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 Western Australia’ is one such member^[4].

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

Donors

Given what Missions Interlink does, ‘CMS Western Australia’ 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 Western Australia’, 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 ‘CMS WA’. 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 Western Australia Inc. (CMS WA).

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

Other registrations

• Both the website and the Facebook page are in the name ‘CMS WA’. This name is still not registered. It is therefore legally only allowed to use only its full name in public (including ‘Inc/Incorporated’ on the end.
• CMS WA has an online invitation to give^[7]. However, it is still not registered to fundraise in Western Australia. Nor in Queensland, Tasmania, Victoria or New South Wales.

Question 2

There is nothing to suggest that CMS WA 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 WA’s ACNC Register record), says that the charity is not entitled to receive tax deductible gifts. We have seen above, however, that CMS WA 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:

CMS-WA works with churches to set apart long-term workers who cross cultures to share the gospel of our Lord Jesus Christ.

‘Charity programs’ on the ACNC Register and the AIS 2020 has just one program, ‘SummerFocus’.

That’s the extent of the public information on what CMS WA does^[8].

Sharing the Gospel^[9]

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:

There may well be limitations, but there is nothing in Note 2 about them. (It could be that the auditor is confused with another audit he did, the audit of another CMS Australia branch, CMS SA).

How is it that four of the other five branches are able to avoid this paragraph?

The directors’ declaration about the statements

The directors signed a declaration [Responsible Persons’ Declaration] 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 WA’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 then ‘potentially interested in the information provided in general purpose financial reports’^[10].

With revenue of $836K (including $790K of donations from individuals (at least hundreds), government grants, professional management, 20 volunteers, and membership open to the public, 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^[11] (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^[12]:

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.

Who was responsible?

We are not told who approved the Financial Report 2020, but it is likely to be most, if not all, of the following people on the Board now (or at least who is shown on the ACNC Register now – the directors are not shown on the CMS WA website):

• Naomi Flavell
• David Greeff
• Graham McKay
• Andrew Mills
• Roslyn Hawker
• Peter Schendzielorz
• Evan McFarlane
• Quicke Paul (round the wrong way?)
• Thorburn Sarah (round the wrong way?)

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):

It may be legal, but it’s 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):

• There is no explanation of the ‘Funds remitted to CMS Australia’ item.
• There is still no comment about the control (if any) that CMS WA has over the amount that has to be paid to CMS-A.
• The website shows three missionary couples. The total paid to CMS Australia represents $154K per couple.
• For the destination of the CMS WA money, you would need to check the CMS Australia Financial Report.

Impact^[13]

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 WA’s direct costs, then ‘administation’, the remaining costs, is 67% 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 67%.

Charity response

• CMS WA do not seek feedback generally, only a way for people to complain about privacy (see ‘Privacy policy’ here).
• Other complaints have their own page.
• Accountability is not mentioned on the webpages.
• 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. 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. The solution is simple: use the ‘Also known as’ section on the Register. ↑
7. It’s response in its AIS 2020 that it doesn’t intend to fundraise is therefore incorrect. ↑
8. ‘What We Do’ on the website is still about CMS Australia, not CMS WA. The relationship between the two bodies is still not explained on the CMS WA website. Unlike the other CMS Australia branches, there is nothing on either of these topics in the Financial Report 2020. ↑
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. He says that he is a partner of Dry Kirkness, but he is not shown on their website, partner or anything else. ↑
12. Enhancing Not-for-Profit Annual and Financial Reporting, March 2013, accessed from their website March 2020. ↑
13. 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. ↑