Alphacrucis College Ltd: charity review

This is review in the series ‘Members of Missions Interlink’, Missions Interlink being ‘the Australian network for global mission[1].

Alphacrucis College Ltd’ is one such Member, and an organisation that allows donations online.

Both Members and Associates have to accept a set of standards, the introduction to which includes this statement:

http://tedsherwood.com/wp-content/uploads/2018/11/word-image-20.png

This Member did not respond to a draft of this review.

The charities’ regulator, the ACNC, in their article, Donating to Legitimate Charities, gives “some things to consider to help you make sure your donation is going where it is intended”:

  1. Check the charity’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’s the results for ‘Alphacrucis College Limited’[2], with #5 supplemented by the essentials of the ACNC’s What should I consider when deciding which charity to support?[3].

1. A search on the ACNC Register of charities gives a charity in that name (Alphacrucis).

2. NA

3. The “web address begins with ‘https’ and there is a closed padlock symbol next to the web address in the address bar”, so the website is secure [the ACNC article above].

There is no mention on the first page of the giving process of the security of your information.

4. The Australian Business Register (linked from Alphacrucis’ ACNC Register record), says that the charity is entitled to receive tax deductible gifts. Likewise, for its fund, ‘Southern Cross College Building Fund’.

5. This is Alphacrucis’ mission: ‘Equipping Christian leaders to change the world.’

This is how they do it.

This is how that translates into giving options:

The audited account of how the donations are used is the Financial Report 2017 on the ACNC Register. Within that there are two statements that give information on how the donations were used. But you should first turn to the Notes to the accounts (Notes to the Financial Statements in this case) to check out the ‘Basis of preparation’.

Do you provide or give things to, receive things from, or have oversight of, or review, of Alphacrucis[4][vii]? Quite apart from perhaps being one the charity’s many students ($12.75 million ‘Gross student fees’, Financial Report 2017), perhaps you intend to donate or are one of the donors who gave $464K last year [Financial Report 2017]? Or you are one of the 167 employees (AIS 2017)? If so, can you ring Alphacrucis’ office and request that they prepare financial statements that answer the question or questions you have about the charity? I doubt it. You are therefore ‘potentially interested in the information provided in general purpose reports[5].

You are therefore in the wrong place – I only have access to the published accounts of Alphacrucis, and the directors[6][ix], with the agreement of the auditor[7], have declared that you don’t exist:

The directors don’t say for whom they have prepared the statements, saying only that ‘These special purpose financial statements have been prepared to meet the reporting requirements of the Act.’ (But if they should be preparing general purpose financial statements, then those requirements have not been met.)

Last year, they made the same decision (but didn’t say why). The previous year, however, they said that you did exist, which led to the decision to produce general purpose financial statements:

It is difficult to see the directors could make such a different decision for what is essentially the same organisation this year.

Their policy on including organisations they control (consolidation) is also confusing: in 2015 they said they didn’t consolidate but gave no reason; in 2016 they said that they had not consolidated, said that this was a contravention of the Accounting Standards, but again gave no reason; and this year they ignore the question of consolidation completely.

If Alphacrucis is still in the running for your donation (or business), here’s what they said about how your donations were used:

  1. Cash: Payments to suppliers and employees $13,249,756
    1. This is 97% of the cash outflows for operating activities.
  2. Accrual (expenses), the four largest:

‘Employee benefits and contractor expenses’ $8.56 million (62% of expenses)

‘Property expense’ $1.03 million (7% of expenses).

‘Other expenses’ $778K (1%)

‘Travel and entertainment expense’ $751K (1%)

There is no further information on the major expense.

There is no information on the relationship between the expenses and the four giving options (above).

There is no information on the impact of the charity’s activities – the change created in the people they help.

 

Please contact me if you need a more in-depth review.

 

 

  1. https://missionsinterlink.org.au/about/http://tedsherwood.com/wp-content/uploads/2018/11/word-image-21.png
  2. See here for my last review.
  3. Focus on the nature of the charity’s work, its beneficiaries and the impact the charity is having in the community.Is it clear what the charity is trying to achieve and how its activities work towards its objectives?

    Would you like to spend your money, or time if volunteering, to support these objectives?

    Is the charity being transparent about its activities? [A section in the article, Donating and Volunteering].

  4.  From Objective of General Purpose Financial Reporting (SAC2), www.aasb.gov.au: http://tedsherwood.com/wp-content/uploads/2018/08/word-image-15.png  
  5. From Objective of General Purpose Financial Reporting (SAC2), www.aasb.gov.au
  6. The people shown under ‘People’ here.
  7. Jeffrey Tulk, Partner, Saward Dawson.

 

Reformed Theological College: charity review

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

The previous review is used as a base, with comment only if the situation has changed or extra information would be helpful.

  • 2018 review: RTC was, and still is, an associate member of Missions Interlink.
  • Such members have to accept a set of standards, the introduction to which includes this statement:

Is it responsive to feedback?

  • When sent a draft of this review, they…did not respond.
  • 2018 review: They did not respond to a draft of this review.

Is RTC registered?

  • As a charity, yes.
  • 2018 review:
    • The registration of Pigdons Road Pty Ltd was voluntarily revoked in December 2017 because the charity was no longer operating.
    • A further charity, a company wholly owned by by RTC, has been registered: RTC Support Services.
    • RTC does not explain why it does not include its subsidiaries when reporting.
  • Other registrations:
    • ITA is a public company, a company limited by guarantee.
      • Its name: It is permitted to omit ‘Ltd/Limited’ at the end.
    • It operates, per the ACNC Register, in all states. No fundraising licences are held[1].
    • 2018 review: RTC does not explain why it has no licences.

What does RTC do?

  • It is a “reformed, evangelical theological college”.
  • Or as they say in the Annual Information Statement 2015 (AIS 2015):
    • The Reformed Theological College is committed to training people to serve God in the whole of life.
    • 2018 review: ‘Reformed Theological College provides Christ-centered education for life and ministry.’

Do they share the Gospel?

  • NA – students would have already heard it.

What impact are they having?

  • No information found.

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

  • The expenses are not classified to allow this calculation.

Can you get a tax deduction?

  • Yes

Is their online giving secure?

  • Security is not mentioned.
  • 2018 review: the site is not secure. And if there is information about credit card security, it is well into the giving process.

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

  • None

Is their reporting up-to-date?

  • Yes (five and a half months after year end).
  • 2018 review: Five months

Does their reporting comply with the regulator’s requirements?

  • AIS 2015: No
    • A number of the financial figures do not match those in the Income Statement.
    • No outcomes reported.
  • 2018 review: AIS 2017: No. Same errors.
  • Financial Report 2015: No
    • Why not consolidated reports? Both Pigdons Road Pty Ltd and The Trustee for the Reformed Theological College Foundation are subsidiaries.
    • Other comprehensive income is not shown.
    • The item ‘Other expenses…’ is 35% of expenses, yet there is no breakup.
    • There is no related parties’ disclosure.
    • RTC says that the financial statement are general purpose; the auditor says they are special purpose.
    • Why are the two ‘Non-Operating Activities’ any less part of the College’s operations than the ones under ‘Operating Activities’? (This is not a distinction used by the ACNC.)
    • Buildings and the library are not depreciated. (The surplus is therefore overstated.)
    • $116,966 in Note 2 is not ‘Net cash provided by from (sic) investing activities’.
    • The land and buildings valuation is long out-of-date.
    • How does an ‘Overseas student assist (sic) fund’ meet the definition of a liability? Likewise, the ‘Other’ provisions?
  • 2018 review: Financial Report 2017: No. Apart from the fifth and last items, the above issues remain. Plus
    • the directors do not say why they have produced special purpose financial statements.
    • The auditor’s ‘Management Letter’ has been, inappropriately, included.

What financial situation was shown in that Report?

  • With the knowledge that
    • the Report, because it omits RTC’s two subsidiaries, shows an incomplete picture, and
    • adjustments to the figures and disclosures are needed (see just above) –
      • The deficit was again approximately 1% of revenue.
      • Current assets are 1.8 times current liabilities.
      • Longer term financial structure is sound.
  • 2018 review:
    • From 8% last year, the deficit is now 29%.
    • From 6.1 times last year, current assets are now 3.8 times current liabilities.
    • From 1.6 times last year, long-term assets have declined to 1.3 times long-term liabilities.

What did the auditor say about the last financial statements?

  • He gave a ‘clean’ opinion[2].
    • However, he says he audited ‘a special purpose financial report’ when Note 1 to the accounts says that the report is a general purpose financial report.
  • The inclusion of an Auditor’s Compilation Report implies that he also produced the financial statements.
  • 2018 review: Instead of the above:
    • The auditor, David John Scott, has agreed with the directors’ assessment that there are no users dependent on general purpose financial statements. (Most likely then, if you are reading this, you are the type of person they imply do not exist.)
    • He has omitted an obligatory paragraph, required because the statements are special purpose statements.

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

  • No
    • One business name is missing
    • ‘Phone’ and ‘Website’ are blank.
  • 2018 review: Neither a phone number nor a website address are compulsory. (The business name, ‘Geelong Bible College’, is still missing.)

Who are the people controlling the organisation?

  • The composition of the board is given on the website, but no names.
  • From ‘Responsible Persons’ on the ACNC Register:
    • John Barkley
    • Johannes Berends
    • John Bylsma
    • Anthony Deenick
    • John Hoogenhout
    • Peter Van Der Schoor
    • Cornelis Van Garderen
    • Dirk Van Garderen
    • Dawid Van Vuuren
    • Harry Westendorp
  • 2018 review:
    • John H, Peter V, Dirk V, and Harry W have been replaced with Ben Murphy and William Gadsby.
    • This has resulted in the board dropping two below the number said to be required.

To whom is RTC accountable?

 

 

  1. The law in this area is not straightforward – is an internet invitation ‘fundraising’ for instance? – and advice varies, so check with the charity before drawing any conclusions.
  2. To take the right amount of comfort from a ‘clean opinion’, please read here and here.

 

Tabor College Inc.: charity review

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

The previous review (in black) is used as a base, with comment only if the situation has changed or extra information would be helpful.

  • 2018 review: Tabor was, and still is, an associate member of Missions Interlink. (In the wrong name though – see below.)
  • Such members have to accept a set of standards, the introduction to which includes this statement:

Is it responsive to feedback?

  • They have not responded to the draft I sent on 17 February.
  • 2018 review: They did not respond to a draft of this review.

Is TC registered?

  • As a charity, yes.
    • But in a different name: Tabor College Inc.
      • TC does not have the name Tabor College of Higher Education registered as a business name.
    • 2018 review: Now in the right name.
  • It appears that TC controls another charity, The Trustee For Tabor College Inc Trust.
  • 2018 review: This charity still hasn’t lodged its governing document, so we can’t identify the trustee.
    • But TC hasn’t taken advantage of the ACNC’s group reporting concessions, meaning that this subsidiary (and any others) must report separately.
  • Other registrations:
    • As a South Australian incorporated association (A6378).
      • Not to be confused with the Western Australian association of the same name.
      • 2018 review: But this one has no ABN – is it Tabor’s WA campus?
    • An ARBN, allowing it to operate interstate.
    • TC operates, per the ACNC Register, in South Australia and Western Australia. It doesn’t have a fundraising licence in these two states, or in the other five that have a licensing regime[1].

What does TC do?

  • See the mission here, and the three commitments that the President thinks are reasons for a student to enrol with them.
  • 2018 review: the commitments, if still valid, are no longer shown.
  • Beside the campus in Adelaide, they have had one in Perth since 2015.
    • Is this the charity Tabor College Inc (WA)?
    • 2018 review: ‘Registration status history’ shows that this registration was ‘Voluntarily revoked’ on 1 September 2016[2].

Do they share the Gospel?

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

What impact are they having?

  • No information found.
    • No educational outcomes given in the Annual Information Statement 2015 (AIS 2015).
    • 2018 review: Nor in the AIS 2017.

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

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

Can you get a tax deduction?

  • Yes
    • Also to a fund that TC runs, The House of Tabor Building Fund Inc.
      • This is not, as the name suggests, an incorporated association.
      • There is no mention of this fund on the website.
      • 2018 review: There is a current invitation to donate to the Building Fund.

Is their online giving secure?

  • Secured by Commonwealth Bank’, so yes.

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

  • None shown online.
  • 2018 review: ‘Gift Fund’ or ‘Building Fund’

Is their reporting up-to-date?

  • Yes (six months after year end, a day late).
  • 2018 review: two and a half weeks earlier than last year.

Does their reporting comply with the regulator’s requirements?

  • AIS 2015: No
    • Business names are missing.
    • No outcomes are reported.
    • ‘Other Income’ does not match the figure in the financial statements.
  • 2018 review: AIS 2017: the first two above continue; in addition, ‘Revenue from providing goods or services’ is incorrect.
  • Financial Report 2015: No
    • Neither the directors nor the auditor comment on what the poor results and financial position mean for the going concern assumption.
    • *Why isn’t their subsidiary included in the results?
    • *It is implausible for an organisation that has revenue of $6.43 m, $7.70 million including money from the taxpayer of $1.32 m, $1.76 million campuses in two states, 143 employees (AIS 2015), 112 staff (AIS 2017) and hundreds of students, to say that it is reasonable to produce the type of financial statements that don’t have to comply with all the Accounting Standards.
      • Not only that, but then only one of these Standards has been followed, rather than the usual subset of those required for the type of statements they have produced.
    • Balance Sheet
      • There’s an unexplained treatment of borrowing costs.
      • The valuation basis of the land and buildings is not given.
      • ‘Registration and Accreditation’ is included as an asset without explanation.
    • Income Statement
      • A ‘Transfer From Reserves’ is shown as income.
      • *There is no ‘Other Comprehensive Income’ section.
      • There’s an unexplained treatment of prior year adjustments.
    • Notes to the Financial Statements
      • Note 1 is missing most of the required Notes.
      • *There is no related parties’ disclosure.
    • Statement of Changes in Equity
      • The deficit does not match the amount shown in the Income Statement.
    • *The Statement of Cash Flows should be included as a statement, not as a Note.
    • The directors do not say why the think that PBC Tabor is not a reporting entity.
    • The audit report is deficient (see below).
    • Neither the directors nor the auditor mention the ACNC Act.
    • The name of the entity is wrong in the directors’ declaration.
    • 2018 review: Those items above marked with * are repeated in 2017.

What financial situation was shown in that Report?

  • Keeping in mind what is said in the previous section
    • A surplus of less than 1% of revenue was turned into a deficit of 3% of revenue.
    • 2018 review: the 2017 result was a 1.2% deficit. This compared to a 2.0% surplus in 2016.
    • ‘Salaries & Wages’ (actually ‘employee benefits expense’ I think) were 83% of expenses.
    • 2018 review: ‘Salaries, Wages and On Costs’ plus ‘Supervisors, Mentors, Guest & Academic Lecturers’ came to 76% of expenses.
    • For at least the last two years, working capital (current assets less current liabilities) has been negative.
    • 2018 review: 2016’s slightly negative working capital (0.95) became a positive 1.5 in 2017.
    • Non-current borrowings increased from $1.66 m to $1.91 m.
    • 2018 review: They increased again, to $2.75 million.
    • Is the going concern assumption valid?

What did the auditor say about the last financial statements?

  • He gave a ‘clean’ opinion[3].
    • However, he
      • makes no comment on the going concern assumption,
      • *agreed with the directors’ decision to produce the lower disclosure special purpose financial statements,
      • excludes the directors’ declaration from the scope of his audit,
      • gives contradictory information on whether he assessed TC’s accounting policies, and
      • has not included an Emphasis of Matter paragraph.
    • 2018 review: Those items above marked with * are repeated in 2017.

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

  • Almost – the business names are missing.
  • 2018 review: in addition,
    • the Financial Report is lodged as an ‘Annual Report’.
    • A page from the Australian Business Register has been lodged as the ‘Governing Document’.

Who are the people controlling the organisation?

  • Not shown on the website, but
  • 2018 review:
    • the people shown here.
    • Which, with a change of Laurence Gillin to Murray Gillin, matches the ACNC Register (see below).
  • From ‘Responsible Persons’ on the ACNC Register:
  • 2018 review: Ursula and Maria are no longer on the Committee.

To whom is TC accountable?

 

 

  1. The law in this area is not straightforward – is an internet invitation ‘fundraising’ for instance? – and advice varies, so check with the charity before drawing any conclusions.
  2. Which doesn’t match with what is on the ‘Overview’ page. Whichever one it was, it appears to have been backdated.
  3. To take the right amount of comfort from a ‘clean opinion’, please read here and here.

 

Moore Theological College Council: charity review

This is review in the series ‘Members of Missions Interlink, Missions Interlink being ‘the Australian network for global mission[1] and a means for a Member to get income tax exemption when it might not otherwise be available[2].

Moore Theological College – Centre for Global Mission is an Associate of Missions Interlink, and an organisation that seeks donations from the public.

Both Members and Associates have to accept a set of standards, the introduction to which includes this statement:

[3]

The ACNC, in their article, Donating to Legitimate Charities, gives “some things to consider to help you make sure your donation is going where it is intended”:

  1. Check the charity’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’s the results for Moore Theological College – Centre for Global Mission[4], with #5 supplemented by the essentials of the ACNC’s What should I consider when deciding which charity to support?[5].

1.  There is no registered[6] charity in that name.

There are three with ‘Moore Theological College’ in their name, but Moore Theological College – Centre for Global Mission isn’t one of them:

The Missions Interlink name is a combination of two business names held by the middle charity above, Moore Theological College Council (Moore).

The website, though, is in a different name, ‘Moore College’. This is a third business name.

There is no explanation of the relationship between the three charities. Moore does not include the other two in its accounts.

2. NA

3. The “web address begins with ‘https’ and there is a closed padlock symbol next to the web address in the address bar”, so the website is secure [the ACNC article above]. The Westpac and VeriSign logos are on the page where you enter your credit card information, but VeriSign’s recognition of Moore is not offered.

4. The ‘Donate’ page says that all gifts (over $2) are tax deductible, which fits with the ‘Deductible gift recipient status’ shown on the Australian Business Register.

5.  The audited account of how the donations are used is the Financial Report 2017 on the ACNC Register. Within that there are two statements that give information on how the donations were used. Most donors think in terms of cash, so if that’s you, you might turn first to the Statement of Cash Flows. What you might not know though, is that you first should turn to the Notes to the accounts (Notes to the Financial Statements in this case) to check out the ‘Basis of preparation’.

Here the directors say that they have produced the lower standard special purpose financial reports because ‘there are no users dependent on general purpose financial reports’. In other words, all ‘resource providers’, ‘recipients of goods and services’, and ‘parties performing a review or oversight function’[7], both present and prospective, are able to ring Moore’s office and request that they prepare financial statements that answer the question or questions they have about the charity, For an organisation that had an income of $25.50 million (including from donors), and 102 employees (AIS 2017) [insert word or phrase of your choice].

______________________________________________________

Moore has the backing of the Anglican Church and is a major educator of the future leading lights in the Christian community, so it may well still be in the running for your business. So here is some further information for No. 5 in the ACNC’s list (above):

  • The auditor, Joseph Santangelo of Nexia Australia, agrees with the decision that there are no users who are dependent on general purpose financial statements.
  • At the time of donating, these are your options:

There is no mention of the spending of this money, that is, there is no information that gives you comfort that the money you give will be spent on the purpose you gave it for.

__________________________________________________________

Contact me if you need a more in-depth review.

 

 

  1. https://missionsinterlink.org.au/about/
  2. I sent a draft of this review to Moore. In my response to the reply by Martin Sumpter, the Risk and Compliance Officer, I asked him to tell me what the Council wanted published as their response. No reply did I receive.
  3. See here for last year’s review.
    • Focus on the nature of the charity’s work, its beneficiaries and the impact the charity is having in the community.
    • Is it clear what the charity is trying to achieve and how its activities work towards its objectives?
    • Would you like to spend your money, or time if volunteering, to support these objectives?
    • Is the charity being transparent about its activities?A section in the article, Donating and Volunteering:
  4. The ACNC implies, therefore, that it is a ‘legitimate’ charity. But this is not correct – as the ACNC itself points out, registration is voluntary.
  5. From Objective of General Purpose Financial Reporting (SAC2), www.aasb.gov.au: http://tedsherwood.com/wp-content/uploads/2018/08/word-image-15.png  

 

Tahlee Ministries: charity review

This is a charity review[1] of Tahlee Ministries, a charity that seeks donations on the internet, and is a ‘Member Organisation’ of Missions Interlink[2].

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 Tahlee Ministries:

1: There is no charity with exactly this name on the Register of charities. The ‘Contact Us’ page on the website (above) identifies it as Tahlee Ministries Inc[3]. But this doesn’t get us to a unique charity because there’s not one, but two charities registered that use this name:

Both charities are at the same address, so that doesn’t help identify the owner of the website. And the website doesn’t show the ABN. End of review?

It is confusing for one charity, Tahlee Bible College, to use the name of another charity. Perhaps it is a subsidiary of that other charity? The Register record of each charity suggests that this is indeed the case – all seven board members of the College are also on the board of Tahlee Ministries Incorporated. But there’s no group reporting, and Tahlee Bible College is not mentioned in the other charity’s accounts.

2. NA

3. Tahlee Ministries has a request for donations on the website but does not offer online giving. (If it did, it would need to secure its website.)

4. It doesn’t offer a tax deduction, but Tahlee Ministries Incorporated is nevertheless a legitimate charity. Tahlee Bible College offers a tax deduction but doesn’t appear to ask for donations anywhere. It too is a legitimate charity.

5. We could look at Tahlee Ministries Incorporated’s accounts to find out how the charity uses its donations, but there’s a problem. The auditor, Ashley Dorse of A J Dorse Accounting, while giving a ‘clean’ opinion on the financial statements, financial statements that are still materially deficient by the way, has again reported that the charity does not have any internal controls in place to ensure that all donations that are received make their way into the charity’s bank account. And the board[4] does not appear to be concerned about this. End of review[5].

 

 

  1. For the previous review, see here.
  2. The ‘General Director’ of Tahlee Ministries, John Anderson, is also a director of Missions Interlink, an organisaton that has an accountability regime for its members.
  3. This means that, because they don’t hold the business name that they use on the website, they are acting contrary to the business names legislation, and most likely their enabling legislation as well.
  4. From the ACNC Register: John Anderson, William Brill, Stuart Fleming, Wayne Forward, Greg Gibbins, Fraser Hannam, Grant Morrison, and Lindsay Teasdale.
  5. I sent them a draft of this review. Like the last two years, they did not respond.

 

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.