This is a review in the series ‘Organisations accredited by the CMA Standards Council’. The CMA Standards Council is ‘a ministry of Christian Ministry Advancement’^[1], with a mission “to help build faith and trust in Christian organisations, be they churches, charities, schools or otherwise, to enable them to achieve more effective outcomes^[2].

The 18^th member, ‘Belgrave Heights Convention’^[3], was recently added^[4] to the ‘Directory of Accredited Partners’.^[5]

The website linked from the Directory goes to a website in the same name, ‘Belgrave Heights Convention’. Here they seek online donations.

Donors

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

1. Check the charity’s name.
2. Ask for identification from anyone seeking a donation.
3. Be careful of online requests for donations.
4. No tax deduction doesn’t mean the charity is not a legitimate one, and
5. Find out more about how the charity says it uses donations.

Here’s the results for ‘Belgrave Heights Convention’, with #5 supplemented by the essentials of the ACNC’s What should I consider when deciding which charity to support?^[6]

Question 1

A search on the ACNC Register of charities for ‘Belgrave Heights Convention’ gives a charity in that name (BHC).

Other registrations

Business names:

Fundraising

There is no mention of fundraising licences on the website^[7], nor in the Financial Report.

BHC holds a fundraising licence only in Victoria.

Question 2

Nothing in BHC’s public materials indicates that it uses either volunteer or professional door-to-door or street collectors.

Question 3

BHC’s web address has a ‘closed padlock symbol next to the website’s URL in the address bar’, so the website is secure [the first ACNC article above].

But there is no information on the first three pages of the donation process about the security of your information.

Question 4

‘Will my donation be tax deductible?’ on the charity’s ACNC Register record shows that no tax deduction is available.

Only for online giving is tax deductibility mentioned.

Question 5: Where’s the money go?

Context

The ACNC Register shows that BHC has one program, ‘Bible-teaching conventions’. (The ‘About’ page on the website shows the aim of these conventions.)^[8]

Sharing the Gospel?^[9]

This is not what they are about.

Financial reporting

The audited account of how donations are used is the Financial Report on the ACNC Register.

The directors’ declaration about the statements

The directors signed a declaration [Directors’ Declaration, Financial Report 2020] that

For this to be true, the directors must have chosen the correct type of financial statements. T

The directors chose special purpose financial statements over general purpose. These are only relevant where all the users can ring the BHC’s office and command the preparation of financial statements tailored to their needs. If they can’t do this, then the users are dependent on a regulator to specify the form and content of the financial statements. As users, you are then ‘potentially interested in the information provided in general purpose financial reports’^[10].

The requirements of special purpose statements are less onerous than those of general purpose. The two main omissions are consolidated financial statements and the disclosure of related parties and their transactions.

With revenue of $1.07 million from multiple distinct sources, including hundreds of paying attendees at conventions, professional management, 100 volunteers, the receipt of government grants, and membership open to the public, the choice of special purpose statements is highly questionable. Which means the directors have made a highly questionable declaration (see below for who they were).

Not something that one would expect from a charity given the stamp of high standards by the CMA Standards Council, the evangelical standards body^[11].

The auditor, Matthew Hung, CA, rdl.accountants, agreed with the directors’ choice. This again is a highly questionable decision, both because of the argument given above, and this opinion of his professional body^[12]:

Additional issues

There are several other issues with the Financial Report that one would not expect from a charity that says it is a cut above the rest in financial reporting:

• The Statement of Profit or Loss and Other Comprehensive Income does not fully comply with the Accounting Standards.
• The Statement of Changes in Equity does not fully comply with the Accounting Standards.
• The Notes to the Financial Statements… is incomplete.

Who was responsible?

From the Directors’ Report [Financial Report 2020], these are the people responsible for the above reporting:

• Anthony Burgum
• Richard Coombs
• Andrew Rayment
• David Webb
• Timothy White

The ACNC Register shows that, since this time, David Lau has joined the board. (Is it this David Lau?)

The directors are accountable to the members, but there are only 12 of them, and as directors must be members, there is effectively no accountability here.

Where the donations went

These are the major expenses (from the Statement of Profit or Loss and Other Comprehensive Income):

‘Employment – Properties’ 148K

‘Employment – Ministry and Admin’ 133K

‘Depreciation’ 97K

‘Other Property Expenses’ 96K

‘Maintenance’ 60K

‘Insurance’ 51K

Impact

Everything BHC is doing may be being done ‘properly’^[13], but unless the money is producing the change in people that the charity intends (i.e., an impact), the money would be better used elsewhere. And the same applies if the impact is less than is being achieved by another charity.

There is no mention of the impact of the work on the website.

Standard 5.6 of the CMA Standards council standards (see above) requires that regular program evaluations. There is no mention of evaluations on the website.

Charity response

We sent a draft of this review to the charity. This was their response:

Thank you for sending us a copy of your review. We will look over it carefully and if we believe that it is necessary to take any action in relation to the matters you have raised, we shall do so.

1. Linked added by us. ↑
2. Emphasis in original. ↑
3. ↑
4. It achieved this by meeting the Council’s ‘Principles and Standards of Responsible Stewardship’, and therefore is able to be promoted as a ‘high quality organisation’. ↑
5. Having the list of accredited organisations on a site that is not secure is inconsistent with this building of ‘faith and trust’: ↑
6. A section in the article, Donating and Volunteering:
   1. Focus on the nature of the charity’s work, its beneficiaries and the impact the charity is having in the community.
   2. Is it clear what the charity is trying to achieve and how its activities work towards its objectives?
   3. Would you like to spend your money, or time if volunteering, to support these objectives?
   4. Is the charity being transparent about its activities?

↑

7.   They also have three Facebook pages: general, women, and business. ↑

8.   If you are interested in BHC’s history, see here and here. ↑

9.  ‘When Helping Hurts’ by Brian Fikkert and Steve Corbett says this about sharing the Gospel: ‘A host of contextual issues determine the best manner and the appropriate time to present the gospel verbally, particularly in militant Muslim or Hindu settings. But without such a presentation, it is not possible for people to be personally transformed in all their relationships, which is what poverty alleviation is all about [Kindle Locations 1262-1264, Moody Publishers] ↑

10.  From Objective of General Purpose Financial Reporting (SAC2), www.aasb.gov.au. ↑

11.  http://www.cmasc-generosity.net.au/directory.php: ↑

12,  Enhancing Not-for-Profit Annual and Financial Reporting, March 2013, accessed from their website March 2020. ↑

13.  The behaviour of its people, its use of money, and how it goes about its business. ↑