Servants to Asia’s Urban Poor Incorporated: charity review

This is a charity review of Servants to Asia’s Urban Poor Incorporated (SAUP), an organisation that seeks donations online, and is a member of Missions Interlink. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

For last year’s review, see here.

Are they responsive to feedback?

  • There is nothing about feedback, complaints, accountability or transparency on the webpage for Australia.
  • I sent them a draft of this review. Like last year, they…did not respond.

Is SAUP registered?

  • Yes, as a charity.
  • SAUP is a Queensland incorporated association (No. IA31696).
  • It operates, per the ACNC Register, in five states.
    • But it does not have the necessary registration, an ARBN, to operate outside Queensland.
    • Four of the states require charities to register if they are ‘fundraising’.
      • SAUP solicits donations on the internet.
      • Tasmania was not checked, but SAUP has no fundraising licences elsewhere. It does not explain why.
  • SAUP has no registered business names, so must use its full name in public.
  • It operates overseas, per the ACNC Register, only in India.
    • But doesn’t match the information in the Financial Report 2017: ‘Manila Team’ and an organization that is in Singapore, Cambodia and Canada, ‘Alongsiders International’, are two of the expenses.

What do they do?

  • SAUP is a ‘linking team’ of Servants.
  • The same page has this description of what SAUP does:
    • If you’re interested in Servants and you live in Australia – you’re not alone! A network of us across the country promote the work of Servants, participate in discernment, prepare folk to make the move to a slum, and to make staying there as hassle-free as possible. The Servants Australia office is located in Brisbane at Windsor Road Baptist Church, and provides the hub for a number of volunteers. Individuals with skills, experience and interest in Servant alongside the poor are in each State, and at times are available for face-to-face discussions.
  • And this is what they did in 2017 (from the AIS 2017):
    • In 2017 worked in Australia, raising awareness of issues in Asian slums, making contact with people interested in working in this environment and providing support and guidance as they considered their options. This included presenting and running information events at a number of key Australian Christian conferences and gatherings, as well as one-on-one support and relationship building with individuals considering future work in this environment. We also spent time supporting teams overseas and providing a link between them and supporters in Australia. This activity also included maintaining a small office at Red Hill to serve as a base for our coordinator and volunteers and for storing information.

Do they pay their directors?

  • From the expenses, it appears not.
    • It is not prohibited by their constitution.

Do they share the Gospel[1]?

  • No

What impact are they having?

  • Nothing systematic found.

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

  • On the giving page on the website, prospective donors are told that
    • Servants offices are fully staffed by volunteers and overheads are kept to a minimum in keeping with our commitment to simplicity. Donations can be made for specific Servants project funds or in support of individual missionaries.* No administration fee is taken out of donations to Servants projects and 100% of your gift will be sent to the field (emphasis in original).
      • But SAUP made grants and gave donations that totalled only 13% of donations received (AIS 2017).
      • And it is not ‘fully staffed by volunteers’: the AIS 2017 shows one employee.

Can you get a tax deduction?

  • No.
    • But SAUP promote a secular organisation, Global Development Group, as a means of getting a tax deduction:
      • Servants is an incorporated not-for-profit association in Queensland. We are presently not registered for Deductible Gift Recipient status therefore cannot issue tax receipts. However we partner with Global Development Group who provide tax receipts for the ‘Big Brothers and Big Sisters’ project in Cambodia, and ‘Lilok Organic Farm’ project in The Philippines. Other projects are currently in the process of obtaining tax deductibility status. 
        • What does this facility cost SA?
        • Global Development Group is not a Christian organisation, and would not be allowed to spread the Gospel via such projects anyway. The work therefore does not appear to be in the spirit of SAUP’s objects [Governing document, ACNC Register].

Is their online giving secure?

  • PayPal is used, so yes.

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

  • The form for a donation via PayPal invites you to “enter name of missionary or project)”, but the names of these missionaries and projects are not given on the website.

Where were your (net) donations sent?

  • Apart from the money declared in the AIS 2017, $7K to ‘Workers Support’, and therefore most likely going to India, there are two other expenses that indicate money sent overseas: ‘Manila Team’ and ‘Alongsiders International’.
    • No further information is disclosed.
    • The Indian Government requires all foreign contributions to be reported, but without the name of the recipient, we can’t check.

Is their reporting up-to-date?

  • Yes (on the last day, seven months after their year-end, and at the same time as last year).
    • But if you are considering a large donation, I would ask for more up-to-date financial information – the accounts are for a year end that is now over 10 months ago.

Does their reporting comply with the regulator’s requirements?

  • AIS 2017: No
    • ‘Grants and donations made for use outside Australia’ omits two expenses that appear to be transfers to overseas recipients.
    • With an online invitation to give, ‘No’ is not correct as the answer to ‘intend to fundraise’.
    • No outcomes are reported.
  • Financial Report 2017: Yes
    • But only because, due to SAUP’s size, no Financial Report is required.
    • It has chosen to lodge one voluntarily, but the ACNC does not require such reports to comply with its requirements.
    • SAUP is a member of Missions Interlink, and one of their requirements is that members ‘have available for its members and supporters a clear and appropriate financial statement which has been approved by its auditor [Standards Statement, 4.1].
    • Although SAUP’s Report was ‘approved by its auditor’ it shouldn’t have been:
      • Two of the four required financial statements are missing.
      • The two statements that are included do not comply with the Accounting Standards.
      • The Notes are deficient.
      • The auditor’s details appear on the cover of the Report. Did he prepare the Report as well as act as auditor?

What financial situation was shown in that Report?

  • No comment

What did the auditor say about the last financial statements?

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

  • No
    • The website address is for the site that covers all the offices of the network worldwide.
    • ‘Date Established’ and ‘Who the Charity Benefits’ are blank.

Who are the people controlling the organisation?

  • The directors are not mentioned on the website. From the ACNC Register they are:
    • Jon Eastgate
    • Nathan Elmes
    • Kelly Otto
    • Ralph Reilly
    • The board is accountable to the members. The number of members is not disclosed.

To whom is SAUP accountable?

  • As a charity, to the ACNC.
  • And to the Queensland regulator of incorporated associations.
  • Although it is an Australian association, another body, the ‘International Leadership Team (undefined), has the power to admit and the power to remove members [the constitution].
  • The page for Australia on the website claims membership of Missions Interlink. Confirmed.
    • For one view on the strength of this accountability, see the section Activities in this review.

 

 

  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]

Crossview Australia Limited: charity review

This is a charity review of Crossview Australia Limited (Crossview), 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.)

For the previous review, see here.

Is it responsive to feedback?

  • There is no invitation to give feedback, or to complain, on the website.
  • Accountability is not mentioned on the website.
  • I sent them a draft of this review. Like last year, they did not respond.

Is Crossview registered?

  • As a charity, yes.
  • And as a public company (a company limited by guarantee).
    • Crossview has the necessary provisions in its constitution to allow it to omit ‘Limited/Ltd’ at the end of its name.
    • Because they have the name registered as a business name, they can shorten their name even more, to Crossview.
  • Crossview operates, per the ACNC Register, in New South Wales (NSW) and Western Australia. And it seeks donations online.
    • It is licensed to fundraise only in NSW. It doesn’t explain why it holds no other fundraising licences.

What do they do?

  • Training’, ‘Sending + Support’, ‘Resourcing’, and ‘Advocacy’. For details, see ‘What We Do’.
  • The same thing is said, using different headings, elsewhere on the website as ministries.
  • Although it was meant to be about what they did in 2017, I think the Annual Information Statement (AIS) has yet another version of what they do:
    • We run a ministry training program called CONNECT and host regular events to equip Christians for cross-cultural ministry. We advocate for the needs of minority people groups through developing media and resources and by sharing at local churches and events. We stay aware of the latest issues and news related to crosscultural (sic) ministry by keeping connected with our ministry partners who work around the world. We also seek to encourage the ongoing work of our ministry partners through consultancy and financial support.

Do they share the Gospel[1]?

  • They collect money ($1.36 m this year) for missionaries, but their accounts imply that these missionaries don’t belong to Crossview. So, based on that, no, they don’t share the gospel.

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.

Do they pay their directors?

  • This is not allowed by their constitution.
  • There is no line item ‘directors’ fees’ (or similar) in the expenses.

Can you get a tax deduction?

  • No

Is their online giving secure?

  • Security is not mentioned.

Where were your (net) donations sent?

  • As you can see from the ‘What do they do?’ section above, donating money is not normally a big part of Crossview’s work. However, this year, in addition to the $38K (3% of expenses) with an unspecified destination, they donated $650K to ‘a related party’, AccessTruth Limited.
    • This was 86% of Crossview’s revenue.
    • They give no explanation for this gift.
    • How is it consistent with Crossview’s objects?
    • AccessTruth Limited is, as Note 2 d. says, controlled by Crossview. (Why Crossview has not therefore consolidated this subsidiary is nowhere explained.)

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

  • ‘Give to an individual or family’
    • The next page requires you to know the name of the person or, despite the previous page, the ‘specific project’.
  • ‘Give to a specific project or cause’
    • ‘General Fund’
    • ‘Connect Training Fund’
  • ‘Support the work of Crossview’
    • ‘General Fund’

Is their reporting up-to-date?

  • Yes (seven months after year end, a day after the deadline, and about the same time as last year).

Does their reporting comply with the regulator’s requirements?

  • AIS 2017: No
    • Most of the figures under in the ‘Comprehensive Income Statement summary’ do not agree with those in the Statement of Profit or Loss and Other Comprehensive Income.
    • With the ‘Description of charity’s activities and outcomes’
      • It does not appear that the information is particularly about 2017.
      • No outcomes are reported.
  • Financial Report 2017: No. Like last year
    • Crossview controls Access Truth Ltd [Note 2 d.] but does not explain why it has not consolidated this organisation.
    • No depreciation is provided on the buildings in the $11.95 m property portfolio. Assets and surplus are therefore overstated.
    • There is no explanation of why a gain of $677K was made on ‘investments’, nor how this fits with ‘Financial assets’ and ‘Property, plant and equipment’.
    • There is no explanation why the $1.36 m ($1.35 m last year) received by Crossview for missionaries was not included in revenue. And the payments to missionaries excluded from expenses.
    • The directors say that Crossview doesn’t have to produce general purpose financial statements (the type that complies with all the Accounting Standards), because ‘there are no users who are dependent on’ such statements. Effectively they are saying that any user, current or prospective, can request Crossview to tailor a set of financial statements to suit them. Given that this is a charity that seeks donations from the public, operates in two states, has a big real estate holding, and received $2.07 m in cash from supporters, members, and lessees.
    • There is no explanation for the large holdings of cash and real estate.
    • And this year, there is no explanation for giving 86% of revenue to AccessTruth Ltd, especially when this contributed to a loss of $485K.

What financial situation was shown in that Report?

  • The directors’ and auditor’s comfort with a Financial Report that is highly questionable as a true and fair view, means that you should be careful drawing any conclusions about Crossview’s financial situation based on that Report.

What did the auditor say about the last financial statements?

  • The auditor, Jason Sharp, of Macquarie Business Accountants, gave a ‘clean’ conclusion on the Financial Report. Given the issues identified above, this opinion is questionable.
    • See his fourth paragraph for what he did to reach his conclusion.
    • A review, rather than an audit is permitted by the ACNC because Crossview’s revenue is less than $1 m. (If the money for missionaries was revenue, an audit would be required.)
  • Even if it were the more rigorous audit rather than a review, you still must be careful to take the right amount of comfort from a ‘clean opinion’. See here and here.

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

  • Almost – ‘Who the Charity Benefits’ is blank.
  • Are the four countries that are listed the destination of the $38K sent overseas? Or is one or more of these countries the home of Crossview missionaries?

Who are the people controlling the organisation?

  • The directors are no longer shown on the website.
  • Here they are from the ACNC Register (under ‘Responsible Persons’).
    • Geoffrey Henderson
      • Presumably this is ‘Keith Henderson’? He isCompany director at Crossview Australia’.
    • Matthew Hillier
    • Paul McIlwain
    • John Sharpe
  • Three of these directors are also three of the four directors of AccessTruth Limited. Although Crossview admits to controlling this charity, it does not incorporate its finances into its Financial Report.
  • Crossview has only 13 members. Since directors must be members, there is only limited accountability from the membership.

To whom is Crossview accountable?

  • As a charity, to the ACNC.
  • And, as a company, still accountable to ASIC for some things.
  • Not mentioned on the website, but they are a member of Missions Interlink.
    • For one opinion of the strength of that accountability, see the section Activities in this review.

 

 

  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. 

Evangelical Missionary Society in Mayurbhanj: charity review

This is a charity review of Evangelical Missionary Society in Mayurbhanj (EMSM), an organisation that 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.)

For the previous review, see here.

Is it responsive to feedback?

  • I sent them a draft of this review.

Ministry comment

The charity is undergoing significant review through a process of consultation and the entry on the ACNC website will be altered accordingly[1].

Is EMSM registered?

  • As a charity, yes.
  • EMSM is an unincorporated association. (Not, as its ABN record still says, an ‘Other Incorporated Entity’, and not, as the constitution says, ‘incorporated in the State of Queensland’.
  • Not registered for GST, but its turnover last year was well below the threshold.
  • EMSM operates, per the ACNC Register, only in Queensland. It does not have a fundraising licence there.
    • In the Annual Information Statement (AIS) 2017, it says that it intends to fundraise in all eight states/territories. The fields for the licence numbers are blank though.
  • Overseas, it operates only in India [ACNC Register].

What do they do?

  • The only information available is what is in the AIS 2017:
    • Finances are used to promote the ministry of EMSM Indian Council and the Myurbhanj (sic) Leprosy Home and to provide resources for them to advance religious community belief, values and well being (sic).
  • The Council is presumably the first of the two organisations mentioned in the constitution (‘Government’):
    • There shall be two divisions known as (1) The Executive Council (previously known as the Field Council in India) and (2) The Consultative Council (previously known as the Home Council in Australia).
      • The cover of last year’s Financial Report – none is offered this year – identifies EMSM as the Consultative Council.
  • A blog gives the history of the Home until 2008, and a local newspaper article the history and situation in 2016.

Do they share the Gospel[2]?

  • No
  • Even though EMSM have registered ‘Advancing Religion’ with the ACNC as their sole ‘Entity Subtype’, there is no mention of Christianity in the objects in the constitution.

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?

  • No financial information is publicly available.

Do they pay their directors?

  • This is not prohibited by the constitution.
  • No financial information is available to check.

Can you get a tax deduction?

  • No

Is their online giving secure?

  • NA

Where were the (net) donations sent?

  • There is no information available.
  • Assuming that (net) donations were sent to India, and following the disclosure in last year’s Council Members’ Report, the laws of India mean that we can see what money was received by Indian organisations from foreigners:
    • For the year ended 31 March 2017, and using the translation rate at 30 September 2016,
      • $12,733 was received by Evangelical Missionary Society from Lloyd Carter (one of EMSM’s directors)
      • $30,863 was received by Mayurbhanji Leprosy House from Lloyd.

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

  • No information is available. But see the question immediately above.

Is their reporting up-to-date?

  • Yes (seven months after year end, a week before the deadline, and two weeks later than last year).

Does their reporting comply with the regulator’s requirements?

  • AIS 2017: Not quite – no outcomes are reported.
  • Financial Report 2017: NA
    • As a Basic Religious Charity, EMSM does not have to submit a Financial Report. Nor financial information in its AIS. And unlike last year, it has chosen to submit neither voluntarily.
    • But as a member of Missions Interlink, it is required to ‘have available for its members and supporters a clear and appropriate financial statement which has been approved by its auditor [Standards Statement, 4.1]. So just ask.

What financial situation was shown in that Report?

  • NA

What did the auditor say about the last financial statements?

  • NA

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

  • No evidence could be found that ‘EMSM’ is another name that the charity uses. It is not a registered business name.
  • The constitution is marked ‘Proposal (Draft 3) Nov 2013’.
  • ‘Phone’ and ‘Website’ are blank (but neither are compulsory).

Who are the people controlling the organisation?

  • Those people listed under ‘Responsible Persons’ on the ACNC Register:

To whom is EMSM accountable?

 

 

  1. This was their comment for publication last year: ‘(T)he Home and Field Councils are currently undergoing an extensive review regarding the future structure of the organisation and compliance issues both in Australia and India will be addressed in these changes.’
  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].

World Outreach Ltd: charity review

This is a charity review of World Outreach Ltd (WO), an organisation that seeks donations online (via both its international organisation, World Outreach International and its controlled trust, Partners in Development Trust Fund), and is a member of Missions Interlink. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

For the previous review, see here.

Is it responsive to feedback?

  • There is no website, so feedback and complaints cannot be invited, nor accountability discussed.
  • I sent them a draft of this review. Like last year, and the year before that, they…did not respond.]

Is WO registered?

  • As a charity, yes.
    • It is a member of a reporting group, World Outreach Ltd_ACNC GROUP (WO Group), with its charity World Outreach as the operator of a PBI (WO PBI).
    • There is another charity that is controlled by the same ‘Responsible Persons’ (see below), and that is part of the family: Partners in Development Trust Fund (PID). Why is this charity not included in the ACNC reporting group?
      • Because it is a very small charity, I have not gone to the trouble of including it in this review.
  • WO is a public company, a company limited by guarantee. (Not, as it has said for at least three years now on the ABN record, an ‘Other Incorporated Entity’.)
    • It does not have the provisions in its constitution to allow it to omit ‘Limited/Ltd’ at the end of its name.
  • WO operates, per the ACNC Register, in New South Wales, Northern Territory, and Queensland, Victoria, and Western Australia. This doesn’t agree with the list for WO Group.
  • It has an online invitation to give.
    • WO has a fundraising licence only in Queensland. It does not explain why it doesn’t have a licence in the other five states that have a licensing regime.

What do they do?

  • There is no clear description anywhere of what WO Group does:
    • There is no website – and no description of WO Group’s activities on the website of World Outreach International.
    • The AIS 2017 for the Group gives a long description of activities that, when seen against what is disclosed in the Financial Report 2017, is unlikely to be about WO Group.
    • The Directors’ Report (in the Financial Report 2016), is again unhelpful:
      • The principal activities of the company during the financial year were that of a charitable organisation. (There are more than 54,000 such organisations in Australia.)
  • WO operates, per the ACNC Register, in 12 countries overseas, WO PBI in none. This doesn’t tally with the WO Group’s listing of only nine countries.
    • Including a country merely if funds are sent there is valid. However, does WO send money to all these countries, or rather to World Outreach International?

Do they share the Gospel[1]?

  • From the objects in the WO constitution they should do:
    • (a) to propagate the gospel of the Lord Jesus Christ through all available means throughout Australia and the rest of the world
    • (b) to send missionaries and to employ national workers in different countries where the companies (sic) mission work operates or will operate….
  • But it is doubtful that they do this themselves, most likely just being a fundraiser.

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?

  • WO Group: If we define ‘direct’ as grants and donations made – and this ignores the fact that not all that money would go to or be spent on beneficiaries – then ‘administration’, from the audited statement, is 100% of expenses.
  • But from the AIS 2017, it is 29%. The reconciliation is in the additional (unaudited) statement that shows that $312K for ‘designations’ was deducted before reporting the revenue figure.

Do they pay their directors?

  • There is no prohibition in the constitutions, but there’s nothing the two income statements to suggest that they do.

Can you get a tax deduction?

  • No, not for a donation to WO.
  • But yes, if you donate to WO PBI, the World Outreach Ltd Benevolent Fund.
  • This is not quite what the website says:

Is their online giving secure?

  • The first page of ‘Make a Donation’ in ‘The Blessing Centre’ doesn’t mention security.
  • The page for Australian dollars says that eWay is used.

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

  • On the first page (‘The Blessing Centre’), there are nine categories, each with multiple (sometimes overlapping) options.
  • Theses donations are in US dollars. When you get to the donation form, there is a small message: You can also choose to pay in Australian Dollars via eWAY…’.

Where were the (net) donations sent?

  • This is not disclosed.

Is their reporting up-to-date?

  • Yes (a month late, seven months after their year-end, and a week 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 10 months ago.

Does their reporting comply with the regulator’s requirements?

  • Group AIS 2017: No
    • There is little support for the claim that their international activities include ‘Operating overseas including delivering programs’. (There is a separate line about transferring money overseas.)
    • The ‘Description of group’s (sic) activities and outcomes’
      • Is not supported by the other publicly available information; that information suggests that the description is about World Outreach International, not WO Group.
      • No outcomes are reported.
    • Neither the states nor the countries listed match those on the Register.
    • How can one full-time plus two part-time employees equal three full-time equivalent staff?
    • None of the figures in the ‘Comprehensive Income Statement Summary’ match those in the first of the two profit and loss statements.
  • Group Financial Report 2017: No. Like last year,
    • Two of the four statements are materially non-compliant with the Accounting Standards.
    • None of the Accounting Standards that are required to be followed have been followed.
    • Without explanation, there are two statements named Statement of Profit or Loss and Other Comprehensive Income.
    • There is no mention of the fact that the statements cover two charities, not one.
      • And should cover three (Partners in Development Trust Fund).
    • Revenue, due to the omission of ‘designations’ (grants made), revenue is over three times larger than the amount reported.
    • Neither of the items that are classified as liabilities appear to meet the definition of a liability.
    • The decision to say that there are no users, either present or prospective, who are dependent on general purpose financial statements is, given WO’s reach and donation income, questionable.
    • There are many other deficiencies in reporting.

What financial situation was shown by that Report?

  • The directors continued comfort with the Financial Report in the face of the issues above means that I am not comfortable making a comment on this.

What did the auditor say about the last financial statements?

  • The auditor, Nathan Boyd, Chartered Accountant, of Boyd Audit, gave a ‘clean’ opinion. Looking at the issues identified above, he shouldn’t have done. Little comfort can be taken from his work – especially as there are several significant mistakes in his actual report.

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

  • WO Group: The state shown doesn’t match the information given by WO and WO PBI.
  • WO: Almost – ‘Email’ is incorrect.
  • WO PBI: No
    • ‘Date Established’, ‘Size of Charity’, and ‘Operates in (Countries)’ is blank.
    • The address under ‘Email’ is incorrect.

Who are the people controlling the organisation?

  • For both charities, from their ACNC Register entries (under ‘Responsible Persons’):

To whom are they accountable?

  • As charities, WO and WO PBI are accountable to the ACNC.
  • WO, as a company, is still accountable for some things to ASIC.
  • It is also is a member of Missions Interlink.
    • For one opinion of the strength of that accountability, see the section Activities in this review.

 

  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.

Church Missionary Society Queensland With Northern NSW: charity review

This is a charity review of Church Missionary Society Queensland With Northern NSW (CMSQN), an organisation that seeks donations and is a member of Missions Interlink[1]. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

For the previous review, see here.

Are they responsive to feedback?

  • Other than an invitation to comment on the new website, CMSQN do not seek feedback, nor complaints other than about the behaviour of its staff.
  • Accountability is not mentioned on the website.
  • I sent them a draft of this review. They…did not respond.

Is CMSQN registered?

  • As a charity, yes.
  • As a Queensland incorporated association (IA18316) (even though the usual ‘Inc’ or ‘Incorporated’ is absent).
  • CMSQN operates, per the ACNC Register, in NSW and Queensland. But it is still not registered to fundraise in either of these states. Perhaps it believes that it is exempt?
  • It is ‘carrying on business’ in NSW, but still it doesn’t have the required registration (an ARBN).
  • CMSQN does not, per the ACNC Register, overseas. What about its missionaries? Plus the fact that the AIS 2017 says that money was sent overseas?

What do they do?

  • There’s not much on this published:
    • The information under ‘What we do’ is not about CMSQN specifically, but about CMS generally (represented by the charity Church Missionary Society – Australia Limited (CMS-Australia).
    • There is one sentence in the AIS 2017:
      • We have continued to encourage churches and individuals in Queensland and Northern NSW to get involved in cross-cultural mission.
    • The Committee’s Report gives the ‘principal activities’ as ‘community and missionary services.’

Does CMSQN share the Gospel[2]?

  • No.

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?

  • If ‘Missionary Support to CMS Australia’ is defined as the money that goes to achieve the impact, then 68% is administration (up from 65% last year).
  • If, as CMSQN imply by the two ‘Grants and donations made…’ lines in the AIS 2016, ‘Missionary – Branch Expenses’ and ‘Missionary – Federal Expenses’ should also be included, then the figure drops to 64%.
  • Either way, it is something that deserves an explanation, especially without any information on impact.

Do they pay their board members?

  • The CMSQN governing document does not prohibit this.
  • The expenses are not classified to allow us to say one way or the other.

Can you get a tax deduction?

  • Not for a donation to CMSQN.
    • Nevertheless, the giving page that they use is, without explanation, the one belonging to CMS-Australia, nd it does offer tax-deductible giving.

Is their online giving secure?

  • Security is still not mentioned.

Is their reporting up-to-date?

  • Yes (lodged seven months after their year-end, two days before the last day allowed).
    • But if you are considering a large donation, I would ask for more up-to-date financial information – the accounts are for a year end that is now nearly 14 months ago.

Does their reporting comply with the regulator’s requirements?

  • AIS 2017: No
    • Like last year,
      • Two of the figures in the Income Statement do not match those in Financial Report.
      • The description of ‘activities’ is, except for one sentence that is common to other branches of CMS-Australia, largely about another charity (albeit an associated one).
      • No outcomes are given.
    • No answer is given to the last two questions in ‘Reporting to state or territory regulators’.
  • Financial Report 2017: No. Like last year
    • Its relationship with CMS-Australia – the organization that collects its online donations and receives its money for missionaries – is not explained.
    • The relationship between the missionaries that it has sent overseas, employees, and CMS-Australia, is not disclosed.
    • The directors have avoided having to comply with all the Accounting Standards by saying, without giving any reason, that CMSQN is not a reporting entity. This means that they believe that there are no users, present (including donors who gave a total of $1.69 m), or prospective, who rely on a regulator to get the information they need to make decisions. For an organization that receives $1.69 m in donations, operates in two states, and has 62 staff, this is implausible.
    • Statement of Comprehensive Income
      • The reimbursements in ‘Federal Expense Reimbursement’ would be more correctly shown as a deduction from the expenses rather than as revenue.
      • ‘Bookstore Sales’ and ‘Bookstore Purchases’ are included, but where is the other component(s) of cost of goods sold?
      • Bequests are not included as donations in the Statement of Cash Flows.
    • Statement of Financial Position
      • Loans from members are usually repayable on demand. Are these any different? Unless an irrevocable authority to defer repayment beyond 12 months is held, ‘Loans from members’ should be classified as a current liability, not a non-current liability.
      • There is no explanation of the ‘Fair Value Reserve’.
      • The Note on ‘Reserves’ does not match the figure in the balance sheet.
    • Statement of Cash Flows
      • Dividends are recognised ‘when the right to receive the dividend has been established’. Why then is the cash amount identical with the revenue.
      • Similarly, with interest?
    • Notes to the Financial Statements
      • There is no information on related parties (an ACNC expectation).
      • There are several other Notes missing.

What financial situation was shown by that Report?

  • The directors continued comfort with the Financial Report in the face of the issues above and a qualified audit opinion, has tipped me over to ‘No comment’.

What did the auditor say about the last financial statements?

  • The auditor, Liam Murphy of PKF Hacketts, was unable to give CMSQN a ‘clean’ opinion. Once again, he qualified the opinion:
    • In common with similar associations, it is not practical to establish control over receipts from donations and other fundraising activities, prior to their initial entry in the accounting records…
      • So, the practices of CMSQN give us no confidence that all the money that was given to CMSQN made it into the bank account.
    • If other branches of CMS-Australia, for instance Tasmania and Victoria, can avoid such a deficiency in internal controls, why can’t CMSQN?
    • Hundreds of reviews of Christian charities like this one, performed by us, show that this inability is the exception rather than the rule.

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

  • No
    • ‘Who the Charity Benefits’ is blank.
    • The Register is blank for ‘Operates in (Countries)’. This is inconsistent with the report of $723K sent overseas (AIS 2017).

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

  • In one sense, you have no choice – it all goes to another charity, CMS-Australia.
  • Your choices at that charity are
    • General Missionary Support’
    • ‘General Tax Deductible (sic) Gift’
    • ‘A particular worker’.
      • With a dropdown listing 93 singles/couples plus ‘Other’.
        • Those working for CMSQN are not identified, but under ‘Missionaries’ on the CMSQN webpage there are 73 singles/couples.
    • Other

Where were your (net) donations sent?

  • The (net) money given for overseas work (AIS 2017) matches the figure for ‘Missionary Support to CMS-Australia’. Beyond that, we are not told. (Presumably the bulk of it goes to CMSQN’s missionaries.)
    • The description of this expense doesn’t sound as if the tax-deductible money is included. Where’s that in the expenses?
  • So, if you give on the website, you give to CMS-Australia, the money is transferred to CMSQN, and then they transfer it back to CMS-Australia. Seems clumsy.
  • The destination of the balance of the money given for local work (AIS 2017) is not disclosed.

Who are the people controlling the organisation?

  • Not shown on the webpages, but per the ACNC Register (under ‘Responsible Persons’), they are:
    • Alison Barlow
    • John Hagidimitriou
    • Martin Hawkins
    • Ronald Herbert
    • Audrey Jordan
    • Peter Kidd
    • Colin Law
    • John Menear
    • Sheila Milton
    • Joy Palmer
    • Maxine Percival
    • Angus Robinson
    • Susan Smith
    • Simon Waller
    • Selena Yen
    • There are 11 directorships recorded for the name ‘Susan Smith’. 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 CMSQN’s Susan Smith 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.  Especially if she has a full-time job.
    • The constitution requires a minimum of 16 ‘regional delegates to the Council’ [clause 7.1]. Combining this with the other compulsory inclusions [clause 6.2], means that the Council is well short of its required number.
  • The Board is responsible to the membership. The number of members is not disclosed.

To whom are CMSQN accountable?

  • As a charity, to the ACNC.
  • And to the Queensland incorporated associations regulator.
  • Although not mentioned on their webpage, they are also accountable as a Member of Missions Interlink.
    • For one opinion on the strength of this accountability, see the section Activities in this review.

 

 

  1. The entry in the list of members leads to a ‘404 Page not found’ message.
  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. 

Northpointe Baptist Church Incorporated: charity review

This is a charity review of Northpointe Baptist Church Incorporated (NBC), an organisation that has a public invitation to give. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

Conflict of interest

I am an active participant in the community that, many years ago, chose to incorporate as NBC.  However, neither myself nor my wife are, nor do we intend to become, members of the legal entity. Some conflict of interest remains though, so I have been careful to review this charity in the same way as I have reviewed every other charity.

Is it responsive to feedback?

  • There is no invitation, on the website, to submit feedback or complaints.
  • Accountability is not mentioned on the website.
  • I sent them a draft of this review. Here is their response:
    • Thanks for performing a charity review of Northpointe.  It is extremely useful to have, and we will use it to guide is through making necessary changes to the way things are administered, recorded and reported.  The church strives to be transparent and accountable in everything that is done.
    • They also gave some feedback. This has been included below the applicable comment.

Is it registered?

  • Yes, as a charity.
  • NBC is an Australian Capital Territory (ACT) incorporated association (A 04911).
  • It operates, per the ACNC Register, in Australia only in that territory.
  • It holds no business names. It therefore should to ‘trade’ only under its full name. Not like it does on its website and on Facebook.
  • The ACNC Register says that it operates overseas only in Vietnam. But the website says otherwise:

  •  Ministry comment: ‘Regarding operating overseas, we do support missionaries overseas, but this was not included in last years (sic) report as we didn’t visit or engage in any “operational” support during the year.  Vietnam was outlined as a mission trip there (sic) was organised during the year.’
    • Reviewer response: Providing funds is an activity for ACNC purposes.
  • It has no fundraising licences. Whether or not it requires one in a state that has a licensing regime applicable to charities, depends on whether that state believes that an internet invitation to give qualifies as ‘fundraising’.

What does NBC do?

  • The usual local church things: see ‘Missions’, ‘Ministries’, and ‘Our Message’ under ‘About’, all on the home page.

Do they share the Gospel[1]?

  • Yes

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 expenditure is not classified to allow an estimate of this figure.

Do they pay their board members?

  • There is nothing to prohibit this in the constitution.
  • The financial disclosure doesn’t allow a check for such payments.

Can you get a tax deduction?

  • No

Is their online giving secure?

  • It is not until the fourth page of the process that security is mentioned. And then in small print.
    • Stripe is used, so your payment should be secure.

Where were the (net) donations sent?

  • For only $12K of the $41K is this disclosed: ‘Manna (Vietnam Orphanage)’.
    • How does this relate to ‘GVI’ (above) and here?

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

  • ‘General Funds’
  • ‘Missions’
  • ‘GVI’
  • ‘Building Fund’

Is their reporting up-to-date?

  • Yes (four and a half months after their year-end, three weeks later than last year).

Does their reporting comply with the regulator’s requirements?

  • Annual Information Statement (AIS) 2017: No
    • The ‘Description of charity’s activities and outcomes’
      • is not about 2017 particularly, and
      • has no outcomes.
    • The ‘Accounting method…’ does not match the one that has been used.
    • ‘Donations and bequests’ does not match the figure in the Profit & Loss Statement.
    • There are again no figures under ‘Balance Sheet Extract’.
  • Financial Report 2017: Yes
    • But only because it has been voluntarily submitted to the ACNC, and voluntarily submitted reports do not need to comply with the ACNC legislation.
      • NBC’s doesn’t comply because it deviates materially from what is required by the accounting profession.
        • For instance, there are no Notes to the accounts or Directors’ Declaration, and there is significant confusion over the reporting framework.
    • The reviewer has also deviated materially from the requirements of his profession.
    • Ministry comment: ‘The committee will work to better understand and improve accounting practices’.

What financial situation was shown in that Report?

  • 44% of the expenditure went on the one full-time employee (Annual Information Statement (AIS)2017).
  • The next highest expenditure was ‘Missions’ plus ‘Love Offering’, 28%.
    • Much more than this could have been given – NBC again has a substantial sum in the bank ($149K).
      • No explanation is given for holding such a large sum.
  • The only other figure greater than $5K was ‘Music Ministry’, $17K (11%).
    • This seems a disproportionately large amount.

What did the auditor say about the last financial statements?

  • The auditor, Doug Burgess, Chartered Accountant, of BLM Accounting Services, concluded that
    • Based on our review, which is not an audit, nothing has come to our attention that causes us to believe that the annual financial report…does not present fairly, in all material respects, the Church’s financial position as at 30th June 2017 and of its financial performance for the year ended on that date in accordance with the Australian Accounting Standards as noted in note 1 (sic).
      • There is no ‘note 1’.
      • If not an audit why this stamp on the financial statements?

      • Under ‘Scope of Review’ he says that ‘With the exception of trade creditors the statements have been prepared on a cash bais (sic)’. This basis is not one that is recognised by the Standard-setters, and there is therefore no way that the statements ‘present fairly’ as he claims.
    • This review falls so far short of the accounting profession’s requirements for a review that it is difficult to have any confidence in his opinion.

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

  • No:
    • A PO Box number is not a ‘street address’.
    • The constitution contains neither of the two clauses necessary to make NBC a not-for-profit.
    • ‘Phone’ and ‘Website’ are missing (but the ACNC says that neither are compulsory.

Who are the people controlling the organisation?

  • Per the website:

  • Which listing has little correspondence with what is shown on the ACNC Register (under ‘Responsible Persons’):
  • Ministry comments: (1) ‘The committee is looking to have the web site better maintained and will aim have any needed changes incorporated. (2) There have been changes to the leadership team over the past few months and the web site update was missed.  Thanks for outlining that.

To whom is NBC accountable?

  • As a charity, to the ACNC.
  • And to the ACT 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.

Cosmos Healthcare Inc: charity review

This is a charity review of Cosmos Healthcare Inc (CH) an organisation that seeks donations online, and is a member of Missions Interlink. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

For the previous review, see here.

Is it responsive to feedback?

  • There is no invitation, on the website, to submit feedback or complaints.
  • Their values include accountability, openness and transparency:

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

Is CH registered?

  • As a charity, yes.
  • CH is a WA incorporated association (No. A1010684A).
  • It holds no business names yet trades under the name Cosmos Healthcare.
  • CH operates, per the ACNC Register, only in Western Australia. It has a fundraising licence there. But nowhere else.
    • Whether it needs one in the other five states that have a licensing regime for charities depends on whether those states think that inviting donations via the internet is ‘fundraising’.

What do they do?

  • They describe themselves as, ‘an intercontinental healthcare organisation’, and ‘an international health and development organisation’. Read more here.
    • The ACNC Register confirms that they operate overseas only in Zimbabwe.
  • Here’s their ‘Description of charity’s activities and outcomes’ in the AIS 2017:
    • The organization supports financially a medical centre in Zimbabwe. We also send medical teams to assist local medical staff, for treatment of local people and to train local people.
  • More balanced, and detailed, is the description on GiveNow:

Do they share the Gospel[1]?

  • No
    • Which fits the absence of (a) ‘Advancing religion’ as one of the four ‘entity subtypes’ that CH have listed on the ACNC Register, and (b) Christianity in the description of its objects in the constitution.
    • But if the plan to implement Community Health Evangelism (CHE), a plan that has existed since at least the last review, comes to pass, sharing the Gospel will be integrated in their work.
      • How will this fit with the fact that the government allows their donors a tax deduction?

What impact are they having?

  • Nothing systematic found.

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

  • The expenses are not classified to allow this calculation.
    • For instance, outside ‘Donations’, what portion, if any, of the other expenses were direct to healthcare delivery in Zimbabwe?
    • There is a figure ‘Administration’ ($12K), but other administrative expenses, like ‘Property’ and ‘Insurance’ are separate items.

Do they pay their directors?

  • There is nothing to prohibit this in the constitution.
  • The financial disclosure doesn’t allow a check for such payments.

Can you get a tax deduction?

  • Yes

Is their online giving secure?

  • Security is still not mentioned on the CH giving page, and after that page redirects to GiveNow, neither do their first two pages mention it.

Where were the (net) donations sent?

  • There is no information in the Financial Report.
  • Presumably, from information on the website, the money is sent to this organization.
    • Despite one of their four values being ‘Accountability’, neither ‘financial statement’ nor ‘audit’ is mentioned on their website.

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

  • ‘Extended Care Patients’
    • There is a list of these patients on the second page under ‘Credit Card’.
  • ‘Medicine Supply Campaign’
  • ‘General Donations – 2017/18’

Is their reporting up-to-date?

  • Yes (seven months after year end, again on the last day allowed).

Does their reporting comply with the regulator’s requirements?

  • AIS 2017: No
    • Cosmos Healthcare is not disclosed as an ‘other name’.
    • The ‘Description of charity’s activities and outcomes’ is not particularly about 2017.
    • No outcomes are reported
    • The state in which they intend to fundraise in 2018 is not shown.
  • Financial Report 2017[2]: No
    • The directors have decided to produce special purpose financial statements, the type of statements that do not have to comply with all the Accounting Standards. Given that this type is only appropriate when the users, both current and prospective, do not need a regulator to help them get the financial information they need, this decision is questionable.
      • The directors do not say why they think that “the association is not a reporting entity” (and is thus qualified to produce the lower standard statements).
    • The Statement by the Committee of Management does not comply with the ACNC’s requirements.
    • Several of the usual Notes are missing.

What financial situation was shown in that Report?

  • The deficit as a percentage of revenue was increased from 1% to 2%.
  • Relatively low liabilities (all current) means that both short- and long-term financial structure are sound.

What did the auditor say about the last financial statements?

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

  • Not quite – the name they use, Cosmos Healthcare, is missing.
  • Both the website and Facebook still have a different phone number: (08) 6168 1670.
  • It is unwise to use a personal email address as a ‘Charity Address for Service’.

Who are the people controlling the organisation?

  • Those listed here on the website.
  • Which is quite different from the list (under ‘Responsible Persons’) on the ACNC Register:

To whom is CH accountable?

  • As a charity, to the ACNC.
    • CH shows the ACNC’s ‘charity tick’ in its website header.
      • Apart from saying that CH is registered with them, the ‘tick’ also means that CH’s AIS is not overdue, and the ACNC has not taken any compliance action against it.
  • Not mentioned on the website, but they are a member of Missions Interlink.
    • For one opinion of the strength of this accountability, see the section Activities in this review.
  • CH is also accountable to the Western Australian regulator of 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.
  2. 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.

EA Insurance: charity review

This is a charity review of EA Insurance (EAI), an Associate member of Missions Interlink, ‘the Australian network for global mission’.

For last year’s review, see here.

Is EAI responsive to feedback?

  • In its ‘Complaints and Disputes Policy’, EAI says that it values feedback.
  • On its website, it talks about the accountability of others, but not of itself.
  • I sent them a draft of this review. Like last year, they did not respond.

Is EAI registered?

  • Not as an entity in its own right.
  • To receive charity tax concessions from the Australian Taxation Office (ATO), a charity must register with the ACNC. The company behind the EAI name (see below) appears to satisfy the requirements for registration, yet neither the company nor its owner (see below) say why it has not registered.
  • EA Insurance is a business name belonging to EA Insurance Services Pty Ltd (the company):

  • The company’s website uses one of the names above, EA Insurance Services.
  • The company is a not-for-profit, one that is wholly-owned by a charity, EA Foundation:

    • In the accounts of the charity, the company is, without explanation, referred to as EA Insurance Project Trust. This entity does not have an ABN.
    • The company is a proprietary company, one limited by shares rather than by guarantee.
    • As a ‘small proprietary company’, it only has to lodge financial reports in limited circumstances.
      • However, their Associate membership of Missions Interlink requires them to “have available for [their] members and supporters a clear and appropriate financial statement which has been approved by its auditor.”
      • Although you will not be donating to them, by insuring with them you are supporting their Christian cause, so are eligible to ask for this ‘financial statement.’

What does EAI do?

  • From the EAI website:
    • EA Insurance Services is a specialist provider of insurance and risk management services to Faith, Charity and Not for Profit organisations throughout Australia.
  • It describes itself as a ‘Christian organisation’.

Does EAI share the Gospel?[1]

  • It appears not.

What impact are they having?

  • No information on the website.
  • Nothing in the Financial Report of its owner.

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

  • No separate financial statements are published.

Do they pay their board members?

  • Neither constitution (without paying an ASIC broker) nor accounts are available to check.

Can you get a tax deduction?

  • NA – donations are not sought.

Is their online giving secure?

  • NA

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

  • NA

Where were your (net) donations sent?

  • NA

Is their reporting up-to-date?

  • Check with their regulator, ASIC.

Does their reporting comply with the regulator’s requirements?

  • Check with their regulator, ASIC.

What financial situation was shown in that Report?

  • No Report is publicly available.

What did the auditor say about the last financial statements?

  • No audit report is available.

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

  • NA

Who are the people controlling the organisation?

  • Not disclosed.

To whom is EAI accountable?

  • To Missions Interlink, because it’s an Associate member.
  • The company is accountable to ASIC.

 

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

Chinese Church Support Ministries Limited: charity review

This is a charity review of Chinese Church Support Ministries Limited (CCS), an organisation that seeks donations online and is an Associate member of Missions Interlink. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

You can read last year’s review here.

Is it responsive to feedback?

  • A ‘News from CCSM Australia’ post last year invited feedback from supporters.
  • There is no mention of accountability on the website that CCS shares.
  • I sent them a draft of this review. Like last year, they did not respond.

Is CCS registered?

  • As a charity, yes.
    • But still, over fourteen months after the last review, in its old name, Antioch Missions.
    • Not to be confused with the charity Antioch Missions International Inc.
  • CCS is a public company, a company limited by guarantee.
  • It has the provisions in its constitution to allow it to omit ‘Ltd/Limited’ at the end of its name, but has not registered as business names the other names it uses, CCSM or CCMS Australia
  • CCS operates, per the ACNC Register in New South Wales (NSW) and Western Australia (WA). Its registered office as a company is an address in WA (www.asic.gov.au,) so that explains the second state. But with an Australian Capital Territory (ACT) address for its ‘Charity Street Address’, why NSW?
  • Information in it its Annual Information Statement (AIS) 2017 shows that it believes that an internet invitation does not count as fundraising, so this probably explains, given its very small donations revenue, why it has no fundraising licences.

What do they do?

  • From the AIS 2017:
    • In Australia, every month we email prayer letters to supporters living in Australia, for purposes of educating those outside of China, about its needs. A major area where our donations are directed to is our Literature ministry which sees the printing of Bibles and Christian teaching material which is distributed throughout China. Organised teams for volunteers to go into China for short trips (2 weeks) to participate in Mercy Work projects, Prayer teams and Cross-Cultural-English Teaching ran throughout 2017 and will continue to do so in 2018. This is the main way that we get people outside of China into China to participate in supporting and serving China.

Does CCS share the Gospel?[1]

  • Presumably those who go on the ‘short trips’ (see above) share the Gospel if they get the opportunity.

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 AIS 2017 shows that it cost them $5K to send $16K (to China).

Do they pay their board members?

  • This is prohibited by the constitution.
  • There’s insufficient financial information disclosed to check for a payment.

Can you get a tax deduction?

  • No

Is their online giving secure?

  • Security is not mentioned, but PayPal is used, so the giving should be secure.

Where were your (net) donations sent?

  • This is not disclosed.
    • $16K is shown for ‘Grants and donations made for use outside Australia’. China, per the ACNC Register is the only overseas country in which CCS operates.

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

  • No choice is given online.

Is their reporting up-to-date?

  • Yes (seven months after year end, two days after the deadline, and two weeks later than last year).

Does their reporting comply with the regulator’s requirements?

  • AIS 2017: No
    • Except for a change of the years mentioned, the ‘Description of charity’s activities and outcomes’ is identical to last year. Which means that it is not specific to 2017.
    • No outcomes are reported.
  • Financial Report 2017: Yes
    • Their size means that they are not required to lodge a Financial Report.
    • But their Associate membership of Missions Interlink requires them to “have available for [their] members and supporters a clear and appropriate financial statement (sic) which has been approved by its auditor.”
    • Assuming that they complied, they could have lodged this ‘financial statement’ voluntarily, but they chose not to.

What financial situation was shown in that Report?

  • The AIS 2017 only has to disclose totals for assets, liabilities and equity (net assets). For CCS they are $25K, $8K, and $17K.

What did the auditor say about the last financial statements?

  • There is nothing to indicate that an audit was performed.

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

  • No
    • Antioch Missions is not the ‘Legal Name’.
    • A postal address is still given instead of the street address.
    • Chinese Church Support Ministries is not an ‘other name’.
    • ‘Phone’ and ‘Website’ are still blank – but the ACNC says that they are not compulsory.

Who are the people controlling the organisation?

  • Not mentioned on the website.
  • From ‘Responsible Persons’ on the ACNC Register, the same three as last year:
    • Daniel Bao
    • Murray Cameron
    • Hercus Graham (the wrong way round?)
    • The constitution allows the company to have only three directors.

To whom is CCS accountable?

  • As a charity, to the ACNC.
  • CCS is an Associate member of Missions Interlink. Missions Interlink has an accountability regime.
    • For one opinion on the strength of this accountability, see the section Activities in this review.
  • The constitution allows the company to have only three members, so if the three directors are members, there may be no accountability from the membership.

 

 

  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.

Asia Evangelistic Fellowship International Inc.: charity review

This is a charity review of Asia Evangelistic Fellowship International Inc. (AEFI), an organisation that seeks donations online and is a member of Missions Interlink. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

To see the situation last year, read this review.

Are they responsive to feedback?

  • Neither feedback nor complaints are invited via the website.
  • I sent them a draft of this review. Unlike last year, they…did not respond.

Is AEFI registered?

  • As a charity, yes.
    • AEFI is controlled by an entity called the (AEFI) ‘International Council’. The membership is not disclosed.
  • AEFI is a Western Australian incorporated association (A1007002D).
  • It has registered, as a business name, the name it uses on the internet, AEF International.
  • Apart from its office in Western Australia, AEFI operates, per the ACNC Register, in New South Wales and Victoria. AEFI also has an invitation to give on the internet.
    • It still does not have the registration necessary, an ARBN, to operate interstate.
    • It still does explain why it has no fundraising licences.
  • There are two countries shown on the ACNC Register additional to those to which AEFI sent money in 2017: China and Malaysia.

What does AEFI do?

  • The website and the AIS 2017 give the wrong impression. They make no distinction between AEFI and the national AEF organisations:

  • AEFI is the coordinating body for ‘the autonomous chartered national organisations and donor bases known as Asia Evangelistic Fellowship and other organsations started by/or affiliated with AEFI’ [the constitution, paragraph 6],
  • There is no other Asia Evangelistic Fellowship entity with an ABN, so it appears that AEFI acts as both this coordinating body – the ‘international office’ – and the local AEF organization.
    • Otherwise, why would AEFI be soliciting donations?

Does AEFI share the Gospel?[1]

What impact are they having?

  • Nothing systematic found.

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

  • ‘Donations and bequests’ were $339K (AIS 2017). ‘Net costs’ (a list of donation destinations) totalled $251K. That’s 74% to ‘the field’. Nowhere near 90%.
    • Is the reconciliation in the definition of ‘designated’? In other words, donations to ‘General’ are excluded? But if that is the case, why assume that people who are giving to ‘General’ are not expecting their donation to go to ‘the field’? There is no explanation on the giving page that ‘General’ is for administration expenses. In fact, elsewhere, the opposite is implied:

    • Either way, the 90% claim is deceptive.
    • It would be reasonable to ask them why if would not be more efficient for you to send the money direct to the destination.

Do they pay their board members?

  • There’s nothing prohibiting this in the constitution.
  • There’s no line item in the expenses that suggests that such payments were made.

Can you get a tax deduction?

  • The ABN record says no. But they accept donations for a third party:

  • GDG is a secular organisation.

Is AEFI online giving secure?

  • Despite saying in the review last year that they would put a statement about security, there still nothing said on the first page.

Where were your (net) donations sent?

  • For 92% of the money only a country is specified.
  • 70% goes to India (8% of the Indian total goes to an organization called ‘Destiny India’).
    • If we knew the state, we could search here to see if the money had been received.

Is their reporting up-to-date?

  • Yes (seven months after their year-end, two days before the (extended) deadline, and over a month later than last year).
    • But if you are considering a large donation, I would ask for more up-to-date financial information – the accounts are for a year end that is now over nine months in the past.

Does their reporting comply with the regulator’s requirements?

  • AIS 2017: No.
    • The activities described are not just those of AEFI; they include AEF organisations overseas.
    • No outcomes are reported.
  • Financial Report 2017: No.
    • Totally inadequate, as it has been for each of the four years that Reports that have required by the ACNC.
    • This is despite saying last year that a review in 2017 would ensure ‘that its financial reporting meets the requirements of all regulators.’
    • The reporting is not only well short of what the ACNC requires and, on any reasonable definition of ‘appropriate’, non-compliant with Mission Interlink’s standards, but it is also non-compliant with its own requirements (its constitution).
    • More is missing from the Report than is included:
      • Two of the four required financial statements.
      • No Responsible Persons Declaration.
      • No Notes
    • And the two statements that are included do not comply with the Accounting Standards – including basic accounting.
      • ‘Gross profit’ is not (Donations + Book Sales) less money sent overseas.
      • The ‘Futures Fund’ is not a liability:

  • The auditor is not qualified to do the audit, and the audit that he has done does not comply with the Australian Auditing Standards.

What financial situation was shown by that Report?

  • Because of the condition of the Report, no comment.

What did the auditor say about AEFI’s last financial statements?

  • The auditor (the third one in as many years), Peter Attwell of Attwell Partners, issued a ‘clean’ opinion. But given the state of the Financial Report (see above), I wouldn’t put much store in this.
    • Peter is not a registered company auditor (asic.gov.au) so is not qualified to do this audit.

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

  • Almost – a PO Box number is not a ‘Street Address’.
  • It is unwise to use a personal email address as the ‘Charity Address for Service.’

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

  • General’
  • ‘AEFI Futures Fund’
  • ‘Solid Rock Cambodia Hospital’
  • ‘Support the General work of AEFI’ – duplicating the first choice
  • ‘Support a Missionary Trainee’
  • ‘Support a Child
  • ‘Support a Community Project’
  • ‘Support a National Worker’
  • There is a brief description of these elsewhere on the website.
    • ‘Nepal Earthquake Appeal’ is no longer an option, and the information on ‘Solid Rock Cambodia Hospital’ is out-of-date.

Who are the people controlling AEFI?

  • This is the way it should be (from the constitution):

  • But this is how it is:

  • You can meet the incumbents of these three offices here.
  • Why no mention of the International Council?
  • The constitution goes on to say that the International Council appoints the International Director and the Board of Directors.
  • But the other members of the Board are not shown.
  • The ACNC Register (under ‘Responsible Persons’) says that the following people are on the AEFI Board:

To whom is AEFI accountable?

  • Despite saying in response to last year’s review that ‘We are happy to state on our website that we are a member of Missions Interlink and also accountable to ACNC’, ’accountability’ is still not mentioned. Nor is Missions Interlink (other than in the newsletter (see below).
  • AEFI is accountable to the ACNC.
  • And to the Western Australian regulator of incorporated associations.
  • In its newsletter it correctly claims to be an ‘accredited member’ of Missions Interlink:

    • Missions Interlink is an organisation that has standards with which AEFI must comply.
      • For one opinion on the strength of this accountability, see the section Activities in this review.

 

 

  1. Good living and social concern are important [to the cause of evangelism], but they are not uniquely Christian graces…I’ve met a lot of fine Hindus, Muslims and atheists. Just living the life is not going to bring someone to Christ. There is much more to it than that. We must help people, certainly, but we must also share with them why we are motivated to do so. We must stand against injustice, poverty and need, but we must at the same time point to the One who brings justice and who can meet the deepest need. Until they know our reasons, how can they come to know our Lord? [Dan Armstrong, the Fifth Gospel: The Gospel According to You, Anzea Books, pp. 13-14.
  2. Last year I did not appreciate the distinction between AEFI and the national AEF organisations.