Steer Incorporated: charity review

Mini charity review of Steer Incorporated (Steer)

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

as an organisation that seeks donations. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

2018 review:

  • Steer is still a Member of Missions Interlink[1], an organisation that gives Members an income tax exemption[2].
  • Members of Missions Interlink have to accept a set of standards, the introduction to which includes this statement:

Are they responsive to feedback?[3]

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

Is Steer registered?

  • As a charity, yes.
  • Other registrations:
    • As a public company, a company limited by guarantee (despite the ‘Incorporated’ in its name).
    • Not registered for fundraising in any of the seven six states that have a fundraising licence regime. This includes the five states in which Steer operates (or eight if we go by their AIS 2015).
      • 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.

What do they do?

  • You place – either give or sell – income-earning assets with them; they manage these assets and distribute the income, tax-free, to missions.

Do they share the Gospel?

  • No

What impact are they making?

  • Nothing found.

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

  • If ‘direct’ is defined as ‘Gifts to missionary organisations’, then 15% 16.4%.

Can you get a tax deduction?

  • No

Is their online giving secure?

  • NA.

Is their reporting up-to-date?

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

Does their reporting comply with the regulator’s requirements?

  • AIS 2015 AIS2017 : Not quite. There are no outcomes given, and a number of the figures in the Income Statement do not match those in the Financial Report.
  • Financial Report 2015: No
    • There is no audit report.
    • The directors have decided that Steer, an organisation that received $4.76 m in revenue, including $2.42 m in gifts, operates in five (maybe eight) states, and appeals publicly for donations, has no users, either present or prospective, who rely on the financial statements to make decisions. This means that they can produce special purpose financial statements, statements that do not have to comply with all the Accounting Standards.
    • Two of the programs for donors are the leasing, at a peppercorn rental, of agricultural land and rental properties.
      • There is no split between the two types of properties.
      • There is no identification of these leases as either operating or finance.
      • There is no policy note on accounting for the rental payment – is it just the peppercorn amount?
    • Another of the programs is ‘Livestock and wool’. This program results in Steer taking ownership, either for no consideration or some, presumably nominal, consideration, of livestock.
      • These livestock are not included in the accounts. Steer says that the geographical location and diversity of these assets mean that valuation is not worth the effort. However, while this may make valuation subsequent to purchase difficult, it does not preclude valuation at the time of acquisition. The value, and if not the value then the cost, would be known at that time.
        • Even if it is still decided not enter figures for the livestock holding, some indication of the type and number of animals would allow at least a rough estimate by a reader.
    • 2018 review:
      • Revenue is now $8.13 million, including gifts of $3.17 million, and yet the directors persist with the untenable position that ‘there are no users who are dependent on [its] general purpose financial reports’. So if you are reading this then you are likely one of those people who the directors say don’t exist.
      • Where in the accounts are the properties that are leased?
      • Steer still doesn’t show a true and fair view about the livestock.

What financial situation was shown by that Report?

  • Last year’s surplus of 7% of revenue was increased to 19% this year, largely due to an increase in ‘Gifts’.
    • 2018 review: From 13% last year to 54% this year. There is no explanation given for not distributing more of the revenue.
  • Due to the practice of only seeking at call loans, their working capital is negative (that is, current (short-term) liabilities slightly exceed current (shot-term) assets.)
    • 2018 review: The ratio increased, from 1.1 to 1.9.
  • There is no consequential comment on the going concern assumption.
    • 2018 review: There is no longer a need for such a comment.
  • No obvious concerns about the longer term structure.
  • 2018 review: Other than overseas or Australia, there is no information about where the donations went.

What did the auditor say about the last financial statements?

  • NA. (No audit report.)
  • 2018 review: The auditor, Jeffrey Tulk, for Saward Dawson, gave a ‘clean’ opinion.
    • But this included acceptance of the directors’ decision to produce the financial statements suitable only if users can ring Steer and get a report tailored to their needs.
    • And the acceptance of the deficient information about the livestock.

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

  • Apart from blanks under ‘Phone’ and ‘Website’, yes.
  • 2018 review:
    • There is now a phone number, and a website address is not compulsory.
    • Most of the grants were to overseas organisations, but there are no countries under ‘Where the charity operates’.
    • Most of the directors are missing from the ‘Responsible People’ section.

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

  • They have six programs:
    • You make an interest-free loan to them.
    • Your family or discretionary trusts makes a distribution to them
    • You rent your investment property to them for $1 p.a.
    • You either give or sell your livestock to them. (They pay you to raise it.)
    • You lease your farm land to Steer at a peppercorn rental. It is then share farmed.
    • ‘Bequests’

Who are the people controlling the organisation?

  • The five men shown here include three of the four directors.
    • Although Terence Crook is included in the list on the ACNC Register, he is not a responsible person.
  • 2018 review: The governing document says that Steer is controlled by the Council. The members of the Council are shown here.
    • The relationship between the ‘Directors’ and the ‘Board Investment subcommittee’ shown on the same page is not explained.
    • The ACNC Register incorrectly shows only the three ‘Directors’ as the responsible persons.

To whom are they accountable?

  • As they claim on the website, they are, apart from being accountable to the ACNC, accountable as a Member of Missions Interlink.
    • For one opinion on the strength of this accountability, see the section Activities in this review.
  • 2018 review: They are also, for some things, accountable to ASIC.

 

 

 

  1. In the name ’Steer Inc’. (For an incorporated association this wouldn’t be an issue, but Steer is a company, and therefore ‘Incorporated’ is part of its legal name.
  2. Even though they do not meet the “in Australia” test and do not have deductible gift recipient status.
  3. This section was originally at the end of the review.

 

People International Australia Inc: charity review

Mini charity review of People International Australia Inc (PIA),

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

as an organisation that seeks donations online, and is exempt from Australian income tax via its membership of Missions Interlink. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

Members of Missions Interlink have to accept a set of standards, the introduction to which includes this statement:

For the previous review, see here.

Are they responsive to feedback?

  • I sent them a draft of this review on 16 August 2017. They…did not respond.
  • 2018 review: They did not respond to a draft of this review.

Is PIA registered?

  • As a charity, yes.
  • Other registrations:
    • From 5 February 2016, a NSW incorporated association (INC1501785). (Previously an unincorporated association.)
    • The Australian Business Register was updated for the incorporation on 22 December 2016.
    • The ACNC Register has yet to catch up with the name change.
    • PIA operates, per the ACNC Register, in New South Wales and Victoria. Their office is in NSW, and they have a representative in Victoria (‘Stuart’).
      • If it is carrying on business in Victoria, it does not have the necessary registration (an ARBN).
      • It has a fundraising licence in NSW (expiring 25 August 2017), but not Victoria.
        • It calls for donations on the website. Whether this means it should register for fundraising in one or more of the other five states that have a licensing regime, depends on whether those states interpret this call as ‘fundraising’.

What do they do?

  • The Annual Information Statement (AIS) 2016 says they
    • Raised funds to support gospel work in Australia and overseas.
    • Last year they raised $164K and sent $27K. $120K went on the two full-time employees.
    • 2018 review:
      • The AIS 2018 gives the ‘activities and outcomes’ as ‘Raised funds and provided opportunities to support gospel work in Australia and overseas.’
      • They raised $159K and sent $48K. $121K went on one full-time and one part-time employee.
  • ‘About Us’ on the website is about the international organisation.

Do they share the Gospel[1]?

  • Although the first primary objective in the constitution supports it – ‘To take Christ’s love to the people of Central Asia primarily, by establishing and enabling His church, as in the International Covenant of PI’ – PIA don’t do this themselves.

What impact are they having?

  • Nothing found.

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

  • There are no financial statements, but from the Annual Information Statement (AIS) 2016 AIS 2018, expenses other than ‘Grants and donations made…’, that is, expenses on ‘administration’, are 84% 75% of the total.

Do they pay their directors?

  • There are no financial statements, and it’s not possible to tell from the limited information disclosed in the AIS 2016 AIS 2018 But if they did pay them, it wasn’t much.

Can you get a tax deduction?

  • No

Is their online giving secure?

  • NA

Where were your (net) donations sent?

  • People International globally is a mission to the twelve countries of Central Asia, but PIA is only involved, per the ACNC Register, in one country, Pakistan.
  • 2018 review: Now also Turkey.
  • We are not told to whom donations are sent in Pakistan.

Is their reporting up-to-date?

  • Yes (four months after their year-end, three months earlier than last year).

Does their reporting comply with the regulator’s requirements?

  • AIS 2016: Yes
  • 2018 review:
    • ‘Legal Name’ is incorrect.
    • ‘Other names…’ is incorrect.
    • ‘Main beneficiary’ (General community in Australia’) is incorrect.
  • Financial Report 2016 (2018): NA
    • As a ‘Small’ charity, PIA doesn’t have to submit a Financial Report.
    • And it chose not to submit one voluntarily.
    • As a Victorian incorporated association, at least financial statements should have been prepared though:
      • As soon as practical after the end of your incorporated association’s financial year, the committee must ensure that financial statements are prepared.
      • And they ‘must give a true and fair view of its financial performance and position during and at the end of the year.
    • As a member of Missions Interlink, PIA is not only required to prepare financial statements, but it must have them audited:
      • have available for its members and supporters a clear and appropriate financial statement which has been approved by its auditor’ [Standards Statement, 4.1].

What was the financial situation shown by that Report?

  • NA
  • But from the AIS 2016:
    • 95% of ‘Revenue/receipts’ was from ‘Donations and bequests’, down from 100% last year.
    • ‘Employee expenses/payments’ have risen from 29% of expenses to 70%.
    • PIA reported that its accounting method was ‘Cash’, a method that doesn’t generate liabilities; therefore, they had to record these outside the double entry system.
    • 2018 review:
      • Because of $50K of ‘Other revenue/receipts’, ‘Donations and bequests’ were only 76% of receipts
      • ‘Employee expenses/payments were 64% of payments.

What did the auditor say about the last financial statements?

  • NA.
    • Their membership of Missions Interlink (see above) means they should have one though.

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

  • Yes
  • 2018 review: No
    • The name is incorrect.
    • It maybe ‘known as’ ‘People International Australia Inc’, but this is because it is its legal name.

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

  • If you know their name, you can give to a specific person.

Who are the people controlling the organisation?

  • There is no mention of the board on the website.
  • From ACNC Register (under ‘Responsible Persons’):
    • Darryl Anderson
    • Rachel Driessen
    • Stephen Ellis
    • Moussa Ghazal
    • David Lewis
      • There are 13 directorships recorded for the name ‘David Lewis’.  And the register only covers charities, not all not-for-profits, and of course doesn’t include for-profit organisations.  Therefore, if after eliminating the charities for which David is not a director, you are left with the total being more than a handful, it would be legitimate for you to question whether his ability to discharge his fiduciary responsibilities is threatened.
    • 2018 review:
      • Driessen has gone, and Bonnie Lepelaar and Robert Morris have joined.
        • Is it this Robert Morris?
      • A search of responsible persons is not possible with the new (ACNC) website.

To whom is PIA accountable?

  • Because of its income tax exemption, PIA is accountable to Missions Interlink.
    • For one view on the strength of this accountability, see the section Activities in this review.
  • As a registered charity, PIA is accountable to the ACNC.
  • And to the New South Wales regulator of incorporated associations.

 

 

 

  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.

 

Awakening Australia: charity review

This is review in the series ‘Christ-led charities in the news’.

Here’s the news:

Another couple of samples, here, and overseas.

As well as having its supporters, there were a number of commentators who issued warnings about the event. For instance The Gospel Coalition, The Church of Brisbane, and Murray Campbell. And Eternity magazine reported on the dispute about the theology of one of the main speakers.

They say that ‘it’s Not a Bethel church Event’, but the connections are very strong. Bethel church divides opinions. Here’s one canvass of the issues. And something on Bill Johnson, the ‘Senior Pastor’, by a well-known discernment ministry.

You can read Awakening Australia’s own post-event reports on their Facebook page.

You make up your own mind on why they did and said. I’m here to give you some information to help with your giving decision.

Awakening Australia called for donations on its website, and, post-event, even though they said that all donations would go to ‘the event’, there is still an invitation. The only way that this might be valid is if they borrowed to stage the event and donations were needed to repay those borrowings. If this is the case, one would expect an explanation.

They said it wasn’t a Bethel Church event, but they have a page on that church’s site, and donations for the event in the US go to that church:

Those attending were invited to make a pledge:

Where’s this money go?

The information on the website leaves little doubt that Awakening Australia is a charity.

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 ‘Awakening Australia’, with #5 supplemented by the essentials of the ACNC’s What should I consider when deciding which charity to support?[1].

1.   A search on the ACNC Register of charities gives no results. What this means is that ‘Awakening Australia’ is not a registered charity, and is therefore not exempted from paying income tax and is not subject to Australia’s regulatory regime for charities.

Last Wednesday I sent them a private message on Facebook. I rejoiced at the reports of sinners repenting as a result of their work and then asked them why they weren’t a registered charity. I got an immediate – no doubt automated – response but have heard nothing since.

ABN Lookup (Australian Business Register) gives an ‘Other Incorporated Entity’ in the name ‘Awakening Australia’, which is not in the format for such an entity. This organisation holds the business name ‘Awakening Australia’ though.

ASIC’s register of organisations and business names shows that the name is ‘Awakening Australia Ministries Incorporated’.

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 first ACNC article above]. Online donations are via PushPay, and you can read about the security of your information via the small print at the bottom of the page where you enter that information.

4. The ABN record above says that ‘Awakening Australia’ is not entitled to receive tax deductible gifts.

5. ‘Awakening Australia’ says that your donation will be used for ‘this event and its outreaches’:

There is no information on the website about reporting, financial statements, audit, accountability or transparency.

 

 

  1. 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].

 

Middle East Christian Outreach (Australia) Inc: charity review

Mini charity review of Middle East Christian Outreach (Australia) Inc (MECO)

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

as an organisation seeking donations online. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

2018 review:

  • MECO is still a Member of Missions Interlink[1], an organisation that gives Members exemption[2] from income tax.
  • Members of Missions Interlink 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 MECO registered?

  • As a charity, yes.
  • Other registrations:
    • MECO is a Victorian incorporated association (A0008890J).
    • The ACNC Register shows that it is operating in all eight states, but it does not have the required ARBN registration to allow it to operate outside Victoria.
    • It also doesn’t have a licence to fundraise in the seven six states that have a licensing regime[3].
    • It uses the name MECO Australia but has not registered it as a business name. (The company of the same name is in administration.)

What do they do?

  • The page for Australia on the MECO International site doesn’t give MECO’s mission, but the mission of the bigger body is to support Middle East Christians in sharing the love of Jesus Christ’.
  • This is how MECO’s Annual Information Statement (AIS) 2015 describes the Australian activities and outcomes:
    • Partner in mission with Middle Eastern churches and communicate, in a variety of ways, the beliefs of the Christian faith. The major activities were to – select and support workers from Australia, – support and care for workers returned from the Middle East, and – publicise and promote the work of the Association throughout Australia.
    • 2018 review: The description is identical in the AIS two years later.
  • Although they said in the AIS 2015 that they had no intention of ‘changing the way charity (sic) pursues its purposes in the next reporting period’, in March 2016 they announced a merger with SIM International.
    • 2018 review: There is no evidence on the website that this new organisation was formed.

Do they share the Gospel?

  • If ‘the beliefs of the Christian faith’ (above) is not only about communicating to church members’, then yes.

What impact are they having?

  • Nothing found.

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

  • If we assume that the expense ‘Ministry Partnership’ is what was ‘directly incurred’ on the mission, then it cost $259K to send $258K.
    • That’s 50% on ‘administration’.
  • 2018 review: The expenses are no longer classified so as to allow this calculation.

Can you get a tax deduction?

  • No

Is their online giving secure?

  • Given that they use PayPal, yes.

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

  • Two: ‘’General Funds’ or ‘Specified Support’ – although the page following that may break up ‘Specified Support’.
  • 2018 review: If this choice still exists, it occurs after the page where you enter the amount.

Is their reporting up-to-date?

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

Does their reporting comply with the regulator’s requirements?

  • AIS 2015: No
    • No outcomes reported.
    • ‘Other Income’ is incorrect.
    • No grants reported.
  • 2018 review:
    • No outcomes.
    • The ‘main beneficiary’ of MECO’s work is not ‘General community in Australia’.
    • Two of the four line items under ‘Gross Income’ are incorrect.
  • Financial Report 2015: Questionable. The ACNC would probably pass it but
    • The directors say that MECO ‘is not a reporting entity’, and therefore doesn’t have to comply with all the Accounting Standards, but they don’t say why. What they are effectively saying is that they have no users, either current or prospective, who rely on MECO’s financial statements. This for an organisation taking $481K in donations, operating in all states and having an invitation to give on the internet.
    • The Notes to the accounts are not a complete set.

What financial situation was shown in that Report?

  • The percentage of surplus to income declined from 10% to negative 4%.
  • They have continued to lend a significant amount, $161K (borrower unspecified), while at the same time continuing to borrow $77K (lender unspecified).
  • 2018 review:
    • A deficit of 23% of income became a surplus of 43%, largely due to an increase in donations.
    • ‘Project Expenses’ went from 13% to zero.
    • There is no explanation for why the extra donations were not used for beneficiaries.
    • The borrowings are from supporters.

What did the auditor say about the last financial statements?

  • MECO, being a Medium-sized charity, took advantage of the law that allows it to have a review, rather than an audit. Still performed by an independent auditor though. This was the reviewer’s conclusion:
    • Based on our review, which is not an audit, we have no become aware of any matter that makes us believe, that the financial report…does not present a true and fair view, in all material respects… [4]
      • But note that he approved of the directors’ decision to produce the type of financial statements that require less disclosure.
  • The auditor is again Matthew Hung, CA, of rdl.accountants.

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

  • Almost. ‘Phone’ and ‘Website’ are blank.
  • 2018 review:
    • A phone number and the website are now included.
    • MECO may be known as ‘MECO Australia’, but the name is not registered.

Who are the people controlling the organisation?

  • Not mentioned on the website.
  • From ‘Responsible Persons’ on the ACNC Register:
    • Joshua Aylward
    • Annette Cook
    • Richard Coombs
    • Lorelei Edwardes
    • John Haig
    • Peter Thomas
  • 2018 review: John Haig has joined, and it appears that Lorelei might have got married.

To whom is MECO accountable?

  • They are accountable because of their membership of Missions Interlink[5].
  • They are also accountable to the ACNC.
  • 2018 review: And to the regulator of Victorian incorporated associations.

 

 

  1. In the name’ Middle East Christian Outreach Australia’.
  2. Even though they do not meet the “in Australia” test and do not have deductible gift recipient status.
  3. 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.
  4. Even if it had been the stronger engagement, an audit, you would need to take care to take the right amount of comfort from a ‘clean’ opinion like this: see here and here.
  5. For one opinion on the strength of that accountability, see the section Activities in this review.

 

LTTN Ministries Incorporated: charity review

Mini charity review of LTTN Ministries Incorporated[1] (LTTN)

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

as an organisation that has a public invitation to donate. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

2018 review:

  • There is no ‘Donate’ or similar button, just (a) information about the different kinds of donations that are received, and (b) information to allow you to donate.
  • LTTN is still an associate member of Missions Interlink[2]. Unlike the case with Members, this does not give it an income tax exemption. Members of Missions Interlink 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 replied the same day. I responded, then later asked whether they would like to amend any of their initial responses because of what I had said. They declined.
  • This was their general comment:
    • ‘LttN Ministries Inc is a fully accountable ministry organization, registered with the ATO, ACNC, NSW Department of Fair Trading as an incorporated association and Missions Interlink.  We do our utmost to provide all reports and statutory obligations well within the time required.‘
  • Their other comments are interspersed below.
  • 2018 review: They did not respond to a draft of this review.

Is LTTN registered?

  • As a charity, yes[3].
  • 2018 review: But the name still doesn’t match either the governing document or the ASIC record.
  • Other registrations:
    • LTTN is a NSW incorporated association (INC9877906).
    • The ACNC Register shows that it is operating outside its home state, in Queensland, but it doesn’t have the required ARBN registration to do this.
    • It doesn’t hold a fundraising licence in either of these states (or in any of the other five states that have a licensing regime[2]).
    • It uses the names LttN, Light to the Nations Ministries Inc, and LttN Ministries Inc on its website, and Lttn Ministries Inc on FaceBook, but does not have any of these names registered. (There are ABNs for other entities called Light to Nations Church Incorporated and Light to The Nations Christian Church.)
    • Ministry comment: ‘LttN Ministries Inc has no connection with either of the above mentioned churches.’
    • 2018 review:
      • On this page there are five different versions of the name: ‘ LttN’, ‘Light to the Nations Ministries Inc’, ‘LttN Ministries Inc, LttN Ministries’, and ‘Light to the Nations Ministries’. None are registered business names, plus there is a company ‘Lttn’, a church with a name that includes ‘Light to the Nations and another with the name ‘Light to Nations…’
      • The Facebook page was not available to check.

What do they do?

  • This is how LTTN’s Annual Information Statement (AIS) 2016 describes the Australian activities and outcomes:
    • Our purpose as an organisation is to Equip (sic) Christian leaders in the Developing World (sic) through the provision of accessible training programs known as SALT Schools. During the year we have facilitated the operation of these training programs in Zambia and Uganda and are working toward the establishment of the programs in the Fiji islands. Our activities also included visitation (sic) of supporters and supporting churches in Australia to inform them of the progress of the work.
  • 2018 review: 2018 AIS ‘activities and outcomes’:
    • ‘We provide resource materials to groups desiring to use our SALT School materials and ongoing mentoring as they implement the strategy. We maintain relationships with a variety of Christian workers serving in many countries for the purpose of encouragement and mentoring. As invited, our representatives speak at conferences, retreats and seminars at the invitation of groups who share our ethos and focus.’
    • From the ‘Annual Report’ on the Register, it appears that, consistent with what it says here, the work is performed by one couple, Gavin and Glenda Williams.
  • The AIS also describes the changes they plan:
    • Changes planned During (sic) the 2017 reporting period (sic) we will progressively withdraw from our work in Africa. We have been preparing African leaders to conduct the training programs and the time has come to entrust the work to them. At the same time we plan to commence the operation of the training programs in the Fiji islands.
    • 2018 review: The ‘Annual Report’ shows that Africa was still being visited in 2018, and there is no mention of Fiji.

Do they share the Gospel?

  • Not to those who haven’t heard it. (Changed from ‘No’.)
    • Ministry comment: ‘YES! The preaching of the Gospel of the Lord Jesus Christ and faithful teaching of His Holy Word, the Bible, are fundamentals of our ministry.
  • 2018 review: From this page, and the Annual Report, preaching the Gospel to non-believers is a minor activity.

What impact are they having?

  • Nothing found.
    • Ministry comment: ‘Since our foundation in 2002, LttN Ministries has been involved in training Christian leaders and cross cultural workers in many nations around the world. By way of example: In Uganda, to date we have more than 450 graduates from our School of Advanced Leadership Training (SALT School). The work continues under the leadership of Ugandan’s whom we have trained.’

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

  • No financial statements have been lodged – they are not required by the ACNC – and the expenses in the AIS 2016 are not classified to allow this calculation.
  • 2018 review: The expenses are not classified so as to allow this calculation.

Can you get a tax deduction?

  • No

Is their online giving secure?

  • NA. (Not offered.)

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

  • None shown on the website. (Changed from ‘None’.)
    • Ministry comment: ‘When donors specify a particular designation for their donation, 100% of their gifts are allocated to the purpose for which it is designated. We willingly provide donors with details of the use of such allocations should they ask.’

Is their reporting up-to-date?

  • Yes. (Three months after year end.)
  • 2018 review: Over four months this year.

Does their reporting comply with the regulator’s requirements?

  • AIS 2016: Apart from the lack of outcomes, yes.
  • 2018 review: AIS 2018:
    • The name is incorrect.
    • It might be known as ‘Light to the Nations Ministries Inc’, but the name is not registered.
    • There are a number of figures that do not match the Financial Report.
  • Financial Report 2016: None required.
    • But they lodged one last year.
    • Their Associate membership of Missions Interlink requires them to have one available, so just ask them.
    • 2018 review: Because no Report is required, the Report that has been lodged does not have to comply with the ACNC legislation. The significant errors and omissions should be of concern to Missions Interlink though.

What financial situation was shown in that Report?

  • NA
    • Ministry comment: ‘LttN Ministries Inc satisfactorily met all financial obligations in the 2015-16 financial year.’
  • 2018 review:
    • After ignoring the unexplained ‘Transfers from (to) fund accounts’, the result for the year was a deficit equal to 19% of income. The previous year it was a deficit of 2%.
    • Despite recent losses, both working capital and financial structure are still OK.

What did the auditor say about the last financial statements?

  • NA
    • Ministry comment: ‘The Audited Financial Statements are available to Association Members and donors on request.
  • 2018 review: The auditor, J.G. Ryan of Thomas Davis & Co, gave a ‘clean’ opinion. However, he
    • accepted the omission of two of the required financial statements, and
    • allowed the material unexplained transfer in the income statement (see above).

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

  • Almost. ‘Phone’ is blank.
  • 2018 review: ‘Phone’ is not a compulsory field; four of LTTN’s names are missing.

Who are the people controlling the organisation?

  • Not mentioned on the website.
  • From ‘Responsible Persons’ on the ACNC Register:
    • Timothy Baker
    • Elizabeth Hancock
    • Nga Kwan
    • Raymond Martin
    • Own McKay
    • Peter Pade
    • Trevor Welsh
    • Andrew Williams
    • Gavin Williams
    • Glenda Williams
  • 2018 review: It’s ‘Owen McKay’, and Timothy Baker is no longer on the Committee.
  • If you ‘search the (ACNC) register by responsible person’, as I did, you will find that, other than ‘Andrew Williams’, these directors have no more than three other charity directorships. There are 14 listed for ‘Andrew Williams’. If, after eliminating the ones that don’t belong to LTTN’s Andrew Williams, more than a handful remain, it would be legitimate for you to question whether his ability to discharge his fiduciary responsibilities to that many charities is threatened.
    • Ministry comment: ‘We believe that there is an error in the ACNC number of directorships allocated to Andrew Williams. So far as we are aware, Andrew is not a director of any other organization.’
      • Reviewer response: ‘No error I expect.  The problem comes when you, and other charities, record your ‘Andrew Williams’ as simply ‘Andrew Williams’.  It is then not possible for the Register user to distinguish between yours and the ones that relate to other charities.  (How you record your ‘Andrew Williams’ is within your control via the ACNC Portal.)’
    • 2018 review: The ACNC have not included this search function in their new website.

To whom is LTTN accountable?

  • Ministry comment:
    • ‘Primarily we are accountable to God for the faithful administration of the affairs of this organization – something we take very seriously. The Management Committee are accountable to the members of the Association for the operation of the Association and report fully at the AGM and by way of regular newsletters. The Annual Audited Financial Statements are available at the AGM and on request to any person who gives to the ministry.
  • They are accountable to Missions Interlink[3] via their Associate membership.
    • Presumably this membership is a result of LTTN’s stated policy that they ‘will seek affiliation with a Christian Financial Integrity group.’
  • They are also accountable to the ACNC.
  • 2018 review: And to the NSW regulator of incorporated associations.

 

 

 

 

  1. But as ‘L T T N…’, i.e. with spaces (no doubt following the ABN record). Which doesn’t match the ASIC record, nor how the charity itself writes it.
  2. The law in this area is not straightforward – is an internet invitation ‘fundraising’ for instance? – and advice varies, so check with the charity before drawing any conclusions.
  3. For one opinion on the strength of that accountability, see the section Activities in this review.

 

 

  1. This is the name on ASIC’s register (www.asic.gov.au). But not quite the name elsewhere.
  2. In the name ‘LTTN Ministries’.
  3. But as ‘L T T N…’, i.e. with spaces (no doubt following the ABN record). Which doesn’t match the ASIC record, nor how the charity itself writes it.

 

World to Christ International (Australia) Inc: charity review

Mini charity review of World to Christ International (Australia) Inc (WTC)

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

as an organisation that (a) seeks donations from the public via the internet (in the website footer), and (b) is a Member of Missions Interlink, an organisation that, among other things, gives Members income tax exemption even though they do not meet the “in Australia” test and do not have deductible gift recipient status. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

See here for the previous review.

Members of Missions Interlink have to accept a set of standards, the introduction to which includes this statement:

Are they responsive to feedback?

  • When sent a draft of this review, on 23 June 2017, they…did not respond.
  • 2018 review: They did not respond to a draft of this review.

Is WTC registered?

  • As a charity, yes.
  • WTC is a Victorian incorporated association (No. A0054699X).
  • Although it trades under the names ‘WTCI’,WTCI Australia’, and ‘Jesus Healing Of the Whole Person’, none are registered as business names.
  • WTC operates in Australia, per the ACNC Register, only in Victoria. But it also calls for donations on its website. It has no fundraising licences[1].
  • 2018 review: In the AIS 2017, WTC said that it did not intend to fundraise in 2018.

What do they do?

  • See ‘Our Ministry’ on a website in the name ‘Jesus’ Healing Of The Whole Person’[2].
  • The ACNC Register says that they operate overseas in Hong Kong. Courses are conducted there (see, for instance, February 2015 on Facebook, and here).
  • 2018 review: there is no evidence that courses are still conducted there.

Do they share the Gospel[3]?

  • No, the ministry is to Christians.

What impact are they having?

  • Nothing systematic found. You might find something anecdotal in the occasional newsletters.

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

  • No financial information is available, (see below).
  • 2018 review: ‘Grants and donations made…’ were 19% of expenses.

Can you get a tax deduction?

  • No

Is their online giving secure?

  • PayPal is used, so yes.

Is their reporting up-to-date?

  • Yes (lodged four months after their year-end).
    • But if you are considering a large donation, I would ask for more up-to-date financial information – the accounts are for a year end that is now a year ago.
  • 2018 review: Down to one month for the AIS 2017.

Does their reporting comply with the regulator’s requirements?

  • AIS 2016: Except for the absence of outcomes, yes.
    • But only because WTC is still saying that it is a Basic Religious Charity, and therefore not required to complete the section on financial information. However, it wasn’t, and still isn’t such a charity.
    • 2018 review: WTC no longer claims to be such a charity; outcomes are still missing.
  • Financial Report 2016: NA
    • Even if had not identified as a Basic Religious Entity, WTC’s revenue would have made it exempt from submitting a Report anyway.
    • However, audited accounts should exist – clause 30(4) of its constitution requires them. And their membership of Missions Interlink means that they must be available to ‘members and supporters’ [Standards Statement, 4.1]. (I asked last year, but they didn’t reply. So I’ll leave it to you this year.)
    • 2018 review: Again, I didn’t ask this year.

What financial situation was shown by that Report?

  • NA
  • 2018 review: However, Section D of the AIS 2017 shows
    • A deficit of 73% of ‘Total income/receipts’.
    • No liabilities and assets of $300K.
      • These assets are 20 times 2017 ‘Total income/receipts’. Why they continue to seek donations when they have such a large holding of assets would be a good question to ask.

What did the auditor say about the last financial statements?

  • NA
  • 2018 review: An audit report should have been produced (see above); it’s just that the ACNC doesn’t require one.

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

  • Yes
    • “Phone” and “Website” are blank, but neither are compulsory.

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

  • None.

Who are the people controlling the organisation?

  • WTC say it’s the people at the bottom here.
  • Which matches what is on the ACNC Register (under ‘Responsible Persons’):
    • Sophia Hunter
    • George Lagwa
    • Wendy Lagwa
    • Robert Nicholls
    • Edward Seymour
    • Karen Seymour
    • Assuming that George and Wendy are related (married?), and similarly Karen and Edward, the board would seem to be too small at six people.

To whom are they 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. The website that is linked from Missions Interlink has been obsolete since 2015.
  3. Good living and social concern are important [to the cause of evangelism], but they are not uniquely Christian graces…I’ve met a lot of fine Hindus, Muslims and atheists. Just living the life is not going to bring someone to Christ. There is much more to it than that. We must help people, certainly, but we must also share with them why we are motivated to do so. We must stand against injustice, poverty and need, but we must at the same time point to the One who brings justice and who can meet the deepest need. Until they know our reasons, how can they come to know our Lord?” [Dan Armstrong, the Fifth Gospel: The Gospel According to You, Anzea Books, pp. 13-14.

 

Logoslife International Incorporated: charity review

Mini-review of Logoslife International Incorporated (LI) as an organisation that (a) seeks donations online, and (b) is a member of Missions Interlink, an organisation that, among other things, gives members income tax exemption even though they do not meet the “in Australia” test and do not have deductible gift recipient status. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

See here for last year’s review.

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

Missions Interlink 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, on 21 June 2017, they…did not respond.
  • 2018 review: They did not respond to a draft of this review.

Is LI registered?

  • As a charity, yes.
  • Other registrations:
    • As a New South Wales incorporated association (No. INC9896528).
    • LI is not registered for GST, but it is still under the revenue at which it has to register.
      • NSW is its home state; there is no information that explains why Queensland is (still) included as an ‘Operating State’ on the ACNC Register.
      • 2018 review: The website doesn’t say anything about operations in Queensland.
        • If indeed it is operating interstate, it is a ‘registrable Australian body’ without a registration (an ARBN).
      • It has a fundraising licence only in NSW.
        • Apart from exemptions, whether it needs such a licence in the other six states that have a licensing regime depends on (a) whether fundraising is part of what LI does in that state, and (b) whether that state thinks that LI, by calling for donations publicly, is ‘fundraising’ in their territory.

What do they do?

  • Presumably the reason they were founded is still what they do:
    • Logoslife International began in Australia in 2012 to provide administrative and home care support to missionaries on the field, and transfer funds with accountability to mission projects/ministry.
  • At least part of this is confirmed in their description of their activities in their Annual Information Statement (AIS) 2016:
    • Receiving donations for the support of missionaries working in Botswana.
    • 2018 review: In the AIS 2017, ‘international activities’ are said to be ‘Supporting two Christian missionaries in Botswana’. This doesn’t, without explanation fit with the information given for ‘activities and outcomes’: ‘Provide support for people from a culturally and linguistically diverse background.’
  • But the website says that they also have a project, ‘S.H.I.N.E. Africa’, which is separate to the work of this couple.
    • No grants were made for this project (AIS 2016).
    • 2018 review: No grants are shown in the financial statement; the ‘Finance’ section in the AIS 2017 is blank, so we can’t check for grants made.
  • They have one missionary couple.
    • Donations are sought (see below), and presumably ‘Employee expenses/payments’ $122K includes (or is?) what was sent to them.
    • 2018 review: The usual financial information is absent from the AIS (2017), but the financial statements show ‘Staffing costs’ of $61K.
      • The AIS 2016 says that LI has two employees, both full-time.
      • 2018 review: ditto the AIS 2017.

Do they share the Gospel[1]?

  • No
    • Which is confirmed by the objects in the constitution:
      • To advance the Christian Faith (sic) throughout the world.   To promote preaching, teaching, training, welfare programs and general activities so as to further the cause of the gospel of our Lord Jesus Christ and to work for the building up, extension and renewal of the Christian faith.

What impact are they having?

  • Nothing found.
    • No outcomes are given in the AIS 2016 (2017).

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

  • If we define ‘direct’ as what was spent on ‘Employee expenses/payments’, ‘administration’ was 1% of expenses.
  • 2018 review: 9% in 2017

Can you get a tax deduction?

  • No

Is their online giving secure?

  • NA

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

  • ‘Freemans’ support’
  • ‘Ministry expenses’
  • ‘Current projects__________’

Is their reporting up-to-date?

  • Yes (four months after their year-end).
    • But if you are considering a large donation, I would ask for more up-to-date financial information – the accounts are for a year end that is now nearly a year ago.
  • 2018 review: three and a half months.

Does their reporting comply with the regulator’s requirements?

  • AIS 2016: Almost – no outcomes are reported.
  • 2018 review: In addition to the above, ‘Section D: Finance’ is blank.
  • Financial Report 2016: Yes
    • Its ACNC rating as ‘Small’ means that LI is not required to submit a financial report to the ACNC. And it hasn’t submitted one voluntarily.
    • LI’s membership of Missions Interlink requires it to ‘have available for its members and supporters a clear and appropriate financial statement which has been approved by its auditor. Last year I asked for this statement but didn’t get a reply. I leave it to you this year.
    • 2018 review:
      • The Financial Report that has been lodged consists of only one statement, an ‘Income and Expenditure Statement’, and that is non-compliant with the Accounting Standards.
      • The Report is therefore not compliant with Mission Interlink’s requirements.
      • However, the ACNC does not require voluntarily submitted Reports to comply with their legislation.

What financial situation was shown in that Report?

  • NA
    • The AIS 2016 shows no liabilities, and minimal assets.
      • LI reported that its accounting method was ‘Cash’, a method that doesn’t generate assets (or liabilities); therefore, they had to record assets outside the double entry system.
    • 2018 review: only an income statement is provided in the Financial Report (see above), and the applicable section in the AIS 2017 is blank.

What did the auditor say about the last financial statements?

  • NA

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

  • Yes
    • ‘Phone’ and ‘Website’ are blank, but neither are compulsory.

Who are the people controlling the organisation?

  • These people on the ACNC Register (under ‘Responsible persons’):
    • Joshua Cocks
    • Sandra Connolly
    • Vonda Copleston
    • John Freeman
    • Elizabeth Groves
    • John Pring
    • Douglas Sands
  • The website has the same names, and a little biography for each.

To whom is LI accountable?

  • There’s a (very) large Missions Interlink ‘Accredited Member’ logo on the website. Membership confirmed.
  • Also accountable to the ACNC.

 

 

  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. 

 

SparkLit: charity review

Mini charity review of The Society For Promoting Christian Knowledge Australia Incorporated (SparkLit) as an organisation that seeks donations online. (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: SparkLit was, and still is, a Member of Missions Interlink.
    • This is the basis of its exemption from income tax.
  • Such members have to accept a set of standards, the introduction to which includes this statement:

Are they responsive to feedback?

  • When sent a draft of this review, they sent comments, then another comment in response to my reply. Where still relevant, these comments have been included below.
  • 2018 review: They did not respond to a draft of this review.

Is SparkLit registered?

  • As a charity, yes.
  • 2018 review: ‘The’ has been incorrectly included at the beginning of the name.
  • Other registrations:
    • As a South Australian incorporated association (A38977).
    • As a registrable body, in this case an association that operates interstate (ARBN 119 800 645)
    • RCF doesn’t have a licence to fundraise in the states that, according to the ACNC Register, it operates. Nor in any of the others that have a licensing regime[1].
  • 2018 review:
    • Sparklit holds the business name ‘Sparklit’.
    • But this is also the name of a ‘Non Registered Entity’:

What do they do?

  • Generally: see the website.
  • 2018 review: From the ‘Donate’ page, these are the three uses of your donation: ‘Supply books’, ‘Nurture emerging publishers’, and ‘Equip publishing professionals’. Read more here.
  • In 2015, from the AIS 2015:
    • Text books and reference works were supplied to students, church leaders and libraries in Cambodia, China, Kenya, Myanmar, Philippines and Tanzania. Grants made possible the publication of books in Burmese, Chinese, Khmer, and Spanish. Training and encouragement has been provided for publishing professionals in Africa, Asia and Latin America.
  • 2018 review: ‘Activities and Outcomes’ in AIS 2017:
    • ‘Text books and reference works were supplied to libraries, students and church leaders in Africa, Asia and the Middle East. Grants made possible the publication of books written in local languages by local authors in Asia. Training and encouragement has been provided for writers and publishing professionals in Africa, Asia and Latin America.’

Do they share the Gospel?

  • No.

What impact are they having?

  • Nothing found.

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

  • If we define ‘direct’ as ‘Grants and donations…’ (in the AIS 2015) then it cost $167K to deliver $167K.
    • ‘Administration’ is therefore 50% of expenses.
    • ‘Employee benefits expense’, for one full-time and three part-time employees, is 38% of expenses.
    • SparkLit comment: ‘The primary benefit provided to our project partners is the training and mentoring delivered by the National Director. However, his salary and travel expenses are counted in our AIS as Employee Expenses and Other Expenses.’
      • Reviewer response: As not all the Director’s time and trouble would be on this work, an allocation would be required to revise the figure for direct costs.
  • 2018 review: For 2017, it cost $171K to deliver $139K, and ‘Employee benefits expense’ was 34%.

Can you get a tax deduction?

  • No

Is their online giving secure?

  • PayPal is used, so yes.

Is their reporting up-to-date?

  • Yes (right on the deadline, six months after their year-end).
    • But if you are considering a large donation, I would ask for more up-to-date financial information – the accounts are for a year end that is now 10 months ago.
  • 2018 review: 10 days earlier than last year.

Does their reporting comply with the regulator’s requirements?

  • AIS 2015: No
    • No outcomes given.
    • Only ‘Government Grants’ and the total match the income figures in the Financial Report.
    • One business name missing.
  • 2018 review: AIS 2017:
    • No outcomes
    • Three of the figures in the ‘Comprehensive Income Statement summary’, and all the figures in the ‘Balance Sheet extract’ are different from those in the Financial Report.
    • One business name missing.
  • Financial Report 2015: Only if
    • you believe that it is reasonable for the directors to say that, for a charity operating in 17 countries, and two states, and with ‘Donations and bequests’ of $286K, there are no users, either current or prospective, who are dependent on its financial statements.
    • 2018 review: 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 now 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’.

Do you provide or give things to, receive things from, or have oversight of, or review, of the SparkLit? Perhaps you intend to donate or are one of those who contributed to the $351K of revenue [Financial Report 2017]? Perhaps you are one of the 23 staff [AIS 2017]. If so, can you ring SparkLit’s office and request that they prepare financial statements that answer the question or questions you have about the charity? I very much doubt it. You are therefore ‘potentially interested in the information provided in general purpose reports[2].

You are therefore in the wrong place – I only have access to the published accounts of SparkLit, and the directors[3]with the agreement of the auditor, have again produced the lower standard special purpose financial statements. This is because they think that you don’t exist.

Even if this type of financial statement was reasonable, The Financial Report does not say either how the donations and grants were used, or to where they were sent.

What financial situation was shown by that Report?

  • The deficit was decreased from 4% of turnover to a surplus of 3%.
  • 2018 review: From a deficit of 6% to a surplus of 12%.
  • ‘Cash and cash equivalents’ and ‘Financial assets’ total $952K. This is approximately three years’ worth of revenue. No explanation is given for holding this much.
    • SparkLit response: ‘Financial assets are held for two purposes. (1) A fund is maintained to provide interest-free loans to emerging publishers. (2) Cash prizes for the Australian Christian Literature Awards are funded by investment income. This enables the awards to be independent and free from any conflict of interest. Donations are not retained as financial assets. Money in our investment portfolio and loans fund has come from (1) bequests and (2) revenue generated by our defunct book publishing enterprise.
  • 2018 review: Financial assets are now $1.09 million. There is still no explanation for holding this much.
  • No obvious concerns with the financial structure.

What did the auditor say about the last financial statements?

  • He was unable to give a ‘clean’ opinion. He qualified the accounts on two grounds:
    • The directors of SparkLit had decided that it was ‘not practicable’ for them to establish any controls over donations until after they were entered in the books.
      • They do not say why SparkLit is one of a small minority of charities who are unable to do this. (What it means is that they, and the auditor, cannot be sure that all the money given to SparkLit made it into the bank account.)
      • SparkLit response: ‘Where possible, SparkLit directs donors to donate electronically. However, while representing SparkLit, the National Director occasionally receives cash donations. In 2015 he received $1840 in cash donations. Neither the directors nor the auditor are in a position to guarantee that cash received by the National Director is deposited into a SparkLit bank account. This is the reason for the first qualification.
        • Reviewer response: An auditor never gives any guarantees; this qualification can be avoided.
    • Saward Dawson say that, because they weren’t the auditor last year, ‘we are not in a position to express an opinion on the comparatives for 31 December 2014’.
      • A different auditor is not sufficient reason under the Auditing Standards to issue a qualified opinion.
  • 2018 review: It is now a ‘clean’ opinion[4].

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

  • Almost. One business name is missing under ‘Other Name(s)’.

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

  • None – at least on the website.

Who are the people controlling the organisation?

  • The names (and some faces) here on the website.
  • Which is two less than is shown under ‘Responsible Persons’ on the ACNC Register.
  • 2018 review: The names on the website are the same as those on the Register, except that on the Register there is no Michael Collie, and Paul Douglas replaces David Painter.

To whom are SparkLit accountable?

  • Membership of Missions Interlink claimed in the (website) footer. Confirmed. Missions Interlink has standards with which members must comply[5].
  • SparkLit is also accountable to the ACNC.
  • 2018 review: And also to the South Australian regulator of incorporated associations.

 

 

 

  1. The law in this area is not straightforward and advice varies, so check with the charity before drawing any conclusions.
  2. From Objective of General Purpose Financial Reporting (SAC2), www.aasb.gov.au: http://tedsherwood.com/wp-content/uploads/2018/08/word-image-15.png  
  3. The people shown here. After removing the Public Officer and adding Grant Robinson, this list matches the ‘Responsible Persons’ on the ACNC Register.
  4. It is a questionable practice for the audit firm’s logo to appear on the front of a report authored by the charity. It’s prominence in this case would, in most other situations in commerce, indicate that the report was written by Saward/Dawson, with the content being Society for Promoting Christian Knowledge Australia Inc.
  5. For one opinion on the strength of this accountability, see the section Activities in this review.

 

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.

 

Love International Limited: charity review

Mini-review of Love International Limited (LI)

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

as an organisation that (a) seeks donations online, and (b) is an associate member of Missions Interlink, an organisation that, among other things, gives Members income tax exemption[1]. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

See here for last year’s review.

Members of Missions Interlink have to accept a set of standards, the introduction to which includes this statement:

Is LI responsive to feedback?

  • When sent a draft of this review, on 21 June 2017, they…did not respond.
  • 2018 review: They did not respond to a draft of this review.

Is it registered?

  • As a charity, yes.
  • Other registrations:
    • As a public company, a company limited by guarantee.
    • LI does not have the necessary provisions in its Articles of Association to allow it to omit ‘Ltd/Limited’ at the end of its name.
      • Their website suggests that maybe they are not always complying with this.
    • LI operates – according to the ACNC Register – only in Queensland. It has a fundraising licence there.
      • The extent to which, after exemptions, it is required to have one in the other six (2018 review: five) states that have a licensing regime depends on whether those states interpret LI’s request for money on its website as fundraising.

What do they do?

  • See here on the website.
  • This ‘News’ is more specific and later than what is given in the Activities section in the Annual Information Statement (AIS) 2016.
  • 2018 review:
    • From the Register:
      • Our activities and outcomes helped achieve our purposes by providing education and food to the very underprivileged and needy children in Africa.
    • AIS 2017:
      • ‘Providing financial assistance for the running of Love International School, Natkiri, Mozambique’
    • The ‘News’ above is still the latest.

Do they share the Gospel?

  • No information found.
    • The sixth and seventh (of eight) ‘principal objects’ in the Memorandum of Association (part of the ‘Governing document’ on the ACNC Register), are about advancing the Gospel.

What impact are they having?

  • Nothing found.

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

  • LI claims that
    • …100% of your donation will go to the persons or project concerned.  We do not use your donation to fund administrative costs.  Everything is done on a voluntary basis…
    • How does this fit with the fact non-gift revenue is less than ‘Other expenses/payments’? That ‘Grants and donations made…’ are not 100% of donations and bequests received? And that ‘Grants and donations made…’ are significantly less than gifts received?
    • 2018 review: If there are no deductions from your donation, how is the charity run?

Can you get a tax deduction?

  • No

Is their online giving secure?

  • NA

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

  • None

Is their reporting up-to-date?

  • Yes (four months after their year-end).
    • But if you are considering a large donation, I would ask for more up-to-date financial information – the accounts are for a year end that is now nearly a year ago.

Does their reporting comply with the regulator’s requirements?

  • AIS 2016: Almost – no outcomes are reported (ditto AIS 2017).
  • Financial Report 2016: Yes (ditto 2017)
    • Its small size means that LI is not required to submit a financial report to the ACNC.
    • LI declares its membership of Missions Interlink (confirmed here):
      • Love International is a member of Missions Interlink, a prominent and well respected organisation in Australia representing colleges, aid and missionary organisations.
      • This membership requires LI to ‘have available for its members and supporters a clear and appropriate financial statement which has been approved by its auditor[iii]. Last year I asked for this statement but didn’t get a reply. I didn’t bother this year.

What financial situation was shown in that Report?

  • NA
    • The AIS 2016 [and 2017] shows no liabilities.

What did the auditor say about the last financial statements?

  • NA
  • 2018 review: An audit should have been done, but it does not have to be lodged with the ACNC.

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

  • Yes
    • ‘Phone’ and ‘Website’ are blank, but neither are compulsory.

Who are the people controlling the organisation?

  • Not shown on the website.
  • These people on the ACNC Register (under ‘Responsible persons’):
    • Tracey Jones
    • Donald Stewart
    • Olivia Stewart
    • Unless the members have, under clause 34 of the Articles of Association changed the composition of the board, it is (still) two members short.
    • Given that Donald and Olivia appear to be a couple, it is questionable wisdom to have a couple as directors of a charity that seeks public money when there are only three directors in total.

To whom is LI accountable?

  • To Missions Interlink.
  • Also to the ACNC, and, for some things still, ASIC (2018 review).

 

 

  1. Even though they do not meet the “in Australia” test and do not have deductible gift recipient status.