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 SA & NT’ is one such member^[4].

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

Donors

Given what Missions Interlink does, ‘CMS SA & NT 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 SA & NT, 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; going to just ‘CMS’ still gives no result. Expanding ‘CMS’ to ‘Church Missionary Society’ gives, on the second page of results, The Church Missionary Society – South Australia Inc. (CMS SA). Nothing with the Northern Territory (NT) in it though.

A charity shouldn’t make it so hard for it to be found on the Register^[6].

Other registrations

• Both the website and the Facebook page are in the name ‘CMS SANT’. This name is still, three years later, not registered^[7]. It is therefore legally only allowed to use only its full name in public (including ‘Inc/Incorporated’ on the end).
• CMSSA operates in South Australia and the Northern Territory. But it still, three years later, doesn’t have the registration required to do business out of South Australia (an ARBN).
• It says, in the AIS 2020, that it intends to fundraise, and it has an online invitation to give. However, it is still, three years later, not registered to fundraise in South Australia (there is no licensing regime in the Northern Territory). Nor in Tasmania, Victoria, NSW or Queensland.

Question 2

There is nothing to suggest that CMS SA 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, three years later, nothing on the giving pages (for instance) about the security of your information.

Question 4

The Australian Business Register (linked from CMS SA’s ACNC Register record), says that the charity is not entitled to receive tax deductible gifts. We have seen above, however, that CMS SA 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, three years later, no explanation given for this.

Question 5  How are donations used

Context

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 still mix information about CMS Australia and CMS SA^[8]. And ‘What We Do’ on the website is still about CMS Australia, not CMS SA. The relationship between the two bodies is still not explained on the CMS SA website.

The ACNC information says that CMS SA operates overseas. But the missionaries it found ‘belong’ to CMS Australia, not CMS SA, and it doesn’t send any money overseas^[9].

From the Directors’ Report [Financial Report] we get both the relationship and what CMS SA does within that relationship:

A user should haven’t to go inside the Financial Report to find out this basic information about the charity.

Sharing the Gospel^[10]

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. This Report includes the results of an audit.

The audit

What the auditor found caused him to include three ‘Emphasis of Matter’ paragraphs in his report. Such a paragraph is required

If the auditor considers it necessary to draw users’ attention to a matter presented or disclosed in the financial report that, in the auditor’s judgement, is of such importance that it is fundamental to users’ understanding of the financial report…(Ref: Para. A5–A6) [ASA 706, www.auasb.gov.au].

His first one reminds the user that special purpose statements have been selected, the second that COVID-19 exists. But it is the third that should concern you. It refers to Note 3(d). This is the relevant paragraph:

Note that this risk only applies to ‘donation revenue that is collected on behalf of the Church Missionary Society – South Australia Inc’.

• The amount that was recorded for this source of revenue is not disclosed.
• CMS SA do not explain why money collected by others, presumably churches, is part of their control environment.
• How is it that four out of the other five branches can avoid getting this paragraph in their audit report?

Whatever the validity of the directors’ concern, the auditor has incorrectly reported it:

It is not, as they say, all ‘funds from donations and fundraising’. This is more than the donations collected by others. The auditor overstates the caution.

The directors’ declaration about the statements

The directors signed a declaration [Statement by the Board of Directors] 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 SA’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. You are ‘potentially interested in the information provided in general purpose financial reports’^[11].

With revenue of $917K (including $510K of donations from individuals over two states), 40 enquiries about becoming a CMS missionary during the year, professional management, the choice of special purpose statements is highly questionable.

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

The auditor, B Rothman^[12] (sic), for Dry Kirkness, 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^[13]:

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.

Other issues

• The expenses are classified inconsistently.
• The audit fee is not disclosed.

Who was responsible?

Here are the directors who approved the Financial Report 2020:

Alison Back

Is it this Alison Back?

Benjamin Harrington

Robert Haynes

Andrew Jackson

Christopher Jolliffe

Rick Maude

Daniel Peet

Tamra Purton

Constantine Papas

Kristan Slack

Mark Peterson

The current members are not shown on the website. From the ACNC Register, Peterson, Purton, and Jackson are no longer, and Rebecca Duff has joined.

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

The use of your donations

If you are still prepared to consider a donation to CMS SA, here is how the donations were used:

Cash spent

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

This presentation doesn’t comply with the relevant Accounting Standard. Even if it were adjusted to comply, we don’t have enough information to know where the cash went.

Resources consumed (i.e., accrual)

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):

‘CMS-A expenses’

• Here’s the Note referred to above:

• There is still no comment about the control (if any) that CMS SA has over the amount that has to be paid to CMS Australia.
• Here’s a listing of the missionaries. The Directors’ Report says that there were 17 at year end, so couples must be counted as two. The total paid to CMS Australia represents $28K per missionary.
• For the destination of the CMS SA money, you would need to check the CMS Australia Financial Report.

Other expenses

• ‘Domestic gospel worker expenses’ does not match the description of what CMS SA does.
• The ‘Staff Employment’ $220K represents $31K per employee. Seems low.

Impact^[14]

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…

If we assume that it is money transferred to missionaries that are CMS SA’s direct costs, then ‘administation’, the remaining costs, is 61% of the total.

Charity response

• CMS SA still does not seek feedback generally (only a way to complain or give feedback about privacy).
• CMS SA only invites complaints about its ‘safe ministry and professional standards’.
• Accountability is not mentioned on the website.
• However, as a Member of Missions Interlink, it 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, they contined their practice of past years in not responding.

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. The solution is simple: use the ‘Also known as’ section on the Register. ↑
7. CMS SA has ‘Summer Encounter’ registered. (And ASIC has two records the same for that registration.) ↑
8. This includes ‘Charity programs’, which shows just one program, ‘Overseas mission’. (CMS Australia is the one that contracts/employs the missionaries and pays them while overseas, not CMS SA. ↑
9. The ACNC Register is clearly wrong in giving no places in Australia where CMS SA operates. ↑
10. ‘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]. ↑
11. From Objective of General Purpose Financial Reporting (SAC2), www.aasb.gov.au ↑
12. He says that he is a partner of Dry Kirkness, but he is not shown on their website, partner or anything else. ↑
13. Enhancing Not-for-Profit Annual and Financial Reporting, March 2013, accessed from their website March 2020. ↑
14. 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. ↑