Archived: Church Missionary Society Western Australia Inc: mini charity review

Mini charity review of Church Missionary Society Western Australia Inc (CMS-WA), an organisation that seeks donations online^[1], and is exempt from Australian income tax via its membership of Missions Interlink. (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

For the previous review, see here.

Are they responsive to feedback?

• I sent them a draft of this review on 21 August 2017. They…did not respond.

Is CMS-WA registered?

• As a charity, yes
• Even though CMS-WA is a branch of CMS Australia, it is an organisation in its own right, a Western Australian incorporated association (A0750136M).
• No business names are held, so CMS-WA should always be using its full name.
  • Not like on Facebook.
• CMS-WA operates, per the ACNC Register, only in Western Australia. It does not have a fundraising licence there. I can see no reason why it would be exempt.
  • As it does not raise money on its website – at least not in its own name – the question of licences in the other five states that have a licensing regime does not arise.

What do they do?

• See the third section here.
• CMS Australia is a ‘ministry organisation’ of the Anglican Church, so presumably that relationship includes the branches like CMS-WA.
• In the AIS 2016:
  • CMS-WA engages with individuals and churches to partner with them to share the great news that God wants His eternal kingdom to be made up of all cultures without discrimination. Our visits to churches and through our 2 events are opportunities to teach that God’s plan it to partner with us to share this great news. CMS is a tax deductible gift recipient for provision of overseas aid in several of the countries we send missionaries to as well as in some work amongst indigenous folk.
    • Note the switch mid-field from CMS-WA to ‘CMS’ (CMS Australia). CMS-WA is not entitled to receive tax deductible gifts.
• CMS-WA, per the ACNC Register, does not operate overseas.
  • Clause 14 of the Constitution shows that CMS-WA recruits missionaries for CMS-Australia.

Do they share the Gospel ^[2]?

• From their ‘Events’, it appears not.

What impact are they having?

• Nothing found.

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

• If ‘impact’ is defined as the contribution to ‘head office’, CMS Australia, plus ‘Events Expenses’, then 44% goes to ‘administration’.

Do they pay their directors?

• It appears not.

Can you get a tax deduction?

• No
  • The ‘Donate’ button in the footer of its webpages leads to a CMS Australia giving facility. Some giving there attracts a tax deduction.

Is their online giving secure?

• NA
  • CMS Australia (see above) does not mention security.

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 $134K, or 52% of expenses.
  • The same amount is incorrectly shown as ‘Grants and donations made for use outside Australia’ in the AIS 2016.

Is their reporting up-to-date?

• Yes (six months after their year-end, a month earlier than last year).

Does their reporting comply with the regulator’s requirements?

• AIS 2016: No
  • The description of activities mixes the activities of CMS Australia with those of CMS-WA.
  • No outcomes are reported.
  • The ‘Type of financial statement’ is incorrect.
  • ‘Other income…’, ‘Employee expenses’, and ‘Grants and donations made…’ do not match the same items in the Income Statement.
• Financial Report 2016: No
  • Most of the issues with the financial statements last year remain.
  • It appears that two pages have been accidentally omitted, including the all-important Note 1.
  • Even with those pages, the Report would fall far short of the ACNC’s expectations.
    • There is no ‘Responsible persons’ declaration.
    • The auditor does not have the professional registration that is required to do this audit.
    • Two of the four compulsory financial statements are missing.
    • Most of the required Notes are missing.
    • The Income Statement uses a long out-of-date format (and is therefore incorrectly titled and missing a key element).
  • For the same reasons, the Report falls far short of any reasonable interpretation of Mission Interlink’s requirement that CMS-WA ‘have available for its members and supporters a clear and appropriate financial  statement which has been approved by its auditor’ [Standards Statement, 4.1].
  • There is no explanation as to why revenue includes tax-deductible donations when CMS-WA is not entitled to receive tax-deductible donations.
  • 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. Do the directors realise they are saying this?
  • The report does not explain the relationship between CMS-WA and CMS Australia, something that is integral to understanding the accounts.

What was the financial situation shown by that Report?

• The surplus as a percentage of income increased markedly, from 11% to 27%.
• A major contributor to this was the fact that much less money was donated (sent to CMS Australia).
• ‘Staffing expenses’ rose from sharply from 23% of expenses to 31%.
• With only $25K of liabilities, both short-term and long-term financial structure are sound.

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 92% 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 Australia 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 2016’ (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^[3].
• Apart from allowing the accounting choices made by the directors, he has also omitted the obligatory ‘Emphasis of Matter’ paragraph.

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

• No
  • The selection of a ‘Entity Subtype’ has been overdue since 30 June 2015.
    • ‘Advancing religion’ would seem to be the right selection according to the constitution:
      • The objects of the Branch are to carry out the principles and objects of CMS-A [The Church Missionary Society – Australia Limited] within the State of Western Australia, namely to work for the coming of God’s Kingdom through the proclamation of the Gospel of Christ throughout the world in fellowship with local churches…
  • By far the largest revenue item is ‘General missionary support’. When, then, is ‘Operates in (Countries) blank?
  • ‘Date Established’ is blank.

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

• NA
  • If you use the ‘Give’ button in the footer of their webpages, CMS Australia has the following choices:
    • ‘General Missionary Support’
    • ‘General Tax Deductible Gift’
    • ‘A particular worker’
    • ‘Other – Choose an option’
      • These include two with CMS-WA in the title:
        • ‘CMS WA Lasting Hope Appeal 2017’
        • ‘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
  • Canon Raymond Arthur
  • Naomi Flavell
  • Bradley Galvin
  • Khim Harris
  • Caitlin Healy
  • Gregory Heath
  • Matthew Lovell
  • Stephen Pivetta
  • Hawker Roslyn (round the wrong way?)
  • Peter Schendzielorz

To whom is CMS-WA accountable?

• Nothing claimed on the website.
• Because of its income tax exemption, CMS-WA is accountable to Missions Interlink.
  • For one view on the strength of this accountability, see the section Activities in this review.
• As a registered charity, CMS-WA is accountable to the ACNC.
• And to the Western Australia regulator of incorporated associations.

1. CMS-WA does not have its own website, just a few pages on the CMS Australia site. The ‘Donate’ button in the footer of its webpages leads therefore to a CMS Australia giving facility. ↑
2. “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. ↑ ↑
3. 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. ↑