PeaceWise Ltd: charity review

Charity review of PeaceWise Ltd (PeaceWise[1]), an organisation that seeks donations online, and is accredited with the CMA Standards Council (a ‘Foundation Partner’). (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

Are they responsive to feedback[2]?

  • There is a PeaceWise ‘Complaints Policy’ on the website.
  • I sent them a draft of this review on 2 January. They responded the next day, requesting a month’s extension. Two days before the due date, they asked for another few days. When they responded on 9 February with comments, I agreed to a few changes and gave my reasoning for not making others. Unfortunately, despite a 14 February follow up request for what they wanted published, they have not responded. Apart from the correction of errors, I have therefore only included their comments where I told them that I would.

Is PeaceWise registered?

  • As a charity, yes.
  • PeaceWise is a public company, a company limited by guarantee.
    • It is not permitted to omit ‘Limited/Ltd’ at the end of its name. As it does on its website and in social media.
  • It has one business name, Peace Wise.
    • The Register shows PeaceWiseKids as a name they are known by. It is not registered.
      • PeaceWiseKids has its own website, but no ABN.
  • PeaceWise has four trademarks, ‘Peacewise’, ‘Peacewisekids’, and the two logos you see on its website.
  • The ACNC Register says that PeaceWise operates all over Australia. And it seeks donations on the internet.
    • It has fundraising licences in New South Wales, Queensland and Tasmania. There are three other states that have a licensing regime applicable to charities. PeaceWise does not explain why it thinks that it doesn’t need a licence in those states.
      • Ministry comment: PeaceWise has not registered in other states because of the statutory definitions of the entity or activities covered by the state or because of various exemptions such as the thresholds for minimum donations within the particular state.’
    • Whether or not it uses street collectors is not disclosed.
      • Ministry comment: PeaceWise does not use street collectors.’
  • PeaceWise operates overseas, per the ACNC Register, only in New Zealand.

What do they do?

  • See here.
  • The ‘Annual Report from PeaceWise Chair Jeroen Bruins’, combined with the Directors’ Report (Financial Report 2016, below), gives a good insight into what PeaceWise does.

Does PeaceWise share the Gospel?[3]

  • Some of their work allows them to do this.
    • Ministry comment: ‘We ask you to correct this. We consider that the correct answer should be “Yes: its website and newsletters are full of the Gospel. Its training is based on the Gospel. Its statement of beliefs in its constitution is unashamed mainstream Christian. Whilst its activities may not be equivalent to a Gospel sermon, this organisation is, in Gospel terms, way beyond a mere good living and social concern charity. I am informed by PeaceWise that: “Our peacemaking teaching and training is based on biblical principles and very clearly focused on and following the teachings of Jesus, the Gospels and NT. We help people in conflict to reconcile with God and those they are in conflict with. This often requires repentance, confession and seeking forgiveness to the ones they are in conflict with. This can only be done on the basis of the Gospel and the saving sacrifice of Jesus. Reconciliation is the heart of the Gospel and comes clearly through in our ministry.’

What impact are they having?

  • In the Directors’ Report, the directors say that
    • Performance in non-material (sic) terms relates to how many lives are impacted by the hope-giving work of the ministry, how many relationships are restored, how many people draw closer to Jesus, how many people learn to deal better with conflict in their marriages, workplaces, families and other contexts. This non-material aspect of ministry is more difficult to measure but vitally important.
  • If these things were measured, the results are not reported.
    • Ministry comment: (What they wanted me to add to the above) ‘However, the Chairman’s Report describes in extensive detail many examples of the impact the ministry is having in these areas.’
  • Regular program evaluations are required by the accreditation held with the CMA Standards Council (Standard 5.6). Evaluation is not mentioned on the website.
    • If evaluations are new to PeaceWise, we might not see one for three years (the CMA standard).

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

  • The expenses are not classified in a way that allows the calculation of this figure.

Do they pay their board members?

  • This is permitted by the constitution.
  • It is not possible to tell from what PeaceWise have published whether they have taken advantage of this ability.
  • If they are paying these members, they are contravening the CMA Standards Council requirements (Standard 3.7).
    • Ministry comment: (What they wanted me to say instead of the above) ‘Their last annual report discloses that their CEO is remunerated $36,000 per annum. I am informed that Board members are all volunteers and are not paid. The National Director (CEO), through a company, consults part time for the ministry and receives financial compensation for his managerial role as CEO. He is a board member, but not paid for this role. The services of the CEO are provided by a contract from Burgess Consultants Pty Ltd, a consulting firm which provides services to a large corporate for the remainder of the CEO’s time each week.’

Can you get a tax deduction?

  • No

Is their online giving secure?

  • Comodo is used, so yes.

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 nearly 14 months ago.

Does their reporting comply with the regulator’s requirements?

  • Annual Information Statement (AIS) 2016: No
    • Why is ‘National Director Fees’ ($36K) omitted from ‘Employee expenses’?
    • The ‘Description of charity’s activities and outcomes’ does not describe 2016’s activities[4].
    • Outcomes are not mentioned.
  • Financial Report 2016[5]: No.
    • Income Statement:
      • The directors declare that one of their aims is to produce a surplus, yet there is no reason given for the second substantial deficit in a row, nor what they are doing about it.
      • There is no information about the sizeable grant that was received (31% of revenue).
      • 43% of the expenses are included in the single item ‘Other expenses’.
      • ‘National director fees’ are, without explanation, not included in ‘Employee benefits expense’.
      • There is no explanation of the item ‘Consumables used’, 23% of expenses.
    • Statement of Financial Position:
      • There is no information about their role as a trustee (‘Cash and cash equivalents’).
      • 7% of the assets are in ‘Patents and trademarks’. But there is no policy Note on intangibles, so there is no defence that the figure recorded for the four patents it holds is not an overstatement.
      • ‘Inventories’ are 12% of the assets, yet there is no description and no policy Note.
      • 76% of the liabilities ($63K), three funds and a project, are questionable as liabilities. There is no Note explaining the items.
      • The information for current liabilities in the Statement of Financial Position does not match the Notes.
    • Notes to the Financial Statements:
      • The item ‘Unearned Income ($44K) in the ‘Reconciliation of cash flow… (Note 11), does not match anything in the Statement of Financial Position.
      • Many of the Notes normally included in Note 1 are missing.
      • The is no information on related parties.
    • There is no reference to the ACNC Act in either the Directors’ Declaration, or the Independent Auditor’s Report.
    • Two required lines in the Statement of Changes in Equity are missing.
    • PeaceWise values feedback, and its display of the CMA Standards Council seal implies thatthe organisation takes governance, accountability and stewardship seriously’, so, in addition to the suggestions flowing from the above points, plus other sections of this review, you might also ask about this decision:
      • The directors have chosen (without giving their reasons), to produce the lower disclosure special purpose financial statements. This is instead of the type of statements that is appropriate if stakeholders need regulatory intervention to ensure that they get the information they need to make decisions. With a range of people and organisations contributing revenue, a request for funds from the public, and operations all over Australia (including ‘regional ministry coordinators’ in four states), it is difficult to see how PeaceWise would be comfortable with supplying a tailored financial report to any stakeholder that asked for one.
    • Because of the above not immaterial issues, it is arguable that the financial statements are not ‘complete and accurate’, and therefore PeaceWise is not complying with Standard 6.1 of the CMA Standards Council standards (see above).
      • Ministry comment: (What they wanted me to write). ‘PeaceWise has advised me that they have asked their auditor to consider these points.’

What financial situation was shown by that Report?

  • Despite an aiming ‘to finish each year with a surplus rather than a deficit’ (Directors’ Report), last year’s deficit was repeated.
    • It is, however, slightly less as a percentage of revenue (negative 13% to negative 11%).
  • Employee benefits was 28% of expenses (down from 34%).
    • But as a measure of payments for labour, it does not include what was paid to the National Director.
  • Current assets as a multiple of current liabilities (working capital) declined markedly from 3.6 times to 2.0 times.
  • With zero non-current liabilities, $14K of long-term assets is sufficient.

What did the auditor say about the last financial statements?

  • The auditor, John Stephens F.C.A., for Omniwealth Accounting & Audit, issued a ‘clean’ opinion.
  • However, before you decide how much comfort to take from this opinion, I suggest you read again the ‘Financial Report 2016’ section (above).

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

  • Yes

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

  • ‘where it’s needed most’
  • ‘kids project – peacewisekids’
  • ‘help build new adult courses’

Where were your (net) donations sent?

  • NA

Who are the people controlling the organisation?

  • The people shown here.
  • The ACNC Register (under ‘Responsible Persons’) is missing John Hollier and Deborah Bensted:
  • The board is responsible to the membership. The number of members is not disclosed.
    • Ministry comment: ‘The Board is the membership – there are no other members.’

To whom are PeaceWise accountable?

  • As a charity, to the ACNC.
    • Its ‘Charity Tick’ is used on the website in support of you giving to them.  And rightly so, because it would be unwise to give to a charity that is unregistered.   The ‘tick’ also means Peacewise’s AIS is not overdue, and the ACNC has not taken any compliance action against it.
  • PeaceWise has gone beyond the charity tick and achieved accreditation with the CMA Standards Council. It is therefore entitled to display their seal – see the right-hand side of each page. For this is must abide by the Council’s  Principles and Standards of Responsible Stewardship.
  • PeaceWise is also accountable for some things, as a company, to ASIC.
  • Ministry comment: ‘As a Christian Charity (sic) we believe we are also accountable to God.’

 

 

  1. The name on the ACNC Register is incorrect. It is ‘PeaceWise Ltd’, not ‘Peacewise Ltd’ [edited 12.03.18].
  2. 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].
  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.
  4. Given that this is in an ‘Annual Information Statement’, it is not unreasonable to think that the ACNC expects a description of what the charity did in the year that is the subject of the Statement, not just a description of what it does generally every year.
  5. I use the Pinnacle Financial Statements, respected in the profession as providing a very sound basis for producing compliant financial reports. To this I add an assessment of materiality (both quantitative and qualitative), where the users being considered are donors.

Hillcrest Christian College Limited: mini-charity review

Mini-charity review of Hillcrest Christian College Limited (HCC), an organization that is connected, through the cross directorship of Jame Lewis, to the CMA Standards Council, a body that accredits those organisations who pass its ‘Nine Principles of Ministry Accountability’. HCC is not accredited.

(Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

Are they responsive to feedback?

  • HCC does not invite feedback and complaints from other than students, parents and employees.
  • I sent them a draft of this review. They…did not respond.

Is HCC registered?

  • As a charity, yes.
  • HCC is a public company, a company limited by guarantee[1].
  • Although it does not have the provisions in its constitution to allow it to omit ‘Ltd’/‘Limited’ from the end of its name, it has Hillcrest Christian College registered as a business name.
  • HCC operates – according to the ACNC Register – only in Queensland.
  • Although it conducts fundraising, it doesn’t have a licence. Perhaps it believes that it is because it is a religious order, or because all fundraising is done by a parents and citizens association (two of the exemptions)?

What do they do?

  • See the video on the homepage, then ‘Our College’ in the main menu.

Do they share the Gospel?[2]

  • Yes. One of HCC’s ‘Cornerstones’ is ‘Evangelistic Outreach’:
    • The first cornerstone of the foundation is our belief that the College has a spiritual ministry to its students and an evangelistic outreach into the community. The most important subject that is taught every day is God and the most important book that is used is the Bible.

Our objectives are to be good stewards of the time that the Lord has given us, to minister to the children in the college, to bring each child to a personal saving knowledge of Jesus Christ, and to train them in the fundamental truths of the faith.

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?

  • With $18.79 m expenses divided into only three figures (see below), there is no way of even estimating this.

Do they pay their board members?

  • This is not prohibited by their constitution.
  • There is insufficient disclosure of the expenses to check for a payment.

Can you get a tax deduction?

  • Not to HCC, but the ABN record says that you can if you donate to either of its two funds, Hillcrest Christian College School Building Fund, or Hillcrest Christian College Ltd Foundation Scholarship Fund.
  • From the lack of mention on the website, though, it appears that neither are active.

Is their online giving secure?

  • NA – not offered.

Is their reporting up-to-date?

  • Yes (four months after their year-end; ten days earlier than last year).
    • But if you are considering a large donation, I would ask for audited financial statements (see below), and more up-to-date financial information – the accounts are for a year end that is now over 13 months ago.

Does their reporting comply with the regulator’s requirements?

  • AIS 2016: No
    • ‘Type of financial statement’ and ‘Financial statement consolidated with more than one entity?’ are blank. Or is that a consequence of the ACNC’s special treatment of non-government schools (see below)?
    • No outcomes are given.
  • Financial Report 2016: Yes
    • The Register says that one was lodged but in fact it is a single sheet produced by the ACNC, not HCC, that says
      • The ACNC receives financial information for this school from the Department of Education and Training and publishes it in Section E: financial information of the Annual Information.
    • So not only no financial statements but no audit report. And this for a charity with revenue of $22.14 m. Contact the school if you want more.

What financial situation was shown by that Report?

  • From the AIS 2016 (see above):
    • From government: $12.52 m.
    • Total revenue: $22.14 m.
    • Employee expenses: $12.35m. 66% of expenses.
    • Interest: $334K. 2% of expenses.
    • Surplus: 15% of revenue. Why is it this high?
    • Current liabilities are 1.4 times current assets. Not so good.
    • No non-current loans – why then the interest paid?
    • Long-term financial structure, because of $30.08 m in non-current assets (presumably mostly land and buildings), is sound.

What did the auditor say about the financial statements?

  • NA. The system of reporting for non-government schools like HCC effectively says to you, ‘Trust me’.

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

  • Almost. ‘Phone’ and ‘Website’ are blank. (Neither are compulsory.)

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

  • NA – none sought

Where were your (net) donations sent?

  • NA

Who are the people controlling the organisation?

  • The website says these people.
    • The introduction to the list says that there should be seven members, but then lists eight.
  • The ACNC Register (under ‘Responsible Persons’) has the addition of Jame Lewis, and doesn’t have Nadine Harvey and Alan King.
  • The directors are responsible to the members of the association. The constitution provides that they must be members of Reedy Creek Baptist Church. The number of members is not disclosed, so we cannot assess the accountability possible via the members.
  • It’s an unusual board though – itfollows a Carver Model of Governance.’

To whom are HCC accountable?

  • HCC does not mention accountability on its website.
  • It gets government funding, so there is accountability there.
  • As a charity, it is accountable to the ACNC.
  • As a company it is accountable to ASIC.

 

 

  1. Not, as they say on the ABN record, an ‘Other Incorporated Entity’.
  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.

Gateway Baptist Church: mini-charity review

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

  • GBC has a ‘Complaints & Feedback Policy’, a requirement of its partnership with the CMA Standards Council. One of the ‘five key elements’ of this policy is ‘Principles’:
    • Our complaints and feedback system is modelled on biblical principles, including humility, fairness, accessibility, responsiveness, efficiency and integration.’
  • I sent them a draft of this review. Like last year, they…did not respond.

Is GBC registered?

  • As a charity, yes.
    • I can’t see a a ‘not-for-profit’ clause in the constitution. If this is the case, then this is unusual, and surprising. Every registered charity should have one, and it is an explicit requirement of the CMA Standards Council.
    • The registration is in the name Gateway Baptist Church Ltd because it is permitted to trade without ‘Limited/’Ltd’ at the end of its name.
    • Not to be confused with Gateway Baptist Church (GBC-old), the charity that was the church before GBC took it over. GBC’s first object in its constitution is
      • To incorporate and continue the ministry and activities of the unincorporated church known as Gateway Baptist Church ABN 25 025 137 207 and to take over its assets and undertakings on and from the date of incorporation hereof.
        • GBC was incorporated on 11 August 2015, but did not begin trading until 1 May 2016 (Directors’ report).
    • Also, not to be confused with Gateway Baptist Church And Community Centre.
      • Especially as GBC has a fund called the Gateway Community Fund (see below).
  • GBC has two other Australian wholly-owned subsidiaries:
    • the charity Bloom Asia Inc. (BAInc) (registered in 2012)
    • the charity Bloom Asia Ltd (BALtd) (registered in June 2016)
      • Because GBC still has not taken advantage of the ACNC’s group reporting concessions, these charities, and GBC-old, must report separately.
  • Other registrations:
    • As a public company, a company limited by guarantee.
    • Only one of the four charities holds a business name: BAInc has Bloom Creations Australia.
    • GBC does not have a fundraising licence in the state, per the ACNC Register, in which it operates[1].
    • BALtd: licensed to fundraise only in Queensland.
    • BAInc: no fundraising licences.
    • GBC-old: no fundraising licences.

What does it do?

  • GBC: other than obviously being a church, there’s no direct statement saying what it does; its activities are shown here.
  • GBC-old: replaced by GBC.
  • BAInc: no website; its Annual Information Statement 2016 (AIS 2016) says the same as last year: ‘As a Christian ministry aligned with Gateway Baptist Church, raised funds and awareness of charity work in Cambodia’.
    • There are no countries listed under ‘Where the Charity Operates’ on the ACNC Register.
  • BALtd: See here.

Do they share the Gospel?[2]

  • GBC: Yes
  • GBC-old: NA (replaced by GBC).
  • BAInc: No information available.
  • BALtd: No mention of the Gospel, Jesus or Christ on the website; tax deductibility (see below) would suggest that it doesn’t share the Gospel.

What impact are they having?

  • GBC:
    • Nothing systematic found. (The Directors’ Report, under ‘Key performance measures’, reports 40 baptisms.)
    • The terms of GBC’s accreditation with the CMA Standards Council require it to perform regular program evaluations. There is no mention of evaluation on the website.
  • GBC-old: No information found.
  • BAInc: No information found.
  • BALtd: No information found.

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

  • GBC: This is not disclosed, and the classification of the expenses does not permit an estimate.
  • GBC-old: Because it is a ‘basic religious charity’, no financial information has to be submitted to the ACNC.
  • BAInc: All expenses were classified as ‘Other expenses/payments’ in the AIS 2016 (no Financial Report 2016 required because of its size).
  • BALtd: Their ‘effective date’ of registration (on the ACNC Register) is 28 June 2016. With a 31 December year-end, the ACNC does not require such a charity to report until the following year.

Do they pay their board members?

  • The constitution does not prohibit such payments.
    • They are, however, prohibited under the terms of GBC’s accreditation with the CMA Standards Council [Standard 3.7].
  • Whether they were made is not disclosed.

Can you get a tax deduction?

  • GBC: No
  • GBC-old: NA (replaced by GBC).
  • BAInc: No
  • BALtd: No
  • Both GBC and BALtd are able to offer tax-deductibility for ‘Bloom’ because they are collecting for a project run by Global Development Group, a secular overseas aid and development organisation.
  • But nowhere is there an explanation for their ability to offer tax-deductibility for an entity that doesn’t even have an ABN, Gateway Community Fund.
    • This contravenes Standard 9.1 of the CMA Standards Council Standards.

Is their online giving secure?

  • GBC: Online giving is offered for five of the six choices. All five use PayPal, so yes, giving is secure.
  • GBC-old: NA
  • BAInc: NA – not offered.
  • BALtd: PayPal is used, so yes.

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

  • GBC:
    • General giving – Mackenzie campus’
    • ‘General giving – Ormeau Campus’
    • Gateway Beyond’
    • ‘Bloom (tax-deductible)’
    • ‘Gateway Community Fund (tax-deductible)’
    • ‘Call to Build Giving’ (not an online option)
  • GBC-old: NA
  • BAInc: No website
  • BALtd:
    • Donate (Without a Tax Receipt)’
    • ‘Donate (AUS – Recurring Gift) (tax-deductible)
    • ‘Donate (AUS – Single Gift) (tax-deductible)
    • ‘Donate (With Tax Receipt USA)’

Is their reporting up-to-date?

  • GBC: Yes (four and a half months after their year-end)
  • GBC-old: Yes (four and a half months after their year-end, a month earlier than last year).
  • BAInc: Yes (six months after their year-end, a week later than last year).
  • BALtd: Yes (none has been required yet).

Does their reporting comply with the regulator’s requirements?

  • GBC:
    • AIS 2016: No.
      • No activities or outcomes are disclosed.
      • ‘Other income’ does not match the financial statement.
      • Surely for a large church ‘Grants and donations…’ is not zero?
    • Financial Report 2016: Questionable
      • GBC acknowledge that GBC-old (the ‘Unincorporated Church’) and BALtd are wholly-owned subsidiaries (Not 16), so why aren’t they consolidated, i.e., included with the GBC figures?
      • Why no mention of the other subsidiary, BLInc?
      • Working capital – current assets less current liabilities – is negative by $235K, yet the directors make no comment on this threat to the going concern assumption.
      • ‘Building fund donations’ are just as much donations as the others. Classifying them as ‘Other income’ therefore understates revenue $403 K.
      • ‘Donation of assets from unincorporated church’ is, as they state elsewhere, part of revenue. It should therefore be included in revenue.
      • Similarly with ‘Finance income’.
      • Note 8 shows the entire net assets received from GBC-old as a non-cash item. How does this fit with the fact that $1.26 m cash is shown in the Statement of cash flows as ‘Donation of cash by unincorporated Church’?
      • A mixed classification of expenses is confusing. (That’s why it is not permitted.)
      • ‘Missions support expenses’, 21% of the total, is unexplained.
      • They say that the receipt of $20 m odd net assets from another entity during the year is a not a ‘significant change’ to GBC’s ‘state of affairs’ (paragraph 5 of the Directors’ Report). I disagree.
      • Having a line item ‘Operating expenses’, for 9% of the total, in a list of operating expenses, says nothing about the nature of that expense.
      • The product that was sold, generating $300K, is not disclosed.
      • The entire charity is a ministry, so what is ‘Ministry income’?
      • How was it that ‘Interest income’ was exactly $8K?
    • Even if the above issues don’t render the Financial Report non-compliant with ACNC’s requirement for ‘a true and fair view’, GBC’s partnership with the CMA Standards Council commits it to the transparency and accountability implied in 2 Corinthians 8:20, and that makes the issues relevant.
    • Because of the above issues, it is questionable whether GBC’s 2016 financial report is compliant with the CMA Standards Council Standards.
  • GBC-old:
    • AIS 2016: No.
      • Neither activities nor outcomes are disclosed.
      • It says that nothing will change in 2017, but if it doesn’t cease to exist it will be nothing like the organization it was up until May 2016.
    • Financial Report 2016: As a ‘basic religious charity’, they weren’t required to submit one. Nor include financial information in the AIS.
  • BAInc:
    • AIS 2016: Not quite – no outcomes are given, and the business name is missing.
    • Financial Report 2016: NA – none required (because of their small size).
  • BALtd:
    • AIS 2016: NA – because they only started in June 2016, not required yet.
    • Financial Report 2016: NA – as for the AIS.

What financial situation was shown in that Report?

  • GBC:
    • Working capital is negative. There is only 80 cents of current assets for every dollar of current liabilities.
    • Long-term financial structure, because of the land and buildings inherited from GBC-old, is sound.
  • GBC-old: NA
  • BAInc: NA. The AIS 2016 shows a surplus of $10K on $20K turnover, and assets and equity of $22K.
  • BALtd: NA

What did the auditor say about the last financial statements?

  • GBC:
    • The auditor, Daniel Gill, for Pilot Partners, gave a ‘clean’ opinion.
      • Not critical to the opinion, but relevant to your confidence in it:
        • He defines the information – ‘the other information’ – that he did not audit by reference to the ‘Company’s annual report’. But there is no annual report.
        • He incorrectly says that GBC’s reporting is defined by the Corporations Act 2001. It should be the ACNC Act.
    • Before you decide how much comfort to take from this opinion
      • Read the ‘Financial Report 2016’ section, above, and
      • Read about audit opinions here and here.
  • GBC-old: NA
  • BAInc: NA
  • BALtd: NA

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

  • GBC: No
    • No countries shown under ‘Where the Charity Operates’.
  • GBC-old: No
    • No countries shown under ‘Where the Charity Operates’.
    • ‘Phone’ and ‘Website’ are blank, but the ACNC says these are not compulsory.
  • BAInc: No
    • An ‘Entity Subtype’ has not been selected.
    • The business name is missing.
    • Email’, ‘Phone’, ‘Website’ are blank, but the ACNC says these are not compulsory.
  • BALtd: Almost – the Secretary has been included as a ‘responsible person’.

Where were your (net) donations sent?

  • NA

Who are the people controlling the organisation?

  • GBC:
    • The ‘Board of Elders’ is still not shown on the website, but
    • These are the people declared to be ‘responsible persons’ (on the ACNC Register):
      • David Angell
      • Paul Bakes
        • Is it this Paul Bakes?
      • Anne Cock
        • Is it this Anne Cock?
      • Megan Cocker
      • Jason Elsmore
      • Matthew Gray
      • Joshua Hanna
      • Derek Peters (a GBC executive)
      • Andrew Ross
      • Trevor Shinners
        • Is it this Trevor Shinners?
    • The board is responsible to the members. There were 590 members at 31 December 2016.
  • GBC-old:
    • Not shown on the GBC website.
    • The same people as for GBC are shown as ‘responsible persons’ (on the ACNC Register):
  • BAInc: From the ACNC Register:
    • David Angell (see above)
    • Derek Peters (see above)
    • Glenn Valentine
      • Is it this Glenn Valentine?
  • BALtd:

To whom is the charity accountable?

  • GBC:
    • As a charity, to the ACNC.
    • As an organisation accredited with them, to the CMA Standards Council.
    • To Missions Interlink via their Associate membership.
      • For one opinion on the strength of that accountability, see the section Activities in this review.
    • As a company, to ASIC.
  • GBC-old: To the Queensland associations regulator.
  • BAInc: To the ACNC and the Queensland associations regulator.
  • BALtd: To the ACNC, and to the companies’ regulator (ASIC).

 

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

Scripture Union Queensland: mini-charity review

Mini-charity review of Scripture Union Queensland (SUQ), an organisation that seeks donations online, and is accredited with the CMA Standards Council[1]. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

Are they responsive to feedback[2]?

Is SUQ registered?

  • As a charity, yes.
    • It has a subsidiary, Body Corporate for Hope Central. No ABN could be found for this entity.
  • SUQ is a public company, a company limited by guarantee.
  • It has many business names.
    • None are disclosed on the ACNC Register.
    • Only one, School Chaplaincy A.C.T., is disclosed on Australian Business Register.
  • Although it is permitted to omit ‘Limited/Ltd’ at the end of its name, it has no licence to trade under other than Scripture Union Queensland. The website and its social media pages contravene this.
  • It has no trademarks.
  • SUQ operates in Australia, per the ACNC Register, in Queensland and the Australian Capital Territory. It seeks donations on the internet, both on its own site, and on others (Good Company, Pro Bono Australia, Everyday Hero, and others?)
    • Whether or not it uses street collectors is not disclosed.
    • It only has a fundraising licence Queensland. There are five other states that have a licensing regime applicable to charities. SUQ doesn’t explain why they have only one licence.
  • SUQ, per the ACNC Register, does not operate overseas.

What do they do?

Does SUQ share the Gospel?[4]

  • Yes – but they are not meant to in the Chaplaincy program:

  • In the three years to 2013, complaints of proselytising were few:
    • The national rate is 13 complaints of proselytising per annum (three year average). With 2,900 schools having chaplains, the rate of proselytising complaints is 0.4 per cent per annum, and has been declining year on year. In 2013, there was one complaint nationally[5].
  • SUQ is required, by its accreditation with the CMA Standards Council (Standard 1.2) to have a statement of faith. There isn’t one on the website, nor is there a ‘What we believe’ section.

What impact are they having?

  • Nothing systematic found.
  • Standard 5.6 of the CMA Standards Council standards (see above) requires that regular program evaluations must be performed. There is no mention of these on the website.

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

  • SUQ says that 84% goes to ‘Programs’. By deduction this is ‘Chaplaincy expenses’ and the undefined ‘Ministry expenses’. The Financial Report 2016 does not have a sufficient level of disclosure to say whether there is any ‘administration’ in these two expenses.

Do they pay their board members?

  • The SUQ governing document does not permit this.
  • Note 10 says that they are not paid.
  • Expenses are not disclosed at a level that allows one to check for a payment.

Can you get a tax deduction?

  • The ABN record shows that you can claim a tax deduction for a donation both to SUQ and to its fund, Scripture Union Queensland Schools Ministry Fund.
    • The ‘Choose where my gift goes’ page, however, distinguishes between those causes that are ‘tax-deductible’ and those that aren’t.

Is their online giving secure?

  • They say, below the fold on the ‘Donate’ page, that ‘Your credit card details are never stored with us. They are sent straight to our payment processor over a highly secure connection.’ The name of the provider is not given.

Is their reporting up-to-date?

  • Yes (lodged four and a half months after their year-end, two months later than last year).
    • But if you are considering a large donation, I would ask for more up-to-date financial information – the accounts are for a year end that is now over 12 months ago.

Does their reporting comply with the regulator’s requirements?

  • Annual Information Statement (AIS) 2016: No
    • The financial information is for the group, not SUQ.
    • It incorrectly says that there is no consolidation of entities.
    • ‘Other Income…’ and ‘Employee expenses’ are incorrect.
    • The business names are omitted.
    • Outcomes are not mentioned.
    • Is it really the case that there are exactly 500 full time and 200 part time employees?
  • Financial Report 2016[6]: Yes.
    • But SUQ is ‘transparent and accountable to its stakeholders’, so here’s some changes that would result in a clearer picture of performance and position:
      • Disclose basic information on the subsidiary, Body Corporate for Hope Central [Note 19].
      • There is no other mention of this entity in the Financial Report, nor on the website.
      • There are only two incidental mentions of ‘Hope Central’ on the website. (A Google search reveals that it is the name of the building they occupy in Brisbane.)
      • Why no ABN?
      • This entity has negative equity (Note 20)?
      • Include all the disclosures required by the Accounting Standards for the Consolidated Statement of Comprehensive Income.
      • Likewise, the Consolidated Statement of Changes in Equity.
      • Separate ‘Other income’ from ‘Revenue’.
      • Although ‘Other income’ is only 4% of revenue, it would be interesting to know what is included in this $1.41 m.
      • Disclose fundraising expenses.
      • Use one of the two expense classifications allowed by the Accounting Standards, not a mixed classification.
      • Explain the major expenses, including ‘Marketing expenses’ and ‘Ministry expenses’ (the entire charity, as a ‘Christian’ charity, is a ‘ministry’.)
      • Disclose information about related parties. (There is only a Note on ‘Controlled entities’.
      • For instance, what is the relationship between SUQ and Scripture Union Australia? (it owes $145K).
      • Distinguish between ‘Objectives’ and ‘Principal activities’ in the Directors’ Report (and report on both).
      • Give a breakup of ‘Ministry Reserves’ (so that donors + know the purpose of retaining some of the profits for the future).
      • The fact that they can ‘appropriately manage and track chaplaincy and other ministry reserves internally’ is not relevant to a decision about whether to disclose information to stakeholders – external reporting should not be a management tool for an organisation of SUQ’s size and complexity.
      • It would be helpful if we knew how many ‘key management personnel’ shared the $619K.
      • Remove ‘Workers compensation insurance’ from the figure for employee benefits [Note 3].
    • Because of the above not immaterial issues, it is arguable that the financial statements are not ‘complete and accurate’, and therefore Arrow is not complying with Standard 6.1 of the CMA Standards Council standards (see above).

What financial situation was shown by that Report?

  • Surplus as a percentage of revenue increased from negative 10% to a little over zero positive.
  • ‘Cash and cash equivalents’ represents approximately two months of revenue.
  • Employee benefits was 77% of expenses.
  • Current assets as a multiple of current liabilities (working capital) was maintained at a positive 1.8.
  • With only $744K of non-current liabilities, long-term financial structure is, based on this report, sound.

What did the auditor say about the last financial statements?

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

  • No[7]
    • It is long overdue in selecting an ‘Entity Subtype’.
    • ‘Other Name(s)’ is missing the 11 business names.

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

  • ‘Where it’s most needed’
  • Two long lists under ‘Choose where my gift goes’, one for tax deductible projects the other for non-tax-deductible projects.

Where were your (net) donations sent?

  • There is no disclosure beyond ‘Chaplaincy expenses’ ($22.70 m) and ‘Ministry expenses’ ($4.68 m).

Who are the people controlling the organisation?

  • The people shown here.
  • The ACNC Register (under ‘Responsible Persons’) has two additional names, Sally-Ann Davis and Storme Vunderink:
  • There are eight (8) charities with a Ruth Limkin as a board member. Her LinkedIn profile says that she is also a director of Christian Super and, although not shown as a responsible person, Northside Christian College. So that’s at least ten directorships.
    • Seven of them belong to Bible Society Australia. (The only member of the Bible Society Australia_ACNC Group for which she is not a board member is Centre for Public Christianity.)
    • But the register only covers charities, not all not-for-profits, and of course doesn’t include for-profit organisations.
    • Therefore, if after eliminating the charities for which SUQ’s Ruth Limkin is not a director, you are left with the total being more than a handful, it would be legitimate for you to question whether her ability to discharge her fiduciary responsibilities is threatened.
  • The quorum for a board meeting does not meet the requirements of SUQ’s accreditation with the CMA Standards Council (Standards 3.2, 3.3).
  • The Board is responsible to the membership. When last disclosed (30 June 2016, Directors’ Report), there were 94 members.

To whom are SUQ accountable?

  • As a charity, to the ACNC.
    • Its ‘Charity Tick’ is used on the website in support of you giving to them.  And rightly so, because it would be unwise to give to a charity that is unregistered.   The ‘tick’ also means SUQ’s AIS is not overdue, and the ACNC has not taken any compliance action against it.
  • SUQ has gone beyond the charity tick, and achieved accreditation with the CMA Standards Council. It is therefore entitled to display their seal – see the website footer. For this is must abide by the Council’s  Principles and Standards of Responsible Stewardship.
  • SUQ is also accountable, as a company, to ASIC.

 

 

  1. SUQ is a Foundation Partner. At the announcement of the Foundation Partners, Steve Kerr, the Executive Director of CMASC, said “Foundation Partner status is tangible recognition and reward for their efforts – these are high quality organisations.” 
  2. 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].
  3. This is a contravention of, if not the letter then certainly the spirit, Standard 8.7 of the CMA Standards Council Standards.
  4. Good living and social concern are important [to the cause of evangelism], but they are not uniquely Christian graces…I’ve met a lot of fine Hindus, Muslims and atheists. Just living the life is not going to bring someone to Christ. There is much more to it than that. We must help people, certainly, but we must also share with them why we are motivated to do so. We must stand against injustice, poverty and need, but we must at the same time point to the One who brings justice and who can meet the deepest need. Until they know our reasons, how can they come to know our Lord? [Dan Armstrong, the Fifth Gospel: The Gospel According to You, Anzea Books, pp. 13-14.
  5. This is the footnote to that quote: ‘These are government figures supplied at the Senate estimates hearing on 4 June 2014, reported at http://www.theguardian.com/world/2014/jun/09/ complaints-about-school-chaplaincy-programme-on-the-decline-fi gures-show (accessed 14 June 2014).’
  6. I use the Pinnacle Financial Statements, respected in the profession as providing a very sound basis for producing compliant financial reports. To this I add an assessment of materiality (both quantitative and qualitative), where the users being considered are donors.
  7. This means that SUQ is contravening Standard 2.4 of the CMA Standards Council Standards.

Arrow Leadership Australia Limited: mini-charity review

Mini-charity review of Arrow Leadership Australia Limited, an organisation that seeks donations online, and is accredited with the CMA Standards Council[1]. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

Are they responsive to feedback[2]?

  • I sent them a draft of this review on 4 January, with publication scheduled for 15 January. The Executive Director, Liam Glover, responded on 11 January. This was the substantive part of his response: ‘Thank you for taking the time to alert us to your observations. We will review in due course that which you have raised below.

Is Arrow registered?

  • As a charity, yes.
  • Arrow is a public company, a company limited by guarantee.
  • It has two business names, ILG Group, and Arrow Marketplace Connections.
    • Neither is disclosed on the ACNC Register.
  • Although it is permitted to omit ‘Limited/Ltd’ at the end of its name, it has no licence to trade under other than Arrow Leadership Australia. The website and Facebook page contravene this.
  • It has no trademarks.
  • Arrow operates, per the ACNC Register, throughout Australia. It seeks donations on the internet.
    • Whether or not it uses street collectors is not disclosed.
    • It has no State fundraising licences[3].
  • Arrow, per the ACNC Register, does not operate overseas.

What do they do?

  • See the first section here.
  • These are the programs that give effect to that ‘calling’.
  • Neither ILG Group or Arrow Marketplace Connections, Arrow’s two business names, are mentioned on the website.
  • There’s no annual report this year; next year one will be required because of their accreditation with the CMA Standards Council [Standard 8.2].

Does Arrow share the Gospel?[4]

  • No (they train Christians).

What impact are they having?

  • Nothing systematic found.
  • Standard 5.6 of the CMA Standards Council standards (see above) requires that regular program evaluations must be performed. There is no mention of these on the website.

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

  • The expenses are not disclosed in a way that allows an estimate of this.

Do they pay their board members?

  • The governing document does not permit this.
  • Expenses are not disclosed at a level that allows one to check for a payment.

Can you get a tax deduction?

  • No
    • This is contradicted by the donation page. Here it says that a donation to The Brian Coombs Sponsorship Fund entitles you to a tax deduction. This is because Arrow is collecting for a third party, the charity ‘Annabel Charitable Foundation’ (actually The Annabel Charitable Foundation Ltd or Annabel Foundation).
      • Arrow implies, here and elsewhere, that The Brian Coombs Sponsorship Fund is part of Arrow. Not only is The Annabel Charitable Foundation Ltd an unrelated charity, but the Fund does not even have an ABN. Their representations are therefore contrary to Standard 9.1 of the CMA Standards Council’s standards with which they must comply.

Is their online giving secure?

  • Security is not mentioned.

Is their reporting up-to-date?

  • Yes (lodged six months after their year-end, four days before the deadline, and the same time as last year).
    • But if you are considering a large donation, I would ask for more up-to-date financial information – the accounts are for a year end that is now over 12 months ago.

Does their reporting comply with the regulator’s requirements?

  • Annual Information Statement (AIS) 2016: No
    • The Annual Information Statement (AIS) 2016 does not describe 2016’s activities, as it should, but just describes what Arrow does.
    • The business names are omitted.
    • Outcomes are not mentioned.
  • Financial Report 2016[5]: Doubtful.
    • With donors and participants in events numbering enough to produce revenue of over $1m, and operations throughout Australia, it is difficult to see how the directors could reasonably conclude, effectively, that all stakeholders, both past and prospective, have the capacity to ask the company to produce financial statements tailored to their individual needs.
    • Arrow is committed to “good governance, transparency and accountability” (as recognized by their recent accreditation with the CMA Standards Council), so you might make the following additional suggestions/comments to them:
      • Disclose the arrangement with The Annabel Charitable Foundation Ltd (see above), and the effect on the accounts.
      • Disclose information about related parties.
      • Include a Note on related parties.
      • What exactly was the issue that caused the auditor to qualify the accounts this year?
      • What changes were made, if any, to avoid last year’s qualification?
      • Use one of the two expense classifications allowed by the Accounting Standards, not a mixed classification.
      • Include all the disclosures required by the Accounting Standards for the Statement of Changes in Equity.
      • What was the reason for the prior period adjustment?
      • Include intangibles in the accounting policy Note.
      • Treat ‘Other income’ consistently between the Statement of Income and Expenditure and Other Comprehensive Income and Note 2.
      • Disclose fundraising expenses.
    • Because of the above not immaterial issues, it is arguable that the financial statements are not ‘complete and accurate’, and therefore Arrow is not complying with Standard 6.1 of the CMA Standards Council standards (see above).

What financial situation was shown by that Report?

  • Surplus as a percentage of revenue increased from 2% to 6%.
  • ‘Cash and cash equivalents’ represents 2.6 months of revenue (down from 3.6 last year).
  • Employee benefits was 40% of expenses (up from 37% last year).
  • Current assets as a multiple of current liabilities (working capital) was increased from 1.2 to 1.7.
  • Although there was only 18K of long-term assets, similar liabilities only totalled $4K.

What did the auditor say about the last financial statements?

  • The auditor, Peter Shields, for Saward Dawson, issued a qualified opinion (that is, not a ‘clean’ opinion).
    • Saward Dawson did not audit the previous financial statements. They said that this meant that they were ‘not in a position to express an opinion on the comparatives for 31 December 2015 as we are uncertain as to the extent of the unidentified errors in the 2015 balances and transactions, as well as the effects on the current year’s financial statements.’
    • It appears that this qualification is in response to this requirement in the Australian Auditing Standards:
      • If the auditor concludes that the opening balances contain a misstatement that materially affects the current period’s financial report, and the effect of the misstatement is not appropriately accounted for or not adequately presented or disclosed, the auditor shall express a qualified opinion or an adverse opinion, as appropriate, in accordance with ASA 705 [ASA 501, paragraph 11, www.aasb.gov.au].
    • The previous auditor also issued a qualified opinion. This was the ‘basis’ for that opinion:
      • As is common for organisations of this type, it is not practical for Arrow Leadership Australia Ltd to maintain an effective system of internal control over the collection of donations and other fund raising (sic) activities until their initial entry in the accounting records. Accordingly, our audit in relation to fund raising (sic) was limited to amounts recorded in the accounting records.
  • Silence on a similar deficiency this year means either that Arrow introduced controls over fundraising revenue, or the current auditor has different thresholds for a qualified opinion on this deficiency [ASA 510, paragraph 9, www.aasb.gov.au].

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

  • No
    • ‘Other Name(s)’ is missing the two business names.
    • The Secretary is included as a ‘responsible person’[6].

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

  • ‘Partnership Fund – Have your gift DOUBLED to equip Christian Leaders’
  • ‘Brian Coombs Sponsorship Fund’
  • ‘Arrow Leadership International Development’

Where were your (net) donations sent?

  • Money is collected for three programs. How much is spent on each is not disclosed.

Who are the people controlling the organisation?

  • The people shown here.
  • The ACNC Register (under ‘Responsible Persons’) has one additional name, Amanda Otten:
  • For only one of the directors with a LinkedIn profile, Adam Lowe, is their Arrow role mentioned.
  • As the Secretary, Amanda Otten is not a ‘responsible person’, she should not be included on the Register.
  • There are 171 charities with an Adam Lowe as a board member, and 13 with a Christopher Edwards. But the register only covers charities, not all not-for-profits, and of course doesn’t include for-profit organisations. Therefore, if after eliminating the charities for which Arrow’s Adam Lowe is not a director, and likewise for Christopher Edwards, you are left with the total being more than a handful, it would be legitimate for you to question whether their ability to discharge their fiduciary responsibilities is threatened.
  • The Board is responsible to the membership. When last disclosed (30 June 2016, Notes to the Financial Statements), there were 23 members. Directors are required to be directors (‘Governing document’), so it is effectively 14 people holding the directors accountable.

To whom are Arrow accountable?

  • As a charity, to the ACNC.
  • Arrow was recently accredited by the CMA Standards Council. It is therefore entitled to display their seal – see the website footer. For this right it must abide by the Council’s Principles and Standards of Responsible Stewardship.
  • Arrow is also accountable, as a company, to ASIC.

 

 

 

  1. Arrow is a Foundation Partner. At the announcement of the Foundation Partners, Steve Kerr, the Executive Director of CMASC, said “Foundation Partner status is tangible recognition and reward for their efforts – these are high quality organisations.” 
  2. Arrow do not invite feedback or complaints. This is contrary to Standard 8.7 of the CMA Standards Council’s standards with which they must comply.
  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. “Good living and social concern are important [to the cause of evangelism], but they are not uniquely Christian graces…I’ve met a lot of fine Hindus, Muslims and atheists. Just living the life is not going to bring someone to Christ. There is much more to it than that. We must help people, certainly, but we must also share with them why we are motivated to do so. We must stand against injustice, poverty and need, but we must at the same time point to the One who brings justice and who can meet the deepest need. Until they know our reasons, how can they come to know our Lord?” [Dan Armstrong, the Fifth Gospel: The Gospel According to You, Anzea Books, pp. 13-14.
  5. I use the Pinnacle Financial Statements, respected in the profession as providing a very sound basis for producing compliant financial reports. To this I add an assessment of materiality (both quantitative and qualitative), where the users being considered are donors.
  6. Although there is no specific requirement in the CMA Standards Council standards for the Register to be complete and accurate, there are other requirements that make it an entirely reasonable expectation.

Mount Tamborine Convention: mini-charity review

Mini-charity review of Mount Tamborine Convention (MTC), an organisation that seeks donations online, and is accredited with the CMA Standards Council (CMASC)[1] (a foundation member). (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

Are they responsive to feedback?[2]

  • I sent them a draft of this review. Although they ‘value complaints and feedback as a means of identifying and understanding how we can do things better’, and although their accreditation with the CMASC (above) requires that they ‘respond in a timely and appropriate manner’ to those who submit feedback, I did not get a response.

Is MTC registered?

  • As a charity, yes.
  • MTC is an incorporated entity, incorporated under The Religious Educational and Charitable Institutions Act of 1861.
    • Both its website and the ACNC Register says that it is a ‘basic religious charity’. Although the two most common types of incorporated entities, companies and incorporated associations, are not eligible for this status (and the consequent concessions), the ACNC says that MTC’s type of incorporation does not disqualify it[3]. Is this an oversight in the legislation?
  • It has three business names: Mount Tamborine Convention Centre, Mount Tamborine Conference Centre, and The Beacon on Tamborine.
  • MTC operates, per the ACNC Register, only in Australia, and then only in Queensland. But it seeks donations via the internet. It has a fundraising licence in Queensland, but does not explain why no licence is held in the other states that have a licensing regime.

What do they do?

  • There is no description under ‘About us’ on the website, but the main menu says that they run conventions, and implies that they also offer accommodation and meeting venues for hire.
    • The camping site is only available ‘as part of organised conferences and group camp bookings’, but the chalets are available to rent. It is unclear whether other facilities are similarly available.
  • They promote, on their site, the camps of various other Christian charities. These are within the ‘MTC precinct’. Does this mean that they are on MTC land? The relationship is not explained.
    • One of these other charities is TLF (Triumphant Life Fellowship).
      • There is no such organisation on the ABN register.
      • The link given leads to a seller of domains.
      • In the annual report the CEO reported that
        • ‘In April 2016 discussions began regarding the possibility of working more closely with TLF. This has now blossomed into a symbiotic relationship where MTC now owns and maintains the land and buildings, with TLC operating as a ministry sub-committee under the umbrella of MTCC.’
        • The information disclosed in the financial statements does not support this statement.
  • Their Annual Information Statement 2016 (AIS 2016), under ‘activities and outcomes’, mentions only the conferences they held:
    • Mt (sic) Tamborine Convention held three conventions on its property at Mount Tamborine during 2016 – The Easter Convention, the Spring Holiday Convention and the Senior’s Convention.

Does MTC share the Gospel?[4]

  • Both the conferences planned so far for 2018 appear to be directed at Christians.

What impact are they having?

  • No information found.
  • MTC present, on their website, the results of some McCrindle research showing the importance of camps to the church generally.
  • The terms of MTC’s accreditation with the CMA Standards Council require it to perform regular program evaluations. There is no mention of evaluation on the website.

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

  • Although MTC have chosen not to make their financial report available on the ACNC Register (see below), it is included in their MTCC 2016 Annual Report, and that report is available on their website.
  • ‘Administration’ is not disclosed.
  • And the expenses are not classified so as to allow an estimate.

Do they pay their board members?

  • Such payments are allowed by the constitution.
    • They are, however, prohibited under the terms of MTC’s accreditation with the CMA Standards Council [Standard 3.7].
  • Whether they were made is not disclosed.

Can you get a tax deduction?

  • No

Is their online giving secure?

  • Security is not mentioned.

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

  • None

Is their reporting up-to-date?

  • Yes (six months after year end, three days before the deadline, and at the same time as last year).

What did the auditor say about the last financial statements?

  • The auditor, Rod Wallbridge FCA, gave a ‘clean’ opinion.
  • However, before you decide how much comfort to take from this opinion
    • Read the next section, and
    • Read about audit opinions here and here.

Does their reporting comply with the regulator’s requirements?

  • AIS 2016: Almost – no outcomes are reported
  • Financial Report 2016: Yes
    • Because they have a revenue of at least $25oK their size is Medium. Ordinarily this would mean that they must lodge accounts (which have been at least reviewed). However, because they are a ‘basic religious charity’, they are exempt from reporting.
    • They did produce a financial report – it is included in their annual report that is available on their website – and could have lodged this voluntarily, but chose not to.
      • This is contrary to the spirit of the CMA Standards Council’s Standards.
    • They say that the financial statements ‘satisfy the financial reporting requirements of the constitution of [MTC]’. Here’s the relevant clause:
      • ‘On behalf of the MTC Board, the treasurer must, as soon as practicable after the end date of each financial year, ensure a financial statement for its last reportable financial year is prepared’ [Clause 13.2.2].
      • They have produced ‘a financial statement’, but this falls well short of what is required by the Australian Accounting Standards.
      • The auditor, a Chartered Accountant, says that the financial report ‘is prepared, in all material respects, in accordance with applicable Australian Accounting Standards to meet the requirements of the Entity’s constituting Letters Patent.’
      • This is the only reference by MTC, either in the financial report or on the website, to ‘letters patent’.
      • A Letters Patent under the same Act, The Religious Educational and Charitable Institutions Acts, 1861 to 1959, for The Baptist Union of Queensland, has no financial reporting requirements. Nor does the Act. So perhaps we can presume that this is MTC’s situation too?
      • As a Chartered Accountant, the auditor, Rod Wallbridge, is therefore obliged to follow the Australian Auditing Standards. These in turn require him to expect MTC to produce a full set of financial statements that are compliant with the Australian Accounting Standards.
      • MTC haven’t done this, falling short by quite a distance.
        • This means that these financial statements do not meet the requirements of their partnership with the CMA Standards Council (Standard 6.1].

What financial situation was shown in the financial report?

  • Last year’s deficit of 9% of revenue was repeated. And without comment.
  • Employee benefits increased from 37% to 52% of expenses.
  • Current assets as a multiple of current liabilities (working capital) declined from 1.8 times to 1.1 times.
    • Combined with the repeated loss, this is of concern. (But it went without comment.)
  • With zero non-current liabilities and land valued at $2.07 m, the longer term financial structure is sound.

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

  • Yes

Where were your (net) donations sent?

  • NA

Who are the people controlling the organisation?

  • Not shown on the website.
  • These are the ‘Responsible Persons’ shown on the ACNC Register:
    • Duncan Drew
    • Rodney Logan
    • Peter Moody
    • Suzanne Nelson
    • Anna Roberts
    • John Sheen
    • Graham Stenton
    • William Vine
  • It appears, from the Mt Tamborine Convention Annual Report, that John Sheen has replaced Wendy Phillpotts.

To whom is MTC accountable?

  • As a charity, to the ACNC.
    • Its ‘Charity Tick’ is used on the website in support of you giving to them (and on most other pages).  And rightly so, because it would be unwise to give to a charity that is unregistered.  The ‘tick’ also means MTC’s AIS is not overdue, and the ACNC has not taken any compliance action against it.
  • MTC has gone beyond the charity tick, and achieved accreditation with the CMA Standards Council. It is therefore entitled to display their seal – you can see this on the right-hand side of most pages. For this privilege is must abide by the Council’s  Principles and Standards of Responsible Stewardship.

 

 

  1. MTC is a Foundation Partner. At the announcement of the Foundation Partners, Steve Kerr, the Executive Director of CMASC, said “Foundation Partner status is tangible recognition and reward for their efforts – these are high quality organisations.” 
  2. 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].
  3. Email from the ACNC, 8 January 2018.
  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.

The Trustee for Crossway Kingdom Fund: mini-charity review

Mini-charity review of The Trustee for Crossway Kingdom Fund (CKF), an organisation that is connected, through the cross directorship of John Peberdy, to the CMA Standards C0uncil, Christian Ministry Advancement Ltd‘s  ‘major new initiative, accrediting Christian organisations against a set of standards of good governance, financial oversight, and fundraising ethics.’

Is it responsive to feedback?

  • When sent a draft of this review, on 18 June 2017, they…did not respond.

Is it registered?

  • Yes, as a charity.
    • The trustee is Crossway Baptist Church (CBC)
      • For some unexplained reason, the trustee does not consolidate the affairs of the Fund, and has not taken advantage of the ACNC’s ‘Group reporting’ concessions.
  • CKF is a public ancillary fund, a fund that collects tax deductible donations and gives them to funds who have Deductible Gift Recipient status[1].

What does CKF do?

  • The only information available, including on the CBC website, is OKF’s ‘Description of charity’s activities and outcomes’ in their Annual Information Statement (AIS) 2016:
    • Crossway Kingdom Fund distributed funds in the 2016 year to eligible entities for the purposes of supporting – building project for a DGR charity – missionary work – ACCESS Ministries.
      • The ‘DGR charity’ was Crossway Lifecare Ltd, another charity controlled by CBC. It received 96% of CKF’s distributions.
      • Given that ACCESS Ministries has DGR status, that status means that it shouldn’t be doing ‘missionary work’.

Do they share the Gospel[2]?

  • No – and nor should the recipients of their grants.

What impact are they having?

  • No information is available.

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

  • There is no mention of impact in CBC’s publications.
    • Expenses other than ‘Distributions’ were less than one percent of expenses.
      • But ‘Employee expenses’ were zero.

Can you get a tax deduction?

  • Yes

Is their online giving secure?

  • CKF has no website. (Giving to CKF is one of the options on the CBC website. Giving there is secure.)

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

  • NA (and none when giving via the CBC website).

Is their reporting up-to-date?

  • Yes (four months after their year-end).

Does their reporting comply with the regulator’s requirements?

  • Annual Information Statement 2016: Not quite
    • No outcomes are reported
    • ‘Interest’ is reported as ‘Other income’.
  • Financial Report 2016:
    • Only if you believe that the decision, by the directors of a ‘Large’ public ancillary fund, to produce the lower-standard financial statements, is correct. (The decision implies that all users, both present and prospective, can command the preparation of a financial report tailored to their needs.)
    • The Report is shy a few of the Notes that are expected.

What financial situation was shown in that Report?

  • The surplus as a percentage of revenue declined from a high 31% to a more typical 9%.
  • Minimal short-term and no long-term liabilities.

What did the auditor say about the last financial statements?

  • He gave a ‘clean’ opinion.

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

  • Almost: No ‘Entity Subtype’ is given.
  • ‘Email’ and ‘Website’ are blank, but neither are compulsory.

Who are the people controlling the organisation?

  • Given that CBC is the trustee I would have thought that its directors would be the directors of CKF. But it’s not quite the same set. From the ACNC Register (under ‘Responsible Persons’):
    • Matthew Buntsma
    • David Caldera
    • Mark Churchward
    • Edward Harrison
    • Francis Hoe
    • Kok Looi
    • Scott Pilgrim
    • Margaret Spicer
    • Dale Stephenson
    • Beth Strybosch
    • Timothy Wilson
    • Michael Yap
    • John Peberdy
      • John is a director of Christian Management Advancement Ltd, an organisation that believes that ‘Christian organisations should be the standard-setters in terms of impeccable corporate behaviour.’
        • The mission of their committee, the CMA Standards Council, is to ‘help build faith and trust in Christian organisations’, including by allowing organisations who are compliant with a set of standards, formed by the Council, to display the Council’s seal of approval.
    • There are 14 directorships recorded for the name ‘John Peberdy’, and 8 for ‘Timothy Wilson’ (there are 12 but five are for the same charity).  And the register only covers charities, not all not-for-profits, and no for-profit organisations.  Therefore, if after eliminating the charities that don’t belong to the CKF director, you are left with their total being more than a handful, it would be legitimate for you to question whether their ability to discharge his fiduciary responsibilities is threatened.

To whom is CKF accountable?

  • To the ACNC.
  • As a public ancillary fund, to the ATO.

 

 

  1. The ‘Entity type’ they have selected on their ABN record, ‘Discretionary Investment Trust’, is therefore, even though one of the choices recommended by the ACNC, perhaps not the most appropriate one.
  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.] 

Baptist Union of Victoria: mini-charity review

Mini-review of Baptist Union of Victoria (BUV) as an organisation that seeks donations online for their Grow-Give-Go campaign. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

BUV is also an organisation that is connected, by the cross-directorship of Jame Lewis, to Christian Ministry Advancement Ltd, the organization that is responsible for the CMA Standards Council’s ‘major new initiative, accrediting Christian organisations against a set of standards of good governance, financial oversight, and fundraising ethics.’

Is it responsive to feedback?

  • When sent a draft of this review, on 15 June 2017, they…did not respond.

Is BUV registered?

What do they do?

Do they share the Gospel?

  • No. (Not their mission.)

What impact are they having?

  • Despite promoting a book with the subtitle The Six Practices of High-Impact Nonprofits, there is no indication that BUV are even assessing their impact.

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

  • From the classification of expenses used by BUV there is no clear way to even estimate this percentage.

Can you get a tax deduction?

  • Only if you give to its Fund, the Refugee Airfare Loan Scheme.

Is their online giving secure?

  • Grow-Give-Go: If it is, it’s not mentioned until after you have entered your information on the first page.
  • Refugee Airfare Loan Scheme: donations are invited but no facility provided.

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

  • None

Is their reporting up-to-date?

  • Yes (five months after their year-end).

Does their reporting comply with the regulator’s requirements?

  • AIS 2016: No
    • No outcomes are reported.
      • And ‘Empowered the leaders of Victorian Baptist Churches for mission.’ is not very helpful as a description of 2016’s activities.
    • Two business names are missing.
    • No explanation is given for the omission of ‘Other comprehensive income’.
  • Financial Report 2016: No
    • The directors give no explanation for their decision that ‘the Union is not a reporting entity’, that is, they have no users dependent on general purpose financial statements to make their decisions about BUV.
    • The decision allows them to produce the lower standard special purpose financial statements. This is only the correct decision if any of BUV’s users, either present or prospective, can request BUV to tailor a financial report to their needs. With a paid staff of 36, ‘constituents’ collectively paying $1.00 m for membership, and control of six significant charities, this is not plausible.
    • The Councillors’ Report (in the Financial Report 2016) says that ‘Insurance reserves totalling $539,321 were written back and taken up as revenue in 2016’. To do so is contrary to basic accounting, there is no ‘insurance reserve’ shown in the accounts, and there is no such movement in reserves.
    • The division of equity between ‘Unrestricted Fund’ and ‘Reserves’ implies that the amounts in the latter are restricted. However, well over half of the total are ‘restricted’ only by ‘internal rules and charters’, that is, are free to be used by BUV at their discretion.
    • The ‘Related Parties’ Note does not mention either Global Interaction (page two of the Financial Report) or Now and Not Yet Inc (also page two).
    • ‘Other’ under Revenue is 16% of the total. A bit large to be unexplained.
    • $431 K was paid in interest yet there are no loans.
    • Why is the increase in trust funds included as a financial activity in the Statement of Cash Flows?
    • The classification of the $38.95 m of investments does not follow that required in the Accounting Standards.

What financial situation was shown in that Report?

  • Remembering that the Report, due to the omission of controlled agencies, falls far short of showing the true position of BUV…
    • A negative return on revenue (-5%) was reversed (3%).
    • ‘Remuneration’ – presumably ‘employee benefits expense’ – declined from 56% of expenses to 49%.
    • Working capital (current assets less current liabilities) remained slightly positive at 120%.
    • Long-term liabilities are minimal compared to long-term assets.

What did the auditor say about the last financial statements?

  • He gave a ‘clean’ opinion.
    • But he agrees with the directors’ decisions not to consolidate and to produce that the lower standard special purpose financial statements are appropriate (see ‘Does their reporting..’, above).

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

  • Almost. It is missing information under ‘Other Name(s)’.
  • ‘Phone’ and ‘Website’ are blank, but neither are compulsory.

Who are the people controlling the organisation?

  • There is an organisation chart on the website, and a page on governance, but neither include the members of the board (Council).
  • Per the ACNC Register (‘Responsible persons’), it is currently these people who control BUV:
    • Jo-anne Bradshaw
    • Mark Browning
    • Daniel Bullock
    • Allan Demond
    • Fiona Hall
    • Darryl Kilker
    • Michael Turnbull
    • Debbie Uy
    • Jame Lewis
      • Jame is a director of Christian Management Advancement Ltd, an organisation that believes that
        • Christian organisations should be the standard-setters in terms of impeccable corporate behaviour.
          • The mission of their committee, the CMA Standards Council, is to ‘help build faith and trust in Christian organisations’, including by allowing organisations who are compliant with a set of standards, formed by the Council, to display the Council’s seal of approval.
    • There are eight directorships recorded for the name ‘Allan Demond’. And the register only covers charities, not all not-for-profits, and no for-profit organisations. Therefore, if after eliminating the charities for which Allan 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.

To whom is BUV accountable?

 

 

  1. A Financial Report normally identifies the organisation’s enabling legislation; the directors do not mention it in the 2016 Report.
  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.

Christian Ministry Advancement Ltd: mini-charity review

Mini-charity review of Christian Ministry Advancement Ltd (CMA), as an organisation that seeks donations on the internet. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

CMA is also the organisation that is, via the CMA Standards Council, giving a seal of approval to Christian organisations who meeta set of standards of good governance, financial oversight, and fundraising ethics.”[1]

Is it responsive to feedback?

  • When sent a draft of this review, on 12 June 2017, they…did not respond.

Is it registered?

  • Yes, as a charity.
  • CMA has several business names, but the one that it uses most, ‘CMA’ is not registered. (And ASIC says that it is not available.)
  • CMA is a member of the EA Foundation ‘family’, an affiliate.
    • The EA Foundation was originally the Evangelical Alliance; Australian Evangelical Alliance Inc is a separate charity trading as Missions Interlink (which is also one of the EA Foundation’s affiliates).
  • CMS is a public company, a company limited by guarantee.
    • It appears to have the provisions in its constitution to enable it to omit ‘Ltd/Limited’ at the end of its name.
  • The ACNC Register says that CMS operates throughout Australia, ‘Grants and donations’ is easily its largest source of revenue, and it seeks donations via its website. But it doesn’t have a fundraising licence in any of the seven states with a licensing regime[2].

What does CMA do?

Do they share the Gospel[3]?

  • No (Not part of their mission.)

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.

Can you get a tax deduction?

  • No

Is their online giving secure?

  • Yes

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

  • None

Is their reporting up-to-date?

  • Yes (nearly six months after their year-end, 10 days before the final due date)

Does their reporting comply with the regulator’s requirements?

  • Annual Information Statement 2016 (AIS 2016): Almost
    • ‘Outcomes’ are not reported.
    • One business name is missing
  • Financial Report 2016[4]: Questionable
    • The directors say that ‘there are no users dependent on general purpose financial statements’, implying that any of CMA’s stakeholders, both present and prospective, who require financial information to make a decision, are able to command the preparation of statements tailored to their needs. With a professional management, operations in all states, hundreds of subscribers, others who attend events who are not subscribers, a public invitation to donate, and a high-profile initiative to give a seal of approval to Christian organisations that meet a set of standards, this is questionable.

What financial situation was shown in that Report?

  • Revenue increased 24%.
    • Within this, ‘Grants and donations’ increased 148%.
  • The surplus as a percentage of income increased from less than 1% to 4%.
  • ‘Employee benefits expense’ increased 54% – something to do with the CMA Standards Council?
  • ‘Professional fees’ of $16K presumably include the (undisclosed) audit fee.
  • There are no non-current liabilities, so how did the ‘’Finance costs’ arise?
    • And where are they in the Statement of Cash Flows?
  • Working capital (current assets less current liabilities) dropped marginally, from 134% to 129%.
  • It appears that a grant was received for the CMA Standards Council that doesn’t yet qualify as revenue, and is therefore included as a liability ($85K).
  • There are no long-term liabilities.

What did the auditor say about the last financial statements?

  • He gave a ‘clean’ opinion[5].
    • To do this he had to agree with the directors that there are no users, past or prospective, who are dependent on the type of accounts that are produced when users are not able to command the preparation of statements tailored to their needs.

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

  • Yes

Who are the people controlling the organisation?

  • On the website here.
  • Which matches ‘Responsible Persons’ on the website:
    • Jame Lewis
    • Richard Menteith
    • Karen Naylor
    • Robert Rawson
    • John Peberdy
      • There are 14 directorships recorded for the name ‘John Peberdy’. And the register only covers charities, not all not-for-profits, and no for-profit organisations. Therefore, if after eliminating the charities for which John is not a director, you are left with his total being more than a handful, it would be legitimate for you to question whether his ability to discharge their fiduciary responsibilities is threatened.

To whom is CMA accountable?

  • To the ACNC as a charity, and to ASIC as a company.

 

 

  1. Here are the first three organisations accredited. See www.tedsherwood.com for a review of each.
  2. The law in this area is not straightforward – is an internet invitation ‘fundraising’ for instance? – and advice varies, so check with the charity before drawing any conclusions.
  3. Good living and social concern are important [to the cause of evangelism], but they are not uniquely Christian graces…I’ve met a lot of fine Hindus, Muslims and atheists. Just living the life is not going to bring someone to Christ. There is much more to it than that. We must help people, certainly, but we must also share with them why we are motivated to do so. We must stand against injustice, poverty and need, but we must at the same time point to the One who brings justice and who can meet the deepest need. Until they know our reasons, how can they come to know our Lord?” [Dan Armstrong, the Fifth Gospel: The Gospel According to You, Anzea Books, pp. 13-14.
  4. Although far from an uncommon practice, I have always wondered about the appropriateness of featuring the logo of the auditor on the cover of a report that is the responsibility of the charity.
  5. To take the right amount of comfort from a ‘clean opinion’, please read here and here.

The Trustee for The Overseas Council Fund: mini-charity review

Mini-charity review of The Trustee for The Overseas Council Fund (OCF), an organisation that is connected, through Stephen Kerr, to the CMA Standards Council, Christian Ministry Advancement Ltd‘s  ‘major new initiative, accrediting Christian organisations against a set of standards of good governance, financial oversight, and fundraising ethics.’

Is it responsive to feedback?

  • When sent a draft of this review, on 7 June 2017, they…didn’t respond.

Is it registered?

  • Yes, as a charity.
    • Its trustee is Overseas Council Australia.
      • For some unexplained reason, the trustee does not consolidate the affairs of the Fund, and has not taken advantage of the ACNC’s ‘Group reporting’ concessions.
  • OCF is a public ancillary fund, a fund that collects tax deductible donations and gives them to funds who have Deductible Gift Recipient status[1].

What does OCF do?

  • The only information available, including on the OCA website, is OCF’s ‘Description of charity’s activities and outcomes’ in their Annual Information Statement (AIS) 2016:
    • Raising funds to assist partner colleges to improve leadership in developing countries.

Do they share the Gospel[2]?

  • From the little information about the Fund that is available, it is not possible to say. However, its Deductible Gift Recipient status means that it shouldn’t.

What impact are they having?

  • No information is available.

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

  • Expenses other than ‘Grants and donations made…for use in Australia’ are 25% of the total.
    • But there is only $450 outside ‘Exployee expenses/ payments’, so it appears that they are not bearing all their own costs.

Can you get a tax deduction?

  • Yes

Is their online giving secure?

  • The Fund has no website, and even though OCF ‘maintains separate accounting and bank accounts, and provides tax deductible receipts to donors’, there is no mention of giving to the Fund on the trustee’s website.

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

  • NA

Is their reporting up-to-date?

  • Yes (eight months after their year-end, one day after the maximum period allowed).
    • Why did the ACNC allow a month more than other charities – and that when they had all been given an extra month?

Does their reporting comply with the regulator’s requirements?

  • Yes
    • The Financial Report 2016 is a single blank page. But a report is not required.

What financial situation was shown in that Report?

  • No Report is available, but from the financial information in the AIS 2016:
    • 75% of the expenses were sent overseas as ‘Grants and donations’.
    • They made a proportionally large loss (28% of revenue).
    • Three full-time and four part-time employees somehow only cost them $54K.
    • They have no liabilities.

What did the auditor say about the last financial statements?

  • NA

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

  • Yes

Who are the people controlling the organisation?

  • The people under ‘Responsible Persons’ on the ACNC Register:
  • There are 29 directorships recorded for the name ‘John Anderson’, 20 for ‘David Brown’, and eight for ‘Kenneth Chapman’. And the register only covers charities, not all not-for-profits, and no for-profit organisations. Therefore, if after eliminating the charities that don’t belong to the OCF director, you are left with his total being more than a handful, it would be legitimate for you to question whether hiability to discharge his fiduciary responsibilities is threatened.
  • The above people are also the directors of OCA.
    • Even though OCA says that OCF ‘has trustees nominated from the OCA Board’, OCF’s responsible persons, because OCA is the trustee, are automatically the same people as those who are the directors of OCA.

To whom is OCF accountable?

  • To the ACNC.
  • As a public ancillary fund, to the ATO.

 

 

  1. The ‘Entity type’ they have selected on their ABN record, ‘Discretionary Investment Trust’ is therefore, although given as an option by the ACNC, not the most appropriate one.
  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.