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 17^th member, ‘Christian Media & the Arts Australia’^[3], was recently added^[4] to the ‘Directory of Accredited Partners’.^[5]

‘Christian Media & the Arts Australia’ is an organisation that seeks donations online.

Donors

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

1. Check the organisation’s name.

2. Ask for identification from anyone seeking a donation.

3. Be careful of online requests for donations.

4. No tax deduction doesn’t mean the charity is not a legitimate one.

5. Find out more about how the charity says it uses donations.

Here’s the results for ‘Christian Media & the Arts Australia’, 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 ‘Christian Media & the Arts Australia’ gives no result.

A check on ABN Lookup shows that the name is different in two ways, one of which is significant, ‘Christian Media & Arts Australia Limited’ (emphasis ours). (An unfortunate carelessness from an organisation promoting, and requiring, high standards!)

Charity comments

I take it this was from the CMA Standards Council Website.  They have simply made an error with our name and we have informed them to update it to our correct name.  

Some grace would be helpful here.  CMA Standards Council and the organisation CMA was in the midst of needing to change their conference after lockdowns with 2 days notice in Melbourne meant they had to place a very quick placeholder on their website.  We have been assured it will be rectified as soon as they possibly can.

Reviewer’s response

There is a level of grace that is appropriate for a secular organisation, a higher level for a Christ-led organisation, and an even higher one for a ‘Christian’ organisation, like the Standards Council, that sells itself as requiring very high standards.

Quite apart from that, all we are talking about is the need to recognise that the website represented the standards of an organisation promoting excellence, and then correctly type the name of an organisation with which they would have been familiar.

The ‘placeholder’ remains there today, weeks, if not months later^[7].

A new search for a charity brings up one in the ABN name, Christian Media & Arts Australia Limited (CMAA).

This, as CMAA themselves report on their Annual Information Statement (AIS) 2020, their legal name^[8]. CMAA does not have the name without ‘Limited’ registered as a business name, yet it is trading under that name. This is an issue because its constitution permits the payment of directors’ fees^[9], and therefore it is illegal to trade without ‘Limited’/’Ltd’ in its name.^[10]

Charity comments

Thank you for the observances on the legal name.  We will review this situation.  We do however disagree with the stated “illegal” comment.    

Reviewer’s response

Illegal: not allowed by the law. The law. CMAA’s situation: see above. Therefore,’ illegal’.

Business names

CMAA says, on its ACNC Register entry, that it is ‘publicly known by’ two other names: ‘Christian Media & Arts Australia Limited’ and ‘Christian Media Australia Limited’. The first is not an ‘other name’, but their name. The second is not, according to Google, a name known by the public.

The ‘Also known as’ section on the Register is the place for the charity’s business names. CMAA’s ABN record says that CMAA has the following names registered:

CMAA Arts Fund

CMAA Media FUND

SPARC

Christian Media Australia^[11]

These names are therefore missing from the ACNC Register.

Question 2

Nothing in CMAA’s public materials indicates that it uses door-to-door or street collectors.

Charity comments

We do not do door to door solicitation.

Question 3

CMAA’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 donation page about the security of your information.

Charity comments

We will review how we communicate and how we deal with information received.  Our Privacy policy already detailing some of this will also be reviewed.

Reviewer’s response

Privacy is not the same as the safe transmittal of information when giving.

Question 4

‘Will my donation be tax deductible?’ on the charity’s ACNC Register record shows that no tax deduction is available. But this is contradicted on the donation page. Not only is tax-deductible giving sought, but that’s the only kind that they are seeking. They don’t explain this contradiction.

Again, not consistent with the claimed ‘high standards’.

The explanation lies in the fact that CMAA, without mention on its ACNC Register information, controls the two other entities^[12] mentioned on the giving page^[13]:

Although these two organisations get their DGR status via registration as a ‘Cultural Organisation’, they are not registered charities^[14]. CMAA do not explain why they aren’t.

Charity comments

We will tidy this detail up as we are just about to commence fundraising (solicitation) for the organisation after our state registrations are all complete.

Reviewer’s response

Lack of registration as a charity is much more than a matter of ‘detail’.

Question 5: Where’s the money go?

Context

The ‘About’ page is a bit hidden (not in the main menu, and not in any of the main menu items), but when we found it, here’s the mission:

Our mission is to advocate and empower the creativity, excellence and unity of members and Christians in media and the arts so as to spark a movement that transforms lives.

This is the entry on the ACNC Register:

The Annual Information Statement (AIS) 2020 has the same paragraph, but also lists the programs:

Sharing the Gospel?^[15]

No

Financial reporting

The audited account of how donations are used is the Financial Report on the ACNC Register. This Report is not of the high standard that one would expect of a charity that has achieved the Standard Council accreditation:

• The directors are confused about the type of statements that they have produced: general purpose in the AIS 2020 and in their Responsible Entities’ Declaration versus special purpose in Note 1 and the audit report.
• If they are special purpose statements – as is likely – then that decision is questionable for an organisation with professional management, 15 staff, a million-dollar turnover, 61 members, and receiving grants.
• They do not explain how an organisation of their size can operate without any ‘fixed assets’ (sic) (office equipment, motor vehicles etc.).
• ‘Provision for Project Disbursements’ doesn’t normally meet the definition of a liability.
• ‘Other Comprehensive Income’ is missing.
• ‘Website development’ is reported as an asset but treated as an expense.
• One or more directors provided goods or services (Note 10), yet the relationship is not disclosed as a related party transaction (Note 11).

Where the donations went

Here’s the expenses (from the Statement of Comprehensive Income):

• Not only is this a listing in no obvious order, but the classification also appears to be a mixture of by nature and by function (which is contrary to the Accounting Standards).
• There is no explanation of the second largest item, ‘CMAA Tours & Ticketing Promotions Expenses’ $304K, 32% of the total.
• CMAA do not explain how activities (‘Activity expenses’), 10% of the total, differ from the activities of running conferences (‘Conference expenses’), tours (‘CMAA Tours…), and projects (‘Project expenses’)?
• ‘Employee Benefits expenses’ are 33% of the total. They cover 2.53 full-time equivalent staff, which is an average of $122.2K p.a.
• CMAA do not explain the distinction between ‘Administration expenses’ and ‘Management expenses’.
• There is no relationship between this list and the list of programs (‘Context’, above).

Charity comments

1. The financial statements you have made are largely opinion. Some items are addressed in the annual reports in the about us section.  Our Accountants and auditor stand by their reports.

Reviewer’s response

Yes, all our comments on the financial statements are our opinion. But an opinion based on a comparison of the law and what’s in the statements. And supported by other expert opinion^[16].

No amount of information in an annual report can, legally, make up for a lack of information presented to achieve a true and fair view in the financial statements.

1. We will review the statements about the financial reports, but stand by our audited accounts and auditor.  The item of staff costs and ratios is an incorrect assumption on your part as we had a reduction in staffing during the year.

Reviewer’s response

It might be wise to wait for the result of the review of the comments before giving unqualified support to the accountants and auditors.

The per employee calculation is merely the expense divided by the figure for staff that the charity gives in its AIS 2020.

Directors responsible

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

Phillip Edwards

Penny Mulvey

Stephen O’Doherty

Joshua Crowther

Richard Daniel

Susan Sohn

Stuart Harris

Sam Valich

They are also the current ‘Responsible People’.

Impact

Everything CMAA is doing may be being done ‘properly’^[17], 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 must be performed. There is no mention of evaluations on the website.

Charity response

We sent a draft of this review to the charity. An exchange of emails resulted in the following general comment by the charity, and the specific comments included above:

Firstly, Thank you for raising the issues in your email of June 22^nd, 2021.  We will be using your review as a further checklist for the organisation to continue increasing our levels of excellence. While we concede there are always areas for improvements to be made, we are nevertheless proud that the CMA Standards Council has accredited the organisation to such a high standard.

Secondly, both myself and my board are committed to, and are endeavouring to run the organisation with the utmost of integrity.  For this reason we went through the process in obtaining accreditation with the CMA Standards Council – only the 17^th organisation to do so.  This stated, we do take your review seriously and thank you for the items raised.  We are committed to working our way through them.

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. Focus on the nature of the charity’s work, its beneficiaries and the impact the charity is having in the community. Is it clear what the charity is trying to achieve and how its activities work towards its objectives? Would you like to spend your money, or time if volunteering, to support these objectives? Is the charity being transparent about its activities? [A section in the article, Donating and Volunteering]. ↑
7. ↑
8. www.asic.gov.au search, confirmed by CMAA’s constitution on the ACNC Register. ↑
9. ↑
10. Quite the opposite in fact: not only does it not prohibit the payment of directors’ fees, it allows them! ↑
11. The fourth name is registered in an historical name for CMAA (Association of Christian Broadcasters Inc, changed on 18 November 2014). ↑
12. The Trustee for CMAA Media Fund, and The Trustee for CMAA Arts Fund ↑
13. The paragraph below, appearing twice, is the only reference on the website to the funds. ↑
14. https://arts.smartygrants.com.au/ROCO20-21: ↑
15. ‘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]. ↑
16. For instance, https://accurri.com/en-au/. ↑
17. The behaviour of its people, its use of money, and how it goes about its business. ↑