Perth Bible College Inc: charity review

This is a charity review of Perth Bible College Inc (PBC), an organisation that seeks donations online and is a member of Missions Interlink. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

For the previous review, see here.

Is it responsive to feedback?

  • There is nothing on the website about feedback, complaints or PBC’s accountability.
  • I sent them a draft of this review. Like the previous two years, they did not respond.

Is PBC registered?

  • As a charity, yes.
  • And as a WA incorporated association (A0390019Y).
  • Its website and social media sites are in the name PBC Perth Bible College. As neither one of these, or both together, are not registered as business names, they are still contravening both the business names legislation and their enabling legislation.
  • They do have two business names though: International Mission Teams is held by PBC and Centre for Biblical Counselling is held by Perth Bible College Inc.
  • PBC still doesn’t have a fundraising licence in the state in which, per the ACNC Register, it operates. Nor in any of the other states that have a licensing regime applicable to charities.

What does PBC do?

Do they share the Gospel[1]?

  • No

What impact are they having?

  • Nothing systematic found.

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

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

Do they pay their board members?

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

Can you get a tax deduction?

  • Yes

Is their online giving secure?

  • PayPal is used, so yes.

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

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

Is their reporting up-to-date?

  • Yes (five months after year end, 11 days later than last year).

Does their reporting comply with the regulator’s requirements?

  • AIS 2017: No
    • PBC’s other names that it uses are missing.
    • Three of the substantive figures in the ‘Comprehensive Income Statement summary’ are incorrect.
    • No outcomes are reported.
    • ‘WA Fundraising No.’ is blank.
  • Financial Report 2017: No. Again, this year
    • PBC’s directors produce special purpose financial statements, implying that any stakeholder can command PBC to prepare financial statements to suit them. As a bible college with a revenue of $1.19 m and 29 staff, this is implausible.
    • 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 classified as ‘Other Income’.
      • there is no calculation of ‘employee benefits expense’.
      • neither buildings nor the library are depreciated.
      • it uses a mixed classification for expenses.
    • The Notes to and forming part of the accounts (sic)
      • are missing many Notes, including one on related parties (an ACNC expectation).
      • do not tell us why the directors think that PBC is not a reporting entity.
      • do not explain the relationship between PBC and the other educational institutions with which it is associated.
    • The Statement of Financial Position
      • has a confusing (non-standard) classification of current liabilities, and
      • divides, without explanation, the liabilities that are not current into ‘Non-Current Liabilities’ and ‘Long Term Liabilities’.

What financial situation was shown in that Report?

  • The surplus as a percentage of revenue was increased from 4% to 8%.
  • ‘Personnel expenses’ were 64% of expenses (68% last year).
  • Working capital (current assets less current liabilities) increased from 120% to 150%.
  • The long term financial structure, because of the land and (undepreciated) buildings they hold, is much healthier than the short-term structure.

What did the auditor say about the last financial statements?

  • The auditor, Geoffrey Carslake, for Shreeve & Carslake, gave a ‘clean’ opinion.
    • But before you decide how much comfort to take from this,
      • note that he has given this ‘clean’ opinion despite the deficiencies identified above, and
      • read here and here on the meaning of an audit opinion.

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

  • Ethiopia and Kenya are missing from ‘Operates in (Countries)’.
  • Its other names are missing.
  • ‘Who the Charity Benefits’ omits the students.
  • ‘Email’, ‘Phone’ and ‘Website’ are blank, but the ACNC says that these are not compulsory.

Where were your (net) donations sent?

  • Although they operate, per the ACNC Register, in three countries other than Australia, the AIS 2017 discloses grants as zero. What do they do there?

Who are the people controlling the organisation?

To whom is PBC accountable?

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

 

 

  1. 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.

 

Sydney Missionary & Bible College: charity review

This is a charity review of Sydney Missionary & Bible College (SMBC), an organisation that seeks donations on the internet, and is a member of Missions Interlink.

The Australian charities regulator, the ACNC, in their Factsheet: Making sure your donation gets to where it needs to, gives “some steps to consider to help make sure your donation is going where it is intended.”

  1. Check the organisation’s name
  2. Ask for identification from anyone seeking a donation.
  3. Be careful of online requests for donations.
  4. No tax deduction doesn’t mean the charity is not a legitimate one.
  5. Find out more about how the charity says it uses donations.

Here are the answers for SMBC[1]:

1: Checked. It is a registered charity.

2. NA

3. SMBC’s “web address begins with ‘https’ and…there is a closed padlock symbol next to the website’s URL in the address bar”. A secure way to give to SMBC.

4. You can get a tax deduction. But four of the seven options are donations to another charity, SMBC Foundation Limited. There is still no explanation of the relationship between the Foundation and SMBC, either on the website or in either charity’s Financial Report 2017. End of review[2].

(Think this a bit tough? Proceed to the fifth of the ACNC’s steps, and you’ll probably make the same decision. For there you will find that the directors of SMBC, supported by the auditor, C I Chandran of Pitcher Partners, have once again made two highly questionable decisions about the reporting of SMBC finances: 1. They still maintain that, despite revenue of $7.14 million and having 71 staff, that they don’t need to produce financial statements that comply with all the Accounting Standards[3] and (2) $550K of borrowings that have no set repayment date can be classified as non-current rather than current, thereby greatly reducing the existing challenge to validity of the going concern assumption. Romans 13:1-7. James 3:1.)

 

  1. I sent them a draft of this review. In not responding, they continued their practice of the previous two years.
  2. Involved with this charity and want to know more? See last year’s review – not much has changed.
  3. This means that they are saying, in effect, that any of the present and prospective stakeholders can get SMBC to prepare financial statements tailored to their needs. Ludicrous.

 

Whitley College: charity review

This is a charity review of Whitley College (Whitley), an organisation that seeks donations online and is a member of Missions Interlink.

The ACNC, the charities regulator, in their Factsheet: Making sure your donation gets to where it needs to, gives “some steps to consider to help make sure your donation is going where it is intended.”

  1. Check the organisation’s name
  2. Ask for identification from anyone seeking a donation.
  3. Be careful of online requests for donations.
  4. No tax deduction doesn’t mean the charity is not a legitimate one.
  5. Find out more about how the charity says it uses donations.

Here are the answers for Whitley:

1: Checked. It is a registered charity, in the name Whitley College The Baptist College of Victoria.  (An earlier attempt to review Whitley was thwarted by the temporary removal of this entire record by the ACNC. See the explanation here.)

2. NA

3. Whitley uses GiveNow to collect donations for it. GiveNow’s “web address begins with ‘https’ and “[that] there is a closed padlock symbol next to the website’s URL in the address bar”. A secure way to give to Whitley.

4. A tax deduction is possible.

5. There might be information about how it uses its donations, but this is in a set of financial statements that are drawn up on the belief by the directors, in effect, that there are no stakeholders of Whitley, either present or prospective, who are unable to command Whitley to prepare financial statements tailored to their needs. So they don’t comply with all the Accounting Standards. With 26 staff, and enough students, donors, grant makers, and others to produce $4.78 million of revenue, this is absurd. And if this is the kind of decision that these directors make…end of review[1].

  1. As usual, I sent a draft of this review to the charity. The Business Manager promised me a reply but, despite a reminder, there’s been no further response.

 

Vose Seminary and the institutional Baptist church

It was Walter Scott (in Marmion), not Shakespeare, who said ‘‘Oh, what a tangled web we weave…when first we practice to deceive.” There’s little romance in what I am about to describe, and I don’t suspect any attempt to deceive[1], but it’s just that I like the first part of this quote for the picture it paints.

A nice simple charity review for me is where the entity is registered, has all the required documents lodged on the Register, and has its own website.

Vose Seminary, a member of Missions Interlink, is so far the opposite that you get this post instead of a review.

Not interested in Vose Seminary? What about Baptists in Western Australia? For that’s where we’ll need to go to get the information a wise donor needs before they donate to Vose Seminary.

Vose Seminary

I start with the Register. Nothing there. Merriam-Webster’s online dictionary gives two closely related definitions for ‘seminary’: ‘an institution of secondary or higher education’ and ‘an institution for the training of candidates for the priesthood, ministry, or rabbinate’. Assuming that it is a not-for-profit, Vose Seminary is likely a charity.

So, unless it’s part of another charity that is on the Register[2], then it should be registered as a charity. Therefore I go to ABN Lookup. It’s name is there, but only as a trading name, a system that was replaced in 2012 by business names.

The trading name belongs to the registered charity The Baptist Union Of Western Australia Incorporated (BUWA).

Sometimes a business name is registered but it doesn’t appear on ABN Lookup. So I check the business names index at ASIC. And there it is, Vose Seminary as a business name. But not held by BUWA, but by an organisation with the same name but without ‘Incorporated’ at the end.

As ‘Incorporated’ is an essential part of an incorporated association’s name, and as this second The Baptist Union…’ has an incorporated association number, and as BUWA reports in its Annual Report that it is incorporated, then it’s likely that these two organisations are one-and-the-same.

But what about the third one, The Baptist Union of Western Au Inc? It holds the business names ‘Baptist Churches of Western Australia’ and ‘Baptist Op Shop’ (as well as ‘Leavers Green Team’.

Having discovered that Vose Seminary is part of BUWA, we turn to the accounts of that charity.

BUWA’s accounts

BUWA’s ‘Financial Report 2017’ (from the Register) confirms that Vose Seminary is included in the figures presented for BUWA:

So, as a department of BUWA, we would not expect to see separate accounts for Vose Seminary. And we don’t. (Why then have they included separate accounts for the two Trusts?) As a donor to Vose Seminary, you therefore need to trust BUWA.

In finding Vose Seminary registered as a business name, I also saw that there were five other ‘Voses’ registered as business names: Vose Leadership Centre, Vose Interns, Vose Research, Vose Mission, and Vose Distance. What’s the connection with Vose Seminary?

Voses

The website that is linked from the name in the list of members at Missions Interlink is not one for Vose Seminary, but for an entity called Vose. What is the relationship between the two?

The ‘About us’ page treats them as synonymous. But this is confused by the main menu having separate pages for ‘Vose Seminary’, ‘Vose College’, ‘Vose Training’, and ‘Vose Leadership’. (Despite the many registered ‘Voses’ (see above), these three are not included. Why?) To add to the confusion, the Annual Report brackets Vose Seminary with ‘Vose College’ as one of the four departments in which the staff work:

What about the other four Voses?

Back to the registers on a search for Voses. Nothing for ‘Vose’, ‘Vose Training’ or ‘Vose Leadership’, but Vose College is a charity in its own right. They are all Voses, so what’s the distinction?

The other parts of the ‘economic entity’ BUWA

The extract from the Financial Report, above, said that the following ‘entities and departments’ formed part of the BUWA economic entity, the group:

  1. Vose Seminary
    • See above.
  2. Campsites
    • There are two campsites that operate under business names registered to BUWA: Baptist Campsite Serpentine, and Baptist Campsite Busselton.
  3. WA Baptist Basketball
    • No such name is registered – to anybody.
  4. Long Service Leave Fund
    • No such name is registered, even with the inclusion of ‘Baptist’.
  5. Vose Seminary Building Fund
    • This is a fund operated by BUWA (gifts to which are tax deductible).
  6. Minnie Bairstow Trust
    • This is a registered charity. The trustee is Vose Foundation. Yes, another Vose, itself a charity.
    • Why is Vose Foundation not included in BUWA’s figures?
  7. Heather and Noel Vose Library Trust
    • This is a registered charity. The trustee is Vose Foundation.
  8. Mount Barker Community Resource Centre
    • A search of the ACNC Register for ‘Mount Barker Community Resource Centre’ gives this result:

The above list of eight entities therefore includes a confusing mixture of departments, funds, and subsidiaries. But neither funds nor departments require consolidation – they are already part of the holding company.

The analysis of the list also shows that one subsidiary is missing – Vose Foundation.

But is that all that is missing?

No, maybe not.  Are one or more of the following organisations also part of the ‘economic entity’?

  • Vose Seminary Library, a fund operated by BUWA (gifts to which are tax deductible).
  • Vose Foundation is the trustee for another charity, The Trustee for Thomas Bailey Trust.
  • The Annual Report of BUWA includes the financial statements of the charity Baptist Relief Fund Inc. Why isn’t this organisation consolidated?
  • The Annual Report includes a report on Baptistcare Inc. Elsewhere in the Report, this organisation is included in the family along with the campsites etc:

Who’s responsible for this mess?

The following people are listed as the ‘Responsible Persons’ of BUWA on the ACNC Register:

And unless you are in a position to command BUWA to prepare you a set of financial statements tailored to your needs, these are the people who, in deciding that BUWA ‘is not a reporting entity’, led to the preparation of accounts that are not the right ones for you – special purpose financial statements instead of general purpose financial statements.

Over to you Western Australian Baptists.

 

  1. But deception may well be the result.
  2. Vose presents to the world as a separate entity – own website, own premises – so you might expect that it has its own ABN (and then uses that to register as a charity). The fact that it doesn’t is OK so long as it operates under the same ‘business structure’ as the owner of an ABN:
  3. There are 11 directorships recorded for the name ‘Mark Wilson’, 10 for ‘Greg(ory) Holland’, and nine for ‘Bruce Watkins’. The ACNC Register has only charities, so if, after eliminating the entries in the Register that don’t belong to BUWA’s Mark Wilson, Gregory Holland and Bruce Watkins, 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.

Malyon College (Queensland Baptists): charity review

This is a charity review of Malyon College (MC), an organisation that seeks donations online[1], and is a member of Missions Interlink. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

For the previous review, see here.

Are they responsive to feedback?

  • There is no invitation on the website to give feedback, nor an invitation to submit a complaint other than if you are a student, and no discussion of accountability as an organization.
  • I sent them a draft of the review. Like last time, they… did not respond.

Is MC registered?

  • Although MC is a charity, it is not a charity registered with the charities regulator, the ACNC. It would no doubt argue that this is the reason for the lack of registration:

  • Although they have omitted it from their ABN record, ‘Queensland Baptists’ is a registered business name of The Baptist Union of Queensland (BUQ), which is a registered charity.
  • MC presents to the world as a separate entity – own website, own premises – so you might expect that it has its own ABN (and then uses that to register as a charity). The fact that it doesn’t is OK so long as it operates under the same ‘business structure’ as The Baptist Union of Queensland:

  • So, MC has no separate legal identity – it is not incorporated. Instead, it is a department or division of BUQ.
    • BUC is incorporated though – under an archaic mechanism called ‘letters patent’. Its letters patent is under an old Act, The Religious Educational and Charitable Institution Act of 1861 (Qld).
  • For BUQ to be able to operate under a name Malyon College (that is, a name other than its own (full) name), it must register a business name. It’s got 27 names registered, but Malyon College – The Queensland Baptist College of Ministries is the closest it’s got to Malyon College. This means that MC not entitled to trade under the names it uses, on both its website and Facebook, Malyon College and Malyon[2].
  • BUQ (and therefore MC) operates, per the ACNC Register, only in Queensland. It said in its AIS 2017 that it did not intend to fundraise. It therefore ignored the fact that MC (and maybe other departments) have an online invitation to give. If it believes that it meets the definition of a ‘religious order’ in Queensland, or that it is a body that has ‘an authority to marry people’ in Victoria, then its lack of a fundraising licence anywhere in Australia is explained for those two states, but what about the others?

What do they do?

  • We provide world-class, accredited theological education and train our students in practical ministry, so they can serve God effectively wherever God places them[3].
  • BUQ operates overseas, per the ACNC Register, only in Solomon Islands. There is nothing on the MC website to suggest that it is MC that is in this country.
  • MC doesn’t have a constitution to check for objects or purposes, but BUQ’s By-Laws tell us that a ‘Purpose Statement’ for MC should have been developed. There is one reference to such a statement on the website, but the document is not there or elsewhere on the internet.

Do they pay their board members?

  • MC should have a Charter. It’s not available publicly so I can’t check for a provision about paying board members.
  • There is insufficient public financial information to say.

Do they share the Gospel[4]?

  • Yes, but you would expect their audience to already be believers.

What impact are they having?

  • Nothing systematic found.

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

  • There is insufficient disclosure to even estimate this.

Can you get a tax deduction?

  • No, you can’t for a donation to BUQ itself, only its two funds. So that means that you can’t get one for a donation to MC either.
  • But this does not match the information on the website:

  • As it says further down that page, this is via a donation to The Malyon Foundation.
    • The Trustee for the Malyon Foundation is a registered charity, not a department of BUQ. It is a public ancillary fund, with three individuals as the ‘trustee’.
    • It can only give gifts to an organization that has deductible gift recipient status. MC doesn’t have this, so why is MC collecting directly for its own operations?

Is their online giving secure?

  • It is not offered.

Where were your (net) donations sent?

  • No information is available.

Is their reporting up-to-date?

  • Yes (via BUQ) (over eight months after their year-end, five weeks late, and six weeks later than last year).
    • But if you are considering a large donation, I would ask for more up-to-date financial information – the accounts are for a year end that is now nearly 11 months ago.

Does their reporting comply with the regulator’s requirements?

  • AIS 2017: NA – MC is not a registered charity.
  • BUQ AIS 2017: No
    • All but one of the business names is missing. And the name The Malyon Foundation.
    • The activities are not specifically those of 2017.
    • No outcomes are reported.
    • It would be surprising if the number of employees were exactly 800, 300, and 100.
    • They will be fundraising next year.
    • It is surprising that there was no ‘Other income’ in $110.84 m of income.
    • ‘Other comprehensive income’ is incorrect.
  • Financial Report 2017: NA – MC is not a registered charity.
    • But as a member of Missions Interlink MC is required 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].
      • There is no evidence that MC produces such a statement.
      • Even if a financial statement for the organization of which MC is a department, BUQ, is acceptable to Missions Interlink, that financial statement needs to be ‘clear and appropriate’.
  • BUQ’s Financial Report 2017, like last year, is neither ‘clear’ nor ‘appropriate’.
    • To claim that there are no users, present or prospective, who are dependent on a regulator to get the financial information that might need to make decisions about an organization that has multiple public-facing departments, and 3200 staff, is…ludicrous.
    • The directors still behave as if they believe that they are above the law – for an organization of this size and complexity run professionally it must be this rather than mere ignorance – in that they continue to
      • omit one of the required financial statements,
      • produce a Statement of Profit or Loss and Other Comprehensive Income that is materially non-compliant with the Accounting Standards, and
      • consolidate one charity they control yet leave another out (without mentioning consolidation).
      • do several other things that are contrary to a true and fair view.

What was the financial situation shown by that Report?

  • Given what is reported above, no comment.

What did the auditor say about the last financial statements?

  • There are no separate financial statements of MC available. So, no audit.
  • The auditor of BUQ, Glen Klein CPA, of Audit Right Pty Ltd, issued a ‘clean’ opinion[5]. Looking at what is reported above, one must ask ‘Why?’

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

  • NA – MC is not a registered charity.
  • For BUQ, no, it’s not:
    • All but one of the business names is missing. And the name The Malyon Foundation.
    • ‘Who the Charity Benefits’ is blank.
    • ‘Phone’ and ‘Website’ are blank (but neither is compulsory).

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

http://malyon.edu.au/about-us/support-malyon/

Who are the people controlling the organisation?

To whom is MC accountable?

  • As a department of BUQ, MC is accountable to BUQ.
  • MC doesn’t mention it, but it is a member of Missions Interlink.
    • See the section Activities in this review for one opinion on the strength of this accountability.

 

 

  1. For another charity, The Trustee for The Malyon Foundation.
  2. Although BU has another 26 business names, it does not show any business names on the Australian Business Register. Nor does it have its four ‘centres’, the Malyon Centres, registered.
  3. http://malyon.edu.au/about-us/
  4. Good living and social concern are important [to the cause of evangelism], but they are not uniquely Christian graces…I’ve met a lot of fine Hindus, Muslims and atheists. Just living the life is not going to bring someone to Christ. There is much more to it than that. We must help people, certainly, but we must also share with them why we are motivated to do so. We must stand against injustice, poverty and need, but we must at the same time point to the One who brings justice and who can meet the deepest need. Until they know our reasons, how can they come to know our Lord?” [Dan Armstrong, the Fifth Gospel: The Gospel According to You, Anzea Books, pp. 13-14. 
  5. Read here and here to draw the right conclusions from such an opinion.

 

An update on ‘The curious case of Whitley College’

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

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

Bible College of Queensland: charity review

A charity review of Bible College of Queensland (BCQ), an organisation that seeks donations online and is an Associate member of Missions Interlink. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

The previous review, in 2016, is here.

Are they responsive to feedback?

  • BCQ does not, on its website, invite feedback.
  • I sent them a draft of this review. Like last time, they…did not respond.

Is BCQ registered?

  • As a charity, yes.
  • BCQ is a public company, a company limited by guarantee.
    • It is permitted to omit ‘Ltd/Limited’ at the end of its name.
  • It has three business names, Brisbane School of Theology, Bible College of Queensland, and Centre for Asian Christianity.
  • BCQ operates in Australia, per the ACNC Register, only in Queensland. It solicits donations via the internet.
    • It has a fundraising licence only in Queensland. Whether it needs one in the other four states that have a licensing regime for charities depends on whether those states think that BCQ, by calling for donations on their website, are ‘fundraising’ in their State.
  • BCQ does not, per the ACNC Register, operate overseas.
    • Why then the membership of Missions Interlink, ‘the Australian network for global mission’?

What does BCQ do?

  • It’s in the name. For how they do it, start here.

Does BCQ share the Gospel?[1]

  • To students, undoubtedly. But the grant of tax-deductible status suggests that the use of the money raised shouldn’t include proselytising.

What impact are they having?

  • Nothing systematic found.

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

  • The expenses are insufficiently disclosed to allow an estimation of this.

Do they pay their board members?

  • This is not permitted under BCQ’s constitution.
  • There is insufficient information about the expenses to check for these payments.

Can you get a tax deduction?

  • Their ABN record says that you can. Both to BCQ itself, and to either of its two funds, Qld Bible Institute College Building & Maintenance Account, and Bible College of Queensland Library Fund.
    • But this is contradicted by the existence of a giving option (see below) that is not tax-deductible.

Is BCQ’s online giving secure?

  • Mycause.com.au is used, and security is not mentioned on their first page.

Is the reporting up-to-date?

  • Yes (five months after their year-end, over two months later than last year).
    • But if you are considering a large donation, I would ask for more up-to-date financial information – the accounts are for a year end that is now 14 months in the past.

Does BCQ’s reporting comply with the regulator’s requirements?

  • AIS 2016: No
    • ‘Other income’ is incorrect. (With a consequence that ‘All other revenue’ and ‘Total revenue’ are also incorrect.) It matches neither the ACNC’s definition, nor the accounts.
    • No outcomes are reported.
  • Financial Report 2016: Yes?
    • The items classified as ‘Other income’ are as much revenue as the items included under ‘Revenue’. Revenue is therefore understated by $201K.
    • There is still no explanation for the non-standard practice of separating ‘Building Improvements’ and ‘Building development costs’ from ‘Buildings’.
    • The disclosure of revenue still includes a combined revenue figure for ‘Student fees, board and functions’ $1.23m.
    • For other observations, see this footnote[2].

What financial situation was shown by that Report?

  • The surplus as a percentage of revenue (adjusted – see above) was still negative, at 3%, but down from last year’s 8%.
  • The wages bill is unchanged from last year’s 70% of expenses.
    • From the workforce disclosed in the AIS 2016, and assuming the casuals average 10% of full-time and the part-timers 50%, this represents an average package of $69K p.a.
  • The margin of current assets over current liabilities (working capital), declined from 1.8 times to 1.3 times.
  • The holding of land and buildings means that the long-term financial structure is sound.

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

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

  • Except for the omission of one business name, yes.

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

  • ‘Give a gift to our General Fund to be used where it is needed most (not tax-deductible)’
  • ‘Support our Centre for Asian Christianity as we equip Christians for contextual Asian ministry’
  • ‘Make a tax-deductible gift and invest in our Library Fund’
  • ‘Make a tax-deductible gift and invest in our Building Fund’

Where were your (net) donations sent?

  • NA

Who are the people controlling BCQ?

  • Shown on the website here.
  • Which are the same people shown on the ACNC Register (under ‘Responsible Persons’):
  • The board is responsible to the members. There were 21 of these at 31 December 2017 (Directors’ Report, Financial Report 2016). As directors must be members (the constitution), 12 outside the board provides some accountability.

To whom is BCQ accountable?

  • As a charity, to the ACNC.
  • Not claimed on the website, but BCQ is a member of Missions Interlink, an organisation that has standards with which BCQ must comply.
    • For one opinion on the strength of this accountability, see the section Activities in this review.
  • BCQ, as a company, is still accountable for some things to ASIC.

 

  • 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.
  • If interest is accrued (Note 1 a), why is the revenue identical to the cash amount?There is still no item in ‘Cash Flows from Operating Activities’ that includes the donations.Neither fundraising nor administration costs are disclosed.There is still no explanation for the unusual item ‘Rental of communication tower’ (7+% of revenue).

    One of the items of ‘Property, Plant and Equipment’ is still ‘Plant and Equipment’. What’s in it?

    The figure for provisions in Note 10 does not match the figures in the Statement of Financial Position.

    We are still not told (a) the functional and presentation currencies, and (b) whether the directors have the power to amend and reissue the financial statements.

    There’s still no policy Note ‘New, revised or amending Accounting Standards and Interpretations adopted’

Melbourne School of Theology: charity review

A charity review of Melbourne School of Theology (MST), 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?

  • MST does not, on its website, invite feedback.
  • I sent them a draft of this review. They…did not respond. (Last year, after they asked whether MST had requested the review and where it would be published, I did not hear from them again.)

Is MST registered?

  • As a charity, yes.
    • It controls another charity, The Trustee For Melbourne School of Theology Ministry Fund (the Fund). It is the trustee.
    • The two form an ACNC ‘reporting group’. This means only one Annual Information Statement (AIS) and one Financial Report is required.
      • The Fund says on the ACNC Register that the MST website is its too, but there is no mention of the Fund on that site.
      • Apart from twice identifying the Fund as its sole subsidiary, MST does not mention it in the Financial Report 2016.
  • MST is a public company, a company limited by guarantee.
    • It is permitted to omit ‘Ltd/Limited’ at the end of its name.
    • It has one business name, Melbourne Bible Institute, but the name that it is uses on the internet, MST, is not registered.
  • MST operates in Australia, per the ACNC Register, in Victoria.
    • If Worldview Centre for Intercultural Studies is correct, though, it also operates in Tasmania.
    • It solicits donations via the internet. It has no fundraising licences.
      • The law in this area is not straightforward and advice varies, so check with the charity before drawing any conclusions.

What does the group do?

  • This is answered here.
  • It has three ‘partnerships’ with other ‘Christian’ educational institutions:

Does MST share the Gospel?[1]

  • To students, undoubtedly. But the grant of tax-deductible status to both charities suggests that the use of the money raised shouldn’t include proselytising.

What impact are they having?

  • Nothing systematic found.

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

  • Although the accounts have an ‘Administration Expense’ item, there are clearly other items that qualify as administration on most reasonable definitions of ‘direct’ for a bible college, plus probably such costs in other line items, so no estimate can be made.

Do they pay their board members?

  • This is not permitted under MST’s constitution.
  • There is insufficient information about the expenses to check for these payments.

Can you get a tax deduction?

  • Yes. Both MST and the Fund are Deductible Gift Recipients.
    • As are MST’s two funds Bible College of Victoria Building Fund and Bible College of Victoria Library.
      • The absence of the funds on the website and in the Financial Report 2016 suggests that either MST is not separating the money between itself and its funds, or that all three are inoperative.

Is MST’s online giving secure?

  • PayPal is used, so yes.

Is the reporting up-to-date?

  • Yes (again on the last day, six months after their year-end).
    • 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 14 months in the past.

Does the Group’s reporting comply with the regulator’s requirements?

  • Group AIS 2016: No
    • ‘Other income’ is incorrect. (With a consequence that ‘All other revenue’ and ‘Total revenue’ are also incorrect.)
    • ‘Net surplus/deficit’ is incorrect. (With a consequence that ‘Total comprehensive income is also incorrect.)
    • The description of activities is not particularly about 2016.
    • No outcomes are reported.
  • Group Financial Report 2016: No
    • There is no explanation for the lack of information about the Fund (other than its exists as a charity). And the usual Note giving the figures for the parent is absent. Did the Fund not operate?
    • The directors are still saying that they don’t have any stakeholders, either present or prospective, who need a regulator to ensure that they get the financial information necessary to make decisions about their involvement with MST. In other words, that all these stakeholders can expect MST to supply them, on request, with a financial report tailored to their needs. This allows them to produce financial statements that don’t comply with all the Accounting Standards. For an organization that collects $1.70 m of fees from students, has 40 staff, and has a significant connection with three other educational institutions, this is not plausible.
    • There is still no explanation – including a classification per the Accounting Standards – of the $532K ‘Investments’.
    • Presumably the $80K debt that was forgiven is included in ‘Donations from Supporters’? (This is on top of $100K last year.)
    • Don’t student fees have to be repaid under certain circumstances?
    • There is no related parties’ disclosure.
    • Is the $45K bond for the lease correctly classified? Can MST ensure that it is not repayable within one year?
    • Similarly, with the loans from supporters classified as non-current liabilities.
    • The Note for revenue doesn’t match the financial statement.
    • Only one of the three partnerships, the one with Eastern College Australia, is mentioned (and that sounds much closer to an amalgamation than a partnership).

What financial situation was shown by that Report?

  • The surplus as a percentage of income was 7% (down markedly from last year’s 24%).
  • No obvious concerns with the financial structure.

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

  • The auditor, Matthew Hung, CA, of rdl.accountants, gave a ‘clean’ opinion.
  • Before you decide how much comfort to take from this opinion
    • read again the section ‘Financial Report 2016’, above, and
    • read about audits here and here.

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

  • The Group: Yes
  • MST: No
    • The business name and the name they use are missing from ‘Other Name(s)’.
    • Responsible persons correct? See below.
  • The Fund: Responsible persons correct? See below.

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

  • None
    • This is even though MST is the trustee of the Fund, and MST itself has two funds.

Where were your (net) donations sent?

  • NA

Who are the people controlling the group?

  • Per the MST website, the people here.
  • The ACNC Register (under ‘Responsible Persons’) doesn’t have Yean Leng Lim or, like last year, Tim Meyers, and adds Rick Cheung and Catroina Wansbrough:
  • With a change from Glenn Ward to David Ward, the same eleven people are the Fund’s responsible persons.
  • There are 10 charities with a Brian Bayston as a board member.  But the register only covers charities, not all not-for-profits, and of course doesn’t include for-profit organisations. Therefore, if after eliminating the charities for which MST’s Brian Bayston is not a director, you are left with more than a handful of directorships, it would be legitimate for you to question whether his ability to discharge his fiduciary responsibilities is threatened.
  • The board is responsible to the members. There were 10 of these at 31 December 2017 (Directors’ Report, Financial Report 2016)[2].
    • As directors must be members (the constitution), there is no accountability here.

To whom is the group accountable?

  • Both charities are accountable to the ACNC.
  • Not claimed on the website, but MST is a member of Missions Interlink, an organisation that has standards with which MA must comply.
    • For one opinion on the strength of this accountability, see the section Activities in this review.
  • MST, as a company, is still accountable for some things to ASIC.

 

  1. Good living and social concern are important [to the cause of evangelism], but they are not uniquely Christian graces…I’ve met a lot of fine Hindus, Muslims and atheists. Just living the life is not going to bring someone to Christ. There is much more to it than that. We must help people, certainly, but we must also share with them why we are motivated to do so. We must stand against injustice, poverty and need, but we must at the same time point to the One who brings justice and who can meet the deepest need. Until they know our reasons, how can they come to know our Lord?” [Dan Armstrong, the Fifth Gospel: The Gospel According to You, Anzea Books, pp. 13-14.
  2. There are now eleven directors, so presumably there are now at least 11 members.

Worldview Centre For Intercultural Studies: charity review

A charity review of Worldview Centre For Intercultural Studies (WC), an organization that invites the public to donate, 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.)

For the previous review, see here.

Is it responsive to feedback?

  • WC does not invite feedback or complaints.
  • I sent them a draft of this review. Like last year, they… did not respond.

Is WC registered?

  • As a charity, yes.
  • WC is a public company, a company limited by guarantee.
    • It is permitted to omit ‘Ltd/Limited’ at the end of its name.
  • It doesn’t hold any business names.
  • WC operates in Australia – per the ACNC Register – in Tasmania only. But has an internet invitation to give. It has no fundraising licences[1].

What do they do?

  • See here.
  • They describe themselves as ‘a campus of the Melbourne School of Theology (MST)’.
    • MST describes it as something less – an ‘educational partnership’.

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?

  • The donate button is not working.

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

  • NA

Is their reporting up-to-date?

  • Yes. (Five months after year end, a month earlier than last year).

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
    • One major item for a bible college that is missing from the expenses is employment benefits. Their absence for most of the staff is explained in Note 1 to the accounts:

But what about the other staff? Where are the benefits for them?[2]

    • ‘Net operating surplus’ is incorrect.
    • The only organization or individual included in the ‘Related Parties’ Note is ‘the worldwide group WEC International, (not the Australian company)’. But there is no relationship described, just the fact that WC have chosen to operate ‘within the accepted practices’ of that group.
    • What is WC’s connection with ‘the Australian company’, W.E.C. International? There is evidence for saying that that company controls WC:
      • It includes WC under ‘Who we are’, and as one ‘of 6 teams that are here to help you & us achieve our vision’ under ‘How we work’ on the website.
      • Under its ‘Related Parties’ Note in its accounts (Note 20), it says that ‘Members of the company are required to be members of WEC International, as are the majority of the Board. The Worldview Board of Directors is the final legal authority for the company…The WEC International Leadership Team approves the appointment of the Worldview Principal or leadership team. WEC International is the owner of the property on which the College is situated.’
      • The Chairman of W.E.C. International is the Chairman of the WC.
    • What about other related parties?
    • There is no explanation for the dramatic increase in ‘Scholarship funds’ (25K to $149K). The accounting policy for these funds is not disclosed. Why are they a liability? They are not shown separately under ‘Revenue’, so does that mean that they are included in ‘Bequests’ & donations’ received?
    • 73% of revenue came from ‘Bequests & donations received’. Note 1(i) says that ‘Donations are recognized as revenue when received’. Why then is there such a large difference between the accrual ($867K) and cash ($1.01 m) figures for revenue?
    • The existence of a 30-year lease from W.E.C. International is disclosed in Note 17, but the accounts do not mention the financial consequences of this lease.
    • Inventories: still not valued correctly, and Note 6 (the figures) does not match the policy (Note 1).
    • There is still neither a breakup of the $1.07 m of ‘Plant & equipment & Fixtures’, nor an explanation of the distinction between ‘fixtures’ and ‘plant & equipment’.
    • Given that WC is a bible college, is there no library?
    • Several of the usual Notes are missing.

What financial situation was shown in that Report?

  • Last year’s deficit of 23% of revenue was improved dramatically to a surplus of 46%. No explanation is given.
  • Working capital (current assets less current liabilities) is again strongly positive.
  • There is no land and buildings, but long-term liabilities are again zero.

What did the auditor say about the last financial statements?

  • The auditor, Geoffrey V Powell, for Tyndale KSG Pty Limited, gave a ‘clean’ opinion.
  • Before you decide how much comfort to take from this opinion, I suggest that you
    • read again the section ‘Financial Report 2016’ above, and
    • read here and here about audit opinions.

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

  • Yes

Who are the people controlling the organisation?

  • On the website, these people.
  • Which matches the ACNC Register (under ‘Responsible Persons’) except with the addition of Mark Jennings;
    • Stephen Brown
    • Eleanor Chee
    • Elizabeth Clarke
    • Neville Clarke
    • Denise George
    • Donald George
    • Patricia Harrison
    • Mark Jennings
    • Jae Hyeong Kim
    • Christoph Ochs
    • Stephen Preston
      • The name ‘Stephen Brown’ appears on the register for nine charities. And the register only covers charities, not all not-for-profits, and of course doesn’t include for-profit organisations.  WC’s Stephen Preston is a CEO of a significant organisation and has at least two non-charity directorships; if after eliminating the charities for which he 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.
  • A majority of the directors are staff in the WEC International group (three are WC staff).
  • The board is responsible to the members. With only nine members though [Directors’ Report, page 8 of the Financial Report 2016, the effective situation may be as WC describe it:

To whom is WC accountable?

  • As a charity, to the ACNC.
  • And, as a company, WC is still accountable to ASIC for some things.
  • WC is an Associate member of Missions Interlink. Missions Interlink has an accountability regime.
    • For one opinion on the strength of that accountability, see the section Activities in this review.

 

 

  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. The lack of payment to most of the staff is probably due to WC’s belief that they are not employees at common law. However, even if this is true, it does not stop the application of taxation law.

Morling College Ltd: a charity review

A charity review of Morling College Ltd (MC), an organisation that seeks donations from the public[1], 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?

  • There is no invitation, on the website, to give feedback.
  • I sent them a draft of this review. Like last year, they… did not respond.

Is MC registered?

  • Yes, as a charity.
    • Although not disclosed in the Financial Report, MC is ‘owned’ 100% by the Baptist Union of NSW. The Union appoints the MC board.
  • MC controls another charity, Morling College (Tinsley Bequest) Limited[2].
    • But it hasn’t taken advantage of the ACNC’s group reporting concessions.
  • It is a public company, a company limited by guarantee.
    • As it has the necessary provisions in its constitution, MC is entitled to omit ‘Limited/Ltd’ when it uses its company name.
  • MC holds four business names:

  • It has an internet invitation to give and operates, per the ACNC Register, in Australian Capital Territory and New South Wales. It doesn’t have any fundraising licences[3].
  • Although it is a member of Missions Interlink – ‘the Australian network for global mission’ – MC says (on the ACNC Register) that it does not operate overseas.

What does MC do?

  • “Morling College is the Baptist Bible & Theological college of NSW & ACT, training pastoral and related ministries in NSW & ACT churches.”

Do they share the Gospel?[4]

  • Not to those who haven’t already heard it.

What impact are they having?

  • Nothing systematic found 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.

Do they pay their board members?

  • Such payments are prohibited by the constitution.
  • Section 5 of the Directors (sic) Report implies that there can be such fees included in the ‘emoluments received…by directors shown in the company’s financial accounts’.
  • Note 9 to the accounts says that ‘No director received Directors Fees’.

Can you get a tax deduction?

  • Even though MC’s ‘Entity subtype’ with the ACNC is ‘Advancing Religion, yes, you can.
  • But MC don’t seek funds – online at least – in their own name. The two giving pages with GiveNow.com are for ‘Morling Foundation’, a charity that is controlled by the Baptist Union of NSW.
  • Given this, why this celebration of tax-deductibility for MC by the Chairman of the Foundation[5]?

Is their online giving secure?

  • GiveNow.com.au is used. MC’s two ‘Make a Donation’ buttons say, ‘Using the secure engine of GiveNow.com.au’, but when you go to the giving page, there’s no mention of security.

Is their reporting up-to-date?

  • Yes (five 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 nearly 14 months ago.

Does their reporting comply with the regulator’s requirements?

  • AIS 2016: No
    • Only the total in the ‘Gross Income’ section in the ‘Comprehensive Income Statement summary’ matches the figures in the Statement of Income and Comprehensive Income.
    • The business names are missing.
    • No outcomes are given.
  • Financial Report 2016: No.
    • The accounting for restricted donations – crediting them direct to reserves – is a continued departure from basic accounting (and the Accounting Standards.)
    • The Statement of Changes in Equity and Funds does not comply with the Accounting Standards.
    • There is no explanation why the charity they control is not consolidated, that is, included in the MC accounts.
    • The Statement of Income and Comprehensive Income is
      • misnamed,
      • has a mixed classification of expenses,
      • includes the label ‘Other Income’ twice,
      • misnames ‘Total Comprehensive Income’ and
      • includes ‘Prior year adjustments’ again without any explanation of them.
    • There continues to be no explanation of the ‘Construction in Progress’, including the reason for the inclusion of ‘Reimbursement of Property Development costs’, $8.68 m, under ‘Other Items of Comprehensive Income’.
    • The Note on related parties does not identify the relationship between MC and those related parties.
    • The library is still, without explanation, not capitalised, that is, all purchases are expensed.

What financial situation was shown by that Report?

  • There are too many potential adjustments to be made to the ‘Statement of Income and Comprehensive Income, above, to allow reliable comment.
  • Working capital is again negative, current assets declining from 99% of current liabilities to 87%.
  • No obvious concerns with the longer term financial structure that is shown.

What did the auditor say about the last financial statements?

  • The auditor, Lawrence R Green FCA, a partner at Shedden & Green Partners, gave a ‘clean’ opinion.
  • But before you decide how much comfort to take from that, re-read the section ‘Financial Report 2016’, above.

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

  • Not quite – under ‘Other Name(s), at least all four of MC’s business names are missing.

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

  • ‘…Morling Foundation’
  • ‘The Morling Postgraduate Scholarship Fund’ (also the Morling Foundation Ltd)
  • There is no explanation to potential donors for why money is sought for the Foundation, a separate (but related) charity. (The Foundation is the trustee of the Morling Foundation Public Fund.)

Where were your (net) donations sent?

  • No donations were received via the internet (they went to the Foundation).
  • The accounts show the receipt of $174K of donations.
  • The AIS 2016 says that ‘Grants and donations made for use in Australia’ totalled $55K (with none overseas). Presumably these went to students.

Who are the people controlling the organisation?

To whom are MC accountable?

  • As a charity, to the ACNC.
  • As well as accountability to ASIC for some things.
  • Not claimed on the website, but they are members of Missions Interlink, an organisation that has a set of standards with which MC must comply.
    • For one opinion on the strength of this accountability, see the section Activities in this review.

 

 

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