Sydney Missionary & Bible College: mini-charity review

Mini-charity review of Sydney Missionary & Bible College (SMBC) as an organisation that seeks donations on the internet, and is a member of Missions Interlink. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

For last year’s review, see here.

Are they responsive to feedback?

  • When sent a draft of this review, they, like last year, didn’t respond.

Is SMBC registered?

  • Yes, as a charity.
  • As a public company, company limited by guarantee.
    • SMBC is entitled to omit ‘Ltd/Limited’ at the end of its name.
    • It also has a business name under which it may operate, SMBC’s The Bridge.
  • SMBC operates, per the ACNC Register, in all six states that have a fundraising licence regime, but is still licensed in only NSW[1].
  • SMBC controls another charity, SMBC Foundation Limited.
    • There is no description of the Foundation on the website.
    • There is no explanation in the Financial Report 2016 for why SMBC doesn’t produce consolidated financial statements.
      • The Foundation is not even mentioned in the Financial Report.
    • The Foundation had revenue of $540K, a surplus of $351K and equity of $594K.

What do they do?

  • Start with what is said in its name, then
    • ‘SMBC is thoroughly evangelical and Bible-centred, interdenominational in character, strongly cross culturally mission minded and underpinned by a committment (sic – still) to learning and being transformed in the context of caring community….’

Do they pay their directors?

  • There is insufficient disclosure in the accounts to answer this.

Do they share the Gospel [2]?

  • No

What impact are they having?

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

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

  • ‘Administration expenditure’ (sic) is 7% of expenses. But all the other expenses may contain ‘administration’ expenses, so there is no clear way to even estimate the figure as defined above.

Can you get a tax deduction?

  • Their ABN record says that SMBC has deductible gift recipient status.
    • Why, then, are only three of the seven funds for which it seeks donations marked as being ‘tax deductible’?

Is their online giving secure?

  • Although there is no logo or link, the page says that ‘Westpac’s Secure Portal’ is used, so I’d suggest that the giving is secure.

Where were your (net) donations sent?

  • They show zero for ‘Grants and donations made…’ in the AIS 2016.

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

  • Seven different funds.
    • However, it appears that not a dollar was received again this year in other than the ‘Building & Maintenance Fund’. Is that because they are collecting for another charity, SMBC Foundation Limited?

Is their reporting up-to-date?

  • Yes (five months after their year-end, and at the same time as last year).
    • But if you are considering a large donation, I would ask for more up-to-date financial information – the accounts are for a year end that is now over 9 months ago.

Does their reporting comply with the regulator’s requirements?

  • AIS 2016: Not quite – it says that general purpose financial statements were prepared whereas it was the lower standard special purpose statements.
  • Financial Report 2016: No
    • There is no explanation of why their subsidiary, SMBC Foundation Limited, is not included in the accounts. (In fact, not only is the relationship not disclosed, but this company is not mentioned.)
    • There is insufficient disclosure of the non-current borrowings. Consequently, there is a question over (a) their classification as non-current (with implications for the going concern assumption), and (b) the relationship between borrower and lender.
    • With revenue of $6.00 m, hundreds of students, operations all over Australia, and 68 staff, it is not credible for the directors to state, as they do, that “there are no users who are dependent on its general purpose financial statements”.
      • This allows them to prepare the lower standard special purpose financial statements.
      • Do they realise that they are effectively saying that all current and prospective donors, students, staff and suppliers are able to command the preparation of a report tailored to their needs?

What financial situation was shown in that Report?

  • The surplus as a percentage of revenue was increased from negative 8% to positive 2%.
    • Due in large part to an 81% increase in donations.
  • However, this and other changes was nowhere near enough to rectify the poor short-term financial structure. The working capital position was sufficiently dire (again) – current liabilities were 1.5 times current assets – that the directors thought it necessary to address whether the company was a going concern, that is, whether it could pay its debts as and when they were due and continue to operate for the next 12 months.
    • Their positive answer was based on
      • Assets exceeding liabilities
        • $30.24 m of buildings – presumably the SMBC campus – was the only reason that assets exceeded liabilities.
      • $750K of the $1.36 m non-current borrowings having ‘no set repayment date’.
        • Without further information, these are incorrectly classified as non-current. And a reclassification to current would mean a much higher deficit of working capital (see above).
      • The balance of those borrowings being due progressively, starting April 2018.
      • An overdraft $338K below its limit.
        • The limit was increased this year.
  • Why the interest rate on one part of the $1.36 m borrowings– the Notes do not disclose which part – is zero is not disclosed.
  • ‘Unpaid fees’ have increased 127% – to $178K – yet there is no mention of bad and doubtful debts.
  • The number of employees at the time of completing the AIS 2016, May 2017, was 68. There were only 52 at 31 December 2016.

What did the auditor say about the last financial statements?

  • He gave a ‘clean’ opinion.
    • But he agrees with the directors’ decision to
      • Produce the lower standard special purpose financial statements
      • Not disclose the existence of the subsidiary, and
      • Classify the $750K of borrowings as non-current.
  • The auditor’s independence was threatened by his involvement in the preparation of the report he was auditing. You might ask how this was countered.

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

  • No. It is (still) missing information under ‘Other Name(s)’ and ‘Date Established’.

Who are the people controlling the organisation?

  • The directors are not mentioned on the website. From the ACNC Register they are:
    • Kirrily Brown
    • Andrew Chen
    • Geoffrey Deane
    • Jennifer Fallon
    • Mark Freeman
    • Stuart Gow
    • James Lane
    • Raymond Notley
    • Dean Rerekura
    • Scott Sanders
    • The board is accountable to the members. But there are only 11 of them – and ten of those may be the board members.

To whom is SMBC accountable?

  • To the ACNC.
    • Its ‘Charity Tick’ is used on the website in support of you giving to them. And rightly so, because it would be unwise to give to a charity that is unregistered. The ‘tick’ also means SMBC’s AIS is not overdue, and the ACNC has not taken any compliance against it.
  • SMBC is, as they claim, also in support of you giving, a Member of Missions Interlink.
    • Confirmed.
    • See the section Activities in this review for one opinion on the strength of this accountability.
  • As a company, SMBC is also accountable to ASIC.
  • It also has some other memberships, listed here. One or more of these may have some ongoing requirements of membership.

 

 

  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. “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. 

G.L.O. Ministries Limited: mini charity review

Mini charity review of G.L.O. Ministries Limited (GLO), an organisation that seeks donations online and is a member of Missions Interlink. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

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

Are they responsive to feedback?

  • I sent them a draft of this review on 6 September 2017. Like last year, they…did not respond.

Is GLO registered?

  • As a charity, yes.
  • As a public company, a company limited by guarantee.
    • The company’s name is G.L.O. Ministries Limited, not as it uses it, GLO Ministries Limited.
    • And, as it doesn’t have the necessary provisions in its constitution, it is not entitled to omit ‘Limited/Ltd’ when it uses its company name. See, for instance, the website.
  • GLO has a registered business name, GLO College of Ministries, for its bible college.
    • But no registration in the name it uses on Facebook for the college, CrossConnect.
  • GLO operates, per the ACNC Register, in all states except the Australian Capital Territory and the Northern Territory. It still doesn’t have any fundraising licences where they might be required[1].

What do they do?

  • Generally.
  • For what they did in 2016, see the comprehensive report in the Directors’ Report in the Financial Report (see below).
  • GLO operates overseas, per the ACNC Register, in nine countries.
    • It is not clear how this relates to their statement that they are ‘partnering with mission workers in over 20 countries’.
    • Gifts were sent to ten countries, eight of which are in the list on the Register.

Do they share the Gospel?[2]

What impact are they having?

  • The only thing found was some anecdotal evidence in GLO’s magazine, Spearhead. But the latest issue is (still) Spring 2014.

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

  • Defining ‘direct’ as the expense ‘Overseas ministries and humanitarian aid’, ‘administration’ is 71% of expenses. And this figure doesn’t include any ‘Employee expenses’.

Do they pay their directors?

  • There is no prohibition on this in their constitution.
  • There is insufficient financial information disclosed to check for such payments.

Can you get a tax deduction?

  • Contrary to what GLO says at the bottom of its giving page, GLO itself does not have deductible gift recipient (DGR) status. However, you can claim a tax deduction for a donation on this page if you restrict your donation to one of its two building funds, GLO School of Team Ministries Building Fund and Gospel Literature Outreach Training Centre Building Fund. No information is given on these two funds though.

Is their online giving secure?

  • NA. (It’s not offered.)

Where were your (net) donations sent?

  • The Directors’ Report (in the Financial Report 2016) says that ‘Gifts were distributed to workers and projects in Afghanistan, Australia, China, India, Indonesia, Mongolia, Myanmar, Nepal, Pakistan, Philippines and Romania’.
    • This list is missing Japan and has the additions of China and Pakistan compared to the one the one prepared at around the same time for the AIS 2016.
  • No more specific information on the destination of donors’ funds is available.
  • GLO continues to claim that it ‘passes on 100% of every gift to the ministry. GLO Ministries trusts the Lord to provide for our overhead costs…
    • This is not borne out by the figures: ‘Donations’ were $413K, yet ‘Overseas ministries and humanitarian aid’ expense was on $312K.
  • In the same note, GLO also claims that ‘our administrative costs are covered through general donations and Course Funds’.
    • This is also not borne out by the figures: even if we assume that ‘general donations’ were 100% of ‘Donations’, and therefore none were sent overseas, ‘Donations’ plus ‘Course fees’ gives a total well short of the $758K incurred on ‘Administration’.

Is their reporting up-to-date?

  • Yes (lodged three 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 end that is now eight months ago.

Does their reporting comply with the regulator’s requirements?

  • AIS 2016: No:
    • ‘Administration and occupancy expenses ($349K) are reported as ‘Grants and donations made for use in Australia’.
    • ‘Other Income’ is overstated.
    • Only some of the ‘home office’ staff raise their own financial support, so how can GLO show zero for employees and zero for ‘Employee expenses’ in the AIS 2016?
    • No outcomes are given.
      • The reader is referred to the ‘annual report’. But there isn’t one.
    • The business name is missing.
  • Financial Report 2016: Questionable.
    • Again this year
      • The directors do not say why they have chosen to prepare the lower standard special purpose financial statements. By this choice, they are saying, in effect, that anyone wanting information about GLO can command the preparation of a report tailored to their needs. For a charity operating in six states and 21 countries, with a turnover of $853K, owning at least two properties, operating a bible college, and seeking donations on the internet, this is stretching credulity.
      • There is no explanation for the fact that GLO reports zero employees. It doesn’t fit with, for instance, the existence of ‘home office’ staff who are not self-supporting.
      • There is no information on the two tax-deductible funds.
    • GLO does not comment on the validity of the going concern assumption.
    • Also
      • Again, the auditor includes a disclaimer about accounting policies from a superseded Auditing Standard.
      • GLO continue to include the statement, on the cover page of the Financial Report, a document that they must lodge on a public register, that the report is not be used by the public ‘unless accompanied with additional information concerning the company or the company’s financial position.’
      • The Directors’ Report is included twice.

What financial situation was shown by that Report?

  • Last year’s deficit of 3% revenue was dramatically increased, to 26%.
  • Is it correct that they have a turnover of $853 K, operate in six states, and have more than one property yet not a single employee?
  • Despite the sale of property, the relationship between short-term assets and short-term liabilities (working capital) decreased from 22% positive to 8% negative.
  • There are no long-term liabilities, so with $5.80 m of land and buildings, long-term structure is sound.

What did the auditor say about the last financial statements?

  • The auditor, S.J. Hutcheon, of StewartBrown, issued a ‘clean’ opinion.
    • His report again includes these two contradictory statements:
      • No opinion is expressed as to whether the accounting policies used, as described in Note 3 to the financial statements are appropriate to meet the needs of the members’, and
      • An audit also includes evaluating the appropriateness of accounting policies used and the reasonableness of accounting estimates made by the Directors…
    • In reaching this opinion, he implicitly agreed with the directors’ decision to produce special purpose rather than general purpose financial statements (see above).
    • As well as the above, these articles (here and here) will help you take the right amount of comfort from this opinion.

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

  • No. Still.
    • GLO is overdue, since 2015, in selecting an ‘Entity Subtype’.
    • The business name is missing.
    • ‘Phone’ and ‘Website’ are blank, but neither are compulsory.

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

  • “Support a Mission Worker
    Partner together with God’s labourers serving in the field by giving a one-off gift or ongoing support. At present we need more support for mission workers in India, Indonesia, Mongolia, Nepal and the Philippines.
  • Donate to a Ministry Project
    We are involved in exciting mission projects in countries like Afghanistan, Nepal, Philippines and Mongolia that all need extra financial support.
  • Give to a Building Project (Australia)
    Help provide new facilities and improve existing ministry facilities. Donations to GLO building projects in Australia are tax deductible…
  • Sponsor a Scholarship Student
    GLO Ministries is equipping new workers from Fiji, Indonesia, Mongolia, Nepal, Papua New Guinea and South Korea.”

Who are the people controlling the organisation?

  • Not shown on the website, but here’s the list from the ACNC Register (under ‘Responsible Persons’):
    • Allan Driver
    • Kenneth Harding
    • John Quilliam
    • David Scott
    • Craig Stokes
      • There are 10 directorships in the name ‘David Scott’. And the register only covers charities, not all not-for-profits, and of course doesn’t include for-profit organisations.  Therefore, if after eliminating the charities for which GLO’s David 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.
    • The directors are accountable to the members. At 31 December 2016 there were 49 of them [Directors’ Report].

To whom are GLO accountable?

  • Although not claimed on their website, they are accountable as a Member of Missions Interlink.
    • For one opinion on the strength of this accountability, see the section Activities in this review.
  • They are also accountable to the ACNC.
  • And, as a company, to ASIC.

 

 

 

  1. The law in this area is not straightforward – for instance, is an internet invitation ‘fundraising’ – and advice varies, so check with the charity before drawing any conclusions.
  2. “Good living and social concern are important [to the cause of evangelism], but they are not uniquely Christian graces…I’ve met a lot of fine Hindus, Muslims and atheists. Just living the life is not going to bring someone to Christ. There is much more to it than that. We must help people, certainly, but we must also share with them why we are motivated to do so. We must stand against injustice, poverty and need, but we must at the same time point to the One who brings justice and who can meet the deepest need. Until they know our reasons, how can they come to know our Lord?” [Dan Armstrong, the Fifth Gospel: The Gospel According to You, Anzea Books, pp. 13-14.

Moore Theological College Council: mini-charity review

Mini charity review of Moore Theological College Council (MTC) 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.)

Is it responsive to feedback?

  • When sent a draft of this review, they replied the same day to say that they did ‘not want to pursue this’.

Is MTC registered?

  • As a charity, yes.
    • There are two other charities with Moore Theological College in their name: Church Property Trust – Moore Theological College Library Ordinances and Moore Theological College – M F Abel Trust – Church Property Trust. What is their relationship to RTC?
    • Note 1(t) in the accounts says that ‘The Council acts as Trustee for Moore Theological College Special Purpose Trust Funds’. This fund does not have an ABN. It is not included in MTC’s accounts.
  • With business names:
    • It uses three names instead of MTC: Moore College, Moore Theological College registered, and Moore. Moore is not a business name.
    • It has four ‘centres’: Centre for Ministry Development, Priscilla&Aquila Centre, Centre for Christian Living, and Centre for Global Mission. All are business names.
      • In the Annual Report 2016, the principal says that they only have three centres, the first three above.
        • Why then is MTC’s membership of Missions Interlink in the name of the fourth, Centre for Global Mission?
    • The ABN record shows only two of these six business names.
      • Plus one that is no longer used, John Chapman Preaching Centre.
  • Incorporation:
    • RTC is ‘a Body Corporate under the Anglican Church of Australia (Bodies Corporate) Act 1938 [Financial Report, page 5].
    • The ABN record says that RTC is an ‘Other Incorporated Entity’. ASIC says that it is unincorporated.
  • TC doesn’t have a fundraising licence in the state in which, per the ACNC Register, it operates. Nor in the other six states that have a licensing regime[1].

What does MTC do?

Do they share the Gospel?

  • No – at least not to show who haven’t heard it.

What impact are they having?

  • Presumably the intended impact is the change brought about in the students. No information found on this.

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?

  • Yes
    • Including the two funds that MTC runs, Moore Theological College Building Fund, and Moore Theological College Library Fund.
      • There is one incidental mention of the first fund, and nothing on the second fund, on the website.

Is their online giving secure?

  • The first page says that giving is secure, but you have fill in your details before you see what that means.

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

  • General work of the College’
  • ‘The new building capital campaign’
    • Note the absence of both the tax-deductible funds (see ‘Can you get…’, above).

Is their reporting up-to-date?

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

Does their reporting comply with the regulator’s requirements?

  • AIS 2015: Not quite:
    • Business names are missing.
    • No outcomes are reported.
  • Financial Report 2015: No
    • It is implausible for an organisation that shows Gross Income of $15.25 m, including $11.81 m from the taxpayer and $2.58 m from donors, 144 employees (AIS 2015), over 500 students, and creditors for $2.26m, to have ‘no users dependent on general purpose financial reports’.
      • This means that MTC can produce financial statements that don’t have to comply with all the Accounting Standards, and implies that all users, both present and prospective, can command the preparation of reports tailored to their needs.
      • For a small organisation with limited resources, a decision such as this might be excusable, but from a major player in the Christian community with the resources of the Anglican Church behind it, is it arrogance rather than ignorance?

What financial situation was shown in that Report?

  • The surplus was a high 21% of Gross Income (AIS 2015).
  • Trade payables increased nearly 10 times to $1.61 m. (There is no explanation.)
  • Although current liabilities were $3.80 m, working capital (current assets less current liabilities) was strongly positive.
  • Long term financial structure is sound.

What did the auditor say about the last financial statements?

  • He gave a ‘clean’ opinion[2].
    • However, he agreed with the directors’ decision to produce the lower disclosure special purpose financial statements.

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

  • No
    • the business names are missing.
    • ‘Phone’ and ‘Website’ are blank.

Who are the people controlling the organisation?

  • Those listed here.
  • The list under ‘Responsible Persons’ on the ACNC Register has the same, except without J.L. Ramsay:
    • Ken Chapman
    • Anthony Clemens
    • David Cohen
    • Glenn Davies
    • Christopher Edwards
    • William Hurditch
    • Talar Khatchoyan
    • Andrew Killen
    • Kevin Kim
    • Gary Koo
    • Edward Loane
    • Mark Thompson
    • Robert Tong
    • Diane Warren
    • There are 386 directorships recorded for the name ‘Glenn Davies’ and 362 for ‘Robert Tong’. Yes, 386 and 362. These people may have directorships other than charities, so these numbers may be higher. If after eliminating the entries in the Register that don’t belong to MTC’s Glenn Davies and Robert Tong, you are left with their total being more than a handful, something that seems likely at least for the Bishop, it would be legitimate for you to question whether their ability to discharge their fiduciary responsibilities is threatened.
      • The same, although to a much lesser extent, applies to ‘David Cohen’ (9), Christopher Edwards (10), and Mark Thompson (9).

To whom is MTC accountable?

  • To Missions Interlink, because it’s an Associate member.
  • To the Synod of the Anglican Diocese of Sydney.
  • MTC is also accountable 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. To take the right amount of comfort from a ‘clean opinion’, please read here and here.

Vose Seminary: mini-charity review

Mini-charity review of Vose Seminary (VS), as an organisation that invites you, on its website, to donate to it (and is an Associate member of Missions Interlink). (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

Is VS registered?

Is VS responsive to feedback?

  • They have not responded to the draft I sent on 18 February.

What does VS do?

Do they share the Gospel?

  • No – at least not to those who haven’t heard it.

What impact are they having?

  • No information found.
    • A Google search of the website shows that an annual report must be produced, but it’s not on the website.

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

  • No calculation is possible – no financial statements for VS are available.
    • VS is an operating arm of The Baptist Union of Western Australia Incorporated. Its results are therefore included in their results.

Can you get a tax deduction?

  • Donations are sought only for ‘Vose’s ‘Invest in the Future’ Capital Campaign’. There it says that ‘All donations are tax deductible’.
    • Presumably this is referring to the two tax-deductible funds run by The Baptist Union of Western Australia Incorporated, ‘Vose Seminary’ and ‘Vose Seminary Library’.

Is their online giving secure?

  • NA – not offered.

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

  • Only the ‘Invest in the Future’ Capital Campaign’ is offered.

Is their reporting up-to-date?

  • They don’t report separately.

Does their reporting comply with the regulator’s requirements?

  • They don’t report separately.

What financial situation was shown in that Report?

  • There is no information about VS in The Baptist Union…’s reports.

What did the auditor say about the last financial statements?

  • NA

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

  • NA

Who are the people controlling the organisation?

  • Only the staff are shown on the website.
  • Here, from ‘Responsible Persons’ on the ACNC Register, and the people who govern The Baptist Union…, and therefore presumably VS as well:
    • Vanessa Chang
      • Is it this Vanessa Chang?
    • Craig Eccleston
    • Bradley Entwistle
      • Is it this Brad Entwistle?
    • Gregory Holland
    • Karen Siggins
    • Darren South
    • Bruce Watkins
    • Mark Wilson
    • There are 12 directorships recorded for the name ‘Mark Wilson’, nine for ‘Gregory Holland’.  The ACNC Register has only charities, so if, after eliminating the entries in the Register that don’t belong to VS’s Mark Wilson and Gregory Holland, you are left with their total being more than a handful, it would be legitimate for you to question whether their ability to discharge their fiduciary responsibilities is threatened.

To whom is VS accountable?

  • VS is an Associate member of Missions Interlink. However, as VS is not an entity without even an ABN, presumably it is The Baptist Union…that should be shown as the member.

Tabor College of Higher Education: mini-charity review

Mini charity review of Tabor College of Higher Education (TC) 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.)

Is it responsive to feedback?

  • They have not responded to the draft I sent on 17 February.

Is TC registered?

  • As a charity, yes.
    • But in a different name: Tabor College Inc.
      • TC does not have the name Tabor College of Higher Education registered as a business name.
  • It appears that TC controls another charity, The Trustee For Tabor College Inc Trust.
    • But TC hasn’t take advantage of the ACNC’s group reporting concessions, meaning that this subsidiary (and any others) must report separately.
  • Other registrations:
    • As a South Australian incorporated association (A6378).
      • Not to be confused with the Western Australian association of the same name.
    • An ARBN, allowing it to operate interstate.
    • TC operates, per the ACNC Register, in South Australia and Western Australia. It doesn’t have a fundraising licence in these two states, or in the other five that have a licensing regime[1].

What does TC do?

  • See the mission here, and the three commitments that the President thinks are reasons for a student to enrol with them.
  • Beside the campus in Adelaide, they have had one in Perth since 2015.

Do they share the Gospel?

  • No – at least not to show who haven’t heard it.

What impact are they having?

  • No information found.
    • No educational outcomes given in the Annual Information Statement 2015 (AIS 2015).

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

  • The expenses are not classified to allow this calculation; for instance, ‘Salaries & Wages are not classified by the function of the employee.

Can you get a tax deduction?

  • Yes
    • Also to a fund that TC runs, The House of Tabor Building Fund Inc.
      • This is not, as the name suggests, an incorporated association.
      • There is no mention of this fund on the website.

Is their online giving secure?

  • Secured by Commonwealth Bank’, so yes.

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

  • None shown online.

Is their reporting up-to-date?

  • Yes (six months after year end, a day late).

Does their reporting comply with the regulator’s requirements?

  • AIS 2015: No
    • Business names are missing.
    • No outcomes are reported.
    • ‘Other Income’ does not match the figure in the financial statements.
  • Financial Report 2015: No
    • Neither the directors nor the auditor comment on what the poor results and financial position mean for the going concern assumption.
    • Why isn’t their subsidiary included in the results?
    • It is implausible for an organisation that has revenue of $6.43 m, including money from the taxpayer of $1.32 m, campuses in two states, 143 employees (AIS 2015), and hundreds of students, to say that it is reasonable to produce the type of financial statements that don’t have to comply with all the Accounting Standards.
      • Not only that, but then only one of these Standards has been followed, rather than the usual subset of those required for the type of statements they have produced.
    • Balance Sheet
      • There’s an unexplained treatment of borrowing costs.
      • The valuation basis of the land and buildings is not given.
      • ‘Registration and Accreditation’ is included as an asset without explanation.
    • Income Statement
      • A ‘Transfer From Reserves’ is shown as income.
      • There is no ‘Other Comprehensive Income’ section.
      • There’s an unexplained treatment of prior year adjustments.
    • Notes to the Financial Statements
      • Note 1 is missing most of the required Notes.
      • There is no related parties’ disclosure.
    • Statement of Changes in Equity
      • The deficit does not match the amount shown in the Income Statement.
    • The Statement of Cash Flows should be included as a statement, not as a Note.
    • The directors do not say why the think that PBC is not a reporting entity.
    • The audit report is deficient (see below).
    • Neither the directors nor the auditor mention the ACNC Act.
    • The name of the entity is wrong in the directors’ declaration.

What financial situation was shown in that Report?

  • Keeping in mind what is said in the previous section
    • A surplus of less than 1% of revenue was turned into a deficit of 3% of revenue.
    • ‘Salaries & Wages’ (actually ‘employee benefits expense’ I think) were 83% of expenses.
    • For at least the last two years, working capital (current assets less current liabilities) has been negative.
    • Non-current borrowings increased from $1.66 m to $1.91 m.
    • Is the going concern assumption valid?

What did the auditor say about the last financial statements?

  • He gave a ‘clean’ opinion[2].
    • However, he
      • makes no comment on the going concern assumption,
      • agreed with the directors’ decision to produce the lower disclosure special purpose financial statements,
      • excludes the directors’ declaration from the scope of his audit,
      • gives contradictory information on whether he assessed TC’s accounting policies, and
      • has not included an Emphasis of Matter paragraph.

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

  • Almost – the business names are missing.

Who are the people controlling the organisation?

To whom is TC accountable?

  • To Missions Interlink, because it’s an Associate member.
  • TC is also accountable to the ACNC, and to the South Australian 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. To take the right amount of comfort from a ‘clean opinion’, please read here and here.

Perth Bible College Inc: mini-charity review

Mini charity review of Perth Bible College Inc (PBC) as an organisation that an organisation that invites you, on its website, to donate to it.

Is it responsive to feedback?

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

Is PBC registered?

  • As a charity, yes.
    • With a slight mistake in the name though – there are no brackets.
  • Other registrations:
    • As a WA incorporated association (A0390019Y).
      • The website is in the name Perth Bible College. It is likely they use this name elsewhere. They don’t have this name registered as a business name, so are contravening their enabling legislation.
    • PBC doesn’t have a fundraising licence in the state in which, per the ACNC Register, it operates[1].

What does PBC do?

Do they share the Gospel?

  • No – at least not to show who haven’t heard it.

What impact are they having?

  • No information found.
    • No outcomes given in the AIS 2015.

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

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

Can you get a tax deduction?

  • Yes

Is their online giving secure?

  • PayPal is used, so yes.

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

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

Is their reporting up-to-date?

  • Yes (six and a half months after year end, half a month late).

Does their reporting comply with the regulator’s requirements?

  • AIS 2015: Not quite. ‘Email address’ is blank, and no outcomes are reported.
  • Financial Report 2015: No
    • The ‘Going Concern’ Note does not explain what, if anything, is being done to overcome the fact that PBC is currently a loss-making operation.
    • There is no Statement of Changes in Equity
    • The Statement of Profit or Loss is incorrect:
      • No Other comprehensive income is shown.
      • ‘Assets written off’ have been excluded from expenses.
      • ‘Donations’ are not ‘Other Income’.
      • There is no calculation of ‘employee benefits expense’.
      • A major expense, ‘SCD Course Expenditure’, is unexplained.
      • Neither buildings nor the library are depreciated.
    • The directors do not say why the think that PBC is not a reporting entity.
    • The audit report is deficient (see below).
    • Neither the directors nor the auditor mention the ACNC Act.

What financial situation was shown in that Report?

  • A surplus of 6% of revenue was turned into a deficit of 10% of revenue.
  • ‘Personnel expenses’ were 67% of expenses.
  • Working capital (current assets less current liabilities) decreased from a positive 1.2 times to negative 0.7.
    • The amount owed to the Department of Education increased from $67K to $301K.
    • The negative working capital has been addressed by borrowing against the property.

What did the auditor say about the last financial statements?

  • He gave a ‘clean’ opinion[2].
    • However, he
      • Makes no comment on the fact, acknowledged by the directors, that PBC’s financial situation means that the validity of the going concern assumption is under question.
      • Allowed PBC to omit a Statement of Changes in Equity;
      • Agreed with the directors’ decision to produce the lower disclosure special purpose financial statements;
      • Excluded the Statement of Cash Flow from the scope of his audit.

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

  • No – ‘Email’, ‘Phone’ and ‘Website’ are blank.
  • There’s a country under ‘Where the Charity Operates’, but there should be four more: Kenya, South Sudan, Uganda, and Ethiopia.
  • The board (see Responsible Persons) is, compared to the constitution, one member short.

Who are the people controlling the organisation?

  • Not shown on the website, but
  • From ‘Responsible Persons’ on the ACNC Register:

To whom is PBC accountable?

  • To Missions Interlink, because it’s an Associate member.
  • RTC is also accountable to the ACNC, and to the WA 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. To take the right amount of comfort from a ‘clean opinion’, please read here and here.

Eastern College Australia Incorporated: mini-charity review

Mini charity review of Eastern College Australia Incorporated (EC) as an organisation that invites you, on its website, to donate to it.

  • You may know EC as Tabor College Victoria. It changed its name in August 2015.

Is it responsive to feedback?

  • When sent a draft of this review, on 13 February, they…did not respond.

Is EC registered?

  • As a charity, yes.
  • Other registrations:
    • As a Victorian incorporated association (VIC A0017676J).
      • On its website and Facebook, it uses its name without ‘Inc/Incorporated’ at the end. This is arguably a contravention of section 23 of its enabling legislation.
    • Someone else holds the business name ‘Eastern College’[1].
    • It operates, per the ACNC Register, in all states. It is exempt from having to register for fundraising in its home state, but has no licences in the other six states that have a licensing regime[2].

What does EC do?

  • The header and body of the home page assumes that we know what they do, but from a link in the footer:
    • EASTERN COLLEGE AUSTRALIA is a Christian Higher Education Provider that exists to equip individuals through provision of accredited teaching, training and research that contribute to the transformation of church (local and global), society and marketplace through the lives of its graduates.
  • More specifically, from their constitution:
    • The Association believes that the Bible is the written word of God and the standard by which the validity and philosophy of all subjects taught must be evaluated. The approach to interpreting scripture adopted by the Association may be generally described as evangelical, charismatic and Pentecostal.

Do they share the Gospel?

  • NA – students would have already heard it.

What impact are they having?

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

  • The expenses are not classified to allow this calculation; for instance, there is only one figure for employee benefits expense.

Can you get a tax deduction?

  • Yes

Is their online giving secure?

  • ‘When you press “Submit Form” you will be taken to a secure area where you can safely enter your credit card information.’ Provided by NAB, so should be secure. (Still in EC’s old name though.)

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

  • None

Is their reporting up-to-date?

  • Yes (four months after year end).

Does their reporting comply with the regulator’s requirements?

  • AIS 2015: Except for specifying the wrong type of financial statements, yes.
  • Financial Report 2015: Only if you
    • agree that it is reasonable for the directors to conclude that all the users of its accounts, both present and prospective, can command EC to prepare accounts to suit them.
    • Also
      • a related parties’ Note, suggested by the ACNC, is not included.
      • property, plant and equipment is carried at cost, yet there an Asset Revaluation Reserve.
      • ‘Other expenses from ordinary activities’, over 9% of expenses, is perhaps a little large to have no breakup.

What financial situation was shown in that Report?

  • The surplus increased slightly, but is still less than 1% of revenue.
  • ‘Employee benefits expense’ is 56% of expenses.
  • ‘Trade and other receivables’ have increased from less than 1% of assets to 8%. (No explanation is given).
  • Current assets are 1.3 times current liabilities.
  • Longer term financial structure is sound.

What did the auditor say about the last financial statements?

  • He gave a ‘clean’ opinion[3].

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

  • Yes

Who are the people controlling the organisation?

  • Those shown here.
  • Or, per the ACNC Register, those nine, plus Michael Wong, and Glenn Ward instead of David Ward:
    • Geoffrey Cox
    • Joanna Cruickshank
    • Jame Lewis
    • Cheryl McCallum
    • Timothy Meyers
    • Gregory Restall
      • It is this Greg Restall?
    • David Rietveld
    • David Ward
      • There are 17 directorships recorded for this name.  The ACNC Register has only charities, so if, after eliminating the entries in the Register that don’t belong to EC’s David Ward, 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.
    • Michael Wong
    • Rosemary Wong
  • Four of these people are also on the board of Melbourne School of Theology. Something to do with this (undated) announcement of a ‘partnership’ with MST?

To whom is EC accountable?

  • To Missions Interlink, because it’s an Associate member.
  • EC is also accountable to the ACNC, and the Victorian associations regulator.

 

 

  1. It is a little surprising that the authorities allowed the registration of this name, six months after ECA had changed its name to ECA.
  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. To take the right amount of comfort from a ‘clean opinion’, please read here and here.

Adelaide College of Ministries (ACM): mini-charity review

N.B. The following appears on the website of this ministry:

The board of Adelaide College of Ministries have made the difficult decision to close the College at the end of 2016 due to a number of significant factors. The finances have reached a stage where it is impossible to continue without going into debt, the search for a new Principal has been unsuccessful, and student numbers have become dangerously low.

The ministry is still a member of Missions Interlink (‘the Australian network for global mission’), and it intends to continue to pursue its mission:

The continuing mission of ACM is to teach the Word of God by training and equipping leaders for the Kingdom. The ACM board believes that scholarships and assistance in such a way will fulfil the wishes of the many donors and supporters we have had over the years. This Fund will be administered by godly men who have a deep commitment to the foundational principles of ACM. Further details will be available in the days ahead, but we feel confident that this is God’s direction for us.

A review in the series ‘Associate members of Missions Interlink’ is therefore still appropriate.

When sent a draft of this review, they…did not respond.

Is ACM registered?

  • Still registered as a charity.
  • Still registered as a South Australian incorporated association (A7728).

What does ACM do?

Until the end of 2016 it was a bible college. It is now reorganising as a fund to provide scholarships and assistance to ‘leaders for the Kingdom’ (see the introduction, above).

Do they share the Gospel?

  • NA – either in the past or their intended future.

What impact are they having?

  • Now irrelevant for the College; no activity yet for the fund.

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

  • Now irrelevant for the College; no activity yet for the fund.

Can you get a tax deduction?

  • They are not calling for donations at the moment, but if they do, then it won’t be for either of the tax-deductible funds (one for building, the other for the library).

Is their online giving secure?

  • NA at the moment.

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

  • NA

Is their reporting up-to-date?

  • Yes (six months after year end, the day before the last day).

Does their reporting comply with the regulator’s requirements?

  • AIS 2015: Except for the lack of outcomes, yes.
  • Financial Report 2015: Yes
    • The audit report is unsigned.
    • There is no related parties’ disclosure.

What financial situation was shown in that Report?

  • Past performance is largely irrelevant now, but at 31 December 2015 they had net assets of $3.05 m at going concern values. Land and buildings were $2.75 m of this, with buildings valued at cost and the land ‘at board’s valuation’ (undated).

What did the auditor say about the last financial statements?

  • He gave a ‘clean’ opinion[1].

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

  • Almost – ‘Phone’ and ‘Website’ are blank.

Who are the people controlling the organisation?

To whom is ACM accountable?

  • To Missions Interlink, because it’s an Associate member.
  • ACM is also accountable to the ACNC, and the South Australian regulator of associations.

 

 

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

Reformed Theological College: mini-charity review

Mini charity review of Reformed Theological College (RTC) as an organisation that invites you, on its website, to donate to it.

Is it responsive to feedback?

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

Is RTC registered?

  • As a charity, yes.
  • Other registrations:
    • ITA is a public company, a company limited by guarantee.
      • Its name: It is permitted to omit ‘Ltd/Limited’ at the end.
    • It operates, per the ACNC Register, in all states. No fundraising licences are held[1].

What does RTC do?

  • It is a “reformed, evangelical theological college”.
  • Or as they say in the Annual Information Statement 2015 (AIS 2015):
    • The Reformed Theological College is committed to training people to serve God in the whole of life.

Do they share the Gospel?

  • NA – students would have already heard it.

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 expenses are not classified to allow this calculation.

Can you get a tax deduction?

  • Yes

Is their online giving secure?

  • Security is not mentioned.

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

  • None

Is their reporting up-to-date?

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

Does their reporting comply with the regulator’s requirements?

  • AIS 2015: No
    • A number of the financial figures do not match those in the Income Statement.
    • No outcomes reported.
  • Financial Report 2015: No
    • Why not consolidated reports? Both Pigdons Road Pty Ltd and The Trustee for the Reformed Theological College Foundation are subsidiaries.
    • Other comprehensive income is not shown.
    • The item ‘Other expenses…’ is 35% of expenses, yet there is no breakup.
    • There is no related parties’ disclosure.
    • RTC says that the financial statement are general purpose; the auditor says they are special purpose.
    • Why are the two ‘Non-Operating Activities’ any less part of the College’s operations than the ones under ‘Operating Activities’? (This is not a distinction used by the ACNC.)
    • Buildings and the library are not depreciated. (The surplus is therefore overstated.)
    • $116,966 in Note 2 is not ‘Net cash provided by from (sic) investing activities’.
    • The land and buildings valuation is long out-of-date.
    • How does an ‘Overseas student assist (sic) fund’ meet the definition of a liability? Likewise, the ‘Other’ provisions?

What financial situation was shown in that Report?

  • With the knowledge that
    • the Report, because it omits RTC’s two subsidiaries, shows an incomplete picture, and
    • adjustments to the figures and disclosures are needed (see just above) –
      • The deficit was again approximately 1% of revenue.
      • Current assets are 1.8 times current liabilities.
      • Longer term financial structure is sound.

What did the auditor say about the last financial statements?

  • He gave a ‘clean’ opinion[2].
    • However, he says he audited ‘a special purpose financial report’ when Note 1 to the accounts says that the report is a general purpose financial report.
  • The inclusion of an Auditor’s Compilation Report implies that he also produced the financial statements.

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

  • No
    • One business name is missing
    • ‘Phone’ and ‘Website’ are blank.

Who are the people controlling the organisation?

  • The composition of the board is given on the website, but no names.
  • From ‘Responsible Persons’ on the ACNC Register:
    • John Barkley
    • Johannes Berends
    • John Bylsma
    • Anthony Deenick
    • John Hoogenhout
    • Peter Van Der Schoor
    • Cornelis Van Garderen
    • Dirk Van Garderen
    • Dawid Van Vuuren
    • Harry Westendorp

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

Worldview Centre For Intercultural Studies: mini-charity review

Mini charity review of Worldview Centre For Intercultural Studies (WC) as an Associate member of Missions Interlink. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

Is it responsive to feedback?

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

Is WC registered?

  • As a charity, yes.
  • Other registrations:
    • WC is a public company, a company limited by guarantee.
    • It is permitted to omit ‘Ltd/Limited’ at the end of its name.

What do they do?

Do they share the Gospel?

  • No – they educate Christians.

What impact are they having?

  • There is no mention of impact, outcomes or results on the website.

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

  • The expenses are not classified to allow this calculation.

Can you get a tax deduction?

  • No

Is their online giving secure?

  • There is no online giving.

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

  • Donations are not sought.

Is their reporting up-to-date?

  • Yes. (Six months after year end, two days before the deadline.)

Does their reporting comply with the regulator’s requirements?

  • AIS 2016: Not quite
    • ‘Other Income’ does not match the same item in the financial statements.
    • There are no outcomes.
  • Financial Report 2016: Questionable
    • The Statement of Comprehensive Income is missing an ‘Other comprehensive income’ section.
    • They report no employee benefits. Although this matches their reporting of zero employees, in the AIS, it is based on their belief that their workers, being ‘religious practitioners’ or ‘members of religious orders’, are not employees at common law. But even if this is true, it does not provide an exemption from the statues that govern staff.
    • Note 3b does not match the body of the statement.
    • Inventories are not valued correctly.
    • There is no breakup of the $978K of ‘Property, Plant & equipment’.
    • There is no related parties’ disclosure.
  • WC must report to the ACNC because its parent, W.E.C. International has not taken advantage of the ACNC’s group reporting concessions.

What financial situation was shown in that Report?

  • Last year’s deficit of 10% of revenue blew out to 23% this year.
  • Working capital (current assets less current liabilities) is strongly positive.
  • There are no long-term liabilities.

What did the auditor say about the last financial statements?

  • He gave a ‘clean’ opinion[1].
    • This means that he agreed with WC’s non-reporting of employee benefits (see above).

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

  • Yes

Who are the people controlling the organisation?

  • Not mentioned on the website. But
  • From ‘Responsible Persons’ on the ACNC Register:
  • If you ‘search the (ACNC) register by responsible person’, you will find that, other than ‘Stephen Brown’, who has eight, these directors have no more than one other charity directorship.  WC’s Stephen Brown has at least two non-charity directorships; if, after eliminating the entries in the Register that don’t belong to him, 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 or her fiduciary responsibilities is threatened.

To whom is WC accountable?

  • WC is an Associate member of Missions Interlink. Missions Interlink has an accountability regime[2].
  • WC is also accountable to the ACNC.

 

 

  1. To take the right amount of comfort from a ‘clean opinion’, please read here and here.
  2. For one opinion on the strength of that accountability, see the section Activities in this review.