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.

Nungalinya College Indigenous Corporation: mini-charity review

Mini-charity review of Nungalinya College Indigenous Corporation (NC), 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.)

Is it responsive to feedback?

  • I sent them a draft of this review. Jude Long, the Principal responded with some suggested changes. One change was made, and the other information appears under ‘Ministry comment’ below.

Is NC registered?

  • As a charity, yes.
  • NC is an Indigenous Corporation.
  • It operates as Nungalinya College without having registered the name as a business name. (It has no business names.)
  • NC operates in Australia, per the ACNC Register, only in Northern Territory.
    • Ministry comment: ‘with a campus in Darwin but students travelling from all over Australia’.
    • But they also seek donations on the internet.
    • There is no licensing of fundraisers in the Northern Territory, but NC do not explain why they don’t hold a licence in the other states that require one.
  • The ACNC Register says that NC does not operate overseas.
    • Does their recent joining of Missions Interlink – ‘We exist to connect Australians with a passion for global mission’ – indicate that they intend to begin working overseas shortly?
    • Ministry comment: ‘Nungalinya College works exclusively with Indigenous Australian people and has no intention to work overseas.’

What do they do?

  • See here.
  • They are an instrument of the Northern Territory arm of three Australian denominations, the Catholic Church, the Anglican Church, and the Uniting Church.
  • There is an Annual Report.

Do they share the Gospel?[1]

  • The ‘Expression of Interest’ form asks for the prospective student’s denomination, so it appears the Gospel would only be shared as part of the training of those who would call themselves Christians.
    • Ministry comment: ‘The primary aim of NC is to train Indigenous Christians and empower them for leadership in their churches and communities.’

What impact are they having?

  • No information found.
    • Ministry comment: ‘Almost all the Indigenous church leaders in the Anglican and Uniting Churches in the Northern Territory have trained at Nungalinya College as well as many others from other states.’

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. (There is an expense ‘Administration expense’, but from the other items in the list, it is clear that it is but a small part of what it costs to deliver the teaching.)

Do they pay their board members?

  • The Rule Book (constitution) does not permit this.
  • There is insufficient disclosure of expenses to check for a payment.
    • Ministry comment: ‘and all Board members serve without payment’.

Can you get a tax deduction?

  • Yes, both to NC itself, and to its fund, Nungalinya College Library Fund.
    • The fund is not mentioned on the website.
      • Ministry comment: ‘The Library Fund still exists, but the need for support for the library is no longer relevant in the electronic age.’

Is their online giving secure?

  • Yes. The link takes you directly to the Commonwealth Bank secure server.

Is their reporting up-to-date?

  • Yes
    • 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 12 months ago.
      • Ministry comment: ‘The College operates on a calendar year rather than a financial year.’

Does their reporting comply with the regulator’s requirements?

  • General Report 2016: Almost – the figure for ‘Total grants’ is incorrect.
  • Financial Report 2016: Yes[2]

What financial situation was shown by that Report?

  • Surplus as a percentage of revenue increased markedly from one percent to 14%.
  • ‘Employee benefits expense’ is 53% of expenses (57% last year).
  • Both short-term and long-term financial structure are sound.

What did the auditor say about the last financial statements?

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

  • Yes

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

  • None
    • Ministry comment: ‘Donors can support specific projects in discussion with the College. Examples include –Building Fund and large or small capital projects, support for Media or Music Courses, supporting an Indigenous Assistant Teacher,’

Where were your (net) donations sent?

  • NA

Who are the people controlling the organisation?

  • Not shown on the website.
  • Per the ACNC Register (under ‘Responsible Persons’):
    • Bishop Gregory Anderson
    • John Bonney
    • Darryn Farrell
    • Father Malcom Fyfe
    • Rev RRonang Garrawurra
    • Rev Djawnydjawny Gondarra
    • Peter Jones
    • Ancilla Kurrupuwu
    • Rev Mildred Mamarika
    • Dominic McCormack
    • Dolly McGaughey
    • Ministry comment: ‘Better information is available via the ORIC site. ACNC is only updated annually.’
      • ‘Pirrwayingi Puruntatameri – Indigenous Chairperson
      • Bishop Gregory Anderson   Anglican Bishop of the NT
      • Mr Peter Jones General Secretary of the UCA Northern Synod
      • Father Malcom Fyfe Vicar General of the Catholic Diocese of Darwin
      • Rev Darryn Farrell – Indigenous Anglican Board Member
      • Rev Mildred Mamarika – Indigenous Anglican Board Member
      • Ms Dolly McGoughey – Indigenous Catholic Board Member
      • Vacant – Indigenous Catholic Board Member
      • Mr Harry Garrawurra – UCA Indigenous Board Member
      • Mr Djawut Gondarra – UCA Indigenous Board Member
      • Dominic McCormack – legal advisor (non-voting)
      • John Bonney – educational advisor (non-voting)’
        • Reviewer’s response: The ACNC Register is updated from ORIC information monthly[3]; the two non-voting members are not ‘responsible persons’.
  • There are 30 charities with a Peter Jones 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 NC’s Peter Jones 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.
    • Ministry comment: ‘Peter Jones as General Secretary of the UCA Northern Synod has a large role in working with the various organisations of the Uniting Church of which Nungalinya College is one. He is a long standing (sic) director and also a member of the Executive.’
  • The board is responsible to the members, all 10 of whom are members at the behest of one of the three controlling denominations.

To whom is NC accountable?

  • Although not claimed, NC is now a member of Missions Interlink:
    • Ministry comment: ‘ANZATS and the South Pacific Association of Evangelical Theological College’
      • Reviewer’s response:
        • ANZATS has no accountability regime. NC is an Associate Member, not a full member.
        • NC is not listed as a ‘member college’ of SPAEC (not SPAETC). It has no accountability regime for members.
    • For one opinion on the strength of the Missions Interlink accountability, see the section Activities in this review.
  • NC is accountable to both the ACNC, and, as an Indigenous Corporate, to ORIC.

 

 

  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. Contact me if you interested in a list of things that I thought were wrong or that I found confusing.
  3. Private email, January 2018.

Perth Bible College Inc: mini-charity review

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

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

Is PBC registered?

  • As a charity, yes[1].
  • As a WA incorporated association (A0390019Y).
  • Its website and social media sites are in the name Perth Bible College. As this is still not registered as a business name, they are still contravening both the business names legislation and their enabling legislation.
  • They do have two business names though: International Mission Teams and Centre for Biblical Counselling.
  • 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[2].

What does PBC do?

Do they share the Gospel?[3]

  • 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 costs 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 (four and a half months after year end, two months earlier than last year).

Does their reporting comply with the regulator’s requirements?

  • AIS 2016: Not quite.
    • Two figures in the ‘Comprehensive Income Statement summary’ are incorrect.
    • The business names are missing.
    • No outcomes are reported.
    • ‘Email address’ is blank
  • Financial Report 2016: No. Again this year
    • PBC 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 $1.08 m this is unlikely.
    • 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’.
      • 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.
      • do not tell us why the directors think that PBC is not a reporting entity.
      • contain a ‘Going Concern’ Note that doesn’t address the going concern assumption.
      • 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’.
      • There is no evidence of a Gift Fund.
    • The Statement by the Board
      • gives a qualified opinion on the ability of PBC to pay its debts, and
      • doesn’t mention the ACNC Act.

What financial situation was shown in that Report?

  • A deficit of 10% of revenue was turned into a surplus of 4% of revenue.
  • ‘Personnel expenses’ were 68% of expenses (67% last year).
  • Working capital (current assets less current liabilities) was made positive by borrowing more money.
  • 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, have a look again at the section above, ‘Financial Report 2016’, to see what he was happy with.

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

  • Ethiopia is missing from ‘Operates in (Countries)’.
  • The board (see Responsible Persons) is, compared to the constitution, one member short.
  • ‘Email’, ‘Phone’ and ‘Website’ are blank.

Where were your (net) donations sent?

  • Although they operate in four countries other than Australia, the AIS 2016 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. Still with a slight mistake in the name though – there are no brackets.
  2. The law in this area is not straightforward – is an internet invitation ‘fundraising’ for instance? – and advice varies, so check with the charity before drawing any conclusions.
  3. “Good living and social concern are important [to the cause of evangelism], but they are not uniquely Christian graces…I’ve met a lot of fine Hindus, Muslims and atheists. Just living the life is not going to bring someone to Christ. There is much more to it than that. We must help people, certainly, but we must also share with them why we are motivated to do so. We must stand against injustice, poverty and need, but we must at the same time point to the One who brings justice and who can meet the deepest need. Until they know our reasons, how can they come to know our Lord?” [Dan Armstrong, the Fifth Gospel: The Gospel According to You, Anzea Books, pp. 13-14.

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.