This is a review^[1] in the series ‘Members of Missions Interlink’, Missions Interlink being ‘the Australian network for global mission’^[2] (and a means for a Member to get income tax exemption when it might not otherwise be available^[3]). ‘CMS Qld & NNSW’ is one such member^[4].

One the website linked from the Missions Interlink they seek online donations.

Donors

Given what Missions Interlink does, ‘CMS Qld & NNSW’ is probably a charity.

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

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

Here’s the results for ‘CMS Qld & NNSW’, with #5 supplemented by the essentials of the ACNC’s ‘What should I consider when deciding which charity to support?’ ^[5]

Question 1

A search on the ACNC Register of charities gives no result in that name; similarly for the name of the website, ‘CMS QNNSW’. Going to just ‘CMS’ still gives no result. Expanding ‘CMS’ to ‘Church Missionary Society’ gives a registered charity in the name The Church Missionary Society Queensland with Northern NSW (CMS QNNSW).

A charity shouldn’t make itself so hard to find on the Register^[6]. ()

Other registrations

• CMS QNNSW, a Queensland incorporated association, is very unusual in that it appears to have been registered without the normally obligatory ‘Inc’ or ‘Incorporated’ on the end of its name.
• CMS QNNSW has the ARBN registration that it requires because it operates across states.
• CMS QNNSW has the necessary Queensland fundraising registration. But not in Victoria, New South Wales or Tasmania.
• It is still missing a business name registration for both ‘CMS QNNSW’ and ‘CMS QLD WITH NNSW’ (website), and CMS QLD with Northern NSW (Facebook). It should therefore, to be legal, trade only its full name.

Question 2

There is nothing to suggest that CMS QNNSW fundraises door-to-door or in the street.

Question 3

The web address begins with a closed padlock symbol, so the website is secure [the ACNC article above]. But there is still nothing on the giving pages (for instance) about the security of your information.

Question 4

The Australian Business Register (linked from CMS QNNSW’s ACNC Register record), says that the charity is not entitled to receive tax deductible gifts. We have seen above, however, that CMS QNNSW is a ‘legitimate charity’.

The Register information does not match the information on the giving pages (for instance):

This is because, as you can see from the bottom of the above page, you are giving to another charity, Church Missionary Society – Australia Ltd (CMS Australia).  There’s still no explanation given for this.

Question 5  How are donations used

Context^[7]

Here’s how, from the ACNC Register, that translates into programs:

The usual places one goes on the ACNC Register to find out what a charity does, the charity’s record and its AIS, are no good in this case because they mix information about CMS Australia and CMS QNNSW. And ‘What We Do’ on the website is about CMS Australia, not CMS QNNSW.

The relationship between the two bodies is still not explained on the CMS QNNSW website. Here it is from the Branch Council’s Report:

But one shouldn’t have to go inside the Financial Report to find this basic information.

Sharing the Gospel^[8]

No – see above. (The missionaries are employed/contracted by CMS Australia.)

Financial Reporting

The account of how a charity uses donations is the Financial Report on the ACNC Register.

The directors signed a declaration [Statement by Members of the Council] Financial Report 2020] that

For this to be true, the directors must have chosen the correct type of financial statements. They chose special purpose financial statements over general purpose. These are only relevant where all the users can ring the CMS QNNSW’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. Users are then ‘potentially interested in the information provided in general purpose financial reports’^[9].

With revenue of $1.66 million, including $1.26 million of donations from individuals and churches across two states, government grants, professional management, 100 volunteers [AIS 2020], and membership sought from the public, the choice of special purpose statements is ludicrous .

The directors’ false declaration

The directors (see below for who they were) have therefore made a false declaration.

The auditor, Daniel Gill, for Pilot Partners, agreed with the directors’ choice. This again is an indefensible decision, both because of the argument given above, and this opinion of his professional body^[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^[11].

Who was responsible?

From the Branch Council’s Report, these are the people responsible for the Financial Report 2020:

Mark Fairhurst

John Hagidimitrou

Martin Hawkins

Audrey Jordan

Peter Kidd

Colin Law

Johnson Leung

Sheila Milton

Joy Palmer

Susan Smith

Robert Stanley

Mike Uptin

Simon Waller

Selena Yen

Is it this Selena Yen?

The current members are not shown on the CMS QNNSW website. The listing on the ACNC Register shows that Uptin has gone from the board, and Tharindu Fernando and Tory Cayzer have joined.

The Board is responsible to the membership. The number of members is still not disclosed.

The use of your donations

From the Statement of Cash Flows (with last year in the second column):

This level of disclosure may be legal, but it’s arguably not ‘a true and fair view’, and definitely not helpful.

This, from the Statement of Profit or Loss and Other Comprehensive Income, is how the activities translated into expenses (with last year in the second column):

‘Missionary Support to CMS – Australia’

• There is still no explanation of this item.
• Or the relationship between this and the two other ‘Missionary’ expenses.
• There is still no comment about the control (if any) that CMS QNNSW has over the amount that has to be paid to CMS Australia.
• The website shows four couples and two singles as missionaries. The total paid to CMS Australia represents $64K per couple.
• For the destination of the CMS QNNSW money, you would need to check the CMS Australia Financial Report.

Other issues with the Financial Report

The most prominent thing on the cover of the Financial Report continues to be the logo of the auditor, Pilot Partners, and a large image that appears to be associated with them. Then every page of the Report, except the first, has the same logo at the top of the page. At best this suggests advertising by the auditor; at worst it suggests that the Report was prepared by him. Which is illegal. Either way, as the Report belongs to CMS QNNSW, and independence of the auditor from the client must be both actual and perceived, it is inappropriate.

Impact^[12]

Nothing systematic found.

It is never legitimate to judge a charity solely by its administration costs as a percentage of its total costs. However, in the absence of information on impact, the cost of ‘administration’ (including fundraising) becomes more relevant. If we assume that it is money transferred to CMS Australia – presumably to pay missionaries – that are CMS QNNSW’s direct costs, then ‘administation’, the remaining costs, is 78% of the total.

However, we know from the Financial Report of other branches, for instance Tasmania, that this figure includes a contribution to CMS Australia’s overhead. The figure for administration is therefore higher than 78%.

Charity response

• Although they don’t specifically mention feedback, CMS QNNSW say ‘We’d love to hear from you!
• Accountability is not mentioned on the webpages.
• As a Member of Missions Interlink, CMS QNNSW has accepted a set of standards, the introduction to which includes this statement:

We would therefore expect a response to a draft of this review. However, like last year, they did not respond.

1. See here for the previous review. ↑
2. https://missionsinterlink.org.au/about/ ↑
3. ↑
4. ↑
5. 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]. ↑
6. It can avoided by using the ‘Also known as’ section on the Register. ↑
7. The usual places one goes on the ACNC Register to find out what a charity does, the charity’s record and its AIS, are no good in this case because they mix information about CMS Australia and CMS QNNSW. And ‘What We Do’ on the website is about CMS Australia, not CMS QNNSW. The relationship between the two bodies is still not explained on the CMS QNNSW website. ↑
8. ‘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]. ↑
9. From Objective of General Purpose Financial Reporting (SAC2), www.aasb.gov.au ↑
10. Enhancing Not-for-Profit Annual and Financial Reporting, March 2013, accessed from their website March 2020. ↑
11. In their AIS 2020 they say they didn’t have any related party transactions. What about CMS – Australia? ↑
12. The ACNC has previously – the Fact Sheet is no longer on the site – explained impact this way: “Every charity has a mission that is associated with producing a public benefit. As this mission is pursued, the changes produced in individuals and their communities can be referred to as the charity’s ‘impact.’ If you are donating to a charity, you may wish to make sure that your donation is creating the greatest impact possible.’ There is no reason why this wouldn’t still be their view. ↑

This is a review^[1] in the series ‘Members of Missions Interlink’, Missions Interlink being ‘the Australian network for global mission’^[2] (and a means for a Member to get income tax exemption when it might not otherwise be available^[3]). ‘CMS Qld & NNSW’ is one such member^[4].

One the website linked from the Missions Interlink they seek online donations.

Donors

Given what Missions Interlink does, ‘CMS Qld & NNSW’ is probably a charity.

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

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

Here’s the results for ‘CMS Qld & NNSW’, with #5 supplemented by the essentials of the ACNC’s ‘What should I consider when deciding which charity to support?’ ^[5]

Question 1

A search on the ACNC Register of charities gives no result in that name; similarly for the name of the website, ‘CMS QNNSW’. Going to just ‘CMS’ still gives no result. Expanding ‘CMS’ to ‘Church Missionary Society’ gives a registered charity in the name The Church Missionary Society Queensland with Northern NSW (CMS QNNSW).

A charity shouldn’t make itself so hard to find on the Register^[6]. ()

Other registrations

• CMS QNNSW, a Queensland incorporated association, is very unusual in that it appears to have been registered without the normally obligatory ‘Inc’ or ‘Incorporated’ on the end of its name.
• CMS QNNSW has the ARBN registration that it requires because it operates across states.
• CMS QNNSW has the necessary Queensland fundraising registration. But not in Victoria, New South Wales or Tasmania.
• It is still missing a business name registration for both ‘CMS QNNSW’ and ‘CMS QLD WITH NNSW’ (website), and CMS QLD with Northern NSW (Facebook). It should therefore, to be legal, trade only its full name.

Question 2

There is nothing to suggest that CMS QNNSW fundraises door-to-door or in the street.

Question 3

The web address begins with a closed padlock symbol, so the website is secure [the ACNC article above]. But there is still nothing on the giving pages (for instance) about the security of your information.

Question 4

The Australian Business Register (linked from CMS QNNSW’s ACNC Register record), says that the charity is not entitled to receive tax deductible gifts. We have seen above, however, that CMS QNNSW is a ‘legitimate charity’.

The Register information does not match the information on the giving pages (for instance):

This is because, as you can see from the bottom of the above page, you are giving to another charity, Church Missionary Society – Australia Ltd (CMS Australia).  There’s still no explanation given for this.

Question 5 How are donations used

Context^[7]

Here’s how, from the ACNC Register, that translates into programs:

The usual places one goes on the ACNC Register to find out what a charity does, the charity’s record and its AIS, are no good in this case because they mix information about CMS Australia and CMS QNNSW. And ‘What We Do’ on the website is about CMS Australia, not CMS QNNSW.

The relationship between the two bodies is still not explained on the CMS QNNSW website. Here it is from the Branch Council’s Report:

But one shouldn’t have to go inside the Financial Report to find this basic information.

Sharing the Gospel^[8]

No – see above. (The missionaries are employed/contracted by CMS Australia.)

Financial Reporting

The account of how a charity uses donations is the Financial Report on the ACNC Register.

The directors signed a declaration [Statement by Members of the Council] Financial Report 2020] that

For this to be true, the directors must have chosen the correct type of financial statements. They chose special purpose financial statements over general purpose. These are only relevant where all the users can ring the CMS QNNSW’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. Users are then ‘potentially interested in the information provided in general purpose financial reports’^[9].

With revenue of $1.66 million, including $1.26 million of donations from individuals and churches across two states, government grants, professional management, 100 volunteers [AIS 2020], and membership sought from the public, the choice of special purpose statements is ludicrous .

The directors’ false declaration

The directors (see below for who they were) have therefore made a false declaration.

The auditor, Daniel Gill, for Pilot Partners, agreed with the directors’ choice. This again is an indefensible decision, both because of the argument given above, and this opinion of his professional body^[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^[11].

Who was responsible?

From the Branch Council’s Report, these are the people responsible for the Financial Report 2020:

Mark Fairhurst

John Hagidimitrou

Martin Hawkins

Audrey Jordan

Peter Kidd

Colin Law

Johnson Leung

Sheila Milton

Joy Palmer

Susan Smith

Robert Stanley

Mike Uptin

Simon Waller

Selena Yen

Is it this Selena Yen?

The current members are not shown on the CMS QNNSW website. The listing on the ACNC Register shows that Uptin has gone from the board, and Tharindu Fernando and Tory Cayzer have joined.

The Board is responsible to the membership. The number of members is still not disclosed.

The use of your donations

From the Statement of Cash Flows (with last year in the second column):

This level of disclosure may be legal, but it’s arguably not ‘a true and fair view’, and definitely not helpful.

This, from the Statement of Profit or Loss and Other Comprehensive Income, is how the activities translated into expenses (with last year in the second column):

‘Missionary Support to CMS – Australia’

• There is still no explanation of this item.
• Or the relationship between this and the two other ‘Missionary’ expenses.
• There is still no comment about the control (if any) that CMS QNNSW has over the amount that has to be paid to CMS Australia.
• The website shows four couples and two singles as missionaries. The total paid to CMS Australia represents $64K per couple.
• For the destination of the CMS QNNSW money, you would need to check the CMS Australia Financial Report.

Other issues with the Financial Report

The most prominent thing on the cover of the Financial Report continues to be the logo of the auditor, Pilot Partners, and a large image that appears to be associated with them. Then every page of the Report, except the first, has the same logo at the top of the page. At best this suggests advertising by the auditor; at worst it suggests that the Report was prepared by him. Which is illegal. Either way, as the Report belongs to CMS QNNSW, and independence of the auditor from the client must be both actual and perceived, it is inappropriate.

Impact^[12]

Nothing systematic found.

It is never legitimate to judge a charity solely by its administration costs as a percentage of its total costs. However, in the absence of information on impact, the cost of ‘administration’ (including fundraising) becomes more relevant. If we assume that it is money transferred to CMS Australia – presumably to pay missionaries – that are CMS QNNSW’s direct costs, then ‘administation’, the remaining costs, is 78% of the total.

However, we know from the Financial Report of other branches, for instance Tasmania, that this figure includes a contribution to CMS Australia’s overhead. The figure for administration is therefore higher than 78%.

Charity response

• Although they don’t specifically mention feedback, CMS QNNSW say ‘We’d love to hear from you!
• Accountability is not mentioned on the webpages.
• As a Member of Missions Interlink, CMS QNNSW has accepted a set of standards, the introduction to which includes this statement:

We would therefore expect a response to a draft of this review. However, like last year, they did not respond.

1. See here for the previous review. ↑
2. https://missionsinterlink.org.au/about/ ↑
3. ↑
4. ↑
5. 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]. ↑
6. It can avoided by using the ‘Also known as’ section on the Register. ↑
7. The usual places one goes on the ACNC Register to find out what a charity does, the charity’s record and its AIS, are no good in this case because they mix information about CMS Australia and CMS QNNSW. And ‘What We Do’ on the website is about CMS Australia, not CMS QNNSW. The relationship between the two bodies is still not explained on the CMS QNNSW website. ↑
8. ‘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]. ↑
9. From Objective of General Purpose Financial Reporting (SAC2), www.aasb.gov.au ↑
10. Enhancing Not-for-Profit Annual and Financial Reporting, March 2013, accessed from their website March 2020. ↑
11. In their AIS 2020 they say they didn’t have any related party transactions. What about CMS – Australia? ↑
12. The ACNC has previously – the Fact Sheet is no longer on the site – explained impact this way: “Every charity has a mission that is associated with producing a public benefit. As this mission is pursued, the changes produced in individuals and their communities can be referred to as the charity’s ‘impact.’ If you are donating to a charity, you may wish to make sure that your donation is creating the greatest impact possible.’ There is no reason why this wouldn’t still be their view. ↑