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.

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.

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

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

(Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

To see the situation last year, read this review.

Is it responsive to feedback?

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

Is it registered?

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

What does YWAMP do?

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

Do they share the Gospel?

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

What impact are they having?

  • Nothing systematic found.
  • YWAMPBI: Nothing found.

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

  • The financial statements that were lodged have been withheld from the Register by the ACNC at YWAMP’s request.
    • There is no reason given for the suppression, and the reason is not available to the public. This just leads us to speculate as to the nature of the information that has caused the ACNC to decide that the harm that may be caused by its publication ‘outweighs the public interest in publishing the information’.
    • The loss of transparency is mitigated by the fact that the statement withheld relates to a year-end that is now over two years ago.
    • Their membership of Missions Interlink requires them to “have available for its members and supporters a clear and appropriate financial statement which has been approved by its auditor [Standards Statement, 4.1]. So just ask.
  • YWAMPBI:
    • The ‘Financial Information’ section in the AIS 2015 has all zeros.
    • The Financial Report is YWAMP’s Financial Report.

Can you get a tax deduction?

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

Is their online giving secure?

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

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

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

Is their reporting up-to-date?

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

Does their reporting comply with the regulator’s requirements?

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

What financial situation was shown in that Report?

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

What did the auditor say about the last financial statements?

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

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

  • Yes
  • YWAMPBI: Yes

Who are the people controlling the organisation?

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

To whom is YWAMP accountable?

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

 

 

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

Far East Broadcasting Co (Australia): mini-charity review

Mini-charity review of Far East Broadcasting Co (Australia) (FEBC) as an organisation that is a member of Missions Interlink, and seeks donations online. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

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

FEBC is also of interest because it shares a director, ‘The Trust Lady’, Vanessa Hall, with the CMA Standards C0uncil, Christian Management Australia’smajor new initiative, accrediting Christian organisations against a set of standards of good governance, financial oversight, and fundraising ethics.’

Are they responsive to feedback?

  • When sent a draft of this review, on 24 March 2017, they responded quickly. However, they did not want to either suggest corrections or submit comments for publication.

Is FEBC registered?

  • As a charity, yes.
    • There’s another company with ‘FEBC’ in its name, FEBC Custodian Limited. Note 17 in the Financial Report (see below) says that this company ‘was established solely to act as trustee for the FEBC Overseas Aid Fund(The Fund).
    • FEBC has produced financial statements that include The Fund, but not FEBC Custodian Limited.
      • Despite reporting as a group, FEBC still hasn’t taken advantage of the ACNC’s group reporting concessions.
  • Other registrations:
    • As a public company, a company limited by guarantee.
      • It is permitted to omit ‘Ltd/Limited’ from its name.
  • FEBC is a fundraising vehicle that operates, the ACNC Register says, in all eight states. It also has an internet invitation to donate. Seven states have a fundraising licensing regime. It is exempt in NSW, and has a licence in four of the others. In South Australia, it has a licence in the name of The Fund. It has no licence in the eighth, Western Australia, but doesn’t appear to fit one of the exemptions.

What do they do?

  • ‘About Us’ on the website is not about FEBC, but the international FEBC organisation generally. For what they did in Australia in 2016, see the first part of the ‘Description of charity’s activities and outcomes’ in the AIS 2016:
    • In the last financial year, FEBC Australia had (sic) worked hard to effectively communicate needs, relay stories, share prayer points and write up project submissions to raise financial support for overseas projects… (The remainder of their description is about the worldwide FEBC ministry rather than Australian activities.)
  • From pages 9 and 17 of the Annual Report, it appears that the countries listed under ‘Operates in (Countries)’ on the ACNC Register, are the countries to which FEBC sends your donation (after expenses), not where it ‘operates’ as conventionally defined.
  • The Fund: From the AIS 2016:
    • Funds were raised through FEBC Overseas Fund to support the projects in Cambodia and Mongolia, to empower the poor and marginalised to address issues related to health, food, security, income generation, employment, basic education, gender issues, social justice and civil society. Emergency Communication for disaster relief and support. Child protection Indonesia

Do they share the Gospel?

  • No.
    • But they raise money for others that do.

What impact are they having?

  • Some anecdotal reports in the Annual Report, but nothing systematic either there or on the website.

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

  • The cost of raising and sending the money is 27% of group expenses (up from 23% last year).
  • The Fund: They had no expenses outside the money sent overseas.

Can you get a tax deduction?

  • No.
    • This is contradicted by the ‘Projects’ page: two projects there are prefaced ‘Tax-deductible project’.
      • The ‘small print’ for each of these projects says that the money goes to a secular organisation, Global Development Group.
    • The Annual Report says that they are investigating
      • Registering FEBC Australia as a public benevolent institution (PBI) to provide another way for tax deductibility for projects and an effective way to relieve poverty and distress to people groups in need across the globe [page 4].
      • How this fits with their mission – Our goal is to communicate the Good News among the nations by media to inspire people to follow Jesus Christ – is not explained.
  • The Fund: Yes

Is their online giving secure?

  • They have the ‘Norton secured’ seal, so yes.

Is their reporting up-to-date?

  • Yes (lodged a little over four months after their year-end – a month earlier than last year).
    • But if you are considering a large donation, I would ask for more up-to-date financial information – the accounts are for a year that finished six months ago.
  • The Fund: The same

Does their reporting comply with the regulator’s requirements?

  • AIS 2016: No
    • The ‘Financial Information’ is for the group, whereas it should be for FEBC on its own.
    • Much of what is under ‘activities’ is about the FEBC organisation overseas.
    • No outcomes are reported.
    • ‘Other income’ does not match the same item in the financial statements.
    • There is no evidence that FEBC operated overseas.
    • The Fund: Almost – no outcomes are reported.
  • Financial Report 2015: No
    • There are more than 4000 recipients of the monthly newsletter, all over Australia, and this and other efforts generates more than $1.47 m in donations. The directors, via their decision, once again, to produce the type of financial statements that do not have to comply fully with the Accounting Standards (special purpose statements), are effectively saying that any of FEBC’s stakeholders, including the newsletter recipients, can command the preparation of a financial report tailored to their needs. This is implausible.
    • Despite the statement, on page 18 of the Annual Report, that the international programs are shown by program or country, there is no breakup of the $1.15 m sent overseas.
    • There is no explanation for the inclusion of a second income statement, Income Statement for ACFID purposes, especially when FEBC is not a member of the ACFID (Australian Council for International Development).
    • Income Statement
      • ‘Other expenses…’ comprise 81% of the expenses but there is no explanatory Note.
      • The part of your donations that was sent overseas for beneficiaries is not shown.
      • There is no Other Comprehensive Income section.
    • Income Statement for ACFID purposes
      • There is no explanation of the terms used.
      • There is no Other Comprehensive Income section.
      • A note says that ‘Direct and indirect costs have been allocated using an activity based absorption costing approach.’, but no explanation of this approach is given.
      • The Annual Report (page 13) says that their ‘activity based absorption costing approach’ includes ‘Showing details of FEBC Australia’s international programs either by program or by country’. These details are not in the Financial Report.
    • Balance Sheet
      • How was FEBC able to operate an office without any ‘Furniture, Fittings and Office Equipment’?
      • Is the ‘Field Staff Retirement & Resettlement’ figure actually a liability, that is, a present obligation to the field staff? If not, it should be a reserve.
      • If it is a liability, why is it not included in ‘Employee Benefits Provisionss’ (sic)?
      • The treatment of ‘Financial Assets’ is not compliant with the Accounting Standards.
      • ‘Land and Buildings’ consist of two properties in Caringbah.
        • How was the combined cost only $93K?
        • Should one be classified as investment property?
    • Notes to the Financial Statements
      • There is no explanation again this year of the choice of a ‘special purpose financial report’ as opposed to the type that the stakeholders need to make their decisions.
    • The Fund: No report required (and none lodged).

What financial situation was shown by that Report?

  • The surplus as a percentage of income was improved marginally.
  • Working capital is strongly positive.
  • Longer term financial structure appears sound.
  • The Fund: NA

What did the auditor say about the last financial statements?

  • He gave a ‘clean’ opinion[1]. However,
    • in accepting the engagement, he implicitly agreed with the directors’ decision to produce special purpose rather than general purpose financial statements (see above),
    • he has not identified the financial reporting framework used, including the type of financial statements (see above),
    • he includes compliance with the Charitable Fundraising Act in his opinion when FEBC is exempt from that Act.
  • The Fund: NA

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

  • Not quite – ‘Phone’ is blank.
    • Did FEBC operate in all 14 countries listed under ‘Operates in (Countries)?
  • The Fund: No
    • The name of the charity does not match the name for the ABN.
      • And if it did then the information would be about FEBC Custodian Limited.
    • ‘Phone’ is blank.

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

  • Quite a few, presented a little confusingly.
  • Under the ‘Donate’ button in the main menu, other than being able to write in the name of a tax-deductible project, there is only one.
  • But to ‘donate’ is not the only way to give. Under ‘Get involved’/ ‘Ways to Give’ in the main menu, there are, in addition to the donate button again, these three options:
    • ‘Give a radio’
    • ‘Give to a project’
      • 10 projects (on of which is a radio, which is also a gift (see below), and a separate option (see above).
    • ‘Give a gift’
      • This leads to the ‘Use Your Gifts’ store, where there are 20 gifts.
      • These are also available under ‘Get involved’/’Gift catalogue’.

Who are the people controlling the organisation?

  • Not shown on the website.
  • But from the ACNC Register under ‘Responsible Persons’:
    • Peter Ronald Elliott
    • Kuet Qeun Ho
    • Kevin Keegan
    • Kenneth Kingwell
    • Rodney Tant
    • Vanessa Rae Hall
      • Although not shown on this profile, Vanessa is the Chair of the ‘Standards Panel’ (or is it the ‘CMA Standards Council’?), a committee of Christian Management Advancement Ltd, an organisation that believes that
        • Christian organisations should be the standard-setters in terms of impeccable corporate behaviour.
          • The Panel’s mission 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.
  • The Fund: The same, but without Kingwell.

To whom are FEBC accountable?

  • They’ve got the FIA ‘Organisational member’ seal, the logo of ‘FEBC International’, the logo of Global Development Group, the ACNC ‘charity tick’, and the Missions Interlink logo towards the bottom here.
    • The ‘FIA’ is Fundraising Institute Australia. Members must comply with its fundraising standards. FIA membership confirmed.
    • FEBC International is ‘an interdenominational radio network ministry, which brings the love of God to the world by broadcasting the gospel of Jesus Christ.’[2] Organisationally it is also a company in Singapore that provides services to the national organisations, including FEBC. There doesn’t appear to be any accountability involved.
    • Global Development Group is a charity, an “Australian-founded non-government overseas humanitarian development organisation”. FEBC is not accountable to it.
    • FEBC is accountable to the ACNC. (The ‘charity tick’ just says that FEBC is a registered charity.)
    • Missions Interlink has an accountability regime[3].

 

 

  1. To take the right amount of comfort from a ‘clean opinion’, please read here and here.
  2. FEBC Annual Report 2015-16, page 2.
  3. For one opinion on the strength of this accountability, see the section Activities in this review.

Overseas Council Australia: mini-charity review

Mini-charity review of Overseas Council Australia (OCA), an organisation that invites the public to donate to it, and that is connected, through Stephen Kerr, 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.’

(Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

To see the situation last year, read this review.

Is it responsive to feedback?

  • Shortly after receiving the draft review, they replied that they were ‘currently working on this’. Three days after the date for publication, in response to my follow-up, they replied that they had decided not to make a formal response.

Is it registered?

  • Yes, as a charity.
  • OCA is a public company, a company limited by guarantee.
    • It is entitled to omit ‘Limited/’Ltd’ from the end of its name.
  • There’s also another charity with ‘Overseas Council’ in its name, The Trustee For Overseas Council Fund.
    • The governing document for this charity is blank, but with responsible persons the same as OCA, I’d say that OCA is the trustee.
  • OCA operates, per the ACNC Register, all over Australia. However, it is only registered as a fundraiser in its home state, NSW[1].

What does OCA do?

  • The ‘About Us’ page says that donations are used to
    • train emerging church leaders in twenty five countries throughout Asia, Africa, and the Middle East.
    • What this translates into practically can be seen below under ‘What choices do you have…?’
    • Page 2 of the Financial Report gives the specifics of what they did in 2016.

Do they share the Gospel?

  • No. (It funds the training of those that will)[2].

What impact are they having?

  • Nothing systematic found.
  • There has been no Annual Report since 2014.

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

  • If we define ‘Payments and in kind allocations to Projects’ as these direct costs, then 34% was ‘administration’.

Can you get a tax deduction?

  • No
    • This is contradicted here.

Is their online giving secure?

  • digicert is used, so yes.

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

  • Where most needed’
  • ‘Student support’
  • ‘Faculty support’
  • ‘Infrastructure project’
    • You will need to know the name of the project
  • ‘Translation or commentary project’
    • You will need to know the name of the project

Is their reporting up-to-date?

  • Yes (on the last day, seven months after their year-end).

Does their reporting comply with the regulator’s requirements?

  • Annual Information Statement 2016 (AIS 2016): No
    • Although consolidated financial statements are not mentioned anywhere by name, Note 1 says that ‘The Financial Statements comprise the following entities: Overseas Council Australia…. Overseas Council Fund. This means that, because OCA still hasn’t taken advantage of the ACNC’s group reporting provisions, its AIS should show only its own figures, not those of the group. OCA hasn’t done this.
    • Even if this were not the case, most of the figures in the ‘Comprehensive Income Statement summary’ do not match the financial statements.
    • No outcomes are reported.
  • Financial Report 2016: No.
    • No audit report is included.
    • The directors have again, and again without explanation, adopted the lower standard special purpose financial statements.
      • Is it really the case that all those currently involved with OCA – a charity with a $1.58 m turnover, operating in all states, and with a public request for money – and all those who might become involved because of OCA’s promotions and website, can get a financial report tailored to their needs? (This is the implication of not producing general purpose financial statements.)
    • Two income statements are, without explanation, included.
    • One income statement is again missing ‘Other comprehensive income’ (again, the other both this and totals.
    • The surplus in the income statements is not the same as the surplus in the Statement of Changes in Equity.
    • The Notes to the accounts are again missing some that are customarily included.

What financial situation was shown in that Report?

  • OCA has negative working capital (current liabilities exceed current assets), and it has used up all its capital and then some, and yet there is no comment by the directors on the going concern assumption.

What did the auditor say about the last financial statements?

  • Not audit report is included in the Financial Report.

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

  • No
    • If the note under Entity Subtype is not an ACNC mistake, then OCA has been overdue in selecting a subtype since 30 June 2015.
    • ‘Phone’ is blank.

Who are the people controlling the organisation?

  • The seven people introduced on the website here.
  • The ACNC Register has these seven plus Sandra Clarke:
    • John Allison
    • John Anderson
    • David Brown
    • Kenneth Chapman
    • Sandra Clarke
    • Timothy Clemens
    • Alan Jeffrey Hall
    • Stephen Kerr
      • Stephen is the Executive Director of 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.’
        • So perhaps he’s now only part-time with this legal firm?
    • There are 35 directorships recorded for the name ‘John Anderson’, 20 for ‘David Brown’, and seven 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 OCA 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 his fiduciary responsibilities is threatened.

To whom is OCA accountable?

 

 

  1. The law in this area is not straightforward – is an internet invitation ‘fundraising’ for instance? – and advice varies, so check with the charity before drawing any conclusions.
  2. There is no mention of evangelism in the ‘Statement of Faith’; the constitution doesn’t even mention Christianity.
  3. For one opinion on the strength of that accountability, see the section Activities in this review.

Heart for Kids Australia Ltd: mini-charity review

Mini-charity review of Heart for Kids Australia Ltd (HFK), an organisation that is an Associate member of Missions Interlink and which invites the public, via the website linked from that membership, to donate to it.

Are they responsive to feedback?

  • After sending a draft of the review on 21 February, an email exchange with one of the ‘responsible persons’ led to an extension of the time to suggest corrections and offer comments to 10 March. I didn’t hear from him again.

Is HFK registered?

  • Yes, as a charity.
    • It appears that it has taken over another charity, Chinaheart International Incorporated (CI):
      • ‘ChinaHeart has become part of our new organisation, Heart For Kids. This is in response to a call to begin serving children in India and Indonesia as well as China.’
        • But CI, per the ACNC Register, doesn’t work in India and Indonesia, only in China.
    • HFK has yet to take advantage of the ACNC’s group reporting concessions.
      • Independent of this, expect to see 2017’s financial statements combining the two charities.
    • CI itself has a wholly-owned subsidiary, ChinaHeart International Aid Fund.
      • Although I have not included information about this charity below, it would need to be considered if you were considering involvement with HFK.
    • HFK is also connected with a business, LST Group (a business name belonging to The Trustee for the David Ryan Trust).
  • HFK is a public company, a company limited by guarantee.
    • CI is a New South Wales incorporated association (INC9884006).
  • No fundraising licence in its home state – or in any other state[1].
    • CI: the same.

What does HFK do?

  • There is no one clear statement but all the information is here.
  • An alternative way to get the answer to this question is to look at the ‘Donations’ page.
    • CI: the website address on the ACNC Register leads to the HFK website.

Do they share the Gospel?

  • 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?

  • The website talks about ‘ChinaHeart’, not HFK. It says that
    • ‘Our aim is to send 85% of your donation through to the children and families in our projects.  Traditionally we have been able to send 85% to 89% of donations.’
      • The 2016 Income Statement of ChinaHeart International Incorporated shows that ‘Project Payments’ were 76% of ‘Income’ other than ‘Miscellaneous Income’ and ‘Interest’. The previous year was 82%.

Can you get a tax deduction?

  • Yes
    • CI: No

Is their online giving secure?

  • eWay and PayPal are used, so yes.

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

  • Sponsor a Child in Need’
  • ‘Purchase an item’
  • ‘Donate’
    • where most needed’
    • ‘orphans’
    • ‘Doves Wing foster home’
    • ‘Morning Light Special Needs Centre’
    • ‘Christmas gifts for rural kids’

Is their reporting up-to-date?

  • Yes (seven months after their year-end, eight days before the deadline)
    • CI: the same

Does their reporting comply with the regulator’s requirements?

  • Annual Information Statement 2016 (AIS 2016): Yes
    • HFK was only established in May 2016, so I’m not sure why the ACNC required an AIS 2016.
    • CI: Not quite: Their business name is missing, no outcomes are given, and isn’t the proceeds of fundraising part of ‘Donations and bequests’?
  • Financial Report 2016: Yes
    • One wasn’t required, either because of HFK’s small size, or because it was only established a month before its year-end.
      • The financial information in the AIS 2016 is all zeros.
    • Next year though, the combination of HFK and its subsidiary CI will mean that a Report will be required.
    • In addition, 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.”  So just ask.

What financial situation was shown in that Report?

  • NA
    • CI:
      • A deficit of 7% of revenue last year was repeated this year.
      • No non-current assets.
      • Minimal liabilities.

What did the auditor say about the last financial statements?

  • NA
    • CI: It was a review, and he gave a ‘clean’ opinion.

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

  • Almost – ‘Operating State(s)’ is blank.
    • CI: No:
      • They are long overdue in selecting an ‘Entity Subtype’.
      • Their business name is missing.
      • They only show two ‘Responsible Persons’.

Who are the people controlling the organisation?

  • The ‘leadership team’ is shown on the website, but the board members are not identified.
  • From ‘Responsible Persons’ on the ACNC Register:
    • Poay Lee
    • David Ryan
    • Adam Tedja
      • Is it this Adam Tedja?
    • CI:
      • Ken Lee
      • David Ryan (as above)
        • Although there are nine directorships recorded for the name ‘David Ryan’, and the ACNC Register has only charities, three are in the HFK group, and he has no executive position outside HFK.

To whom is HFK accountable?

  • To Missions Interlink[2] via its an Associate membership.
  • HFK is also accountable to the ACNC.
  • And, as a company, to ASIC.
    • CI: to the ACNC and the New South Wales associations regulator.

 

 

  1. The law in this area is not straightforward – is an internet invitation ‘fundraising’ for instance? – and advice varies, so check with the charity before drawing any conclusions.
  2. For one opinion on the strength of that accountability, see the section Activities in this review.

Pipeline Ministries International Incorporated: mini-charity review

Mini charity review of Pipeline Ministries International Incorporated (PMI), an Associate member of Missions Link, and an organisation that provides an online donations facility.

Is it responsive to feedback?

  • The draft review I sent on 24 February started a conversation that culminated in a few minor changes and the comments included below.

Is PMI registered?

  • As a charity, yes.
  • Other registrations:
    • As a Victorian incorporated association (A0028363C).
    • It has no fundraising licence in its home state, or in any of the six others that have a licensing regime[1].

What do they do?

  • Generally: Under the pictures here.
  • More specifically, from the AIS 2016 (and with no intention of changing in 2017):
    • Pipeline raises funds in Australia through events such as trivia nights and garage sales and also from direct donations and sponsorships. This money is mainly used in the Philippines to support: – child feeding, – education of the less fortunate through child sponsorship and teachers’ salaries, – micros loans for small business, – emergency relief – community workers/pastors Pipeline works with a church organisation in the Philippines to carry these activities out. All work here and overseas is voluntary and sometimes dangerous. We travel to the Philippines at least annually at our own cost to oversee activities. Pipeline has a small activity in Melbourne’s Western suburbs to connect and support local women through a variety of activities

Do they share the Gospel?

  • It appears not.
    • Ministry comment: ‘All activities are humanitarian in nature.’

What impact are they having?

  • Nothing found.

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

  • The expenses are not presented to allow this calculation.
    • Ministry comment: ‘All activities in Australia and the Philippines are carried out by volunteers.  Expenses such as volunteers travelling to the Philippines are paid by the volunteers.  A part time co-ordinator in the Philippines is paid a small allowance, but this money does not come from donations to Pipeline.  All money raised by or donated to Pipeline is used to support others in need.’

Can you get a tax deduction?

  • Yes

Is their online giving secure?

  • NA – not offered.

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

  • For a straight donation, no choices are shown on the website.
    • Ministry comment: ‘Please contact Pipeline (see link on website) if you would like to direct a donation to a specific activity.’
  • You can also ‘Sponsor a child’s education or
  • Buy an Amazing Gift Card
    • Schooling and School Supplies…
    • Support a Community Worker…’
    • Women’s Health (sic) Clinic’
    • Livestock…
    • Child Feeding Program’
  • ‘Provide ongoing support to a community worker. Please contact us.’

Is their reporting up-to-date?

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

Does their reporting comply with the regulator’s requirements?

  • AIS 2016: No
    • ‘Pipeline’ is neither a business name nor a trading name.
    • No outcomes reported.
    • The ‘Expenses/Payments’ do not match those in the Financial Report.
  • Financial Report 2016:  Yes – but only because they don’t have to lodge one.
    • Having lodged one voluntarily, there is no requirement for it to comply with the ACNC’s requirements.
    • 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.”
      • There is no audit report.
      • Even without this omission, it is arguable that a financial report that lacks two of the four financial statements required by the accounting profession, deviates markedly from what is required for the other two, and has no directors’ declaration, is not ‘appropriate’.

What financial situation was shown in that Report?

  • Recognising that the financial statements are unaudited, and that the statements are not compliant with the Accounting Standards –
    • PMIrecorded a deficit, a deficit that was 18% of revenue.
    • The AIS 2016 says that almost 100% of the expenses were ‘Grants and donations…for use outside Australia’, but there isn’t enough to tell which organisations received this money.
    • Zero liabilities.
    • The remaining equity is only 1.5 times the last deficit.

What did the auditor say about the last financial statements?

  • NA (see above).

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

  • Not quite – ‘Phone’ and ‘Website’ are blank.

Who are the people controlling the organisation?

  • Not shown on the website,
  • But from ‘Responsible Persons’ on the ACNC Register:
    • Glenis Brown
    • Thompson Debra (the wrong way around?)
    • Colin Lesueur
    • Denise Prince
    • Roger Vistarini

To whom is PMI accountable?

  • To Missions Interlink[2] via their Associate membership.
  • Also to the Victorian regulator of incorporated associations.
  • And, as an Australian registered charity, to the ACNC.

 

  1. The law in this area is not straightforward – is an internet invitation ‘fundraising’ for instance? – and advice varies, so check with the charity before drawing any conclusions.
  2. For one opinion on the strength of that accountability, see the section Activities in this review.

International Gospel Centre Inc: mini-charity review

Mini charity review of International Gospel Centre Inc (IGC), an Associate member of Missions Link, and an organisation that asks you, online, to donate to it.

Is it responsive to feedback?

  • When sent a draft of this review, they responded immediately, and with openness and humility. The ensuing conversation led to the correction of an error, a rephrasing, the comments you see throughout below, and this general comment:
    • Thank you for the opportunity to respond to your review. Your ministry is very important and we respond in the love of Jesus. Have made comment and/or correction under each applicable point you raise as necessary. Please let me know if there is anything else you require.

Is IGC registered?

  • As a charity, yes.
  • Incorporated as a South Australian incorporated association (A12906).
  • Business names? None
    • Under the legislation (section 54) for this incorporation, IGC, because it doesn’t have any business names, must use its full name, including ‘Inc’ or ‘Incorporated’, on ‘every notice, advertisement, bill of exchange, receipt or other document given, published, drawn or issued by the association[1].
      • Ministry comment: ‘International Gospel Centre Inc. uses our registered and official name to the best of our knowledge. We are ascertaining where this hasn’t occurred in the past and taking steps to ensure it does as we move forward. We’re also looking at a “trading as” name to allow us to use IGC- Compassion LOVE Action as an addition to International Gospel Centre Inc.’
      • It is arguable that, nowadays, this includes at least some of what is published on IGC’s social media pages.
        • Ministry comment: ‘IGC has sent a request to Facebook to change our Facebook name to International Gospel Centre.’
    • It also cannot trade under the names ‘IGC Foundation’ (YouTube)[2], or ‘IGC’ (Facebook)[3].
      • Ministry comment: ‘We are looking at all of our social media to ensure that not only are we removing confusion but ensuring there are no questions in regards to legality.’
  • IGC says, on the ACNC Register, that it operates in all eight states.
    • It does not have the necessary ASIC registration (an ARBN).
      • Ministry comment: ‘We are incorporated under state law, we are on the ASIC register, and do not have offices in any other state except for SA. The use of the word “operate” is ambigious and we will make the necessary change on the ACNC Register.’
    • It has a fundraising licence in South Australia, New South Wales, Victoria and Western Australia. Perhaps it has assessed that one is not required in the other three states that have a licensing regime?[4]
      • Ministry comment: ‘Our understanding is that we do not need a license in the other states and territories as we do not physically operate in these places. If we held an event in any of these places, we would require a license but I note the following: Qld is okay as we are registered through ACNC; Tas covered by SA license; ACT if donations are $15k per year or more; (and) NT is only required if we sell raffle tickets.

What do they do?

  • ‘For more than 26 years, ‘International Gospel Centre’ has been committed to reaching the most destitute and vulnerable children in the Philippines, Uganda and Zambia by impacting their lives with the power of love in action – giving them hope for the future. We do this through comprehensive and effective programs that not only reach each child, but their families and their local and wider communities. Our largest program is Child Sponsorship where, for a small donation each month, sponsors provide children with basic health and education costs.’ [‘Who we are’]
  • But they don’t do this themselves:
    • ‘Our mission partners with ‘IGC Foundation SE Asia’ in Cebu, Philippines, ‘ABC Children’s Aid’ in Uganda and ‘Grace Ministries’ in Zambia.
    • Partnerships?
      • The banner on the home page suggests that the relationship between IGC and the overseas organisations is considerably more than the usual partnership: it says ‘IGC International Gospel Centre Inc.’ ‘IGC Zambia’, ‘Philippines IGC Foundation SE Asia’, and ‘IGC Uganda’.
        • Ministry comment: ‘These partners operate from funds received from our fundraising activities. We are in the process of changing our web site to better reflect the partnership arrangements.’
      • There is no doubt that there is a strong relationship between IGC Foundation SEAsia Inc and IGC, but the IGC website does not make that relationship clear. In most places it presents them as two parts of an IGC whole, even interchangeably. For instance, both IGCs are described under ‘Our Team’.
        • The relationship between IGC Foundation SEAsia Inc, Pro Vision Kids and Christian Frontier Ministries is also not clear.
          • Ministry comment: ‘The relationship will be made clear in our new website and, as required, through our published materials. Agree that it is currently ambigious.’
          • Then there’s The Jesus Fellowship.
            • Ministry comment: ‘This is part of another organisation that works in conjunction with the Field Directors but is separate and should be separate on our website.’
        • There is no mention on the page for Uganda that it what is being talked about is the activities of a separate Ugandan organisation. And with the similar page for Zambia, it is not until half way through that it is apparent that the article was written by the partner (Grace Ministries Mission International).
          • Ministry comment: ‘New website being developed. This will also clearly define our partnership arrangement.’
        • IGC says, in a Note to the accounts, that it ‘ensures that funds are received and expended for designated purposes.’
          • Ministry comment: ‘Our partnership arrangements are very clear in this regard.’

Do they share the Gospel?

  • NA. (Assuming that their partners are not actually ICG entities – see the discussion above – then they just collect money to fund their partners’ programs.)
    • Although IGC’s first ‘Entity Subtype’ on the ACNC Register is one that is consistent with sharing the Gospel, sharing the Gospel is not required by their constitution (under either ‘Purpose’ or ‘Objectives’).
  • The partners: Yes, they do share the Gospel – at least the one in the Philippines does:
    • Ministry comment: ‘We are strengthening the relationship between us and our partners to truly reflect the fact that our foundation is in Jesus Christ. That is, our “business model” exists to enable the sharing of the Gospel. This is a carry over from the past and we will be very clear as we move forward and remove any ambiguity.’

What impact are they having?

  • Nothing found.
    • Ministry comment: ‘This is a very important part of our public engagement and will be incorporated into the website we are developing.’

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

  • Ministry comment: ‘These “costs” are donated “in kind” by a benefactor.
  • If we define ‘direct’ as ‘Overseas Mission Distributions’, then it cost $101K to send $278K (that is, 27%).

Can you get a tax deduction?

  • Yes
    • But how does this fit with the fact that the Gospel is shared by at least one of the partners?
      • Ministry comment: ‘We are currently working through this.

Is their online giving secure?

  • PayPal is used, so yes.

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

  • None

Is their reporting up-to-date?

  • Yes (lodged seven months after their year-end, a week before the deadline).

Does their reporting comply with the regulator’s requirements?

  • AIS 2016: No
    • IGC – Compassion LOVE Action is neither a business name nor a trading name.
    • No outcomes reported.
    • The figure for ‘Other Income’ does not match that in the Financial Report.
    • Ministry comment: ‘Thank you, we take this on notice.’
  • Financial Report 2016:  Questionable
    • The choice of special purpose financial statements over normal statements, a choice that allows less than full compliance with the Accounting Standards, is, given the size and complexity of the charity, questionable.
      • The directors say that the financial statements ‘do not purport to be general purpose financial statements’, but they do not say what they are.
      • The directors don’t say why they didn’t produce general purpose financial statements.
    • The direct adjustment of equity, that is, not via the Statement of Comprehensive Income, of $45K (1.8 times the deficit), is said to be due to revised accounting policies and ‘other direct adjustments’. There is insufficient information disclosed about these changes. Has the applicable Accounting Standard been followed?
    • The ACNC Act, the legislation under which IGC reports, is not mentioned.
    • There is no disclosure of related parties (an ACNC expectation).
    • How is an office run without any non-current assets (including, for instance, office equipment)?
    • The distinction between direct and indirect income is not explained. Why would donations be direct but legacies – another form of donation – indirect?
    • The explanation for ‘Apostolic Ministry Expenses’, and the associated income, is guarded:
      • ‘Transactions described as Apostolic Ministry income and expenditure are made in various forms and include donations received, remuneration payments and benefits to a significant promoter of IGC. These payments are directly funded by donations in support of the Apostolic work of IGC together with direct ministry income that IGC derives from the Apostolic ministry within the organisation.’
        • There is no mention of any ‘apostolic’ activity on the website.
        • Remuneration should be included under Employee benefits expense.
        • If money is received on behalf of another ministry it should not be included in revenue.
        • Is it the money that is talked about by Cliff and Helen Beard on their site?
    • The name on the largest ‘mission distribution’, Cebu Missionary Foundation (Philippines) does not match the name of the partner elsewhere in the IGC material. (The name is nowhere on the website.)
    • Many of the Notes one would expect to see are missing.
      • Ministry comment:Thank you, we take this on notice.’

What financial situation was shown in that Report?

  • Last year’s surplus of 30% of income was dramatically reversed this year, to a negative 7%.
  • Minimal liabilities – either current or non-current.
  • No non-current assets.
  • Salaries and wages $45K: this is for one part-time employee [AIS 2016].

What did the auditor say about the last financial statements?

  • He said that ‘nothing has come to our attention that causes us to believe that the financial report…does not satisfy the requirements of (the ACNC Act)’. So not an audit, but the lesser assurance from a review[5].

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

  • Yes

Who are the people controlling the organisation?

  • There is an undated photo of the ‘IGC Australia Board Members’ on the website, but no names.
  • There are eleven people in the photo but only five on the ACNC Register:
  • Ministry comment: ‘Our board will be reflected on our new website.’

To whom is IGC accountable?

  • To Missions Interlink[6] via their Associate membership.
  • Also to the South Australian regulator of incorporated associations.
  • And, as an Australian registered charity, to the ACNC.

 

 

  1. The only exception is in the Regulations: For the purposes of section 54 of the Act, a chit or ticket evidencing the receipt by an association of an amount not exceeding $10 is prescribed as a receipt or document to which that section does not apply.
  2. Duplicated by, for instance, Investigator College.
  3. Duplicated by, for instance, a recent consultant of IGC.
  4. 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.
  5. As he says in his report, ‘A review…consists of making enquiries, primarily of persons responsible for financial and accounting matters, and applying analytical and other review procedures. A review is substantially less in scope than an audit…and consequently does not enable us to obtain assurance that we would become aware of all significant matters that might be identified in an audit.’
  6. For one opinion on the strength of that accountability, see the section Activities in this review.

CWCI International: mini-charity review

Mini charity review of CWCI International (CWCI), as an organisation that invites you, on its website, to donate to it. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

Are they responsive to feedback?

  • They did not respond to the draft that I sent them on 10 February, nor, because of the ABN added to their website, to the amended draft sent on 27 February.

Is CWCI registered?

  • Yes, as a charity. But in a different name, Christian Women Communicating International.
    • The name they are using, CWCI International, is not registered to them.
    • Not to be confused with the charity, CWCI International Aust Inc Halls Gap Committee.
  • Not to be confused with Christian Women Communicating Intl in Aust.

What does CWCI do?

  • ‘The International Board’s primary ministry is to arrange the production of Know Your Bible (KYB) studies and their translation for use worldwide’ (emphasis in original) [http://www.cwci.org.au/about.php].
  • Donations are for ‘the current translation projects’.

Do they share the Gospel?

  • Not their mission.

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?

  • No financial information is available.
    • As a Basic Religious Charity they are even exempt from completing Section E of the Annual Information Statement 2015 (AIS 2015).
    • 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.” So just ask.

Can you get a tax deduction?

  • No

Is their online giving secure?

  • PayPal is used, so yes.

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

  • None

Is their reporting up-to-date?

  • Yes (six months after their year-end, two days before the deadline).

Does their reporting comply with the regulator’s requirements?

  • AIS 2015: Almost – no outcomes are given.
  • Financial Report 2015: Yes

What financial situation was shown in that Report?

  • NA

What did the auditor say about the last financial statements?

  • No audit report has been made public.

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

  • Except for their phone number, yes.

Who are the people controlling the organisation?

  • No names on the website.
  • From ‘Responsible Persons’ on the ACNC Register:
    • Margaret Gardner
    • Kate Graham
    • Diana James
    • Lynette Schier
    • Lisa Watson

To whom is CWCI accountable?