Archived: Mount Tamborine Convention: mini-charity review

Mini-charity review of Mount Tamborine Convention (MTC), an organisation that seeks donations online, and is accredited with the CMA Standards Council (CMASC)^[1] (a foundation member). (Including the answers to the questions that the Australian charity regulator, the ACNC, suggests that you ask.)

Are they responsive to feedback?^[2]

• I sent them a draft of this review. Although they ‘value complaints and feedback as a means of identifying and understanding how we can do things better’, and although their accreditation with the CMASC (above) requires that they ‘respond in a timely and appropriate manner’ to those who submit feedback, I did not get a response.

Is MTC registered?

• As a charity, yes.
• MTC is an incorporated entity, incorporated under The Religious Educational and Charitable Institutions Act of 1861.
  • Both its website and the ACNC Register says that it is a ‘basic religious charity’. Although the two most common types of incorporated entities, companies and incorporated associations, are not eligible for this status (and the consequent concessions), the ACNC says that MTC’s type of incorporation does not disqualify it^[3]. Is this an oversight in the legislation?
• It has three business names: Mount Tamborine Convention Centre, Mount Tamborine Conference Centre, and The Beacon on Tamborine.
• MTC operates, per the ACNC Register, only in Australia, and then only in Queensland. But it seeks donations via the internet. It has a fundraising licence in Queensland, but does not explain why no licence is held in the other states that have a licensing regime.

What do they do?

• There is no description under ‘About us’ on the website, but the main menu says that they run conventions, and implies that they also offer accommodation and meeting venues for hire.
  • The camping site is only available ‘as part of organised conferences and group camp bookings’, but the chalets are available to rent. It is unclear whether other facilities are similarly available.
• They promote, on their site, the camps of various other Christian charities. These are within the ‘MTC precinct’. Does this mean that they are on MTC land? The relationship is not explained.
  • One of these other charities is TLF (Triumphant Life Fellowship).
    • There is no such organisation on the ABN register.
    • The link given leads to a seller of domains.
    • In the annual report the CEO reported that
      • ‘In April 2016 discussions began regarding the possibility of working more closely with TLF. This has now blossomed into a symbiotic relationship where MTC now owns and maintains the land and buildings, with TLC operating as a ministry sub-committee under the umbrella of MTCC.’
      • The information disclosed in the financial statements does not support this statement.
• Their Annual Information Statement 2016 (AIS 2016), under ‘activities and outcomes’, mentions only the conferences they held:
  • Mt (sic) Tamborine Convention held three conventions on its property at Mount Tamborine during 2016 – The Easter Convention, the Spring Holiday Convention and the Senior’s Convention.

Does MTC share the Gospel?^[4]

• Both the conferences planned so far for 2018 appear to be directed at Christians.

What impact are they having?

• No information found.
• MTC present, on their website, the results of some McCrindle research showing the importance of camps to the church generally.
• The terms of MTC’s accreditation with the CMA Standards Council require it to perform regular program evaluations. There is no mention of evaluation on the website.

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

• Although MTC have chosen not to make their financial report available on the ACNC Register (see below), it is included in their MTCC 2016 Annual Report, and that report is available on their website.
• ‘Administration’ is not disclosed.
• And the expenses are not classified so as to allow an estimate.

Do they pay their board members?

• Such payments are allowed by the constitution.
  • They are, however, prohibited under the terms of MTC’s accreditation with the CMA Standards Council [Standard 3.7].
• Whether they were made is not disclosed.

Can you get a tax deduction?

• No

Is their online giving secure?

• Security is not mentioned.

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

• None

Is their reporting up-to-date?

• Yes (six months after year end, three days before the deadline, and at the same time as last year).

What did the auditor say about the last financial statements?

• The auditor, Rod Wallbridge FCA, gave a ‘clean’ opinion.
• However, before you decide how much comfort to take from this opinion
  • Read the next section, and
  • Read about audit opinions here and here.

Does their reporting comply with the regulator’s requirements?

• AIS 2016: Almost – no outcomes are reported
• Financial Report 2016: Yes
  • Because they have a revenue of at least $25oK their size is Medium. Ordinarily this would mean that they must lodge accounts (which have been at least reviewed). However, because they are a ‘basic religious charity’, they are exempt from reporting.
  • They did produce a financial report – it is included in their annual report that is available on their website – and could have lodged this voluntarily, but chose not to.
    • This is contrary to the spirit of the CMA Standards Council’s Standards.
  • They say that the financial statements ‘satisfy the financial reporting requirements of the constitution of [MTC]’. Here’s the relevant clause:
    • ‘On behalf of the MTC Board, the treasurer must, as soon as practicable after the end date of each financial year, ensure a financial statement for its last reportable financial year is prepared’ [Clause 13.2.2].
    • They have produced ‘a financial statement’, but this falls well short of what is required by the Australian Accounting Standards.
    • The auditor, a Chartered Accountant, says that the financial report ‘is prepared, in all material respects, in accordance with applicable Australian Accounting Standards to meet the requirements of the Entity’s constituting Letters Patent.’
    • This is the only reference by MTC, either in the financial report or on the website, to ‘letters patent’.
    • A Letters Patent under the same Act, The Religious Educational and Charitable Institutions Acts, 1861 to 1959, for The Baptist Union of Queensland, has no financial reporting requirements. Nor does the Act. So perhaps we can presume that this is MTC’s situation too?
    • As a Chartered Accountant, the auditor, Rod Wallbridge, is therefore obliged to follow the Australian Auditing Standards. These in turn require him to expect MTC to produce a full set of financial statements that are compliant with the Australian Accounting Standards.
    • MTC haven’t done this, falling short by quite a distance.
      • This means that these financial statements do not meet the requirements of their partnership with the CMA Standards Council (Standard 6.1].

What financial situation was shown in the financial report?

• Last year’s deficit of 9% of revenue was repeated. And without comment.
• Employee benefits increased from 37% to 52% of expenses.
• Current assets as a multiple of current liabilities (working capital) declined from 1.8 times to 1.1 times.
  • Combined with the repeated loss, this is of concern. (But it went without comment.)
• With zero non-current liabilities and land valued at $2.07 m, the longer term financial structure is sound.

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

• Yes

Where were your (net) donations sent?

• NA

Who are the people controlling the organisation?

• Not shown on the website.
• These are the ‘Responsible Persons’ shown on the ACNC Register:
  • Duncan Drew
  • Rodney Logan
  • Peter Moody
  • Suzanne Nelson
  • Anna Roberts
  • John Sheen
  • Graham Stenton
  • William Vine
• It appears, from the Mt Tamborine Convention Annual Report, that John Sheen has replaced Wendy Phillpotts.

To whom is MTC accountable?

• As a charity, to the ACNC.
  • Its ‘Charity Tick’ is used on the website in support of you giving to them (and on most other pages).  And rightly so, because it would be unwise to give to a charity that is unregistered.  The ‘tick’ also means MTC’s AIS is not overdue, and the ACNC has not taken any compliance action against it.
    • But no more than this.
• MTC has gone beyond the charity tick, and achieved accreditation with the CMA Standards Council. It is therefore entitled to display their seal – you can see this on the right-hand side of most pages. For this privilege is must abide by the Council’s  Principles and Standards of Responsible Stewardship.

1. MTC is a Foundation Partner. At the announcement of the Foundation Partners, Steve Kerr, the Executive Director of CMASC, said “Foundation Partner status is tangible recognition and reward for their efforts – these are high quality organisations.”  ↑
2. I agree with Randy Alcorn [Money, Possessions, & Eternity, Tyndale, 2003] when he says that ‘Any Christian leaders who resist financial accountability make themselves suspect.’ [page 425]. ↑
3. Email from the ACNC, 8 January 2018. ↑
4. “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. ↑