Gateway Baptist Church: charity review

This is a charity review of Gateway Baptist Church (Gateway), an organisation that seeks donations online, is a ‘Associated Organisation’ of Missions Interlink, and is accredited with the CMA Standards Council (a founding member).

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’s the results for Gateway:

1: A search of the Register of charities shows two charities with that exact name, and another with ‘Ltd’ at the end:

The one we are looking for, from its website, has Queensland phone numbers. So that leaves just one, in Mansfield. But the ABN at the bottom of each webpage belongs to Gateway Baptist Church Ltd in Mackenzie. It appears that Gateway is using the name without ‘Ltd’, something it is allowed to do under certain conditions.

The Register shows that both charities in postcode 4156 are controlled by the same people. That’s confusing – to which one does your donation go? Whose accounts should you review?

Unfortunately, the giving page makes no distinction between the two. End of review?

2. NA

3. Gateway’s web address does not begin with ‘https’, and there is no ‘closed padlock symbol next to the website’s URL in the address bar”. This is not a secure way to give to Gateway. End of review?

4. It is a legitimate charity (or two), even though its ABN record confirms that, as a church, it does not have deductible gift recipient status.

Why, then, do two of the six giving options offer, without explanation, a tax deduction? And with one of them to a charity with no obvious connection to Gateway, Bloom Asia Ltd? End of review?

  1. The accounts for the Gateway that is said to own the website, Gateway Baptist Church, are not consolidated accounts. That is, they do not include the figures for the other Gateway. The directors don’t say why. They also don’t say why they have changed from general purpose to special purpose financial statements. They are saying, in effect, that all Gateway’s stakeholders, both present and prospective, can get Gateway to prepare a financial report tailored to their needs. For a charity with revenue of $5.97 m, 50 employees, and 996 volunteers (AIS 2017), this is ludicrous.

And all this from an organisation held up as a standard-setter ‘in terms of impeccable corporate behaviour’, a leading light in transparency and accountability. End of review[1].

 

 

  1. I sent the website Gateway a draft of this review. Like the last two years, they…did not respond.

 

Entrust Foundation: charity review

This is a charity review of Entrust Foundation, an organisation that seeks donations online, and is a ‘Member Organisation’ 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’s the results for Entrust Foundation:

1: A search of the Register of charities shows not one, but two, charities with that name:

The name in brackets under the registered name is a result of the ACNC allowing – no, requiring – a charity to record on the Register any names by which it is known. The name may be registered or not. And in this case, the name is not registered to either of these charities, but to a third one, Mission Enterprises (Victoria) Limited[1].

The existence of three possible claimants for the money you give to Entrust Foundation does not inspire confidence. End of review.

 

 

Think this is too tough? Let’s continue by seeing where your money given on the above website goes, and therefore whose accounts to look at (step 5 above).

Of the three ways to give, direct deposit, online, and by cheque, only the latter one identifies the organisation to which you are giving:

So, the particular Entrust Foundation is not identified. And a fourth name is introduced, Entrust Projects. End of review[2].

 

 

  1. The first charity, Entrust Capital, has an ABN is another name, so it appears that the Register is in error. Its ABN is in the name The Trustee for Entrust Foundation. (Entrust Capital does not have an ABN, and it is neither an organisation name nor a business name with ASIC.)
  2. I sent a draft of this review to the contact email on the website. They…did not respond.

 

ACCI Relief : charity review

This is a charity review of ACCI Relief (ACCIR), an organisation that seeks donations online[1] 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 ACCIR:

1: A search of the ACNC Register leads to the registered charity, ACC International Relief Inc. That charity has ACCI Relief recorded on the Register as an ‘Other Name’. (They don’t have it registered as a business name though.)

2. NA

3. ACCIR’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 ACCIR.

4. The ABN record for ACCIM says that a tax deduction is possible, both to itself, plus to the two funds that it operates.

5. The Financial Report 2017 shows that 91% of its expenses – $5.93 million – are for a single item, ‘Funds to international programs’. There is no explanation of this item. No breakup. No destinations. Just like last year. End of review.

 

 

  1. Also via its sister charity, Acc International Missions Ltd.

 

ACC International Missions Ltd: charity review

This is a charity review of ACC International Missions Ltd (ACCIM), an organisation that seeks donations online 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 ACCIM:

1. The website is one badged ACCI Missions & Relief. There’s no registered charity in this name. Reading further down the home page, we see the name ACC International Missions Ltd. There is one in this name.

2. NA

3. ACCIM’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 ACCIM.

4. The ABN record for ACCIM says that no tax deduction is possible, but from 1. above we know that it is a ‘legitimate charity’. (The fact that the website is shared with another charity, ACC International Relief Inc., and they have a combined donation page, explains why there are tax-deductible giving options on the website.)

5. The Financial Report 2017 shows that 75% of its expenses – $2.24 million – go to a single item, ‘Disbursements to missionaries and projects’. There is no explanation of this item. No breakup. No destinations. Just like last year. End of review.

 

 

If you think that’s a bit tough and want to see how they fared with the other questions you should ask, read on.

Are they responsive to feedback?

  • This is the only mention of ‘accountability’ of the website.
  • I sent them a draft of this review. Like the last two years, they…did not respond[1].

Is ACCIM registered?

  • As a charity, yes[2].
  • As a public company, a company limited by guarantee[3].
  • It uses the name ACCI Missions. Whereas it has the necessary provisions in its constitution to allow it to omit ‘Limited/Ltd’ on the end of its name, it does not have the registration, a business name, to allow it to trade under the name ACCI Missions.
    • It holds two business names, ACCI Missions & Relief, and Australian Christian Churches World Missions[4].
  • ACCIM operates in all six states that have a fundraising regime for charities and seeks donations online. They do not explain why they hold no fundraising licences[5].

What do they do?

  • ACCI Missions is the missionary sending and support agency of the Australian Christian Churches movemen.t
    • This is on an ‘About’ page on ACCIM’s website that starts by describing the work of the unregistered charity ‘ACCI’[6]. Further down it identifies ACCI as being composed of ACCIM and another charity, Acc International Relief Inc. (Relief)[7].
  • Per the Annual Information Statement (AIS) 2017:[8]
    • The principal activities of ACC International Missions Ltd during the financial year were: • To recruit, enable, support and send field workers to Australia and foreign countries to establish self-governing, self supporting and self propagating (sic) churches and preach the Gospel in Australia and other nations around the world; • To provide pastoral support, direction, vision and strategy for field workers as they prepare for ministry and minister overseas; • To work in synergy with local congregations within the Australian Christian Churches movement and assist them to fulfil the Company’s vision; and • To otherwise fulfil and follow the missionary objects of the Australian Christian Churches.

Do they share the Gospel[9]?

  • Via their missionaries, yes.

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?

  • If we define ‘direct’ as ‘Disbursements to missionaries and projects’, then ‘administration’ is 25% of expenses (up from 22% last year). Making the cost object smaller will increase this percentage, e.g. by recognizing that there is overhead in the projects in the overseas country.

Do they pay their board members?

  • This is not permitted by the ACCIM constitution.
  • The expenses are not disclosed sufficiently to allow a check.

Can you get a tax deduction?

  • No
    • But their website also collects for Relief, a separate charity. Donations to Relief are tax deductible.

Is their online giving secure?

  • Security is still not mentioned.

Is their reporting up-to-date?

  • Yes (five months after their year-end, approximately three 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 over six months ago.

Does their reporting comply with the regulator’s requirements?

  • AIS 2017: No
    • Two names (one business, one used without registration) are missing.
    • The description of the international activities includes the work of Relief.
    • ‘Employee expenses’ includes ‘other associated costs’.
    • The states where it intends to fundraise have not been specified.
    • The activities are not specific to 2017.
    • No outcomes are given.
  • Financial Report 2017: No
    • 75% of its expenses – $2.24 million – go to a single item, ‘Disbursements to missionaries and projects’. There is no explanation of this item.
    • It is hard to see that a report that makes no mention of (a) the organization the objects of which it is required to follow, Australian Christian Churches, and (b) the organization with which it shares a business name and a website, Relief, can be judged as showing a true and fair view.

What financial situation was shown by that Report?

  • The surplus as a percentage of revenue has increased from negative 3% to positive 1%.
  • Less than two and a quarter months of revenue is held in ‘Cash and cash equivalents’ plus ‘Financial assets’.
  • Both short-term and long-term financial structure are, based on this Report, sound.

Where were your (net) donations sent?

  • The Statement of Profit or Loss and Other Comprehensive Income just says ‘Disbursements to missionaries and projects’ $2.24 m.

What did the auditor say about the last financial statements?

  • The auditor, Jeffrey Tulk, for Saward Dawson, gave a ‘clean’ opinion.
  • Before you conclude on how much comfort to take from this
    • re-read the ‘Financial Report 2017’ section above, and
    • read here and here about audit opinions.

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

  • No
    • One business name, Australian Christian Churches World Missions, and the name their most use, ACCI Missions, is missing.
    • ‘Who the Charity Benefits’ is blank.
    • With the directors, which is correct, website or ACNC Register?

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

  • Many – via a visually confusing set of pages and tiles:
    • Most of the first set offer giving:

  • All of them in the second set offer giving:

Then there’s the third set:

Who are the people controlling the organisation?

  • Again, this year, the listing under ‘Our Board of Directors’ on the website has only one name in common with the list under ‘Responsible Persons’ on the ACNC Register (and even that one has a different spelling):
    • Elisa Colak
    • Alan Davies
    • Matt Heins
    • Danny Major
    • Ben Teefy
    • Catherine Thambiratnam
    • This list is unchanged from last year.
  • The board is accountable to the members. The number of members is not disclosed.

To whom are ACCIM accountable?

  • As a charity, to the ACNC.
    • Its ‘Charity Tick’ is used on the in the footer (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 ACCIM’s AIS is not overdue, and the ACNC has not taken any compliance action against it.
  • ACCIM claims that it ‘is an accredited member of Missions Interlink and operates in compliance with Missions Interlink Statements and Accreditation Standards.’ Membership confirmed.
    • For one opinion on the strength of this accountability, see the section Activities in this review.
  • ACCIM is also accountable for some things, as a company, to ASIC.

 

 

  1. I agree with Randy Alcorn [Money, Possessions, & Eternity, Tyndale, 2003] when he says that ‘Any Christian leaders who resist financial accountability make themselves suspect.’ [page 425]
  2. But as Acc International…(emphasis mine).
  3. Not, as the ABN record still says, an ‘Other Incorporated Entity’.
  4. The second is not shown on either the ABN record or the ACNC record.
  5. The Tasmanian list is currently unavailable, but there was no registration when it was last checked.
  6. ACCI is a business name held by the Australian Carpet Cleaning Institute Pty Ltd (www.asic.gov.au).
  7. Relief also has its own website, www.accir.org.au, a website that does not include information about ACCIM. The combination of the two ‘Acc International’ organisations has been formalised in a business name for ACCIM, ACCI Missions & Relief. See, for instance the ‘Donate’ page on the ACCIM site. Confusing.
  8. This is the same description as the last two years.
  9. 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.

 

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.

 

P4T Inc: charity review

This is a charity review of P4T Inc (P4T), 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 situation last year, read the review here.)

Are they responsive to feedback?

  • There is nothing about feedback, complaints or accountability on the website.
  • I sent them a draft of this review. Unlike last year, they did not respond.

Is P4T registered?

  • As a charity, yes.
  • P4T is a Victorian incorporated association (A0055403B).
  • P4T operates, per the ACNC Register, all over Australia. Plus they have an internet invitation to give.
    • It has the necessary registration to carry on business interstate (an ARBN), and it is registered to fundraise in all the states that require charities to register.

What do they do?

  • ‘About’ on the website:
    • ‘Ping Pong-A-Thon is a fundraising & advocacy movement, combating human trafficking and exploitation of young people in South East Asia through a series of table tennis events held annually in October’.].
  • But it’s more than this:
    • Engaging and empowering other organisations and individuals to provide benevolent relief is fundamental to the purpose and implicit of our philosophy of “Partnering for Transformation”. These are the words that stand behind our name P4T. We are a small core group but have highly developed skills sets and networks which we leverage to the benefit of the broader community. Our largest project is the “Pingpongathon”, which engages people to volunteer to play table tennis in their local community as a means of raising both awareness and funds for the cause of eliminating human trafficking and sexual exploitation of young people. In 2017 we have partnered with 100 community groups across Australia (churches, high schools, sporting groups, community groups, businesses, and a hotel), who connected with their local community inviting individuals to participate and fundraise. In the process, P4T provides educational material to raise awareness of the existence of the problem of human trafficking and also challenges the attitudes of participants about respect for individual rights. This aspect is also aimed at reducing the incidence of domestic violence in the community. Local participating community groups encourage their participants to register and fundraise through the Pingponga-thon website and online fundraising system. Funds raised through the Pingpong-athon project are distributed to partner organisations that provide on the ground benevolent assistance to the victims of human trafficking[1] [The AIS 2017’s ‘activities and outcomes’].
    • For more detailed information about what they did in 2017, see ‘Principal Activities’ in the Committee’s Report [Financial Report 2017].

Do they share the Gospel[2]?

  • No.
  • Despite P4T’s membership of Missions Interlink, ‘the Australian network for global mission’, there is no evidence that P4T is a ‘Christian’ organisation. The constitution doesn’t mention faith, let alone Christianity. ‘Christ’, ‘Jesus’, ‘the gospel’, ‘Christian’ and ‘Christ-centered’ are not mentioned on the website.

What impact are they having?

  • There is no discussion of the impact that is being sought.
  • Here’s their description of the achievements of the seven organisations that received the proceeds of the 2016 Pingpong-A-Thon. There’s no update for 2017.

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

  • If we define ‘direct’ as ‘Pingpongathon Beneficiary Support[3], it cost P4T $198K to make grants of $358K. That’s ‘administration’ of 36%.
  • P4T says (Note 1 e) that only 65% of the ‘Pingpongathon’ revenue is earmarked for recipients, the remaining 35% being for ‘project operating costs’. If the 35% is not spent, the balance is transferred to a reserve, the Pingpongathon Development Reserve.
  • P4T’s record on the Victorian fundraising regulator’s database says that administration is 20%.
  • All the recipients of P4T grants, except Home of New Beginnings, accept donations from the public (see links below).

Do they pay their board members?

  • The constitution is silent on paying board members.
  • There is insufficient disclosure of expenses to check for a payment.

Can you get a tax deduction?

  • Yes

Is their online giving secure?

  • Security is (still) not mentioned.

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 over six months ago.

Does their reporting comply with the regulator’s requirements?

  • AIS 2017: No
    • The ‘Other name(s)…’ is misspelt.
    • The figure for ‘Employee expenses’ is only the amount for ‘Pingponathon Employment Expenses’.
    • ‘All other expenses’ is incorrect.
    • Contrary to the answer for ‘Annual Report’, there is no annual report on the website.
  • Financial Report 2017: No
    • Despite claiming compliance with the Accounting Standards, P4T continue to produce a statement about profit or loss and the statement about changes in equity without including ‘Other comprehensive income’[4].

What financial situation was shown by that Report?

  • The surplus as a percentage of income was reduced from a relatively high 25% to 9%.
  • No issues with either short-term or long-term financial structure.

What did the auditor say about the last financial statements?

  • The auditor, C P Brown, ‘Registered Companies Auditor’, issued a ‘clean’ opinion.
    • But he has again omitted one of the statements from the scope of his audit, and has again included one that shouldn’t be included, the Committee’s Report.
    • To take the right amount of comfort from his finding, please read here and here.

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

  • No
    • The business name is (still) misspelt.
      • P4T themselves use two other variations of this name.
    • Overseas beneficiaries are omitted from ‘Who the Charity Benefits’.

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

  • None – just ‘Ping Pong-A-Thon’

Where were your (net) donations sent?

Who are the people controlling the organisation?

  • Not shown on the website, but as shown on the ACNC Register (under ‘Responsible Persons’):
  • Missing from this list, to match the Committee’s Report [Financial Report 2017], is Matthew Maudin.
  • The committee is responsible to the members. The number of members is not disclosed, so we can’t assess this accountability.

To whom are P4T accountable?

  • As a charity, to the ACNC.
  • Also to the Victorian regulator of incorporated associations.
  • Not claimed on the website, but P4T is a member of Missions Interlink, an organisation that has a general accountability regime.
    • For one opinion on the strength of this accountability, see the section Activities in this review.

 

 

  1. Board member Ian Skurrie has a different idea of what P4T is about:
  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.
  3. This includes $21K ‘PPAT Partner Visitation & In Country Support’.
  4. And why is interest not accrued?

 

Slavic Gospel Association Inc: charity review

This is a charity review of Slavic Gospel Association Inc (SGA), an organisation that seeks donations 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 situation last year, read the review here.)

Are they responsive to feedback?

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

Is SGA registered?

  • As a charity, yes.
    • Incorporated as The Slavic Gospel Association Inc. (emphasis mine)[1].
  • As a Victorian incorporated association (A0027142A)[2].
  • If it’s ‘carrying on business’ outside Victoria, as it appears to be, then it still doesn’t have the required registration (an ARBN).
  • It uses the names Slavic Gospel Australia, and Slavic Gospel Association, without them being registered as business names[3].
  • SGA operates – per the ACNC Register – and says it is going to fundraise, in all six states that have licensing regime for charities that are fundraisers. But it still, without explanation, has no fundraising registrations.

What do they do?

  • From the Annual Information Statement (AIS) 2017:
    • Funds were provided to help share the Gospel with the orphans, missionaries, pastors and Bible school students.
  • For what happens under the Slavic Gospel Association name overseas, see ‘Ministry Areas’ on the right-hand side of the home page.
  • SGA operates overseas – per the ACNC Register – in seven overseas countries. This is, presumably, where the money that was collected went.

Do they share the Gospel[4]?

  • No. (They raise money.)

What impact are they having?

  • Nothing systematic found.
  • There are stories of change in the countries to which SGA sends money in the Slavic Gospel News on the website.

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

  • If we define ‘direct’ as ‘Designated gifts distributed’ (there were no undesignated gifts distributed), ‘administration’ is 33% of expenses, a significant increase on the 26% of last year.

Do they pay their board members?

  • Such payments are not prohibited by the constitution.
  • The disclosure of expenses is insufficiently detailed to allow the question to be answered.

Can you get a tax deduction?

  • No

Is their online giving secure?

  • Such giving is not offered.

Is their reporting up-to-date?

  • Yes (lodged four and a half months after their year-end, two 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 six months ago.

Does their reporting comply with the regulator’s requirements?

  • AIS 2017: No
    • The name is (still) incorrect.
    • The description of the type of financial statements is still incorrect.
    • Interest is not shown as ‘Revenue from investments’.
    • There are still no outcomes reported.
    • What is included under ‘Annual Report’ is not an annual report as is meant by the ACNC.
  • Financial Report 2017: The regulator would probably give it a passing grade, but
    • The directors’ say that all SGA’s stakeholders, both present and prospective, can command the charity to produce a report tailored to their specific needs. For a charity seeking public donations, having three employees, collecting $385K, and operating in six states and seven overseas countries, this is questionable.
    • Can a Financial Report that doesn’t explain what the charity does give a true and fair view?
    • What about one that doesn’t say where it’s net donations go?
    • As there were last year, there are some other less critical issues.

What financial situation was shown by that Report?

  • The surplus as a percentage of revenue was reduced again, this time dramatically (from negative 2% to negative 15%).
  • ‘Employment expenses’ represented 22% of expenses (a significant increase on last year’s 15%).
  • Current assets are now only just over 100% of current liabilities (down from 150%).
  • The long term financial structure, thanks to the ownership of unencumbered land and buildings, is sound.

What did the auditor say about the last financial statements?

  • The auditor, Matthew Hung, CA, of rdl.accountants, gave a ‘clean’ opinion. To take the right amount of comfort for this finding, please
    • read here and here.
    • re-read the ‘Financial Report 2017’ section above.

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

  • No:
    • Their name is (still) incorrect.
    • There’s still a message ‘Charity to select subtype’ under ‘Entity subtype’.
    • ‘Who the Charity Benefits’ does not mention the overseas recipients of money.
    • The document labelled ‘Annual Report’ is not what the ACNC means by an annual report.
    • ‘Phone’ and ‘Website’ are (still) blank, but the ACNC says that these are not compulsory.

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

  • None given on the website.

Where were your (net) donations sent?

  • This is not disclosed.

Who are the people controlling the organisation?

  • On the website, as well as on the ACNC Register (under ‘Responsible Persons’), it’s these people:
    • Douglas Brown
    • Harry Chudasko (still misspelt on the Register))
    • Peter Dubyna
    • Ralph Hewes
    • Larissa Porublev
    • Nickolai Porublev
    • Bruce Ronalds
      • Is it this Bruce Ronalds?
    • Alexander Shevchuk
  • Unless Larissa is a committee member, not just the Public Officer, she should not be in the ACNC list.
  • As the membership of SGA is limited to board members, there is no accountability from the membership.

To whom are SGA accountable?

  • As a charity, to the ACNC.
  • As an association, to the Victorian regulator of incorporated associations.
  • Membership of Missions Interlink claimed on the website is confirmed. Missions Interlink has a general accountability regime.
    • For one opinion on the strength of this accountability, see the section Activities in this review.

 

 

  1. Not The Slavic Gospel Association, as both the Australian Business Register and the ACNC continue to report.
  2. Not unincorporated, as the ABN record, still says.
  3. It’s enabling legislation also requires the full name, and only the full name, to be used on all publications.
  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.

 

Far East Broadcasting Co (Australia): charity review

This is a charity review of Far East Broadcasting Co (Australia) (FEBC), an organisation that seeks donations online[1]. (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. They…did not respond[2].

Is FEBC registered?

  • As a charity, yes.
    • FEBC reports as part of an ACNC reporting group (the Group). The other members of the group are FEBC Overseas Fund (the Fund), and FEBC Relief Limited (Relief).
      • There’s another company with ‘FEBC’ in its name, FEBC Custodian Limited. Note 17 in the Financial Report (see below) says that this company ‘was established solely to act as trustee for the FEBC Overseas Aid Fund’. It has not been included in the Group[3].
  • FEBC is a public company, a company limited by guarantee.
    • It is permitted to omit ‘Ltd/Limited’ from its name.
  • FEBC holds the business name FEBC Australia, the name it trades under.
  • FEBC is a fundraising vehicle that operates, the ACNC Register says, in all eight states. It also has an internet invitation to donate. It is exempt from registering to fundraise in New South Wales, and has a licence in Queensland and Victoria. No explanation was found for why there is no licence in South Australia or Western Australia[4].
  • The Fund:
    • A public ancillary fund[5].
    • No business names held.
    • Operates, the ACNC Register says, in all eight states. And asks for donations online. But has a fundraising licence only in South Australia[6].
  • Relief:
    • Is a public company, a company limited by guarantee;.
      • It is permitted to omit ‘Ltd/Limited’ from its name.
    • No business names held.
    • Operates, the ACNC Register says, in all eight states, and asks for donations online.
      • But has a fundraising licence only in South Australia, Victoria and Western.[7]

What does FEBC do?

  • ‘About Us’ on the website is not about FEBC, but the international FEBC organisation generally.
  • Here’s what FEBC did in 2017 (from the AIS 2017):
    • In the last financial year, FEBC Australia had (sic) worked hard to effectively communicate needs, relay stories, share prayer points and write up project submissions to raise financial support for overseas projects… (The remainder of their description is about the worldwide FEBC ministry rather than Australian activities.)
  • FEBC operates overseas. The ACNC says that it is in 14 countries, the Annual Report (page 16) 16.
    • The 16 countries are the countries that received ‘Disbursements To Projects and Field…’. Whether this money is sent direct to these countries or via FEBC International or an FEBC office overseas is not disclosed.
  • The Fund: Other than a mention in two superseded Annual Reports, there is no reference to the Fund on the website.
  • Relief: See here.

Do they share the Gospel[8]?

  • No.
    • But they raise money for others that do.
  • The Fund: Not disclosed.
  • Relief: Not disclosed – although with tax deductibility, I doubt it.

What impact are they having?

  • Some anecdotal reports in the Annual Report 2016-2017, and on the website, but nothing systematic.
  • This comment in the Annual Report implies that each radio is heard by 25.12 people:

  • And the statement implies that every listener is changed.
  • The impact is not specified though. Similarly, with the statistic on the ‘Ways to Give’ page:

  • The Fund: No information found.
  • Relief: No information found.

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

  • If we define ‘International Programs’ expense as the expenses that are direct to delivery of the impact, ‘administration’ is 28%.
  • The Fund: Not separately shown.
  • Relief: Not separately shown.

Do they pay their directors?

  • Note 17 to the accounts says that ‘No director received any remuneration’.

Can you get a tax deduction?

  • Not to FEBC, but you can if you donate to Relief.
    • How this fits with their mission – Our goal is to communicate the Good News among the nations by media to inspire people to follow Jesus Christ – is not explained.
  • The Fund: Yes (a public ancillary fund that must give to a deductible gift recipient organisation).
  • Relief: Yes

Is their online giving secure?

  • They have a https URL preceded by a green padlock, so yes.
  • The Fund: as for FEBC
  • Relief: as for FEBC

Where were your (net) donations sent?

  • There is a bar chart in the Annual Report 2016-2017 showing the percentage sent to each of 16 countries, but there is no information in the Financial Report 2017.

Is their reporting up-to-date?

  • Yes (lodged five months after their year-end – a month 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 that finished nine months ago.
  • The Fund: doesn’t report separately
  • Relief: doesn’t report separately

Does their reporting comply with the regulator’s requirements?

  • Group AIS 2017: No
    • Most of what is under ‘activities’ is about the FEBC organisation overseas.
    • No outcomes are reported.
    • The list of countries is one sort of that for FEBC.
    • ‘Other income’ does not match the same item in the financial statements.
  • Group Financial Report 2017: Above the minimum, yes, but not anywhere near ‘the utmost integrity’ [footnote viii]. Like last year
    • There is no explanation for
      • the inclusion of a second income statement, Income Statement for ACFID purposes, especially when FEBC is not a member of the ACFID (Australian Council for International Development); and
      • the relationship between the two statements.
    • Statement of Income and Other Comprehensive Income
      • There is no explanation for
        • Revenue, and
        • The item that comprises 77% of expenses, ‘Other expenses…’
    • Income Statement for ACFID purposes
      • There is no explanation of the terms used.
      • A note says that ‘Direct and indirect costs have been allocated using an activity based absorption costing approach.’, but no explanation of this approach is given.
      • The Annual Report (page 13) says that their ‘activity based (sic) absorption costing approach’ includes ‘Showing details of FEBC Australia’s international programs either by program or by country’. There is no such disclosure in the Financial Report.
    • Balance Sheet
      • There is no explanation for how a Group of this size was able to operate an office without any ‘Furniture, Fittings and Office Equipment’?
      • The treatment of ‘Financial Assets’ does not appear to be compliant with the Accounting Standards.
        • There is a ‘Change in Fair Value of Financial Assets’ included in profit or loss.
      • ‘Land and Buildings’ consist of two properties in Caringbah.
        • How was the combined cost only $93K?
        • Should one be classified as investment property?
  • The Fund: doesn’t report separately
  • Relief: doesn’t report separately

What financial situation was shown by that Report?

  • The surplus as a percentage of income declined slightly, from less than one half a per cent positive to the same figure but negative.
  • Working capital (current assets less current liabilities) is strongly positive.
  • With minimal non-current liabilities, longer term financial structure appears sound.
  • The Fund: doesn’t report separately
  • Relief: doesn’t report separately

What did the auditor say about the last financial statements?

  • The auditor, Lawrence R Green FCA, of Shedden & Green Partners, issued a ‘clean’ opinion.
    • To take the right amount of comfort from a ‘clean opinion’, please read here and here.
    • His report misnames two of the reports and includes a reference to an Act that FEBC is not required to comply with.
  • The Fund: not separately audited
  • Relief: not separately audited

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

  • Group: No
    • Overseas is not mentioned under ‘Who the Group Benefits’.
    • The number of countries is one short of the number shown by FEBC.
  • FEBC: No
    • Overseas is not mentioned under ‘Who the Charity Benefits’.
    • Did FEBC operate in all 14 countries listed under ‘Operates in (Countries)?
    • ‘Phone’ and ‘Website’ are blank, but the ACNC says that they are not compulsory.
  • The Fund: ‘General community in Australia’ is not correct for ‘Who the Charity Benefits’. (‘Phone’ and ‘Website’ are blank, but the ACNC says that these are not compulsory.)
  • Relief: ‘Size of Charity’ is blank. (‘Email’ and ‘Website’ are blank, but the ACNC they are not compulsory.)

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

  • Quite a few, presented a little confusingly.
  • Under the ‘Donate’ button in the main menu, other than being able to write in the name of a tax-deductible project, there is only one.
  • But to ‘donate’ is not the only way to give. Under ‘Get involved’/ ‘Ways to Give’ in the main menu, there are these three options:
    • ‘Give a radio’
      • Why is there a box to write the name of a tax-deducible project?
    • ‘Give to a project’
      • 12 projects (one of which is a radio, which is also a gift (see below), and a separate option (see above).
    • ‘Give a gift’
      • “The page you are looking for is no longer here, or never existed in the first place (bummer).”
  • The Fund: Not distinguished from FEBC (above).
  • Relief: Not distinguished from FEBC (above).

Who are the people controlling the organisation?

  • Not shown on the website, but the ACNC Register shows them (under ‘Responsible Persons’):
  • Six board meetings were held during the year. Peter Elliott attended four, Vanessa Hall only three.
  • There are 11 directorships on the ACNC Register in the name ‘David McDonald’. And the register only covers charities, not all not-for-profits, and of course no for-profit organisations.  Therefore, if after eliminating the charities for which FEBC’s David McDonald is not a director, you are left with the total being more than a handful or so, it would be legitimate for you to question whether his ability to discharge his fiduciary responsibilities is threatened.
  • The board is accountable to the members. They were 47 members at year-end (unchanged from last year).
  • The Fund: Elliott, Keegan, McDonald and Tant above.
  • Relief: the same four as The Fund

To whom are FEBC accountable?

  • The following five logos and one button appear at the bottom of the About Us page on the website:

    • The ‘FIA’ is Fundraising Institute Australia. Members must comply with its fundraising standards. FIA membership confirmed.
    • FEBC International is ‘an interdenominational radio network ministry, which brings the love of God to the world by broadcasting the gospel of Jesus Christ.’[10] Organisationally it is also a company in Singapore that provides services to the national organisations, including FEBC. There doesn’t appear to be any accountability involved.
    • Global Development Group is a charity, an “Australian-founded non-government overseas humanitarian development organisation”. FEBC is not accountable to it.
    • Missions Interlink has an accountability regime.
      • For one opinion on the strength of this accountability, see the section Activities in this review.
    • The last logo is ACNC’s ‘Charity Tick’.  It is used to show that FEBC is registered.  Rightly so, because it would be unwise to give to a charity that is unregistered.
    • Beyond registration, the ‘tick’ only means that the charity’s AIS is not overdue, and that no compliance action has been take against it.
    • The ‘FEBC Policies, Terms & Conditions’, leading as it does to a policy on feedback/complaints, shows that FEBC believes that it is accountable to its stakeholders.
  • Elsewhere, FEBC displays a seal issued by the CMA Standards Council:

[11]

  • One of the FEBC board members, Vanessa Hall, is the Chair of this Council (‘CMA Standards Panel’ on her profile), the body that accredited FEBC.
  • The Fund: Not separately identified.
  • Relief: Not separately identified.

 

 

  1. Although the button is called ‘Donate’, maybe it will change to ‘Support us’:I think they mean ‘name recognition’, not ‘name acquisition’.
  2. Last year, when sent a draft of this review, they responded quickly. However, they did not want to either suggest corrections or submit comments for publication.
  3. Whether this is because it was not included in the application to the ACNC, or whether the ACNC refused the request, is not known.
  4. No search of Tasmanian licences was possible.
  5. The ABN record incorrectly records (a) the ‘Entity name’ as The Trustee for FEBC Overseas Fund’ (the trustee is FEBC Custodian Limited), (b) the ‘Entity type’ as ‘Discretionary investment trust’.
  6. No search of Tasmanian licences was possible.
  7. No search of Tasmanian licences was possible.
  8. 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.
  9. His description for FEBC is ‘Civil Rights and Social Action’.
  10. FEBC Annual Report 2016-17, page 3.
  11. This ‘passing grade’ does not, as is claimed in the Annual Report 2016-2017, show ‘clearly that FEBC carries out tremendous work across the world, bringing hope, changing lives, with utmost integrity’. There’s nothing in the accreditation about impact, nor enough to warrant claiming that level of integrity.

 

WEC: charity review

This is a charity review of WEC, a charity that seeks donations on the internet, and is a ‘Member Organisation’ 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 WEC:

1: No such charity on the Register of charities. And no ABN on the website’s home page to use in the ACNC’s search box.

On ABN Lookup, ‘WEC’ is a trading name held by a Wagner Cardoso. And ‘WEC Co’ is a business name held by HRL Electrical Pty Ltd.

Further down the WEC home page, we see that ‘WEC’ is an acronym for ‘Worldwide Evangelisation for Christ’. But there’s nothing in this name on the Register. And nothing on ABN Lookup.

But gold when we go to ASIC’s database: WEC is likely W.E.C. (i.e., with full stops between the letters), either W.E.C. Incorporated, or W.E.C. International:

The Register than shows us that the WEC of the website is indeed a registered charity.

Not a confidence-inspiring start to our due diligence. (Especially if you look at the ‘Historical details’ on the ABN record; it shows a name change on 30 May 2000 from WEC International to W.E.C. International. So why are they using the old name on their website and with Missions Interlink? And without having registered it, or WEC International Australia, as business names?)

2. NA

3. WEC’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 WEC.

4. The ABN record says no tax deduction. But this doesn’t match what WEC says:

There’s no mention of WEC (under either spelling) at Hada. And Hada is not a ‘Christian’ charity anyway. Disappointment #2. End of review[1].

(Think this a bit tough? Proceed to the fifth of the ACNC’s steps, and you’ll probably make the same decision. Most of the issues raised last year remain. Including a holding of financial assets and property for a ‘Medium’ charity, a charity that doesn’t have any employees or keep money for missionaries, large enough for you to ask why they need your money).

 

  1. I sent a draft of this review to WEC. Like last year, they did not respond.

 

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.