Archived: Church Missionary Society Western Australia Inc: charity review

This is a charity review of Church Missionary Society Western Australia Inc (CMS-WA), an organisation that seeks donations online, and is a member of Missions Interlink.

The Australian charities regulator, the ACNC, has a ‘factsheet’ titled Making sure your donation gets to where it needs to.

CMS-WA has again submitted a qualified audit report as part of its accountability to the public (via the ACNC Register). The auditor says that the directors of CMS-WA have ‘determined that it is impracticable to establish control over the collection of gifts and donations prior to entry into its financial records’.

So they can’t be sure that what you give will get into their bank account. End of review.

Still interested to know about CMS-WA? Read on.

Are they responsive to feedback?

• CMS-WA do not seek feedback generally, but they do provide a way for complaints or feedback about privacy
• Other complaints have their own page.
• Accountability is not mentioned on the webpages.
• I sent them a draft of this review. This year, unlike last year, they responded, but not with comments for publication.

Is CMS-WA registered?

• Even though CMS-WA is a branch of Church Missionary Society – Australia Limited (CMS-A), it is an autonomous organisation [Governing document, the ACNC Register].
  • CMS-A is a ‘ministry organisation’ of the Anglican Church.
• It is a Western Australian incorporated association (A0750136M), and a registered charity.
• It trades under two other names, CMS Western Australia and CMS WA. Neither these nor any other name is registered. So it should always be using its full name (including ‘Inc/Incorporated’ on the end).
  • Not like on Facebook, and not like on its webpages.
• CMS-WA operates, per the ACNC Register, only in Western Australia. It doesn’t explain why it has no fundraising licence there.
  • Although it has an online request for donations, it is collecting for another organisation (CMS-A), so perhaps that explains the lack of fundraising licences in the other states that have a licensing regime for charities.

What do they do?

• See the main menu headings on their webpages.
• CMS-WA says, on the ACNC Register, that it does not operate overseas. What about its missionaries?

Do they share the Gospel^[1]?

• Only if they have one or more missionaries who are proselytizing rather than working with believers.

What impact are they having?

• No information found.

What do they spend outside the costs directly incurred in delivering the above impact, that is, on administration?

• If ‘impact’ is defined as ‘Funds remitted to CMS-Aust’, then 48% goes to ‘administration’.
  • However, we know from the Financial Report of other branches, for instance Tasmania, that this figure includes a contribution to CMS-A’s overhead. The figure for administration is therefore higher than 48%.

Do they pay their directors?

• The CMS-WA governing document does not prohibit this.
• Unless this is included in ‘Staffing Expenses’, it appears that no such payment is made.

Can you get a tax deduction?

• Not for a donation to CMS-WA.
  • Nevertheless, the giving page that they use is, without explanation, the one belonging to CMS-A, and it does offer tax-deductible giving.

Is their online giving secure?

• Security is not mentioned.

Where are your (net) donations sent?

• The only obvious remittance of money in the expenses is the item ‘Funds remitted to CMS-Aust’. This is $150K, or 52% of expenses.
  • We are not told the reason for this remittance.
  • The same amount is shown as ‘Grants and donations made for use in Australia’ in the AIS 2017. With the revenue being ‘General missionary support’, one would expect the money to end up overseas.

Is their reporting up-to-date?

• Yes (lodged seven months after their year-end, on the second last day, and over a month later than last year).
  • If you are considering a large donation, I would ask for more up-to-date financial information – the accounts are for a year end that is now nearly 12 months ago.

Does their reporting comply with the regulator’s requirements?

• AIS 2017: No
  • If by ‘Other names’ the ACNC includes unregistered names by which the charity is known by, then two are missing.
  • CMS-WA’s objectives are described instead of activities.
  • No outcomes are reported.
  • With an online invitation to give, they do intend to fundraise.
• Financial Report 2017: No.
  • Two of the four compulsory financial statements are again missing.
  • Most of the required Notes are again missing.
  • The Income Statement still uses a long out-of-date format (and is therefore incorrectly titled and missing a key element).
  • The ‘Responsible persons’ declaration does not comply with the ACNC’s requirements.
  • The audit is deficient (see below).
  • The directors do not explain why they continue to believe that they cannot institute controls over gifts and donations.
    • The Treasurer told the AGM [Annual Report, the Register] that the audit qualification ‘is something that is (sic) we will encounter when cash is handed to us and processed at a later time.’ This is not true.
  • There is no explanation as to why revenue includes tax-deductible donations when CMS-WA is not entitled to receive tax-deductible donations.
  • Without explanation, the directors believe that a special purpose financial report is acceptable. This choice allows them to make less than a full disclosure about CMS-WA’s finances and operations, and is implicitly a statement that any current or prospective user can command the preparation of a financial report tailored to their needs. With overseas missionaries, 82 staff [AIS 2017], a 20% increase in membership this year and 39 churches visited in 2017 [Annual Report, the Register], and an online invitation to give, this is hard to see.
  • The report does not explain the relationship between CMS-WA and CMS-A, something that is integral to understanding the accounts.
    • For instance, why are funds remitted to CMS-A?
  • The report does not explain the treatment of payments to missionaries compared to payments to employees.
  • ‘Equipment and Furniture’ appears to be still being used even though it has been written off.
  • There is no explanation for 45% of the liabilities, the ‘Other liabilities’. Or for the 314% increase in that item.

What did the auditor say about the last financial statements?

• The auditor, Jeffrey T. Byerley, CPA, has again issued a qualified opinion.
  • Read here to see what this means compared to a ‘clean’ opinion.
  • He says that CMS-WA ‘has determined that it is impracticable to establish control over the collection of gifts and donations prior to entry into its financial records’. So, for 95% of the revenue, CMS-WA cannot be sure that what is included in revenue in the financial statements is all that was given by donors.
  • Why is it not possible for CMS-WA to implement the necessary internal controls? Four out of the other five CMS-A branches can do it, including the other one that is audited by this auditor.
• With this size gap in the audit procedures, and the deficiencies described under ‘Financial Report 2017’ (see above), CMS-WA got off lightly – an adverse opinion would seem to be more appropriate.
• Because he is still not a registered company auditor, the audit has again been done by someone who is not qualified to do it^[2].
• Apart from allowing the accounting choices made by the directors, he has also omitted the obligatory ‘Emphasis of Matter’ paragraph.
• He signed his report before the directors had signed theirs.

What was the financial situation shown by that Report?

• Within the limitations of the Report submitted (see above) –
  • The surplus as a percentage of income decreased from 27% to 20%.
  • ‘Staffing expenses’ again rose, from 31% of expenses to 34%.
  • Even though liabilities rose markedly – see ‘Financial Report 2017’ above – both short-term and long-term financial structure are sound.
  • There is no explanation of why 19 months of revenue is held in cash and cash equivalents.

If a charity, is their information on the ACNC Register complete/correct?

• No
  • The selection of a ‘Entity Subtype’ has been overdue since 30 June 2015.
  • If by ‘Other names’ the ACNC includes unregistered names by which the charity is known by, then two are missing.
  • ‘Date Established’ is blank.
  • ‘Who the Charity Benefits’ is blank.
  • By far the largest revenue item is ‘General missionary support’. When, then, is ‘Operates in (Countries) blank?

What choices do you have in how your donation is used?

• In one sense, you have no choice – it all goes to another charity, CMS-Australia.
• These are the choices given by CMS-A:
  • ‘General Missionary Support’
  • ‘General Tax Deductible (sic) Gift’
  • ‘A particular worker’ (with a dropdown listing all the workers)
  • ‘Other’
    • This includes one with CMS-WA in its title, ‘CMS WA Membership Contribution’.

Who are the people controlling the organisation?

• There is no mention of the board on CMS-WA’s webpages.
• From the ACNC Register (under ‘Responsible Persons’) it is
  • Naomi Flavell
  • Bradley Galvin
  • David Greeff
  • Matthew Lovell
  • Graham McKay
  • Andrew Mills
  • Stephen Pivetta
  • Hawker Roslyn (round the wrong way?)
  • Peter Schendzielorz

To whom is CMS-WA accountable?

• Nothing claimed on the webpages.
• As a (registered) charity, to the ACNC.
• And to the Western Australia regulator of incorporated associations.
• Its membership of Missions Interlink comes with accountability.
  • For one view on the strength of this accountability, see the section Activities in this review.

1. “Good living and social concern are important [to the cause of evangelism], but they are not uniquely Christian graces…I’ve met a lot of fine Hindus, Muslims and atheists. Just living the life is not going to bring someone to Christ. There is much more to it than that. We must help people, certainly, but we must also share with them why we are motivated to do so. We must stand against injustice, poverty and need, but we must at the same time point to the One who brings justice and who can meet the deepest need. Until they know our reasons, how can they come to know our Lord?” [Dan Armstrong, the Fifth Gospel: The Gospel According to You, Anzea Books, pp. 13-14. ↑
2. Because Western Australian incorporated associations don’t need to submit a financial report to the regulator, the ACNC’s concession to incorporated associations doesn’t apply. ↑