and its inability to receive tax deductible gifts, I expect so.

What impact are they having?

  • NA – no report of any activity yet.

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

  • NA – no activity reported yet.

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

Does their reporting comply with the regulator’s requirements?

  • Yes

What financial situation was shown in that Report?

  • NA

What did the auditor say about the last financial statements?

  • NA

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

  • ‘Website’ is blank, but they don’t appear to have a website.

Who are the people controlling the organisation?

  • Under ‘Responsible Persons’ on the ACNC Register:
    • Peter Brook
    • Rex Campbell
    • Allan Gibson
    • David Harvey
    • Robert Rawson
  • These same five people are also the directors of Power to Change.

To whom is GCF accountable?

  • To the ACNC as a charity, and to ASIC as a company.

 

 

  1. The other six states with a licensing regime were not checked.
  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.

Melbourne Prayer Breakfast Committee Incorporated: mini-charity review

Mini-charity review of Melbourne Prayer Breakfast Committee Incorporated (MPB), an organisation that is connected, by the cross directorship of John Peberdy to Christian Management Australia, the body 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 27 May 2017, they…did not respond.
    • By the time of publication, MPB’s website had been restored, so the review was modified.

Is it registered?

  • Yes, as a charity.
  • The accounts (see below) do not give the source of the revenue; if a Victorian fundraising licence is required it doesn’t have one.

What does MPB do?

Do they share the Gospel[1]?

  • There is nothing current on the website that mentions Christ, Jesus, or the Gospel. (Pages from 2012 now give a 404 error.)
  • The keynote speaker for 2017 is Josh Wilkins, the founder and CEO of the charity One Voice For Aussie Youth LTD. He’s a Christian, with this view on sharing the Gospel:
    • I am very passionate about helping young people achieve their dreams. I am a Christian and believe that we should show people Jesus and not so much push Jesus onto people. Most people on the streets know about God and Jesus and it’s time we showed them his love.

What impact are they having?

  • No information is available.

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

  • Perhaps for a single event charity like this, it could be argued that 100% of the expenses are direct, that is, administration is zero?

Can you get a tax deduction?

  • No

Is their online giving secure?

  • They do not seek donations online.

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

  • Online: NA
  • There is no information to suggest that donations are sought at the breakfast.

Is their reporting up-to-date?

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

Does their reporting comply with the regulator’s requirements?

  • Yes
    • The Financial Report complies only because it has been voluntarily submitted to the ACNC, and voluntarily submitted reports do not need to comply with the ACNC legislation. But it doesn’t comply with the legislation under which MPB is incorporated, the Associations Incorporation Reform Act 2012. It is missing two financial statements and Notes to the accounts.

What financial situation was shown in that Report?

  • MPB made a loss of 9% of revenue, but is still in a healthy financial position.

What did the auditor say about the last financial statements?

  • MPB chose a review rather than an audit.
  • Despite the omission of two of the required financial statements, and the Notes to the accounts, the reviewer, Douglas Mitchell, Chartered Accountant, of MitchellWilson, gave a clean conclusion.

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

  • ‘Phone’ and ‘Website’ are missing, but neither are compulsory.

Who are the people controlling the organisation?

  • Under ‘Responsible Persons’ on the ACNC Register:
    • James Ayling
    • Rochelle Chan
    • Paul De Mare
    • Geoff Harrison
    • Dawn Penney
    • John Peberdy
      • John Peberdy 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 the register only covers charities, not all not-for-profits, and no for-profit organisations. Therefore, if after eliminating the charities for which John is not a director, you are left with the total being more than a handful, it would be legitimate for you to question whether his ability to discharge his fiduciary responsibilities is threatened.

To whom is MPB accountable?

  • To the ACNC.
  • And to the Victorian 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.