This is a review^[1] in the series ‘Organisations accredited by the CMA Standards Council’. The CMA Standards Council is ‘a ministry of Christian Ministry Advancement’^[2], with a mission “to help build faith and trust in Christian organisations, be they churches, charities, schools or otherwise, to enable them to achieve more effective outcomes^[3].

The 19^th member, ‘Overseas Council Australia’^[4], was recently added^[5] to the Standard Council’s ‘Directory of Accredited Partners’.^[6]

The chair of the board committee responsible for the application for accreditation Council^[7] is also the chief executive officer of the body giving the accreditation^[8]:

This review is also a review in the series ‘Members of Missions Interlink’, Missions Interlink being ‘the Australian network for global mission’[9] (and a means for a Member to get income tax exemption when it might not otherwise be available^[10]). ‘Overseas Council Australia’ is one such member^[11].

The website linked from the Standard Council’s Directory goes to a website in the same name, ‘Overseas Council Australia’. Here they seek online donations.

Donors

Given what Missions Interlink does, ‘Overseas Council Australia’ is probably a charity.

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, and
5. Find out more about how the charity says it uses donations.

Here’s the results for ‘Overseas Council Australia’, with #5 supplemented by the essentials of the ACNC’s What should I consider when deciding which charity to support?^[12].

Question 1

A search on the charity regulator’s site shows that there is a registered^[13] charity in that name (OCA).

• The Register record shows that OCA is a member of an ACNC_Group. The other member is The Trustee for Overseas Council Fund^[14].
  • This is a public ancillary fund controlled by OCA. Donations to the Fund are tax deductible.
• Although OCA is a public company, ASIC has permitted registration without the usual ‘Ltd’/’Limited’ at the end of the name.

Other registrations

Fundraising:

Question 2

There is nothing to indicate that OCA uses either volunteer or professional collectors 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 nothing about the security of the payment portal used by OCA on the giving page^[15].

Question 4

The ABN records say that donations to OCA are not tax deductible, but those to the Fund are. Even though the website covers both OCA and its Fund (see above), and OCA says that a tax deduction is possible for some projects, the Fund is not mentioned on the giving page^[16].

Question 5  How are donations used

Context

Bible colleges

Faculty and scholars

Theological students

Sharing the Gospel^[17]

Not what they are about.

Financial Reporting

The audited account of how a charity uses donations is the Financial Report on the ACNC Register. For OCA it is the Group Financial Report.

In this Report, the directors signed a declaration (Directors’ Declaration) that

However, like last year, and despite their accreditation by the Standards Council, there are many deviations from these Standards, some of which are material:

• The Statement of Changes in Equity is non-compliant.
• A ‘statement of profit or loss and other comprehensive income’ (or ‘statement of comprehensive income’) is required. OCA have instead submitted an Income Statement and a Detailed Income Statement.
• The content of both income statements is non-compliant.
• The Statement of Cash Flows is non-complaint.
• A note on related parties has been omitted.
• The statement giving the financial position is misnamed.
• The surplus in the income statements is different from the surplus in the Statement of Changes in Equity.
• ‘Ministry Expenses Income’, an unusual item, and comprising 25% of revenue, is unexplained.
• The non-current asset is misnamed.
• ‘Prior-year adjustments’ are unexplained.
• Some of the required notes under ‘Summary of Significant Policies’ are missing, some of those included are incomplete, and the ‘Depreciation’ Note does not match the Balance Sheet.
• No ‘critical accounting judgments etc’ are disclosed.
• There is no reconciliation for the property, plant and equipment.
• The information in Note 13 is internally inconsistent.
• Superannuation expense is not disclosed.
• Revenue is not disaggregated.

This means that the directors’ declaration (see above) is false.

Not the high standard of behaviour they claim, especially from a charity that has the chief of the body that gave the high standards accreditation, Stephen Kerr, on its board.

Who was responsible?

From the Directors’ Report:

David Brown

Kenneth Chapman

Catherine Crouch

Sandra Errey

Alan Jeffrey Hall

Stephen Robert Kerr

The same people are still the directors. The ACNC Register has the same six.

The directors are accountable to the members. There were 65 of those on 31 December 2020 [Directors’ Report].

The audit

You might ask how, with the list of deviations from a true and fair view shown above, the auditor, Lawrence R Green, a Fellow of Chartered Accountants Australia and New Zealand, could give a ‘clean’ opinion. But this decision is consistent with his support for special purpose financial statements for OCA last year, consistent with his ‘clean’ opinion last year in the face of similar issues to those above, and consistent with his questionable performance in several other audits reviewed by us.

His report is also materially non-compliant with the Australian Auditing Standards:

• He again omits to say which ‘financial report’ he audited, and what reports in that ‘financial repor’t he audited.
• He incorrectly includes an ‘emphasis of matter’ paragraph for ‘Basis of Accounting’.

The use of your donations

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

Cash spent

From the Statement of Cashflows (with last period in the second column):

(This year’s figures are for 18 months – OCA changed its financial year.)

It’s one line more than most charities have, but because no further information is given on these figures, we don’t have enough information to understand where the cash went.

Resources consumed (i.e., accrual)

This, from the Income Statement, is how the activities translated into expenses (with last period’s figures in the second column):

Note 4 (above) has nothing to do with ‘Payments and in kind…’ Instead, the breakup of this item is given in the second income statement:

The destination of these payments is not given. Presumably the tax-deductible money went to these charities identified on the website:

Since last year they have dropped WorldShare and Melbourne School of Theology and added World Relief Australia.

The first two in the list have been reviewed by us. Search here.

Where the rest of the money went, we are not told. Nor is there any comment on how they ensure that (a) whether the money sent overseas was received, and (b) whether it was used for the purpose given.

Impact

Everything OCA is doing may be being done ‘properly’^[18], but unless the money is producing the change in people that the charity intends (i.e., an impact), the money would be better used elsewhere. And the same applies if the impact is less than is being achieved by another charity.

Nothing systematic about impact was found on the website.

Standard 5.6 of the CMA Standards council standards (see above) requires that regular program evaluations must be performed. This, from the Winter 2017 ‘Prayer Alert’, is the only mention of ‘evaluation’ on the website:

Charity response

OCA says, in its ‘OCA Complaints Handling Policy’, that it values feedback:

We sent a draft of this review to the charity. They….did not respond.

1. See here for the last review. ↑
2. Linked added by us. ↑
3. Emphasis in original. ↑
4. It achieved this by meeting the Council’s ‘Principles and Standards of Responsible Stewardship’, and therefore is able to be promoted as a ‘high quality organisation’. ↑
5. ↑
6. Having the list of accredited organisations on a site that is not secure is inconsistent with this building of ‘faith and trust’: ↑
7. Directors’ Report, Financial Report 2020, www.acnc.gov.au: ↑
8. https://www.cmasc.net.au/about/our-people: ↑
9. https://missionsinterlink.org.au/about/ ↑
10. ↑
11. ↑
12. A section in the article, Donating and Volunteering:
    1. Focus on the nature of the charity’s work, its beneficiaries and the impact the charity is having in the community.
    2. Is it clear what the charity is trying to achieve and how its activities work towards its objectives?
    3. Would you like to spend your money, or time if volunteering, to support these objectives?
    4. Is the charity being transparent about its activities?

    ↑

13. The ACNC implies, therefore, that it is a ‘legitimate’ charity. But this is not correct – as the ACNC itself points out, registration is voluntary. ↑
14. The Fund continues to be registered without the second ‘The’ in its name. ↑
15. As separate to the security of the information once collected, that is, as part of a privacy policy. ↑
16. There are only two references to the Fund on the website. ↑
17. ‘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]. ↑
18. The behaviour of its people, its use of money, and how it goes about its business. ↑